Interpretation ID: aiam2574
Vice President
Public Responsibility and Consumer Affairs
Chrysler Corporation
P.O. Box 1919
Detroit
MI 48231;
Dear Mr. Terry: This responds to your November 29 and December 20, 1976, petitions fo rulemaking to amend the definition of 'unloaded vehicle weight.' The National Highway Traffic Safety Administration (NHTSA) grants your November 29 petition for rulemaking and denies your December 20 petition.; The NHTSA, in a letter of interpretation to the Jeep Corporation stated that 'unloaded vehicle weight' does not include the weight of accessories ordinarily removed when they are not in use. Your November 29 petition for rulemaking suggests that we formally incorporate this interpretation into the definition of 'unloaded vehicle weight' for purposes of clarity. The agency agrees that this change should be made. Accordingly, we intend to commence rulemaking in response to your petition.; Your December 20, 1976, petition amended your November 29, 1976 petition by suggesting that the agency permit barrier testing of specified vehicles at the lesser of the unloaded vehicle weight or 5,500 pounds. We have determined that this proposal would establish arbitrary weights for vehicles undergoing compliance testing which could result in vehicles being subjected to crash tests in a condition which is not representative of their actual on-road condition. Your suggested change in the definition could thus result in a reduction in the effectiveness of some motor vehicle safety standards. In Standard No. 301-75, *Fuel System Integrity*, the Congress mandated that the agency not diminish the level of safety established at that time in the standard. Your proposal, if implemented, could violate that Congressional mandate since vehicles could be tested at a weight which differs from their actual weight. Therefore, the recommendations advanced in your December 20 petition are denied to the extent that they differ from those originally proposed in your November 29 petition.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;