Interpretation ID: nht70-1.46

DATE: 03/19/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Melvin Hart

TITLE: FMVSR INTERPRETATION

TEXT: We have received your petition of March 10 for temporary exemption from Federal Motor Vehicle Safety Standard No. 201 (Occupant Protection in Interior Impact). The petition raises several questions.

Standard No. 201 does not, as you appear to assume, pertain only to instrument panels. It also covers seat backs, interior compartment doors, sunvisors, and armrests. Please explain whether you are seeking an exemption from the entire Standard, or only from S3.1.

The comment on p. 6 of the petition, "two of the standards loom higher than the rest as problems", raises the question whether you are still requesting an exemption from Federal Standard No. 103 (Defrosting and Defogging Systems). If so, then you should submit a supplemental petition containing the information we requested on February 19 in returning to you your petition of February 13.

The signature "Melvin Hart Owner" does not fulfill the requirement (49 C.F.R. @ 355.5(b)(13)) that the application be signed "by an officer of the petitioner and state his authority and area of responsibility".

If you will explain the scope of your request for exemption from Standard No. 201, whether an exemption from Standard No. 103 is still needed, and your corporate position with Transer, Inc. we shall consider your petition further.

In closing permit me to suggest that it would be to your advantage to submit as much information as possible on the safety characteristics of the T6.A, including relevant drawings and photographs. An exemption is based in part upon a finding that it is "consistent with the public interest and the objectives of the [National Traffic and Motor Vehicle Safety] Act". Since an exemption is, in effect, a license to manufacture motor vehicles, the Administrator must more data than the written assurances of a manufacturer that it will produce a "safe" vehicle before he can find that the exemption is "consistent with the public interest". This is especially true concerning a new vehicle produced by a new company which his not manufactured motor vehicles before. If you would like to discuss the T6.A with our engineers we shall be happy to arrange such a meeting.