ID: nht95-3.62

TYPE: INTERPRETATION-NHTSA

DATE: July 28, 1995

FROM: T. J. Sommer -- President, White Bear Sales

TO: Taylor Vinson -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 9/19/95 LETTER FROM JOHN WOMACK TO T. J. SOMMER (SEC. 30162(a)(6); A43; REDBOOK 2)

TEXT: Dear Mr. Vinson,

I was directed to you for information regarding the legality of licensing four wheel all-terrain vehicles.

White Bear Sales Inc. is the U.S. distributor of a three wheel police vehicle classified as a "motorcycle" by the DOT, CARB and EPA. Our vehicle is street legal and licensable and has been emission certified.

The City of Chicago Police Dept. is using a number of four wheel all terrain vehicles for patrol work within the downtown area. These vehicles have been issued Illinois State license plates and the officers are using them on public roadways.

We believe that these vehicles are illegal to use on the streets. The City of Chicago is placing their employees at high risk by allowing officers to operate this unit on their routes. The director of Chicago's fleet asked me to compile all federal def initions and statutes which apply to the quad runners, regarding classification, certification, and compliance for street use.

Would you direct me to this information or send me a copy of the statute(s) that apply to licensing (or proof that it is not licensable) for this type of vehicle? We would appreciate any pertinent information regarding this topic.

Phone: 414-466-6868 Fax: 414-466-6936

Thank you in advance for your help.

ID: nht95-3.63

TYPE: INTERPRETATION-NHTSA

DATE: July 31, 1995

FROM: Steven B. Fisher -- Kostow And Daar, P.C.

TO: Phillip R. Recht -- Chief Counsel, NHTSA

TITLE: Re: Motor Vehicle Safety Standard No. 108

ATTACHMT: ATTACHED TO 8/30/95 LETTER FROM JOHN WOMACK TO STEVEN B. FISHER (REDBOOK 2; STD. 108)

TEXT: Dear Mr. Recht:

I am writing you in hopes of obtaining an opinion and/or interpretation concerning Safety Standard No. 108, including but not limited to Table II of such Motor Vehicle Safety Standard.

Pursuant to the above safety standard, with respect to truck, trailer identification lights (red), what is meant exactly by the word "practicable" as used in @@ 5.3.1.1, and 5.3.1.4.

Secondly, whose responsibility is it to assess, or in other words to determine, what is "practicable" and what is not "practicable" relative to the placement and location of rear, identification lamps (red). Is it the manufacturer of the particular i dentification light who provides the trailer manufacturer with tye type of identification light requested or is it the duty of the trailer manufacturer who receives the identification light for incorporation into its trailer to make such determination as they see fit in accordance with No. 108 and in light of the particular design/configuration of the trailer involved?

Third, given the "practicability" term as used in the above standard, combined with the many number of different types of trailers which are made each year and travel the public roadways, is there any way for a manufacturer of a single, rear identific ation light to know for certain, anticipate or otherwise predict where the trailer manufacturer will ultimately place and/or locate the identification lights on any given trailer?

Your cooperation and assistance concerning the above request for an advisory opinion and/or interpretation of the aforementioned standard would be greatly appreciated.

Should you have any questions, please feel free to give me a call. My direct number is 312/474-1404. Thanks again.

ID: nht95-3.64

TYPE: INTERPRETATION-NHTSA

DATE: July 31, 1995

FROM: Dennis G. Moore -- President, Sierra Products Inc.

TO: Chief Council -- NHTSA

TITLE: Legal Interpretation Request for FMVSS # 108

ATTACHMT: ATTACHED TO 9/20/95 LETTER FROM JOHN WOMACK TO DENNIS G. MOORE (A43; REDBOOK 2; STD. 108)

TEXT: Around 1985 * , NHTSA significantly reduced the Amber (Yellow) Photometric output minimals for all Rear Amber Turn Signal Lights. This reduction was implemented, I believe, partially as an act of Common Sense and partially as a positive Harmonization ge sture to European Vehicle Safety people. Whereas these European Safety people did then and still do require "significantly less" Amber Photometric Output area, which was not correspondingly reduced when NHTSA reduced the required Photometric Output. Fu rther, the Europeans still require significantly less Area for Amber lenses than the U.S. still requires.

* Presently I can't find the Federal Register Announcement with Details on this issue, however, I will attempt to send it later. I do know this data is readily available from your Docket Files.

European Safety leaders, I've been told, have "tests" that substantiate their position that a "Smaller" and less bright Amber Turn Singal yields "less conspicuosity", which is a desirable feature when compared to the Conspicuosity demanded by the Very Im portant Red Brake Lights . . . and rightfully so. As one can see for themselves . . . just the fact that a Turn Signal is Amber and not Red (as are all other Rear Safety Lights) makes it adequately "conspicuous", even if it is "smaller" and significantl y less bright compared to the Brake Lights.

Also, European Scientists contend they have always had a "safer system" than the U.S. System as they have always required Two Brightly Lit Brake Lights, whereas the U.S. System allows only One Brake Light to be illuminated, leaving the other as a "Red" T urn (Blinking) Signal -- They contend that the U.S. approach can confuse the human mind and in fact, perhaps be comprehended as an Impending Turn and "not specifically" as a Braking Action whereas their system using. Two Brake Lights - both clearly Lit - means nothing but "Braking . . . Danger!"

They indicate that their smaller in size and brightness, Rear Amber Turn Signal "clearly indicates" to following traffic the situation when a Turn is occurring by itself or simultaneously with the Braking Action.

In any case, I believe our U.S. NHTSA Rulemakers of several years past were in error or experienced an oversight when they reduced and Harmonized the U.S.'s Rear Amber Turn Singal's required output but at the same time did not reduce the "Area" of output which would have kept the "Density * "of U.S. Amber Lights output about the same as the Europeans have found to be effective . . . thus making the U.S. more or less completely Harmonized with the New EU Specifications effective January 1, 1996.

* "Density", a better layman's term than getting into Luminesec and Luminous intensity . . . at this time.

Any American that is actively involved in the Manufacturing of Vehicle Lights knows it is ludicrous to require U.S. Manufacturers to Design Amber Turn Singal lenses in the 12in<2> range * , and then ask them to try and Balance our Trade by attempting to sell larger than necessary (therefore more expensive Lights) in Europe whereas European Manufacturers enjoy the advantage over U.S. Manufacturers of less expense simply because of size.

* which is what is now required for Big Rig and RV Rear Amber Turn Signals

I am asking that a better Trade Balance Policy be adopted as well as seeing that Common Sense reasoning prevails at NHTSA by asking that this situation be corrected.

If NHTSA's Legal Council feels this error should be corrected through the Petitioning Process, I ask that this writing be considered a "Petition for Change of FMVSS # 108 Request" and given consideration for "rapid processing" through the Public Commenti ng period. I seriously doubt if any American Company or Engineer is in possession of any Scientific Data that would refute what reasoning and facts I have presented here. By reducing the minimal area of the Amber Turn Signal light lens from 12 in<2> to approximately 8 in<2> or 6 in<2>, the U.S. would have more practical Rules for U.S. Exports at no expense to Safety.

Please handle this expendiently!

Yours truly,

Dennis G. Moore President

P.S. Please understand that I believe I speak primarily for the "Big Rig", Small Trailer and RV Type Lighting Manufacturers in the U.S., not for the typical S.A.E. Detroit Auto Designer and/or Auto Engineer.

My type of manufacturing is forced, through extreme competition pressure, to make Multi-purpose Rear Lights for about $ 3.00 each in order to be competitive here in the U.S., whereas, Detroit Auto Stylists know that small Amber Turn Signal Lights on Auto s look puny and degrading to their potential customers. They know the bigger these Amber Lenses are, the better they look, the more they cost, and, therefore, the more overall profit is made on them as they are broken and replaced during the life of the Vehicle. Therefore, Detroit stylists and economists don't really want small sized Amber Turn Signals even if they know that small ones do the Safety Job they're intended to do -- they must compete in "Styling" whereas larger and more elaborate lights se ll cars and makes them more money in the long run than what would be saved on small lights, whereas this is not at all true with "Other" Vehicle Lighting Manufacturers like I represent who are trying to Compete in the U.S. and Europe in the Non-Auto Vehi cle Lighting business.

I believe, and apparently so do most European Safety people, that Location, Color and the Density * Output of a Safety Light is more important for "Conspicuosity" than a large lens with low output.

ID: nht95-3.65

TYPE: INTERPRETATION-NHTSA

DATE: July 31, 1995

FROM: Dennis G. Moore -- President, Sierra Products

TO: Chief Council -- NHTSA

TITLE: Subject: Legal Interpretation Request for FMVSS # 108

ATTACHMT: ATTACHED TO 9/25/95 LETTER FROM JOHN WOMACK TO DENNIS G. MOORE (A43; REDBOOK 2; STD. 108); ALSO ATTACHED TO 3/4/77 LETTER FROM FRANK BERNDT TO DENNIS G. MOORE

TEXT: I have been reviewing all NHTSA's attempts over the years at improving the definition of "OPTICAL COMBINATION" as the subject applies to Vehicle Lighting. I have numerous pages of information from the Federal Register and from NHTSA's Docket "Legal Inter pretation" Files gathered over the past 20 years and I must say the situation is now worse than it ever has been.

Back in 1977 I was sent the attached letter from NHTSA lawyers. This was sent to me after five pieces of rather Technical back and forth correspondence * . The substance of the letter is that NHTSA's legal experts finally admitted that Lighting function s that share the same housing and the same lens (and when both use Separate Bulb Filaments and fulfill all other Lighting requirements for their particular function when lit separately), were "not" to be considered Optically Combined.

* All five pieces of Correspondence available upon request, but also in NHTSA's Docket Records.

Later, the Canadians, in spite of U.S. and Canadian written agreements to adopt identical rules and interpretations on this issue, said essentially they would only honor the common housing portion of this Interpretation, which "somehow?", NHTSA also late r adopted in spite of the 1977 Legal Interpretation sent me that was based on well thought out scientific discussions and conclusions. *

Then, around 1990, "out of the blue", NHTSA put a "Rider" into a proposed change that had no relevance to this subject, whereas the Rulemakers added the expression, "NOT TO SHARE THE SAME HOUSING", which of course, knocked out the second part of the Lega l Interpretation sent me. In response, I wrote NHTSA asking for clarification and a reasonable explanation, and was essentially ignored.

Using the Scientific Argument and discussions I submitted back in 1975, 1976 and 1977, and the Re-Interpretation letter sent me, how can NHTSA support the SAME HOUSING definition they currently support?

ID: nht95-3.66

TYPE: INTERPRETATION-NHTSA

DATE: August 2, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Steven Sinkez -- Vice-President, Mitsubishi Motors of America, Inc.

TITLE: NONE

TEXT: Dear Mr. Sinkez:

This responds to your request for an interpretation of our Vehicle Identification Number regulation, which you made in a July 5, 1995, meeting with Dorothy Nakama and Steve Wood of this office. You asked, after Diamond Star Motors Corporation's (DSM's) name is changed to Mitsubishi Motor Manufacturing of America, Inc. (MMMA), whether that company may continue to use the world manufacturer identifier (WMI) assigned to DSM. As discussed below, the answer is yes.

We understand the facts as follows. When DSM was formed, shares of DSM stock were split between Mitsubishi Corporation and Chrysler Corporation. In 1994, Mitsubishi purchased all of Chrysler's shares in DSM. Mitsubishi now owns 100% of DSM stock. Eff ective July 1, 1995, Mitsubishi changed DSM's name to MMMA. We have been informed that no changes other than transfers of shares in DSM stock and the name change were made in MMMA's corporate form.

By way of background information, 49 CFR part 565 Vehicle Identification Number - Content Requirements is intended to simplify VIN information retrieval and to increase the accuracy and efficiency of vehicle defect recall campaigns. Section 565.4(a) prov ides that a portion of the VIN, called the WMI, must "uniquely identify the manufacturer."

The basic issue raised by your question is, if MMMA continues to use the WMI assigned to DSM, whether the WMI will "uniquely identify the manufacturer." In the factual situation at issue, only the company's name is changed, and not the identity of the ma nufacturer, i.e., MMMA is the same corporation as DSM. Therefore, MMMA may continue to use the WMI assigned to DSM.

I hope this response is helpful. If there are any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

ID: nht95-3.67

TYPE: INTERPRETATION-NHTSA

DATE: August 2, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Terrence S. Lockman -- Investigator, Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A., Attorneys-at-Law

TITLE: NONE

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM TERRENCE, S. LOCKMAN TO NHTSA CHIEF COUNSEL (OCC 10855)

TEXT: Dear Mr. Lockman:

This responds to your request for an interpretation whether a Model Year (MY) 1981 Versa Sweeper road sweeper is a "motor vehicle" and therefore subject to the Federal Motor Vehicle Safety Standards (FMVSSs) that were in effect when the vehicle was manuf actured. Further, you ask whether the Versa Sweeper had to comply with requirements for an occupant restraint system or for rollover protection. You explained that you are conducting an investigation, and that "At the time in question, the vehicle was being used in a construction zone, to sweep debris off the roadway."

I note, before beginning, that your letter had asked for certain information under the Freedom of Information Act (FOIA). NHTSA separately answered your FOIA request by letter dated May 22, 1995, from Ms. Heidi Coleman of my staff, Assistant Chief Couns el for General Law.

Yours is an unusual interpretation request. Typically, questions concerning whether a vehicle is a motor vehicle are raised around the time of manufacture of a vehicle or its importation into the country, and by a person knowledgeable about the intended use of the vehicle, such as the vehicle's manufacturer. In contrast, your question asks about another entity's vehicle 14 years after the vehicle's manufacture, which makes our response more difficult. We cannot say for certain what principles would h ave applied in 1981 concerning the Versa Sweeper, and our knowledge of the vehicle is limited to the information you provided. Thus, a conclusive answer is beyond our reach.

We can make the following observations, however. NHTSA applies several principles when making a determination of whether a vehicle is a motor vehicle. Section 102(3) of the National Traffic and Motor Vehicle Safety Act n1 defined a motor vehicle as "a v ehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways . . ." We are not certain, based on the information you provided, that the Versa Sweeper was manufactured for use on public highways. Th e literature you sent indicates that the Versa Sweeper is intended for "road maintenance sweeping and highway preparation cleaning." It appears that the vehicle might be a construction vehicle. Moreover, you indicated that the vehicle was being used in a construction zone "at the time in question." Construction-related vehicles generally are "motor vehicles" for purposes of our statute if they frequently use the highway going to and from job sites and stay at a job site for only a limited time. With r egard to the 1981 Versa Sweeper, its use of the highway is unclear.

n1 In 1994, the Safety Act was recodified, without substantial change, at 49 U.S.C. 30101 et seq. The motor vehicle" definition is set forth in section 30102(a).

Assuming the Versa Sweeper had regularly used the highway, NHTSA's longstanding position has been that vehicles of unusual configuration that are incapable of obtaining speeds greater than 20 miles per hour (mph) are not required to comply with the FMVSS s. It is unclear how this principle applies to a 1989 Versa Sweeper has "Indefinitely variable speeds from 0-30 miles per hour. . ." It is unclear whether this means each Versa Sweeper can attain a speed of 30 mph or whether some, but not all, can. A V ersa Sweeper that had a maximum speed of less than 20 mph is excluded. One that went over 20 mph might not have been.

You ask about requirements for occupant restraints and rollover protection. The agency has stated that "street sweepers" -- that are motor vehicles -- are trucks. In 1981, FMVSS No. 208, Occupant Crash Protection (49 CFR @ 571.208), required open-bodie d light trucks to have a lap belt system. There was no rollover requirement.

If you have any further questions, please contact Ms. Dorothy Nakama of my staff at (202) 366-2992.

ID: nht95-3.68

TYPE: INTERPRETATION-NHTSA

DATE: August 2, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Bonnie Ward -- Eagle County School District RE 50J

TITLE: NONE

ATTACHMT: ATTACHED TO 5/2/95 LETTER FROM BONNIE WARD TO NHTSA CHIEF COUNSEL; ALSO ATTACHED TO 5/28/85 LETTER FROM DIANE K. STEED TO GEORGE L. SIMONTON

TEXT: Dear Ms. Ward:

This responds to your May 2, 1995, letter following up on information provided you by Charles Hott and Leon DeLarm of this agency, concerning the safety of school buses and "over-the-road type coaches" (e.g., Greyhound-type buses). You ask for confirmat ion that our safety standards for school buses "are above and beyond the requirements for over-the-road coaches."

That statement is correct. Our Federal motor vehicle safety standards (FMVSSs) apply to vehicles according to vehicle type. We have FMVSSs that apply to "buses," and those that apply to "school buses." Since a "school bus" is a type of "bus" under our regulations, a new school bus must meet the Federal motor vehicle safety standards that apply to "school buses" in addition to those that apply to "buses." A new over-the-road coach would have to meet our "bus" standards, but not our "school bus" standar ds.

We would like to emphasize the importance that our agency attaches to the use of safe buses to transport children. A school bus meeting the school bus safety standards is the safest means of transportation for school children. It may not be the most co mfortable for long trips, since it lacks the reclining seats and restroom facilities of some over-the-road coaches, but it has safety features that the coaches lack, such as seat backs designed to cushion impacts, windows that prevent ejections, and exit s that facilitate escape after crashes. In the years since buses began to be manufactured with these features, there has been a marked improvement in school bus safety. We urge schools and school districts to consider these features when making school transportation decisions.

For your information, I am enclosing a pamphlet that gives a brief description of the FMVSSs, and an information sheet that explains how you can obtain copies of our standards.

If you other questions on this or any other issue, please do not hesitate to call Deirdre Fujita of my staff at (202) 366-2992.

ID: nht95-3.69

TYPE: INTERPRETATION-NHTSA

DATE: August 3, 1995

FROM: Thomas K. O'Connor -- Chief of Maintenance and Operations, Metropolitan Water Reclamation District of Greater Chicago

TO: Office of the Chief Counsel -- NHTSA

TITLE: Verification of Seat Belt Regulations for Step Vans Over 10,000 Pounds GVW-Federal Motor Vehicle Safety Standards (FMVSS) 207, 208, 209, and 210

ATTACHMT: ATTACHED TO 10/11/95 LETTER FROM JOHN WOMACK TO THOMAS K. O'CONNOR (A43; STD. 208)

TEXT: We are requesting written verification on the type of seat belt needed for our step van vehicles in order to comply with FMVSS 207, 208, 209, and 210. At issue is whether a lap-only seat belt versus a shoulder harness seat belt is needed for compliance. In a phone conversation between members of our respective staffs, we were informed that a lap-type belt would comply. We were further informed that written verification of this could be obtained by writing to your office.

In our field work, we use step vans with a Gross Vehicle Weight over 10,000 pounds, equipped with two front seats, a passenger's seat and a driver's seat. The passenger's seat is mounted on a metal pedestal which allows the seat to tilt forward, making e asier access to the rear. The driver's seat is stationary. If both the passenger and driver seats are certified by the manufacturer to comply with FMVSS 207, 208, and 210 when properly installed, and if a certified seat belt (FMVSS 209) is properly ins talled, the question arose as to whether a lap-only seat belt would comply with FMVSS 207, 208, 209, and 210, or whether a shoulder harness type belt had to be used.

If there are any questions concerning our request for written verification on this matter, please contact Sally Yagol of my staff at (708) 222-4080, from 7:00 a.m. to 3:00 p.m., CST, Monday-Friday.

Thank you for consideration.

ID: nht95-3.7

TYPE: INTERPRETATION-NHTSA

DATE: June 8, 1995

FROM: David A. Lowell -- Engineering Manager, Bankhead Enterprises, Inc.

TO: Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 7/25/95 LETTER FROM JOHN WOMACK TO DAVID A. LOWELL (REDBOOK 2; STD. 108)

TEXT: Dear Chief Counsel,

Bankhead Transportation Equipment designs and manufactures stinger steered automobile transport trailers as defined in 23 CFR Part 658.5 K, M, N. As shown in the enclosed pictures we currently place tail, turn and clearance lights on the back of our truck-tractor. Per 49 CFR Part 571.108 S5.1.1.1 and S5.1.1.2 these items do not seem to be necessary.

We are considering removing these lights but realize we have a specialized unit. Please confirm the legality of the necessity of tail, turn and clearance lights on the back of our truck-tractor.

Enclosures (photos) omitted.

ID: nht95-3.70

TYPE: INTERPRETATION-NHTSA

DATE: August 4, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: The Honorable Chuck Chvala -- Wisconsin State Senator

TITLE: NONE

ATTACHMT: ATTACHED TO 7/24/95 LETTER FROM DOUG BURNETT TO DOROTHY NAKAMA

TEXT: Dear Senator Chvala:

This responds to a letter from U.S. Senator Russell D. Feingold on your behalf, asking whether a pending redefinition of Wisconsin's "school bus" definition would violate Federal law. Senator Feingold contacted the National Highway Traffic Safety Admini stration (NHTSA) because our agency administers the Federal requirements for school buses.

I appreciate this opportunity to address your concerns. As explained below, my review leads me to conclude that Wisconsin's contemplated redefinition of a school bus would not conflict with Federal law, insofar as the redefinition relates to the operati on of school buses. However, an area of possible conflict relates to the requirements for mirrors on school buses.

By way of background information, Chapter 301 of Title 49 of the U.S. Code, authorizes NHTSA to issue Federal motor vehicle safety standards (FMVSS's) applicable to new motor vehicles and motor vehicle equipment. In 1974, Congress directed NHTSA to requ ire new school buses to meet FMVSS's on specific aspects of school bus safety, including floor strength, seating systems, and crashworthiness. The legislation requires each person selling a new "school bus" to ensure that the vehicle is certified as mee ting the school bus FMVSS's. Following the first retail purchase, the use of vehicles becomes a matter of state regulation.

NHTSA defines a "school bus" as a "bus" that is sold for purposes that include carrying students to and from school or related events, and defines a "bus" as a vehicle designed to carry 11 or more persons. 49 CFR 571.3.

We understand that the new definition contemplated by Wisconsin would exclude some vehicles that are school buses under our definition. Information from Mr. Doug Burnett of your staff indicates that the new definition would define a school bus as "a mot or vehicle which carries 16 or more passengers (in addition to the operator)." Thus, a motor vehicle that can carry 11-16 persons (including the driver) would be a "school bus" for Federal purposes, but apparently not for Wisconsin's purposes.

Since the States, and not NHTSA, regulate the use of vehicles, the inconsistency would be immaterial with regard to requirements adopted by Wisconsin pertaining to the use of school buses. Wisconsin may set the operational requirements for those vehicle s the State defines as "school buses" without regard to our school bus definition.

However, the inconsistency would matter at the point of sale of a new school bus. The FMVSS's specify requirements for school buses that do not apply to other buses. See, e.g., 49 CFR part 571.222, School bus passenger seating and crash protection. A d ecision by Wisconsin to adopt a definition other than the Federal definition of a school bus has no effect on the application of the Federal school bus safety standards to a vehicle. Any person selling a new "bus" (a vehicle designed to carry 11 or more persons) to a school must sell a certified "school bus," regardless of whether the vehicle is considered a school bus under Wisconsin law. The vehicle would have to be equipped with the safety features NHTSA requires for school buses.

The information provided by Mr. Burnett indicates that Wisconsin would redefine "school bus" for two purposes. First, Wisconsin would prohibit the operation of a "school bus" -- a vehicle with a capacity of 17 persons (including the driver) -- unless th e bus has a specific type of mirror. (Section 347.40) As explained above, this requirement would not affect NHTSA's requirement that vehicles considered to be "school buses" under our definition must be equipped with the mirrors and other safety feature s we require for school buses, even if the vehicles are not "school buses" under Wisconsin law.

Chapter 301 further provides that a Federal standard preempts any state or local standard applicable to the same aspect of performance that is not identical to the Federal standard. 49 U.S.C. 30103(b). A State standard for mirrors that is not identical to the Federal standard is preempted unless it imposes a higher level of safety and is applicable only to vehicles procured for the State's own use (e.g., public school buses). Wisconsin's requirements for school bus mirrors could be preempted, dependi ng on the type of mirror required and whether the vehicles equipped with it are public buses.

We understand that the second purpose of Wisconsin's contemplated redefinition of a school bus is to require privately-owned vehicles carrying 15 or fewer students to be insured by a policy providing specified minimum coverage. (Section 121.555). This p rovision concerns matters wholly within State law and would not conflict with Federal law.

I hope the above information is helpful to you. If you have any further questions or need additional information, please contact me or Dorothy Nakama of my staff at this address, or at (202) 366-2992.