Interpretation ID: nht81-2.13

DATE: 04/07/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Meadowood Management Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your letter of February 5, 1981, in which you seek help in defining the terms "van," "motor home," "recreational vehicle," and "motor coach."

The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act), authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards which are applicable to motor vehicles or motor vehicle equipment. Our regulations do not specifically define the terms you use in your letter. Rather, the agency's regulations establish generic categories such as "passenger car," "truck," "trailer," "bus," and "multipurpose passenger vehicle." These terms are defined in 49 CFR @ 571.3 (copy enclosed). A particular vehicle may fall into one or another category depending upon its design and use. For example, a "van" may be either a "bus," "multipurpose passenger vehicle," or a "truck," depending upon the number of designated seating positions and the use of the vehicle.

The Recreation Vehicle Industry Association, P.O. Box 204, 14650 Lee Road, Chantilly, Virginia 22021, or The Society of Automotive Engineers, Inc., 400 Commonwealth Drive, Warrendale, Pennsylvania 15096, may be able to provide you with specific definitions.

Please contact this office if you have further questions.

Sincerely

ATTACH.

FEBRUARY 5, 1981

Motor Highway Traffic Safety Administrator Department of Transportation

Dear Sir:

Our Community Association, like many others, has restrictions that apply to different types of vehicles. The problem common to all such Associations is how to distinguish the types of vehicles. The confusion arises out of contradictions of definitions as between manufacturers certifications and license bureaus, and even between license bureaus. The problem is the hybrid types of vehicles now being marketed.

We will appreciate any assistance you can give us in defining the following types of vehicles:

A. Vans B. Motor Homes

C. Recreational Vehicles

D. Motor Coaches

Thank you for your time.

Sincerely,

Roger F. Dunn -- Manager, MEADOWBROOK MANAGEMENT COMPANY, INC.