Interpretation ID: nht72-4.40

DATE: 06/21/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Pennsylvania Recreational Vehicle and Camping Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 9 to Mr. Schneider asking whether mobile homes and modular homes which have (Illegible Words) can be exempt from (Illegible Word) and (Illegible Word) requirements.

It is my understanding that a mobile home is a structure which may be, and generally is, used more than once, from site to site, on its own wheels. Accordingly as determined several years ago that mobile homes are "motor vehicles" under its National Traffic and Motor Vehicle Safety Act of 1966, however infrequent their use of the public roads. As motor vehicles, they must (Illegible Word) certification labels that specify (Illegible Words) ratings.

If a modular home on wheels uses the public roads "only for the (Illegible Word) trip to the (Illegible Word) lot," on your letter states, (Illegible Word) is planned on a permanent foundation, we would not consider it a "motor vehicle."