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Interpretation ID: 21249.rbm


    Mr. Thomas W. Blasingame
    T.W. Blasingame Company, Inc.
    P.O. Box 1532
    Boise, ID 83701



    Dear Mr. Blasingame:

    This letter responds to your request that the National Highway Traffic Safety Administration (NHTSA) authorize you to certify a vehicle as a "modular truck/tractor chassis". I apologize for the delay in NHTSA's response.

    Your letter requesting a legal interpretation included a service manual for which you subsequently requested confidential treatment. Your request for confidential treatment was granted on August 29, 2000.

    You indicate in your letter that your company wants to market a new vehicle that can operate either as a truck or as a truck tractor. NHTSA does not have a vehicle classification for this type of hybrid vehicle. Rather, our regulations provide for a "truck", which is defined as a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment, and "truck tractor", which is a truck designed primarily for drawing other motor vehicles and not so constructed as to carry a load other than a part of the weight of the vehicle and the load so drawn (49 CFR 571.3).

    While we do not specifically address hybrid vehicles such as yours in our regulations, nothing in the regulations would prohibit a manufacturer from certifying a particular vehicle as complying with all applicable safety standards for separate vehicle types. Thus, we would not object to your classifying your vehicles as "truck/truck tractors". Please note, however, that such a characterization would require your company to certify compliance with all Federal motor vehicle safety standards (FMVSS) that are applicable to both vehicle types. As a practical matter, only FMVSS No. 108 and FMVSS No. 121 currently have requirements for truck tractors that are in addition to or different from the requirements for trucks.

    I hope this information is helpful. If you have any further questions, please contact Rebecca MacPherson of my staff at (202) 366-2992.


    Sincerely,
    Frank Seales, Jr.
    Chief Counsel

    ref:567
    d.11/6/00