ID: nht74-5.10

DATE: 03/06/74

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Flagg; Cooper; Hayner; Miller; Long & Owen

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 17, 1974, in which you enclose a sample of the wording your client intends to use on his certification label, and solicit our comments.

The proposal that would allow an alternative to the required listing of individual axles (Docket No. 73-31, Notice 1) would become effective on the date of publication of the final rule. Consequently, certification labels using a single value for identical weight ratings may not be used until that time. The label you submit for approval does conform to the current proposal. However, we are considering requiring the inclusion of tire-size designations on the certification label when the gross axle weight ratings are combined.

We have no objection to the additional information contained on the label on the right of the required information. As we understand it, this will lessen the likelihood of mislabeling by the assembler in the field. It would not be possible for him to use a label that would overrate the trailer.

ID: nht74-5.11

DATE: 03/07/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Kirkland; Ellis & Rowe

TITLE: FMVSR INTERPRETATION

TEXT: We have reviewed the revised defect notification letters in International Harvester campaigns number 73505, 73503, 73511, 73513, G-73520 and G-73521 which you forwarded to us. We believe these revised letters conform to 49 CFR Part 577. However, we believe the letters in campaigns 73505, 73513, and 73521, which involve an accelerator problem, should, in response to the requirements of @ 577.4(c)(4), include some guidance as to how the driver can stop the vehicle.

While we find the letters you submit to conform to the requirements, we are of the opinion that, in general, the format you use to describe the defect (577.4(c)) goes little further than meeting the regulation's literal requirements. We suggest you review the letters we have received from other companies in order to obtain an indication of other, more complete approaches to meeting the requirements. While we had indicated that we might furnish you specific letters as examples, we prefer not to recommend any specific letter as a model or to imply that it is preferable to others.

SINCERELY,

2/14/74

From the Desk of

Bert W. Rein

Per our conversation of yesterday.

IH Recall No. 73505

Dear International Customer:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

International has determined that a defect which relates to motor vehicle safety exists in the vehicle identified on the enclosed form. This defect exists in the carburetor control linkage fast idle cam retaining screw. The screw can loosen and fall out, dislodging the fast idle cam. Any loss of fast idle (engine cold) would be a sign of this screw loosening.

If the cam becomes jammed in the throttle linkage, it can stick the throttle linkage up to one-half open thus preventing the driver from decreasing vehicle speed by reducing accelerator pressure. The malfunction may occur without warning and can cause vehicle crash.

We urge that you contact your International dealer or branch immediately to arrange an appointment to have your vehicle corrected. Dealers and branches have instructions for correcting this defect. Parts are available at dealers and branches.

It is estimated that it will take 0.4 hour to replace this retaining screw. There will be no charge to you for parts and labor involved. Presentation of this notification and the enclosed Customer Authorization for Required Service form to your International dealer or branch will assist him in completing the necessary service.

INTERNATIONAL HARVESTER COMPANY

IMPORTANT: In the event you no longer own the vehicle described, please fill in the requested information on the front side of the enclosed postage prepaid card and return it to us. Thank you.

IH Recall No. 73503

Dear International Customer:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

International has determined that a defect which relates to motor vehicle safety in the 1010 pickup truck with power brakes exists in the vehicle identified on the enclosed form. The defect exists in a low percentage of the vehicles produced but its existence may not be apparent to the average driver.

The defect is the installation of the wrong vacuum power booster master cylinder assembly (one intended for disc brakes) which results in the brakes seemingly acting normal but which may leave the brake pedal somewhat lower than normal. Without prior warning to the driver, substantial loss of stopping ability may be experienced and, in beyond normal braking situations where rapid stops are required, vehicle crash can occur.

We request that you contact your International dealer or branch immediately to arrange an appointment to have your vehicle inspected and the correct power brake unit (master vac) installed, if needed. Dealers and branches have the instructions for correcting this defect. We estimate that parts will be available at dealers and branches by .

It is estimated that it will take 1.3 hours to replace the unit. There will be no charge to you for parts and labor involved. Presentation of notification and the enclosed Customer Authorization for Required Service form to your International dealer or branch will assist him in completing the necessary service.

INTERNATIONAL HARVESTER COMPANY

IMPORTANT: In the event you no longer own the vehicle described, please fill in the requested information on the front side of the enclosed postage prepaid card and return it to us. Thank you.

IH Recall No. 73511

Dear International Customer: This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

International has determined that a defect which relates to motor vehicle safety exists in the Loadstar truck identified on the enclosed form. The defect is the installation of a gas tank filler cap which does not have a pressure and vacuum relief. Should the vehicle become upset and involved in a fire, the absence of pressure and vacuum relief could cause explosion from excess pressure in the gas tank.

We urge you to contact your International dealer or branch immediately and have a new gas tank filler cap installed. Dealers and branches have the instructions for correcting this defect. We estimate that parts will be available at dealers and branches by .

It is estimated that it will take 18 minutes to replace the gas cap. There will be no charge to you for parts and labor involved. Presentation of notification and the enclosed Customer Authorization for Required Service form to your International dealer or branch will assist him in completing the necessary service.

INTERNATIONAL HARVESTER COMPANY

IMPORTANT: In the event you no longer own the vehicle described, please fill in the requested information on the front side of the enclosed postage prepaid card and return it to us. Thank you.

IH Recall No. 73513

Dear International Customer:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

International has determined that a defect which relates to motor vehicle safety exists in the Travelall or pickup truck equipped with a V-400 engine identified on the enclosed form.

The defect exists in the idle screw which acts as the rest stop for the throttle linkage determining the idle speed (engine hot). The screw may back out by itself in normal use and can interfere with the throttle linkage, sticking it in an open position and preventing the driver from decreasing vehicle speed by reducing accelerator pressure. The malfunction may occur without prior warning and can cause vehicle crash.

We urge that you contact your International dealer or branch immediately to arrange an appointment to have your vehicle corrected. Dealers and branches have instructions for correcting this defect. Parts are available at dealers and branches.

It is estimated that it will take 30 minutes to replace this curb idle screw. There will be no charge to you for parts and labor involved. Presentation of this notification and the enclosed Customer Authorization for Required Service form to your International dealer or branch will assist him in completing the necessary service.

INTERNATIONAL HARVESTER COMPANY

IMPORTANT: In the event you no longer own the vehicle described, please fill in the requested information on the front side of the enclosed postage prepaid card and return it to us. Thank you.

IH Recall No. G-73520

Dear International Customer:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

International has determined that a defect which relates to motor vehicle safety exists in the diesel powered Loadstar identified on the enclosed form. This defect pertains to the accelerator pedal and, specifically, the pin located above the heel of the accelerator pedal, lower side. This pin may catch on the engine cover or carpet and cause the throttle to hold in the open position preventing the driver from decreasing vehicle speed by reducing accelerator pressure. The malfunction may occur without warning and can cause vehicle crash.

We urge that you contact your International dealer or branch immediately to arrange an appointment to have this pin removed from your vehicle. Dealers and branches have instructions for correcting this defect. No additional parts are required.

It is estimated that it will take 30 minutes to remove this pin from the vehicle. There will be no charge to you for labor involved. Presentation of this notification and the enclosed Customer Authorization for Required Service form to your International dealer or branch will assist him in completing the necessary service.

INTERNATIONAL HARVESTER COMPANY

IMPORTANT: In the event you no longer own the vehicle described, please fill in the required information on the enclosed postage prepaid card and return it to us. Thank you.

IH Recall No. G-73521

Dear International Customer:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

International has determined that a defect which relates to motor vehicle safety exists in the D-500 vehicle identified on the enclosed form. This defect pertains to the vacuum hoses supplying vacuum to the power brake unit (Master-Vac) or vacuum reserve tank if so equipped. These hoses should be double wrap hoses but, inadvertently, single wrap hoses were installed. These weaker single wrap hoses may collapse and thus cause total loss of braking power assistance from the power brake unit. Loss of the power brake unit may reduce total braking efficiency by up to 60% and loss of this assistance will require much greater brake pedal effort to effect a stop. This malfunction may occur without warning and can cause vehicle crash.

We urge that you contact your International dealer or branch immediately to arrange an appointment to have your vehicle corrected. Dealers and branches have instructions for correcting this defect. Parts are available at dealers and branches.

It is estimated that it will take an average of 40 minutes to replace these hoses. There will be no charge to you for parts and labor involved. Presentation of this notification and the enclosed Customer Authorization for Required Service form to your International dealer or branch will assist him in completing the necessary service.

INTERNATIONAL HARVESTER COMPANY

IMPORTANT: In the event you no longer own the vehicle described, please fill in the requested information on the front side of the enclosed postage prepaid card and return it to us. Thank you.

ID: nht74-5.12

DATE: 03/08/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Toyo Kogyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 1, 1974, request for interpretation of Standard No. 106, Brake Hoses, concerning "collapse" in S9.2.8, an incorrect value in Table VI, and proper labeling format.

Your confusion about the meaning of "collapse" in S9.2.8 points out that the requirement was inadvertently changed between notices 7 and 8 and that it should require "no leakage or separation of the inner tube from the fabric reinforcement of the hose". The language will be amended in the near future.

In our response to petitions for reconsideration of Standard 106, we corrected the 5/64 value (question 2) and we accommodated labeling of short hose by permitting labeling separated by any amount up to 6 inches (question 4). You must use one line for labeling required by Standard 106, but you may interrupt the stripe on the opposite side of the required labeling with labeling for other countries, in accordance with S5.2.1 (question 5). In answer to question 3, the fractions should read 3/16, as you indicate you wish to do it.

Your associate, Mr. Hirai, asked our office for an explanation of the certification requirements of S114 of the National Traffic and Motor Vehicle Safety Act of 1966, as they apply to items of motor vehicle equipment to which a standard applies. I have enclosed a notice of clarification.

ENC.

February 1, 1974

Richard B. Dyson

Assistant Chief Counsel

National Highway Traffic Safety Administration

Re: FMVSS 106, Hydraulic Brake Hoses, Docket No. 1-5; Notice 8.

On January 31, 1974, I talked with Miss Grace Robinson, she gave me the information I requested and informed me to send an official letter for confirmation.

Toyo Kogyo has the following question on these regulations:

(Question 1)

Section 9.2.8

"...The vacuum brake hose shall not collapse in a vacuum test of 26 inches of Hg. for 10 minutes." Its' "collapse" may be allowed, if it shall not fully collapse, is this correct?

In section 9.2.6, it shall be allowed with 1/16 inches collapse, with the less severe test condition of 26 inches Hg. and even 5 minutes.

(Question 2)

In table VI dimension of test specimen and feeler gage for deformation tests.

Inside diameter of hose Spec. D (in.) 11/32 inches 3/64 is described, but we think is 11/32 5/64 correct. Is this a misprint?

1) Based on SAE J1403 table 4, 5/64 is correct.

2) Other inside diameter is complete same as the thickness.

(Question 3)

In S9.1 of labeling, may we use the 3/16, (3 and 16 are located in the same line) shape of inside diameter, instead of 3/16?

(Question 4)

In S9.1 of labeling may we describe it with 2 lines?

The length of this labeling shall be assumed with 80mm. We are using 150mm length of hose but in some cases about 55mm length one will be considered in future.

(Question 5)

May we use another labeling on the hose along with the FMVSS 106 labeling?

We are now considering utilizing the hose in another country as well as in the U.S.A.. In that case we want to describe 2-labelings at the same time on the hose. If one more labeling is located on the backside there's no confusion.

Your earliest reply will be appreciated.

Thank you.

Gorou Utsunomiya Branch Manager Toyo Kogyo Co., Ltd. U.SA. Representative Office

cc: Miss Grace Robinson

Dr. Kazushi Sakashita Mr. Eisuke Niguma

ID: nht74-5.13

DATE: 03/12/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: McIntosh & Boynton

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 19, 1974, forwarding to us for approval a draft notification letter regarding the Checker front seat adjuster (CIR-727).

The one remaining problem we have with your letter is in the second paragraph. Because Checker is a manufacturer of motor vehicles, the appropriate determination by Checker pursuant to @ 577.4(b)(1) is that the defect exists in the motor vehicles in question. Your second sentence should be changed, and may be changed to read, "The Checker Motors Corporation has determined that a defect which relates to motor vehicle safety exists in some 1972 model Checker vehicles manufactured from December 9, 1971, through April 5, 1972, and results from improperly installed front seat adjuster assemblies."

We have decided to accept notification letters in which the reference to "some" vehicles (@ 577.4(b)(2)) is placed in the sentence required by @ 577.4(b)(1).

SINCERELY,

Dear Checker Owner:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

The Checker Motors Corporation has determined that a defect which relates to motor vehicle safety exists in the front seat adjuster. This defect exists in some 1972 model Checker vehicles manufactured from December 9, 1971 through April 5, 1972 and results from improperly installed front seat adjuster assemblies.

Your vehicle is equipped with an adjuster assembly which allows selective fore and aft positioning of the front seat (see attached illustration). The seat is secured at the selected position by the engagement of a pawl and notch on the right and left hand seat adjuster track. The right hand pawl is engaged by a spring and disengaged by a wire attached to both the left and right hand pawl. If tension was introduced in the wire during installation, it may not allow full engagement of the pawl and notch at the right hand seat adjuster track. If a vehicle with only partial engagement between the pawl and notch is involved in an accident or is suddenly decelerated, the seat could slide forward and cause injury to the front seat occupants from impact with the vehicle interior (windshield, dashboard and steering column).

You are urged to take your vehicle to a Checker dealership to have the front seat adjuster installation checked for proper operation. Should your seat adjuster require repair, your Checker dealer will at "no cost" to you:

1. Using the prescribed template, drill four (4) 3/16 diameter holes through the center section of the seat frame.

2. Install a new pawl actuator wire.

3. Anchor the pawl actuator wire with a 1/8 x 1 cotter pin at the hole which removes the minimum amount of slack necessary to accurate the right hand pawl.

In the majority of cases, the actual work described above will take less than 30 minutes, however, prior to taking your vehicle to a Checker dealership, it is suggested that you contact the dealer's service department and determine when service time will be available. The necessary parts and instructions will be available at Checker dealerships by March 1, 1974. Presentation of this letter will assist you in obtaining this service.

CHECKER MOTORS CORPORATION

ID: nht74-5.14

DATE: 02/26/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 19, 1973, asking whether Blue Bird may use the manufacturing date of incomplete vehicles it manufactures, to be completed at a later time, as the date by which conformity to applicable safety standards is to be determined. You indicate that Blue Bird manufactures both incomplete and complete vehicles.

The Certification and Vehicles Manufactured in Two or More Stages regulations (49 CFR Parts, 567, 568) allow only final-stage manufacturers to certify conformity to applicable standards as of the manufacture date of an "incomplete vehicle." A person who manufactures the entire vehicle, including the chassis, is not a final-stage manufacturer within the intent of the regulation, and such a vehicle must be certified as of the date of its completion.

Part 568 clearly intends that multistage vehicles will be manufactured by more than one party. As your letter points out, the documentation required by Part 568 is unnecessary when only one manufacturer is involved. Moreover, the justification in the regulations for allowing a final-stage manufacturer to utilize the manufacture date of the incomplete vehicle is based partially on the fact that he has no control over the configuration of the incomplete vehicle, and that the incomplete vehicle manufacturer has no control over when and how the vehicle is completed. This justification does not exist when a single party builds the entire vehicle.

To permit a manufacturer of a complete vehicle to choose a date other than the completion date for purposes of conformity would present this agency with serious enforcement problems.

Which standards would apply would depend on how "separate" were a single company's manufacturing operations. Due to the endless possibilities that may arise in this regard, it is difficult to envision fair and objective criteria by which this decision could be made. Finally, providing the relief you request would allow a manufacturer to avoid compliance with a forthcoming standard by manufacturing large numbers of incomplete vehicles for completion by him at a later time.

You should note that the legal status of Parts 567 and 568 is unclear, due to the recent Court decisions in the Rex Chainbelt case. You will encounter no problems, however, by continuing to follow the regulations until further agency action is taken.

ID: nht74-5.15

DATE: 02/28/74

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Mercedes-Benz of No. America

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 11, 1973, asking whether each of the following tire labeling formats used by the Michelin Tire Corporation complies with Motor Vehicle Safety Standard No. 109:

1. "2 steel tread plies/2 rayon body plies";

2. "max load 1,310 lbs at 36 psi max press."

We find that the first label format fails to conform to the standard. Paragraph S4.3(a) requires the tire to be labeled with, "the actual number of plies in the sidewall, and the actual number of plies in the tread area, if different." The labeling format used by Michelin creates the impression, contrary to the stated requirements, that the number of plies in the sidewall and the tread area is the same, viz. "2". We consider the body plies, running from bead to bead and lying under the plies in the tread area, to be counted also as plies in the tread area. Thus, the number of plies in the tread area is "4", 2 steel and 2 rayon. Moreover, while we understand the words "body plies" to be essentially synonymous with "sidewall plies", we feel there is little justification for departing from the words of the standard, which uses the word "sidewall" in referring to plies.

We find the second labeling format, that dealing with maximum permissible inflation pressure and maximum load rating, to conform to Standard No. 109. The words "permissible," "inflation," and "rating" are not essential to conformity as long as the appropriate values, clearly identified, are provided.

For your information, I point out that NHTSA test laboratories are without authority to interpret Federal motor vehicle safety standards or provide such interpretations to companies whose

products they test. Only interpretations issued in the form of correspondence signed by authorized NHTSA personnel or by notice published in the Federal Register are considered by this agency to be binding.

ID: nht74-5.16

DATE: 03/01/74

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Mercedes-Benz

COPYEE: C. KACHN; D. PRITCHARD

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 21, 1974, which requested interpretation of Federal Motor Vehicle Safety Standard No. 104, "Windshield Wiping and Washing Systems."

The wiped area as stated in S4.1.2, is to be evaluated as a percentage of areas A, B, and C "of the windshield." This means that areas A, B, and C are evaluated in "unwrapped view." rather than in the form of a projection of the Windshield's surface.

SINCERELY,

MERCEDES-BENZ OF NORTH AMERICA, INC.

January 21, 1974

National Highway Traffic Safety Administration Mr. Elwood Driver

Re: Ruling Standard 104

As discussed with Mr. Pritchard on January 18, 1974 Daimler-Benz AG. is seeking a ruling with respect to interpretation of S4.1.2 of paragraph 571.104, windshield wiping and washing systems.

S4.1.2 references in respect of the wiped area to SAE recommended practice J903a from May 1966. Definition of the wiped area on the windshield is outlined in this recommended practice under 2.4 (a), (b), (c) and (d) and constitutes tangential cut-off of the two-dimensional eye range contour.

You are undoubtedly aware that SAE recommended practice J903a has been superseded by SAE J903b, last revised in July 1968. In this practice the wiped area is evaluated in an unwrapped view in which the wiped pattern and the areas A, B and C have been incorporated.

571.104 as well as J903a do not state whether the areas A, B and C should be evaluated in relation to the A area in projected form or in unwrapped view as exercised in J903b.

An early ruling in clarification of the above mentioned problem area is highly appreciated.

G. M. Hespelar Manager Safety Engineering

ID: nht74-5.17

DATE: 03/01/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Distributors

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 18, 1973, inquiring whether a manufacturer would be an intermediate or final-stage manufacturer if he installs truck bodies or material handling devices (frequently final-stage manufacturing operations) but he expects that a later manufacturer will either extend the chassis frame or add a third axle. These additions are necessary to make the vehicle safe to operate.

In most cases, we would consider the manufacturer in question to be an intermediate manufacturer. Under the definitions of "completed vehicle," "intermediate manufacturer," and "final-stage manufacturer" (49 CFR 568.3), the manufacturer would be a final-stage manufacturer only if, at the time he completes his manufacturing operation, the vehicle requires no further manufacturing to perform its intended function, unless the further manufacturing involves only "readily-attachable components."

In the case you present, the vehicle cannot perform its intended function unless further modifications are made. That it be able to perform its intended function implies that it be able to do so safely. The answer ultimately depends, therefore, on whether the additions that will be made to the vehicle involve only readily attachable components. We would not generally consider either an extension of the chassis or the addition of a third axle to involve only readily attachable components.

Of course, in those cases where no further modifications are necessary for safe operation, the crane or body installer will be the final-stage manufacturer.

ID: nht74-5.18

DATE: 03/06/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mobile Auto Glass of Iowa, Inc.

COPYEE: MR. HUNTER

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 30, 1974, concerning requirements for replacement glazing material in trucks and buses.

Glazing materials for use in motor vehicles must comply with the requirements of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, which incorporates the American National Standards Institute Standard No. Z26.1-1966. Section S6 of Standard No. 205 specifies requirements for certification and marking.

Paragraph S6.4 and S6.5 of Standard No. 205 covers the specific question you asked. If you cut a section of glass to which this standard applies, for use in a motor vehicle or comper, you are required to mark that glass in accordance with section 6 of Standard No. Z26.1-1966 and to certify that it complies with the standard in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act.

I am enclosing a copy of Standard No. 205, Standard No. Z26.1-1966 and section 114 of the National Traffic and Motor Vehicle Safety Act. If I can be of further assistance, do not hesitate to contact me.

3 ENCLS.

ID: nht74-5.19

DATE: 02/22/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Office of the Attorney General; State of Kansas

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 30, 1974, concerning the application of the Federal odometer law to certain automobile operated by the Kansas State Department of Education. The cars in question are equipped with special odometers whose use normally requires the disconnection of the original equipment odometers.

The question posed by the Department of Education is whether this practice violates the Federal law and whether the Department must keep the special odometer in the car when selling it. Our reply is that the Department is not violating the Federal law, and that while it must make certain disclosures when it sells the cars, it need not leave the special odometers installed.

Sections 404 and 405 of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1981) make it unlawful for a person to disconnect an odometer with the intent to change the number of miles it indicates (section 404) and for a person with the intent to defraud to operate a vehicle with an inoperative odometer (section 405).

With respect to section 404, it does not appear that the Department will be changing the indicated mileage. With respect to section 405, it is apparent that the Department has no fraudulent intent in operating the vehicles with the standard odometers disconnected. We therefore find that the Department's practice does not violate the odometer law and may be continued.

We suggest that in executing the disclosure statement required by Section 408 of the Act, the Department should indicate that the indicated mileage is in error. Although section 408 does not

require disclosure of the true mileage, we regard full disclosure to be in the public interest and therefore recommend that the Department also include the true mileage on the disclosure statement. By doing this, it will avoid any appearance of deceptive intent.

YOURS TRULY,

STATE OF KANSAS

Office of the Attorney General

January 30, 1974

Hon. Claude S. Brinegar Secretary of Transportation

Re: Our File No. AC=63-82-3 Kansas State Department of Education Building 120 East Tenth Street Topeka, Kansas 66612 office has been requested to issue an opinion regarding the Kansas State and Federal odometer laws as applied to forty three automobiles assigned to the Kansas State Department of Education. It appears that these automobiles perform a certain function which necessitates removal of the original odometer and substitution of another for precision measurement of mileage.

While we feel most capable of rendering an opinion regarding the Kansas law on the matter, I am requesting your assistance for an opinion based upon the recently enacted federal legislation regarding odometers in motor vehicles. I am enclosing a copy of Dr. Whittier's letter for your reference.

Let me thank you in advance for whatever assistance you can render.

Very truly yours,(Illegible Word) MILLER Attorney General

BY: JOSEPH P. O'SULLIVAN Assistant Attorney General Consumer Protection Division