Interpretation ID: aiam0595
Chairman
Technical Advisory Committee
Electric Vehicle Council
Edison Electric Institute
Petro- Electric Motors
Ltd.
342 Madison Avenue
New York
NY 10017;
Dear Mr. Wouk:#This is in further response to your letter of Decembe 16, 1971, requesting interpretations of several Federal motor vehicle safety standards as they apply to electric vehicles.#The engine retardation braking effect of Standard No. 102 applies only to vehicles equipped with automatic transmission, and not to an electric vehicle that has no transmission.#Standards Nos. 201 through 204 do not apply to trucks. You have stated that your electric vehicle is designed to that 'the rear . . . will normally be used for tools, service equipment, spare parts, etc., as would be required in a service vehicle as used by an electric utility company for going out and making repairs.' You have also stated that the back area could be converted to a seating area for two passengers, but that this would be 'unusual and occasional.' On the basis of this information we have concluded that you vehicle is a 'truck' and need not meet Standards Nos. 201-204.#Sincerely, Richard B. Dyson, Assistant Chief Counsel;