Interpretation ID: 21066.ztv

Mr. Jay C. Ackerman
Vice President - Operations
G & C, Inc.
500 W. Southgate
Enid, OK 73701

Dear Mr. Ackerman:

This is in response to your e-mail of December 10, 1999, to Steve Wood, Assistant Chief Counsel for Rulemaking.

You describe a parking brake system you wish to install on a low-speed vehicle that you intend to manufacture, and have asked whether the system is allowable under Federal Motor Vehicle Safety Standard No. 500, Low Speed Vehicles.

At the present time, Standard No. 500 simply requires a low-speed vehicle to be equipped with a parking brake (S5(b)(7)). We have adopted no performance specifications for a parking brake on a low-speed vehicle. We define "parking brake" as "a mechanism designed to prevent the movement of a stationary motor vehicle" (Sec. 571.3(b)). Therefore, any device or mechanism installed on a low-speed vehicle that performs the function stated in the definition would be acceptable as a parking brake.

If we decide that specific parking brake performance requirements should be adopted for low-speed vehicles, we will first publish a notice of a proposed rule so that you and other interested persons may comment on it. We anticipate that parking brake performance requirements for low-speed vehicles would be similar to those specified in Standards Nos. 105, Hydraulic and Electric Brake Systems, and 135, Passenger Car Brake Systems, for faster motor vehicles. These standards specify a parking brake system of a friction type with a solely mechanical means to retain engagement. Your hydraulic-type parking brake system would not be acceptable if we propose and adopt the same type of parking-brake specification for low-speed vehicles. We do not favor hydraulic-type parking brake systems because, if a leak in the system caused the pressure to drop, the vehicle could roll away. This would not necessarily be prevented by your additional feature that will disengage the electrical drive system when the line-lock system is engaged.

Because it appears that G&C is a new manufacturer of motor vehicles, I enclose an information package that we provide, explaining our laws and regulations. We particularly call your attention to Part 565, Vehicle Information Number Requirements, and Part 566, Manufacturer Identification.

If you have any questions, you may phone Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:500
d.3/15/2000