Interpretation ID: aiam1390
Administrative Manager
KAR-KRAFT
INC.
10611 Haggerty Street
Dearborn
MI 48126;
Dear Mr. Volberding: This is in reply to your letter dated December 6, 1973, in which yo ask whether there is a distinction between the reference to the 'lowest seating position' for motorcycles in S5.1.2.1 of Motor Vehicle Safety Standard No. 205, and the reference to 'lowest seating surface' in proposed 'Fields of Direct View' (Docket No. 70-7, Notice 2, 37 FR 7210, April 12, 1972). You also request an explanation for the difference between the reference to 15 inches above the seating surface in Standard No. 205, and 18 inches in Docket No. 70-7.; The notice in Docket No. 70-7, as you may know, has been withdrawn (3 FR 6194, March 7, 1973). However, we would consider the phrase 'lowest seating position' to be synonymous with 'lowest seating surface' with respect to these particular items. The 18-inch requirement proposed in Docket No. 70-7 represented a more recent evaluation than the 15-inch requirement in Standard No. 205 of the minimum desirable area for motorcycle visibility. Had that requirement become effective the agency would have taken steps to ensure that the requirements were consistent with each other.; Yours truly, Richard B. Dyson, Assistant Chief Counsel