ID: nht93-7.42

DATE: October 27, 1993

FROM: Larry R. Lynch -- General Manager, AT&D Corporation

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/10/94 from John Womack to Larry R. Lynch (A42; Std. 121)

TEXT:

I have enclosed data describing a new product developed by our Company for the trucking industry. I am requesting that you peruse the information about the product and advise us as to how the current safety standard might be applicable.

Our product has been named the AeroCon System. It was developed from the original concept of typical air deflectors seen on most tractor trailer vehicles. The AeroCon could be referred to as an atypical air deflector/fairing. It incorporates aerodynamic principles to create a stable slipstream and provide aerodynamic braking to the vehicle. By opening doors on the fairing unit, the full force of the relative wind speed is redirected to strike the trailer face, greatly decreasing the stopping distance. The pneumatic power required to actuate the system's doors utilizes the auxiliary air system of the tractor.

Should you require additional data or information for your interpretation, please call us at (904) 588-2700 or FAX (904) 588-2701. Our physical address is: One Pasco Center 30435 Commerce Drive San Antonio, Florida 33576

Please return the enclosed materials, upon the completion of your interpretation.

Your attention to our request is greatly appreciated.

ID: nht93-7.43

DATE: October 28, 1993

FROM: Jelly, Rachel -- Executive Engineer, Legislation and Certification., Lotus Cars Ltd.

TO: Womak, John -- Acting Chief Council, NHTSA

TITLE: NONE

ATTACHMT: Attached To A Letter Dated 5/9/94 From John Womack To John Bloomfield (A42; PART 525)

TEXT: Lotus / Bugatti, request for clarification regarding CAFE petition(s) for alternative CAFE standards.

Since January 1986 General Motors has owned 100% of Group Lotus. Under GM ownership the fuel economy data from the Lotus vehicles has been included with the GM import fleet for the purposes of CAFE fines and reporting. As GM had enough fuel efficient vehicles in its import fleet to offset the shortfall of the Lotus vehicles fuel economy-performance, no fines were required and thus no waiver petition for an alternative CAFE value was necessary.

On the 27th August 1993 General Motors sold 100% of Group Lotus Ltd to Bugatti International. Bugatti is also a vehicle manufacturer and plans to market passenger cars in the USA commencing with the 1994 model year. Both companies actual/projected sales volumes when taken individually, and combined, will make the companies eligible for classification as a small volume manufacturer. Please see the supporting data on page 3 of this letter for sales projections and fuel economy information.

Lotus now finds itself in the position where it needs to apply for an alternative CAFE standard for the 1994 thru 1997 (and possibly subsequent) model years. Also Bugatti is planning to submit a petition for alternative standards in the near future.

Please could you officially advise me if Lotus will be permitted to petition for its own CAFE value for its vehicles and Bugatti will be able to petition for another value for its fleet, or will Lotus and Bugatti have to combine sales projections and fuel economy data and petition for a joint value? The two manufacturing companies are run as separate entities within the group to maintain the individual identity of the products.

If you require any further information please do not hesitate to contact me, my direct line telephone and fax numbers are 44 953 608131 (tel) and 44 953 608132 (fax).

CONFIDENTIAL.

Lotus and Bugatti US manufacturing and fuel economy data:-

ID: nht93-7.44

DATE: October 29, 1993

FROM: John B. Walsh -- Legal Affairs Manager, Corporate Attorney, American Suzuki Motor Corporation

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Request for Interpretation - FMVSS 208 - Sun Visor Label

ATTACHMT: Attached to letter dated 11/4/93 from John Womack to John B. Walsh (A41; Std. 208)

TEXT:

American Suzuki Motor Corporation ("ASMC") requests an interpretation of FMVSS 208 regarding the sun visor label requirements issued by NHTSA on September 2, 1993 (Docket No. 74-14; Notice 82). I understand that the agency discussed this final rule at the most recent NHTSA/Industry public meeting and announced that the agency plans to respond to several pending requests for interpretation of the new rule at the same time that the agency responds to the pending petitions for reconsideration of the rule. ASMC respectfully suggests that its interpretation request contained in this letter could appropriately be handled in the same fashion. Although ASMC has framed this request as seeking an interpretation of the rule, ASMC would not object if NHTSA were to conclude that this request should be handled instead by means of an amendment to the final rule issued in the course of responding to the petitions for reconsideration.

1. Specifically, ASMC requests an very limited interpretation that use of the signal word Warning, but no other word, complies with the requirement to use the signal word Caution for the sun visor label specified in S4.5.1(b)(1).

Discussion

a. The interpretation requested by ASMC conforms with the agency's concern that consistent information and instructions on sun visor labels be presented in a consistent format. All vehicles will bear uniform labels, with the only potential difference being the signal word used. Every signal word will be either Warning or Caution, consistent with the manufacturer's use of those signal words on other vehicle labels and in the vehicle owner's manual. Vehicle occupants will be constantly exposed to the same list of do's and don't's regardless of vehicle manufacturer, and will not be confused by the manufacturer's use of the appropriate signal word.

b. The American National Standards Institute (ANSI) Standard Z535.4-1991, Product Safety Signs and Labels, specifies that Warning or Caution (or Danger) be used as a signal word to indicate risk of personal injury. The ANSI Standard specifies that Warning be used to alert product users to non-imminent risks of serious injury or death. The language from the Standard is:

4.15 Signal Word. The word or words that designate a degree or level of hazard seriousness. The signal words for product safety signs are DANGER, WARNING, and CAUTION.

4.15.1 DANGER indicates an imminently hazardous situation which, if not avoided, will result in death or serious injury. This signal word is to be limited to the most extreme situations.

4.15.2 WARNING indicates a potentially hazardous situation which, if not avoided, could result in death or serious injury.

4.15.3 CAUTION indicates a potentially hazardous situation which, if not avoided, may result in minor or moderate injury. It may also be used to alert against unsafe practices.

Note: DANGER or WARNING should not be considered for property damage accidents unless personal injury risk appropriate to these levels is also involved. CAUTION is permitted for property-damage-only accidents.

If NHTSA permits use of the signal word "Warning" on the air bag sun visor label, this will be consistent with a national effort toward uniformity in safety labeling of products.

c. Many motor vehicle manufacturers currently use the word "Warning," rather than, or in addition to, the word "Caution", as a signal word in owner's manuals or on vehicle labels indicating risk of personal injury. A brief review of a small sample of 1991 through 1993 owner's manuals reveals that Ford, Chrysler, Honda, Nissan, Volvo, Saab, and Suzuki are in this group. Allowing manufacturers to use the signal word "Warning" on the air bag sun visor label would contribute to motor vehicle safety by assuring that occupants of vehicles already employing the word "Warning" for risks of personal injury will be provided with consistent messages about such risks.

d. In the preamble to the Final Rule, NHTSA relates that several commenters referred to various label statements as "warnings." Use of the word Warning as a signal word will not cause any confusion about the nature of the label, as Warning clearly indicates something related to a potential hazard.

2. In addition to the interpretation requested above, ASMC offers the following comment in support of the petitions for reconsideration submitted by General Motors and Ford regarding a change in the final rule to permit placement of the Part 575.105 label on the driver's sun visor.

Discussion

a. It is consistent with motor vehicle safety to permit two labels required by NHTSA to appear on the same portion of a motor vehicle. NHTSA has required both labels. The air bag label must be on the sun visor. The utility vehicle label would be permitted to be on the driver's sun visor, absent the prohibition of S4.5.1(b)(2). NHTSA can resolve the conflict by amending the FMVSS 208 final rule to permit the utility vehicle label to be placed on the driver's sun visor.

b. Having two labels on the sun visor will not cause information overload. The two labels relate to two different aspects of vehicle

use - basic do's and don't's that occupants should follow to obtain maximum protection from air bags, and an alert for drivers of utility vehicles to follow when driving utility vehicles on paved roads. Both labels will be present in air bag-equipped utility vehicles pursuant to regulation, so the utility vehicle label should not be banished from the sun visor because the manufacturer has installed an air bag. Encountering two required labels on two separate parts of the vehicle interior causes no more information overload than encountering the same two labels on the sun visor.

Thank you for considering this request for interpretation and this comment.

ID: nht93-7.45

DATE: October 29, 1993

FROM: Darryl Cobb (Abbeville, GA)

TO: Office of Chief Counsel, U.S. Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 4/7/94 from John Womack to Darryl Cobb (A42; Std. 111)

TEXT:

Enclosed in this letter you will find information on a mirror that I would like to import into this country. My questions are, is there any prohibitions in the law that would keep the mirror from being sold as an AFTER MARKET PRODUCT? Would it be legal for people who sell the mirror to also install them? (I am specifically referring to outside rearview mirror-driver's side of the car.) Finally, will the law allow someone other than the owner of the car to install the mirror? Please send me an interpretation and copy of the law(s) which pertain to my questions. Thank you for your attention.

(Brochure and photos omitted.)

ID: nht93-7.46

DATE: November 1, 1993

FROM: Dan Neaga -- Project Engineer, Advanced Engineering Business Unit, Johnson Controls, Inc.; Dianna Sabo -- Engineering Manager, Advanced Engineering Business Unit, Johnson Controls Inc.

TO: DOCKET SECTION, NHTSA

COPYEE: S. Furr; B. Batzer

TITLE: Re: Request For Clarification On FMVSS 213 S5.2.2.1 (b)

ATTACHMT: Attached To Letter Dated 6/9/94 From John Womack To Dan Neaga And Dianna Sabo (A42; Std. 213)

TEXT: Dear Sir/Madam:

This letter is in regard to FMVSS 213 S5.2.2.1 (b). Johnson Controls, Inc. designs child seats for children that weigh from 20 to 60 pounds. We have developed a new design for an Integrated Child Restraint System (ICRS) that uses the same seat back surface as the adult occupant. Therefore, no lateral support other than the one offered to the adult occupant is provided.

We have enclosed a set of three illustrations that show a generic adult seat (a) with the child seat in fully stored position; (b) with the child seat deploying; (c) with the child seat fully deployed.

The wording in FMVSS 213 S5.2.2.1 (b) is "Each system surface provided for support of the side of the child's torso shall be flat or concave and have a continuous surface of not less than 24 square inches for systems recommended for children weighing 20 pounds or more . . . ", and we have interpreted it to mean that lateral support is not necessarily required. Please confirm that surface provided for support of the side of the child's torso is not required by FMVSS 213 under these circumstances.

The information and design concepts that we have provided you with are confidential. If you need additional information regarding this matter, please contact me at the above address, or you may reach me at [Illegible Word]. My fax number, should you require it, is (313) 454-7874.

2

We thank you very much for your cooperation and look forward to hearing from you soon.

Sincerely,

JOHNSON CONTROLS, INC.

Enclosures

ID: nht93-7.47

DATE: November 3, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: The Honorable Phil Gramm -- United States Senate

TITLE: None

ATTACHMT: Attached to Privacy Form dated 9/19/93 from Thomas J. Devon to Senator Phil Gram (OCC number illegible)

TEXT:

Thank you for your inquiry on behalf of your constituent, Mr. Thomas J. Devon of Longview, Texas. The Federal Highway Administration (FHWA) referred your inquiry to this office, since the National Highway Traffic Safety Administration (NHTSA) administers Federal safety standards for tires.

In his communication with you, Mr. Devon expressed concern about separated treads from retreaded large truck tires. He "referred to the deaths of two young women reportedly caused when they lost control of their vehicle after striking a separated tread in the road. Mr. Devon is concerned that retreaded tires do not meet the same standards as new tires and requested data on accidents caused by separated tire tread sections on the roadway.

By way of background information, the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C. S1381, et seq. (Safety Act) authorizes NHTSA to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Pursuant to that authority, NHTSA has issued various Federal Motor Vehicle Safety Standards (FMVSS) applicable to tires: FMVSS Nos. 109 and 110 for new pneumatic passenger car tires; FMVSS Nos. 119 and 120 for new pneumatic tires for other than passenger cars; and FMVSS No. 117 for retreaded passenger car tires. There is currently no standard applicable to retreaded tires for vehicles other than passenger cars. This is because the agency is not aware of any data suggesting a safety need for such a standard.

With respect to tire tread separation, examination of actual tire scraps from the nation's highways have indicated that about 60 percent came from retreaded tires and 40 percent from original tires. Because of the many complaints about heavy truck tire tread scraps on and around the highways, the University of Michigan conducted a study in the mid-1980s' entitled "Large Truck Accidents Involving Tire Failure." That study concluded that most large truck tire failures are caused by vehicle overload and/or tire underinflation. Underinflation causes excessive flexing of the tire. The friction resulting from that flexing causes excessive heat buildup which can, in turn, result in tread separation or other tire failure. Indeed, the heat buildup has been known to be so extreme as to cause the tire to burst into flame.

The findings from the Michigan study led the FHWA to prohibit the operation of commercial motor vehicles with overloaded and underinflated tires, unless the vehicle is operated pursuant to a special permit issued by a state. That permit, however, requires a reduced speed to compensate for the increased tire loading. In addition, the vehicle and the tires must be maintained in a safe operating condition at all times. FHWA conducts

roadside inspection programs to ensure that such requirements are being met.

While scraps of tires on the roadway could pose a safety hazard to motorists, this agency has no real world crash data to indicate what percentage of motor vehicle crashes could be attributed to separated tire treads. Our crash data are limited to the general category of tire failure.

Please be assured that NHTSA and FHWA, as well as the tire industry itself, are engaged in ongoing efforts to alleviate this problem by appropriate publicity to large truck owners and operators regarding proper tire care and maintenance and by vigorous vehicle inspection programs.

I hope this information is helpful. If your constituent has any further questions, he may contact Walter Myers of this office at this address or at (202) 366-2992.

ID: nht93-7.48

DATE: November 3, 1993

FROM: Ronald L. Signorino -- Director, Health, Safety & Regulatory Affairs, Universal Maritime Service Corp.

TO: John Womack -- Acting Chief Counsel, Federal Highway Administration

TITLE: VIA FAX: 202 366 3820

ATTACHMT: Attached to letter dated 11/19/93 from John Womack to Ronald L. Signorino (A41; Std. 108)

TEXT:

I write representing Maersk Line, Inc., a shipping corporation having considerable interests in intermodal transportation issues worldwide.

Maersk Line is poised to have production begun on a very large number of intermodal container chassis. They will be fabricated by manufacturers in the United States. Indeed, Maersk Line's purchasing representatives are due to view prototype chassis next week; authorization to begin actual production is expected at that time.

Desiring to remain consistent with the Federal Highway Administration's (FHWA) Conspicuity Rule, Maersk Line sought the assistance of Selecto- Flash, Inc., of Orange, New Jersey. Selecto-Flash has for some time serviced the marking, stenciling, and decaling needs of intermodal interests, and was thought to be well-positioned in determining proper routes of compliance with the conspicuity requirements.

To that end, they had been in contact with FHWA and had been given advice relative to the conspicuity marking of intermodal container chassis. Once in receipt of that advice Selecto-Flash shared it with Maersk Line, hoping to provide them with the benefit of FHWA's considered interpretation. Subsequently, Selecto-Flash received a letter from you dated October 20, 1993, in which you reversed that FHWA interpretation. That reversal gives rise to this communication in which I, as the individual responsible for regulatory issues to this firm's parent, Maersk Line, Inc., am compelled to gain a clearer understanding of FHWA's conspicuity position. This is necessary so that Maersk Line may effectively act next week in approving prototype versions of U.S. manufactured intermodal container chassis.

My understanding can be gained by providing you with a set of given facts and posing one question.

Fact: With particular reference to Maersk Line's prospective order for forty-foot gooseneck chassis (drawing accompanies this fax), your October 20 letter makes clear that calculable conspicuity treatments must not be obscured by trailer cargo;

Fact: In calculating the area of conspicuity treatment for such chassis, the gooseneck section, as it is often hidden from view by mounted intermodal containers (trailer cargo), cannot properly be considered as an appropriate site; and

Fact: In determining the fifty percent of side surface area to receive conspicuity treatment on such chassis, the length of the chassis, from its rear bolster to its point immediately behind the gooseneck's terminus, is

solely relevant.

Question: Are the foregoing facts right, or wrong?

Please appreciate, Mr. Womack, that the timeliness of your response is important to all parties concerned in this matter. Given the contrasting nature of positions on this matter emanating from FHWA, I know you will make every effort to be sympathetic to Maersk Line's production schedule. With kindest regards.

ID: nht93-7.49

DATE: November 3, 1993

FROM: Leo Chung -- Operational Services, Genstar Container Corporation

TO: Taylor Vinson -- Chief Counsel, NHTSA

TITLE: Re: Trailer Conspicuity Requirement of Federal Motor Vehicle Safety Standard no. 108: Lamps, Reflective Devices and Associated Equipment

ATTACHMT: Attached to letter dated 11/29/93 from John Womack to Leo Chung (A41; Std. 108)

TEXT:

We are one of the worldwide container leasing companies and I am writing to request any further interpretations of the captioned requirement which concerns our U.S. container chassis equipment operation due to the information we received from various sources giving different interpretations on the application of the side horizontal strip of conspicuity marking over 50% of the trailer length.

In order to comply with the law, please kindly clarify the actual definition of the trailer length and how the 50% computation applies to our container chassis because there are chances that this equipment will be running around with NO container being carried on top. Therefore, shall the gooseneck be included in the 50% computation and the length be the OVERALL length? (ie. measure from the very end point of one end to another)

Look forward to hearing from you soonest.

ID: nht93-7.5

DATE: October 1, 1993 Est.

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tom DeLapp -- Executive Coach Builders, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 8/18/93 from Tom DeLapp to Chief Council, NHTSA (OCC-9085)

TEXT:

This responds to your letter of August 18, 1993, concerning a modification you wish to make on limousines manufactured by your company. You wish to modify the hinge assembly controlling forward and reclining movement of the front seat to provide access to the area between the front of the privacy panel and the back of the front seat. (The area contains auxiliary fuse panels and relays.) The modification would involve removal of a metal pin in the hinge assembly, allowing the seat to articulate forward to a greater degree. You asked whether Standard No. 207, Seating Systems, prohibits the removal of a limiting pin or limits forward movement of a seat back.

Standard No. 207 specifies strength and other performance requirements for seats in passenger cars, multipurpose passenger vehicles, trucks, and buses. Section S4.3 of Standard No. 207 contains requirements for hinged or folding seat backs, except for passenger seats in buses or a seat adjustable only for its occupants. Section S4.3(a) requires a self-locking device for restraining the hinged or folding seat back. Section S4.3.2 contains performance requirements for this restraining device.

Section S4.3 does not limit the degree of movement of a hinged or folding seat back. Thus, you may remove the limiting pin if removing it only increases the degree of movement of the seat. However, the seat must still meet the requirements of S4.3 with the pin removed. Accordingly, the seat must have a self-locking device that can withstand the force applications specified in S4.3.2.1 and acceleration specified in S4.3.2.2.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht93-7.50

DATE: November 3, 1993

FROM: Thomas D. Price -- President, Strait-Stop Manufacturing Co., Inc.

TO: Senator David Boren

TITLE: None

ATTACHMT: Attached to letter dated 12/23/93 from Howard M. Smolkin to David L. Boren (A41; Std. 121); Also attached to letter dated 4/13/93 from Howard M. Smolkin to David Boren

TEXT:

In August, 1992, I wrote to inform you of our noncomputerized antilock brake system and to enlist your aid in monitoring the activities of the National Highway Traffic Safety Administration during the amendment process for FMVSS 105, and FMVSS 121. Since then, and on several occasions, we have communicated our views and our concerns to the Agency as to the possible discrimination which might be employed by NHTSA regarding a definition of ABS. Our requests that the Agency become familiar with the Strait-Stop system before they reach final decisions have regularly ignored or rejected.

Meanwhile, our system has continued to prove itself as an effective antilock device that also significantly reduces maintenance expense for the vehicle operator. Whereas, the computerized systems only activate when lockup is imminent, the Strait-Stop ABS actuates almost every time the driver applies the brakes. In NHTSA's own final report on a two year test of computerized ABS on trucks, they concluded the systems activated 1.4 times per 10,000 brake applications or 1.1 times per 10,000 miles traveled. Our system activates 7.000 times more often than theirs. It is an aid with which the drivers can become familiar. It is a constant approach to maintaining enhanced stability and controlled braking, not a dire emergency, last minute device.

This brings me to the extreme concern of the moment and my purpose in approaching you. On September 28, 1993, NHTSA published in the Federal Register two NPRMs relating to FMVSS 105, and FMVSS 121. Included therein is the following proposed definition of ABS to be included both at S571.105, S4 and at S571.121, S4:

Braking System means a portion of a service brake system that automatically controls the degree of rotational wheel slip during braking by:

1. Sensing the rate of angular rotation of the wheels; 2. Transmitting signals regarding the rate of wheel angular rotation to one or more devices which interpret those signals and generate responsible controlling out put signals; and 3. Transmitting those controlling signals to one or more devices which adjust brake actuating forces in response to those signals.

This definition is absolutely restrictive and discriminatory to the benefit of only one technology. It not only excludes the Strait-Stop ABS, but also precludes the development of any future technology which might be even more effective in achieving brake safety. Although NHTSA persists in the position that they never approve nor disapprove equipment, they are, very effectively, attempting to prescribe one specific technology. The defense for such a biased

opinion is the three year testing of only one technology, which DID NOT demonstrate an irreproachable, overwhelming body of evidence that the computerized ABS is the only solution to vehicle stability and control problems. Since they have not completed nor even entertained a comparison of the computerized versus the noncomputerized technologies, one can only conclude NHTSA is proposing an arbitrary restraint favoring one vested interest.

The antilock brake industry will be a multibillion dollar business and we resent what we believe to be an overt attempt to exclude our opportunity to compete. In addition, there are several segments of the transportation market which can only use the Strait-Stop technology to their benefit. One of those segments is transit buses. The computerized systems can never be anything but an unmitigated cost, whereas, the noncomputerized system has proven it can substantially reduce operating and maintenance expense.

We will continue in our response to NHTSA's NPRMs and in our attempts to rally other transportation industry participants to our views. We desperately need immediate political intervention to avoid an economic catastrophe for our company and a deprivation of the transportation industry of a viable aid to safety and the right of self-determination as to how to best meet their needs. We are the smallest of a minority now, but we can grow to be a significant contributor to the economic welfare of Oklahoma in general and Cleveland County in particular.

Please lend us your immediate knowledgeable support in this very critical battle.

Enclosure:

ABS DEFINITION

The NHTSA is doing precisely what it has said all along it would not do. Instead of limiting itself to requiring performance standards for stopping distance, steering control and maintaining vehicle lateral stability, it is proposing a definition for ABS that adopts ONLY ONE antilock braking system technology currently available and may very well preclude the utilization of existing and future alternative, more effective systems.

ABS is an acronym for antilock braking system, which is a compound term of four words having the following meanings:

anti - opposing in effect or activity (as by inhibiting, curing, neutralizing or combating)

lock - to hold fast or inactive; to make fast by the interlacing or interlocking of parts

braking - arresting the motion of a mechanism, usually employing friction; slowing down or stopping movement or activity

system - a group of interacting bodies under the influence of related forces

Therefore, generically, ABS is defined as, "a group of interacting bodies (components) opposing (inhibiting) loss of activity capability necessary to arrest the motion of vehicle by employment of friction".

More specifically, ABS could be defined as, "a group of mechanical and/or electronic components, which inhibits the nullification of frictional forces employed in arresting the longitudinal and lateral motion of a motor vehicle".

Any ABS, so defined would be required to meet or exceed the performance standards for stopping, control and stability. The only elements lost by the above definition are (1) the propensity of the Agency staff to consider computerized technology as the only viable approach to ABS and (2) the economic compulsion of Rockwell/WABCO, Midland/Grau, Bendix/Knorr and Robert Bosch to limit the scope of competition, via Federal mandate, in the United States.

- - - -

The following letter transmits Mr. Price's letter to the NHTSA:

November 15, 1993

Howard Smolkin, Acting Administrator NHTSA 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Smolkin:

I have again been contacted by my constituent, Mr. Thomas Price, of ABAS Marketing concerning his anti-locking braking system. Mr. Price is concerned that the proposed rule-making by the NHTSA is discriminatory and by definition would exclude his braking system from being considered for future use.

Enclosed is his most recent letter to me raising these issues and his concerns about them. In an effort to be helpful to Mr. Price, I would appreciate your review of his letter and a response that I can share with him.

Thank you for your thoughtful consideration. I will look forward to hearing from you. Please send your response to my Oklahoma City office, to the attention of Jim Hopper.

Sincerely,

David L. Boren United States Senator