Interpretation ID: aiam3355
Director of Safety
City of Phoenix Transit System
P.O. Box 4275
Phoenix
Arizona 85030;
Dear Mr. Gephart: This responds to your letter of August 14, 1980, regarding speedomete requirements on buses. In your letter, you ask us to confirm your belief that buses purchased prior to September 1, 1979, are not required to have speedometers. The key question is the date of manufacture, not the date of purchase. Federal Motor Vehicle Safety Standard (FMVSS) No.127, *Speedometers and Odometers*, requires motor vehicles *manufactured* on or after September 1,1979, to have speedometers that meet certain criteria. Thus, none of your buses that were manufactured before that date are required to have speedometers. To determine the date of manufacture of any of your buses, check the certification label.; We noted your statement that the Phoenix Transit System serves 'onl the Phoenix and surrounding suburbs' passenger population with limited boundaries.' If you begin to offer interstate service, we recommend that you contact the Federal Highway Administration (FHWA), Bureau of Motor Carrier Safety, regarding the regulation of interstate motor carriers. The FHWA may have rules requiring speedometers on all vehicles used in the interstate transportation of passengers. Their address is 400 - 7th St. S.W., Washington, D.C., 20590.; We hope you find this information helpful. Please contact this offic if you have any questions.; Sincerely, Frank Berndt, Chief Counsel