Interpretation ID: nht91-2.50

DATE: March 26, 1991

FROM: Eric G. Hoffman -- Russell & Hoffman Incorporated

TO: Harry Thompson -- NHTSA

TITLE: Re: NEF 32; National Traffic and Motor Vehicle Safety Act of 1966, 49CFR, Chapter V, Subpart A-571 (the "Act")

ATTACHMT: Attached to letter dated 4-29-91 from Paul Jackson Rice to Eric G. Hoffman (A37; Part 571.3)

TEXT:

This firm represents a private school which operates and/or rents mini-vans which are designed to carry more than 10 passengers.

The school has become aware of the Act and is concerned whether the operation of the vans is in compliance with the applicable regulations under the Act. We would appreciate your providing us: (1) guidance as to the continuing effect of this Act; (2) the procedures for obtaining a variance from the regulations of the Act under certain circumstances; (3) the procedures regarding modification of any non-complying vehicles; (4) the federal guidelines for the estimated cost of such modifications; (5) the terms of any grace period for modification of vehicles to bring them into compliance; (6) the applicable administrative entity charged with enforcement of the Act; and (7) any certification process for vehicles having been modified. To the extent any of the above are non-existent, please so advise us.

After your review of this letter, I would appreciate your contacting me at your earliest convenience to further discuss this matter.

Thank you for your attention and cooperation.