Interpretation ID: aiam2594
Hendrickson Mfg. Co.
8001 West Forty-Seventh Street
Lyons
IL 60534;
Dear Mr. Brennan: This responds to your May 17, 1977, letter asking for an interpretatio of 'unloaded vehicle weight.' You are interested specifically in whether cranes and drill rigs are included in the computation of a vehicle's 'unloaded vehicle weight.'; 'Unloaded vehicle weight' is defined in the Code of Federa Regulations, Title 49, Part 571.3 to mean; >>>the weight of a vehicle with maximum capacity of all fluid necessary for operation of the vehicle, but without cargo or occupants.<<<; Through a previous interpretation (copy enclosed), the National Highwa Traffic Safety Administration (NHTSA) has determined that the 'weight of the vehicle' includes the weight of those accessories that are installed on a vehicle before delivery and are not ordinarily removed.; From the description of the apparatus to which you refer in you letter, it would appear that the cranes or drilling rigs are not normally removed from the vehicle when not in use. Further, the removal of these pieces of equipment appears to be a cumbersome task. Accordingly, it is the opinion of the NHTSA that the weight of the equipment to which you refer would be part of the 'weight of the vehicle' and, therefore, would be included in the computation of the 'unloaded vehicle weight.'; Sincerely, Joseph J. Levin, Jr., Chief Counsel