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Interpretation ID: aiam2772

Mr. James J. Kearney, Vice President, Baltimore Cycles, Inc., 6020 Eastern Avenue, Baltimore, Maryland 21224; Mr. James J. Kearney
Vice President
Baltimore Cycles
Inc.
6020 Eastern Avenue
Baltimore
Maryland 21224;

Dear Mr. Kearney: This is in reply to your letter of January 12, 1978, asking whether th braking system on your Casal mopeds meets Federal requirements.; Table 1 of Federal Motor Vehicle Safety Standard No. 123, *Motorcycl Controls and Displays*, requires that the control for read brakes on motorcycles shall be located at the right foot control (with the option of the left handlebar permissible for motor driven cycles such as mopeds) and operate by depressing to engage. The rear brake on the Casals moped in operated by 'back peddling, similar to a bicycle.' We understand that this is accomplished by application of force to the right foot pedal.; We have concluded that this system meets the requirements of th standard, since the brake is engaged by depressing the right foot pedal.; Sincerely, Joseph J. Levin, Jr., Chief Counsel