Interpretation ID: nht91-6.40

DATE: October 25, 1991

FROM: Russell J. Eisert

TO: Steve Kratze -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/18/92 from Paul Jackson Rice to Russell J. Eisert (A39; Std. 208)

TEXT:

I am writing this with reference to the new laws that were passed pertaining to the conversion of vans. I am a quadriplegic and have been trying to purchase a new van and have run into all kinds of problems. Because I drive from my wheelchair I do not want a seat put in on the drivers side. Also because I sit in the wheelchair a little bit higher than a normal seat I would like to have the roof cut out over the front to give me a couple of inches more headroom. The other problem is because I need space to maneuver inside the van I would like to have the rear seats and folding bed moved to the rear of the side door. I have been driving my other vans with this arrangement since 1978 without any problems.

The Chevy dealers and the Conversion people all tell me that this can not be done in 1992. American International Conversions said I would have to write to you and obtain a letter of waiver from you to cover these items so they can convert a van for me.

I therefore respectfully request a letter of waiver from you to allow them to modify these three items for me.

Your early response to this matter would be very much appreciated. If it would be possible, could you please fax a copy of the letter to American International Conversions, Fax# 813/586-6627. This would save a few days of mail time.

Thank you very much for your consideration of this very disturbing problem.