Interpretation ID: aiam2726
Manager
Electric Products Division
General Engines Company
591 Montana Boulevard
Jewell
N.J. 08080;
Dear Mr. Flowers: This is in reply to your letter of November 4, 1977, asking for a interpretation of Federal Motor Vehicles Safety Standard No. 123 *Motorcycle Controls and Displays* as it applies to electricity-powered motor driven cycles that you manufacture.; "Paragraph S5.1 of Standard No. 123 requires each motorcycle to b equipped with a supplemental engine stop control. Your Electroped GX 2000 is operated through a 'uni-control lever' which, when released, turns off the power j source 'thereby acting as an automatic motor stop in the event of an accident.' Your Electroscooter is operated through a twist-grip throttle and when it is released 'the motor is completely off.' You have asked how S5.1 applies to your vehicles."; In our opinion, Standard No. 123 was not drafted wit electricity-powered motorcycles in mind. Unlike a motorcycle powered by an internal combustion engine, the driving force (i.e. current) of an electricity-powered motorcycle is terminated when the force control is released, and no supplemental engine stop control or 'emergency kill button' is required. In other words, S5.1 does not appear to be an appropriate requirements for an electricity-powered vehicle.; however, until Standard 123 can be amended appropriately your vehicle are required to be equipped with the supplemental engine stop control. In other instances where manufacturers have found conflicts between the safety standards and electricity-powered vehicles they have applied for a temporary exemption from such standards.; Work is in progress on your request to be exempted from Standard No 120, and by including your letter and this interpretation to it in the docket, we can include in the *Federal Register* notice a request to be exempted from S5.1 as well. Please confirm that this is acceptable to you.; Sincerely, Joseph J. Levin, Jr., Chief Counsel