Interpretation ID: aiam1541
Flyer Industries Limited
6 Otter Street
Winnipeg
Canada R3T OM6;
Dear Mr. Deane: This responds to your June 5, 1974, question whether electric trackles trolley coaches are motor vehicles under the National Traffic and Motor Vehicle Act of 1966, and if so, whether Standard No. 121, *Air brake systems*, or any other special requirements must be met by this type of vehicle. Section 102(3) of the Act defines motor vehicle:; >>>'Motor vehicle' means any vehicle driven or drawn by mechanica power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.<<<; An electric trackless trolley coach is a motor vehicle under thi definition, and Standard No. 121, *Air brake systems*, applies to a coach equipped with an air brake system. No special requirements apply to trackless trolley coaches. Standard No. 121, *Air brake systems*, requires stopping distance performance which must be met by any bus equipped with air brakes, whether or not it is equipped with supplementary dynamic braking means. In evaluating a vehicle's compliance with the stopping distance performance requirements of S5.3 and S5.7.2.3, auxiliary braking devices may be utilized in making the stops provided such devices are engaged by means of the same service brake pedal or parking brake control that operates the air brakes. It should be noted, however, that these stops must be made with the transmission selector control in neutral or the clutch disengaged (S6.1.3).; Yours truly, Richard B. Dyson, Assistant Chief Counsel