Interpretation ID: 3195yy
Vice President
Solar Car Corporation
1300 Lake Washington Road
Melbourne, FL 32935
Dear Dr. Adams:
This responds to the petition by Solar Car Corporation dated September 12, l991, for a temporary exemption from the Federal motor vehicle safety standards. The basis of the petition is "low-emission engine features."
According to the petition, Solar Car "retrofits" Ford Festivas, Dodge Colts, and Chevrolet S 10 pickup trucks to electric and solar electric configuration. We understand this to mean that Solar Car converts new, previously untitled vehicles, rather than that it converts vehicles that are brought to it by their owners. If the latter is the situation, a temporary exemption is unavailable for these vehicles, as our authority to provide exemptions does not cover vehicles that have been in use.
The petition requests a blanket exemption from compliance with the Federal motor vehicle safety standards. If such a petition is to be submitted, it must follow the format specified by the exemption regulation, 49 CFR 555.6(c), providing information with respect to each standard as to how an exempted vehicle would differ from a conforming one, and why an exemption from that standard would not unduly degrade motor vehicle safety. This information is completely lacking from the Solar Car petition. As you might imagine, NHTSA does not encourage petitions that request exemption from all applicable Federal motor vehicle safety standards, and, in point of fact, has never considered such a petition. Furthermore, in the case of Solar Car, such a comprehensive petition does not appear necessary for it to pursue its business plan.
The base car or truck converted by Solar Car will already have been certified by its manufacturer as complying with all applicable Federal motor vehicle safety standards (which are found at 49 CFR Part 571). What Solar Car must do is to determine which of those standards may be affected by its conversion operations, and then determine the extent of any noncompliance that may be created. With the thought that it may assist you, I enclose a copy of a Federal Register notice that discusses the petition of another vehicle converter, and the standards which appeared to be affected by its conversion operations. Although the notice was published in l975, our requirements have not changed since that time.
We shall be pleased to consider this matter further when we have received a petition that meets the procedural requirements of Part 555. If you have any questions, Taylor Vinson of my staff is available to answer them (202-366-5263).
Sincerely,
Paul Jackson Rice Chief Counsel
Enclosure ref:555#567 d:l0/2l/9l