Interpretation ID: aiam2361
Assistant Manager
Safety & Environmental Activities
American Honda Motor Co. Inc.
P.O. Box 50
100 W. Alondra Blvd. #Gardena
Calif. 90247;
Dear Mr. Gill: This is in reply to your letter of July 16,1976, asking for interpretation of S6.1 of Motor Vehicle standards No. 122, *Motorcycle Brake Systems*.; S6 requires the performance requirements of S5 to be met under certai specified conditions. One of these, S6.1, states that the test weight is unloaded vehicle weight plus 200 pounds. You have stated that some Honda motor cycles with limited engine displacement are equipped to carry the driver only and that the recommended vehicles load limit is less than 200 pounds. You have requested an interpretation that will allow Honda to perform tests for Standard No. 122 at unloaded vehicle weight plus 1500 pounds.; There is no requirements that tests be conducted at any specifie weight, only that the performance requirements of Standard No. 122 will be met when the test weight is unloaded vehicle weight plus 150 pounds. Thus Honda may test at unloaded vehicle weight plus 150 pounds and certify compliance with Standard No. 122 as long as it is reasonably certain, (through extrapolation of test results for example) that the vehicle will comply if tested by NHTSA under the condition imposed by S6.1.; I do not know if this interpretation is responsive to your concern. I Honda believes that the 200 pound test condition is impracticable for small motorcycles it may wish to submit a petition for rulemaking to amend S6.1.; Yours truly, Frank Berndt, Acting Chief Counsel