Interpretation ID: aiam1022
Center for Auto Safety
Post Office Box 7250
Washington
DC 20044;
Dear Ms. Cannon: This is in reply to your letter of February 14, 1973, concerning ou plans for publicizing the new Federal odometer requirements.; To begin with your third question, the NHTSA does not have th authority to require State departments of motor vehicles to notify the public of the odometer requirements. Because the participation of the States is voluntary, and not subject to regulation, we have not attempted to instruct the States in our regulatory notices. The approach you suggested, of sending notice of the Federal law with the auto registration cards, would be useful, particularly in States whose forms cannot be readily converted to contain the disclosure statement. This is one of the publicity measures that we are discussing with the States at the present time.; In the short run, we are going to have to rely on the public media t distribute information about the requirements. We issued press releases upon issuance of the notices establishing the requirement, and have been encouraging the press to highlight the problems of odometer tampering and to tell of the existence of the disclosure requirements. These efforts fall short, however, of providing the type of general coverage needed for regulations having a national effect. It is likely that most consumers will learn of the requirements from automobile dealers, most of whom have been advised of the requirements by their national dealer associations.; The problem of odometer fraud deserves full exposure, and we intend t do what we can to expose it. The scale of our long term efforts, however, including the question of the use of TV spots, is a matter that has not been resolved as yet.; Yours truly, Richard B. Dyson, Assistant Chief Counsel