Interpretation ID: nht93-7.15

DATE: October 7, 1993

FROM: Milford R. Bennett -- Head, Safety Affairs and Operations, NAO Engineering Safety Center, GM

TO: H. M. Smolkin -- Acting Administrator, NHTSA

COPYEE: John Womack -- Acting Chief Counsel; Barry Felrice -- Associate Administrator for Rulemaking; Taylor Vinson -- Office of Chief Counsel

TITLE: USG 3024, Part IV; Re: Part 555 Temporary Exemption from Motor Vehicle Safety Standards - Docket No. 93-39; Notice 2

ATTACHMT: Attached to letter dated 10/22/93 from John Womack to Milford R. Bennett (A41; Part 555)

TEXT:

The above referenced docket, as published in the Federal Register, Volume 58, Number 177, page 48421 on September 15, 1993, granted the petition of General Motors Corporation (GM) to allow a temporary exemption from several Federal Motor Vehicle Safety Standards (FMVSS) for a fleet of 50 GM Electric Vehicles (GMEV).

In accordance with Part 555.9(a), and as requested by Mr. John Womack, Acting Chief Counsel of the NHTSA, in his letter dated September 9, 1993, GM is submitting a sample of the certification label that will be affixed to the left front door of each GMEV. This label conforms with the requirements found in Part 567 and Part 555.9(c)(1), including revisions to Part 555.9(c)(1) proposed by the NHTSA (Docket 93-40, Notice 1).

Part 555.9(b) requires that a windshield or side window label containing the statement required by Part 555.9(c)(1) or (2) be affixed securely to each exempted vehicle. After a study of this label requirement, including discussion with Mr. T. Vinson, NHTSA Office of Chief Counsel, GM has concluded that this label is intended to notify prospective buyers that the vehicle has been exempted from certain FMVSS. GM therefore believes that the requirement of Part 555.9(b) to affix a window label to each GMEV is not applicable because GM does not intend to sell the exempted GMEVs. However, if the agency believes that this interpretation is incorrect, please notify us.

If you have any questions regarding these labels, please contact either Mr. R. F. Humphrey of our Washington, D.C. office at (202) 775-5071 or Mr. G. A. Zuchniewicz in Warren, MI at (313) 947-1726.

Attachment (sample of certification label) omitted.