Interpretation ID: aiam3661
Project Manager
E-Z-Go Textron
P.O. Box 388
Augusta
GA 30913-2699;
Dear Mr. Dobbs: This is in reply to your letter of February 4, 1983, telling of you wish to build a four-wheeled light weight traffic enforcement vehicle similar to a three-wheeled machine manufactured by Cushman. You have asked whether you have to meet passenger car safety standards 'or can we obtain a waiver for this vehicle only to comply with motorcycle safety standards?' You have enclosed a brochure on the vehicle you propose to modify, Textron's GX-800.; I am sorry to say that only vehicles with three wheels or less ar defined as 'motorcycles' for purposes of compliance with the Federal motor vehicle safety standards. Years ago, the agency totally excluded from the application of those standards four-wheeled vehicles with a curb weight of 1000 pounds or less such as the GX-800. However, that exclusion was terminated in the early 1970's.; A manufacturer of 10,000 vehicles or less per year may petition for temporary exemption from any safety standard where immediate compliance would cause substantial economic hardship. However, he must make a good faith effort to bring the vehicle into compliance during the exemption period. Although this would appear impossible with your vehicle because of its physical limitations, the agency has in the past exempted replicas of 1900-style vehicles where full compliance was manifestly not feasible. I enclose a copy of Title 49 Code of Federal Regulations Part 555 which sets out the exemption procedures. If your planned vehicle would have a cargo box, similar to the one on the Cushman vehicle, your vehicle could be considered a 'truck' for compliance purposes.; As a car or truck, your vehicle would also have to comply with Federa fuel economy and emissions standards. Exemptions from fuel economy standards may be sought under 49 CFR Part 525. As to the emissions standards, you should write the Environmental Protection Agency.; Sincerely, Frank Berndt, Chief Counsel