Interpretation ID: aiam1320
Rolls-Royce Motors Limited
Car Division
Crewe Cheshire CWI
3PL England;
Dear Mr. Knight: This is in reply to your letter of October 16, 1973, requesting clarification of S7.2 of Federal Motor Vehicle Safety Standard No. 301 (9-1-75) (Docket No. 70-20, Notice 2).; As you are aware, a proposed amendment to Federal Motor Vehicle Safet Standard No. 301 (9-1-75) was published on August 20, 1973 with an anticipated September 1975 effective date (Docket No. 73-20, Notice 1). In the event that the proposed amendment of loading conditions is adopted, the present passenger car requirement, that the vehicle be at its GVWR during testing, will be superseded by the requirement that the passenger car be loaded 'to its unloaded vehicle weight plus its rated cargo and luggage capacity weight, secured in the luggage area, plus the weight of the necessary dummies.' under these specifications, rear sear occupant weight will not be a factor of the test load condition unless a specific test requirement calls for dummies to be placed in designated rear seating positions. The proposed amendment would also make it unnecessary to firmly fix the dummies to the vehicle as is presently the case under S7.2.; We have also noted your views on luggage capacity weight and ar placing your letter in Docket No. 73-20 as a comment to be considered.; If you require any further clarification, please do not hesitate to le us know.; Sincerely, Lawrence R. Schneider, Chief Counsel