Interpretation ID: aiam1426
President
L and R Enterprises
P.O. Box 2201
Wichita Falls
TX 76307;
Dear Mr. Lang: This responds to your February 15, 1974, letter asking whether you installation of spotlights through the left A-pillar of passenger cars is subject to Standards 201 and 216.; Standard 201 does not apply to the instrument panel area on th driver's side from the left door to a longitudinal plane 3- 1/4 inches to the right of the steering wheel. The left A pillar is within this excluded area.; Your drilling operation may affect roof strength and I have enclosed copy of Standard 216, our standard on roof crush resistance. Under the National traffic and Motor Vehicle Safety Act of 1966, it is the responsibility of the person who manufacturers or alters a vehicle to determine whether his vehicle meets the requirements.; Your business is subject to these requirements, however, only if yo qualify as an alterer of motor vehicles under 49 CFR 567.7, which is enclosed. The mounting of a spotlight by drilling the A-pillar is a 'non- readily attachable' alteration. Such an alteration would be subject to the S567.7 requirement only if you mount it 'before the first purchase of the vehicle in good faith for purposes other than resale.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel