Interpretation ID: nht93-1.41

DATE: 02/18/93

FROM: JOHN WOMACK -- ACTING CHIEF COUNSEL, NHTSA

TO: DALE E. DAWKINS -- DIRECTOR, VEHICLE COMPLIANCE AND SAFETY AFFAIRS, CHRYSLER CORPORATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12-16-92 FROM P. E. DAWKINS TO MARION C. BLAKEY

TEXT: This responds to your letter of December 16, 1992, to the Administrator informing the agency about the intent of Chrysler Corporation to manufacture 10 Chesapeake Consortium Electric Vehicles (CCEV) under NHTSA Temporary Exemption 92-1.

According to your letter, these vehicles are "almost identical" to the TEVans for which the agency granted the temporary exemption, except that they will utilize an AC electrical motor, while the ones which were the subject of the exemption petition will be powered by a DC electrical motor. You seek no broader exemption as the combined volumes of CCEVs and TEVans "will not exceed the maximum units of the petition that was granted." You have submitted this information to us so that NHTSA will have a clear understanding of the content of your electric vehicle development program and the extent of the exemptions under which these vehicles will be manufactured.

It appears that you would like confirmation from NHTSA that the CCEV vehicles are covered by Temporary Exemption 92-1. In order for the agency to provide this confirmation, it must determine that CCEV and TEVans are essentially the same vehicle and that none of the minor differences between the vehicles affects the findings made by the agency in issuing the TEVan exemption. In granting Chrysler's exemption petition covering three standards, the Administrator first found that the exemption would facilitate the development and field evaluation of a low emission motor vehicle. We do not believe that the change in electrical propulsion from DC to AC affects this finding. The Administrator next found that an exemption from the three standards would not unduly degrade the safety of the vehicle. You state that "[based] on our engineering judgement, there is no significant difference between the CCEV or TEVan in terms of overall vehicle safety." While you may have used the work "significant" in an excess of caution, it implies that there are differences between CCEV and TEVan and that there is a difference in overall vehicle safety between the CCEV and TEVan, although not an important one from Chrysler's viewpoint. We would appreciate your identification of the differences between the vehicles, and of the differences, if any, in the safety between the CCEVs and TEVans that may have led to Chrysler's engineering conclusion. With this information, we shall be better able to evaluate whether the two vehicles are essentially the same and whether there is any undue degradation in safety that might render it inappropriate to consider the CCEVs covered by the TEVan exemption.

We appreciate your calling our attention to this matter.