Interpretation ID: aiam5011
#1500 Dallas
TX 75201;
Dear Senator Gramm: This responds to your Memorandum attachin correspondence from your constituent Stephen Newmark of Tarrant County. Mr. Newmark, Vice-President of Lonestar Classics, Inc., states that his company 'has requested an exemption' from this agency 'for the purposes of manufacturing kit cars,' and asks your help 'in determining whether our exemption will be granted or whether the National Highway Traffic Safety Administration (NHTSA) requires further information.' He also states that 'the timing of NHTSA's response is critical to our moving ahead.' Mr. Newmark FAXED the Administrator on May 5, 1992, about the possibility of obtaining an exemption, and followed up with a telephone call to the Office of Chief Counsel on May 15. As we understand it from that conversation, the business plan intended by Lonestar is to sell and deliver a certain number of unassembled components to purchasers who will complete the assembly of the vehicle by providing the engine, drive train, and suspension. We informed Mr. Newmark orally that, given these facts, Lonestar is not considered to be a 'manufacturer' of motor vehicles under the National Traffic and Motor Vehicle Safety Act. Because of this, Lonestar is not required to ensure the compliance of the completed vehicle with the Federal motor vehicle safety standards, and, hence, no exemption is required for it to implement its business plan. We informed Mr. Newmark of your interest in his behalf, and that our response to you would also serve as a reply to his FAX of the 5th to the Administrator. For this reason we are providing him a copy of this letter. Sincerely, Frederick H. Grubbe Enclosure: Constituent's Correspondence cc: Washington Office;