ID: 86-1.19

TYPE: INTERPRETATION-NHTSA

DATE: 02/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Robert C. Shaver -- Mohawk Customs Service

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Robert C. Shaver Mohawk Customs Service Air Cargo Building Hancock International Airport North Syracuse, NY 13212

This responds to your letter to this office, asking whether there was some procedure whereby you could import new truck tires into this country, if those tires do not have the name of the manufacturer on the sidewall. You enclosed an invoice with a note written by a Customs Service officer stating that much tires do not conform with the requirements of our tire standards, because the "tires bear no brand name." Our tire standards do not require that new truck tires have the manufacturer's name or a brand name on the sidewall. For your information, I have enclosed a copy of Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR 571.119). This is the standard applicable to new truck tires. Section S6.5 of this standard lists all of the information that must appear on the sidewalls of all new tires subject to Standard No. 119. As you see, there is no requirement that either the manufacturer's or a brand name appear on the sidewall of these tires. The tire is required to have a tire identification number which identifies the manufacturer. It is possible that the Customs Service was confusing the requirements for truck tires with those for passenger car tires. New passenger car tires are subject to the requirements of Standard No. 119. As you see, there is no requirement that either the manufacturer's name or a brand name appear on the sidewall of these tires. The tire is required to have a tire identification number which identifies the manufacturer. It is possible that the Customs Service was confusing the requirements for truck tires those for passenger car tires. New passenger car tires are subject to the requirements of Standard No. 109, New Pneumatic Tires - Passenger Cars (49 CFR 571.109; copy enclosed). Section S4.3.2 does require that new passenger car tires be "labeled with the name of the manufacturer, or brand name and number assigned to the manufacturer." However, the tires you are seeking to import are not subject to this requirement, because they are not passenger car tires. I suggest that you show this letter to the appropriate officers of the Customs Service, and ask then to reconsider their determination that the tires you seek to import do not comply with Standard No. 119. If you have any further questions in this area, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 426-2992. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosure

ID: 86-1.2

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/86 EST

FROM: ROGER WILLIAMS -- PRESIDENT TECHNICAL HALLMARK ENTERPRISES INC

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/18/86, TO ROGER WILLIAMS FROM ERIKA Z JONES, REDBOOK A29(3), STANDARD 108

TEXT: Dear Sir:

I am writing this letter as an inquiry of what regulations if any are applicable to the new lights that are now being seen on the trunk lids, and the rear windows of new automobiles.

Are there any laws regarding size of the light, color of lens, location, if there are any restrictions on when the light is allowed to come on and if a sequencing such as two or possibly even three individual bulbs pulsating in a on/off pattern would be legal? Would it be possible to allow the light to take on a specific shape or in this case logo or design (example - an Eagle, Cat, bolt of lightning). Could the light be in the form of letters or numbers (#1, U C L A.).

Is there a specific legal name for this light?

Should your department not be able to answer these questions or maybe only part of them, it would be very much appreciated if you would forward it to the correct one. If this is not possible please inform me of the address of that department and I will contact them.

We are looking into the possibility of manufacturing similar lights for installation on automobiles that do not have them and would need the above information to be sure we are within the law.

Thank you very much for your time and help in this effort.

Sincerely,

ID: 86-1.20

TYPE: INTERPRETATION-NHTSA

DATE: 02/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Patrick R. McCreary -- General Manager, Van Patton Vans

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Patrick R. McCreary General Manager Van Patton Vans 22865 Pine Creek Road P.O. Box 1305 Elkhart, IN 46515

This responds to your recent letter concerning the manufacturing operations you intend to perform on Ford Econoline vans. In a December 16 telephone conversation with Ms. Hom of my staff, you explained that the vans are incomplete vehicles which you will be receiving from a Ford dealership prior to the vehicles' first sale. A company other than your own will "stretch" the vehicle 48 to 60 inches, but your company will be completing the manufacture of the vehicle by adding seats (for 20 passengers), windows, carpeting, and so forth. You asked what your responsibilities would be under NHTSA's regulations and safety standards. Under our regulations, a motor vehicle designed for carrying more than 10 persons is a "bus" (Part 571.3). Since the vans, as completed, will meet that definition, the applicable safety standards for the vehicle you will be producing are those applying to buses. If you are performing manufacturing operations on an imcomplete vehicle, as that term is defined in Title 49 of the Code of Federal Regulations (CFR) Part 568.3, so that is becomes a completed vehicle, then Part 568, Vehicles manufactured in two or more stages, set forth the requirements you must meet. Under Part 568.6, Van Patton Vans, as the "final-stage manufacturer," would be required to complete the vehicle in such a manner that it conforms to all safety standards for buses in effect on a date no earlier than the manufacturing date of the incomplete vehicle, and no later than the date of completion of the final-stage manufacture. Also, your company must affix a label to the completed vehicle in accordance with the certification requirements set forth in Part 567,5, Requirements for manufacturers of vehicles manufactured in two or more stages. I have enclosed copies of 49 CFR Parts 567 and 568, for your convenience. I have also enclosed an information sheet that describes how you can obtain copies of NHTSA's regulations and motor vehicle safety standards. Please contact my office if you have further questions. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosures

ID: 86-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 02/04/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Benjamin R. Jackson

TITLE: FMVSS INTERPRETATION

TEXT:

February 4, 1986 Mr. Benjamin R. Jackson Executive Director Automobile Importers Compliance Association 1607 New Hampshire Avenue, N.W. Washington, D.C. 20009 Dear Mr. Jackson: This responds to your letter requesting an interpretation of 49 CFR Part 541, Federal Motor Vehicle Theft Prevention Standard. Specifically, you on vehicles subject to the theft prevention standard to have the required markings entirely within the target area specified for the part by the original manufacturer of the vehicle. You stated that it was possible that target areas specified by the original manufacturer might be suitable for marking by means of labels, but not suitable for marking by means of inscription. If this situation were to occur, you asked if Part 541 could be interpreted to permit manufacturers that must mark by means of inscription to place those markings outside the target area designated by the original manufacturer. Part 541 cannot be so interpreted. In the case of inscribed markings, 541(d)(2)(iii) specifies that the required markings shall be "placed entirely within the target area specified by the original manufacturer for that part." This requirement applies to all markings inscribed for the purposes of Part 541, whether done by an original manufacturer or a direct importer. The policy bases underlying this requirement were explained at length in the preamble to the final rule establishing Part 541. See 50 FR 43166, at 43172, October 24, 1985. First, it is important that all parts be marked in the same target area so that investigators will know exactly where to look on a part for the required marking. The investigator would be alerted to possible suspicious activity if the marking were outside the target area. Second, the different target areas for original equipment and replacement parts marking are intended to ensure that there will be an adequate separation between the areas where the different types of parts will be marked. This will ensure that a thief cannot obliterate an original equipment part marking and affix a counterfeit replacement part marking directly over the area where the original equipment part marking was located. Both of these purposes would be undercut if original manufacturers and direct importers were allowed to designate different target areas for marking vehicles in the same line, Accordingly, Part 541 explicitly requires only one target area for the required marking on each part of a covered line. We do not believe that your concern about inscribing markings on curved surfaces in well-founded. The agency knows of a number of means of inscribing numbers on curved surfaces that would permit direct importers to mark those surfaces within the $15 cost limit set forth in section 604(a)(2) of the Cost Savings Act. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.22

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Robert J. Crail

TITLE: FMVSS INTERPRETATION

TEXT:

February 6, 1986 Mr. Robert J. Crail Theurer, Inc. Route 1, Box 300 Helenwood, Tennessee 37755 Dear Mr. Crail: This responds to your letter of August 20, 1985, requesting an interpretation of Standard No. 121, Air Brake Systems (49 CFR 571.121). You asked whether an extendible intermodel container chassis which adjusts to haul containers which vary in length between 40 feet and 48 feet is a "heavy hauler trailer" as defined in Section S4 of Standard No. 121. Specifically, you would like to know whether the extendible container chassis described above must comply with Sections S5.2.1.2 and S5.3, and whether you or your customer may utilize the options available in Section S5.6 for parking brake systems and in Section S5.8 for emergency brake systems. By way of background information, this agency does not give approvals of motor vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter. The extendible container chassis trailers which you describe have brake lines which are designed to extend with the vehicle frame. According to Section S4 of Standard No. 121, a trailer whose "brake lines are designed to adapt to separation or extension of the vehicle frame...." is, by definition, a heavy hauler trailer. Thus, your extendible chassis trailer would be considered a heavy hauler trailer within the definition of S4. Section S5.2.1.2 of Standard No. 121 provides that trailers with air brakes are generally required to have total service reservoir volume which is "at least eight time the combined volume of all service brake chambers at maximum travel of the pistons or diaphragms." This general rule is limited by the last sentence of S5.2.1.2 which provides, "However, the reservoir on a heavy hauler trailer ... need not meet this requirement." Section S5.3 sets forth road test requirements, compliance with which must be certified for all trucks, buses and trailers. Generally, all trailers are required to be certified as complying with the timing requirements of S5.3.3 and S5.3.4. This general rule is limited by the last sentence of S5.3, which specifies, "However, a heavy hauler trailer ... need not meet the requirements of S5.3." Thus, heavy hauler trailers are expressly excepted from all of the requirements of S5.3. Finally, you asked whether the trailer you manufacture may take advantage of the options available in Section S5.6 for the parking brake system and in Section S5.8 for the emergency brake system. Both Sections S5.6 and S5.8 specifically give manufacturers of heavy hauler trailers the choice of complying with the requirements of those sections... "or at the option of the manufacturer, the requirements of sec. 393.43 of this title." Title 49 CFR section 393.43 sets forth requirements for breakaway and emergency brakes. An extendible container chassis which comes within the S4 definition of heavy hauler trailer may comply with the section 393.43 requirements or the parking emergency brake requirements or the parking and emergency brake requirements of Standard No. 121 Sections S5.6 and S5.8, respectively. If you have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. D. Black

TITLE: FMVSS INTERPRETATION

TEXT:

February 6, 1986 Mr. D. Black Director, U.S. Engineering Alfa Romeo, Inc. 250 Sylvan Avenue Englewood Cliffs, NJ 07632 Dear Mr. Black: This responds to your letter to Mr. Barry Felrice, our Associate Administrator for Rulemaking, requesting an interpretation of Part 541, Federal Motor Vehicle Theft Prevention Standard. You stated that you plan to begin production of a 1987 carline in March 1986. This particular carline has been selected as one that will be subject to the requirements of Part 541. However, Part 541 does not become effective until April 24, 1986. You stated your belief that the introduction of the 1987 carline before the effective date of Part 541 means that none of the 1987 vehicles would be required to comply. Your belief is essentially correct. As you noted, the effective date for Part 541 is April 24, 1986. This effective date means that Part 541 applies to all selected carlines beginning with the 1987 model year. However, the legislative history for Title VI of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 2021 et seq.), which Title requires that Part 541 be promulgated, expressly states: "The theft prevention standard cannot apply to a car in the middle of the model year." H. R. Rep. No. 1087, 98th Cong., 2d Sess. at 11 (1984). For the purposes of Title VI of the Cost Savings Act, NHTSA believes that the model year for a carline begins on the day on which a vehicle in that carline is introduced into commerce in the United States, the start of production does not constitute an introduction into commerce in the United States when the first vehicle is imported into the customs territory of the United States. Assuming that one of the 1987 vehicles in this carline is imported, and thus introduced into commerce, before April 24, 1986 (the effective date for Part 541), the 1987 model year for that carline would have begun prior to the effective date of the theft prevention standard. Obviously, the requirements of any standard do not apply before the effective date. Given the clear expression of Congressional intent that this theft prevention standard cannot apply to a carline in the middle of its model year, NHTSA concludes that a 1987 model year version of a carline introduced into commerce before the effective date of the theft prevention standard during the 1987 model year. It would, of course, be subject to the requirements during the 1988 model year. If you have any further questions or need more information on this subject, please do not hesitate to contact me. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.24

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Hans W. Metzger

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Hans W. Metzger Scottsdale, AZ 85253

Thank you for your letter of October 14, 1985, asking several questions about Standard No. 208, Occupant Crash Protection. I hope that the following discussion answers your questions. You first asked for a clarification of S4.1.3.1.2. That section provides that a manufacturer must equip a specific amount of its vehicles manufactured on or after September 1, 1986, and before September 1, 1987, with automatic restraints. The amount must not be less than 10 percent of the average annual production of passenger cars manufactured for sale in the United States during the period September 1, 1983, to August 31, 1986 (the base period). You explained that your client did not produce any vehicles for the U.S. during one year of the base period (September 1, 1983 -September 1, 1984). For the other two years of the base period, your client produced a limited number of vehicles for sale in the U.S. You asked whether in calculating the average yearly production for the base period, it is correct for your client to use zero for the production for the production between September 1, 1983 and August 31, 1984, and the actual production figures for two subsequent years. The three year base period addresses a situation where a manufacturer has produced vehicles for sale in the U.S. in each of those years. The purpose of averaging the production is to ensure that the calculation of the percentage of a manufacturer's passenger cars that must comply with the automatic restraint requirements is based on a production figure which is representative of the manufacturer's typical production. In the case of a manufacturer who has produced vehicles for two of those years, it would defeat the purpose of the rule to allow the manufacturer to lower artificially the number of vehicles which must comply with the automatic restraint requirement by counting its production as zero for one of the base years. Thus, in a situation where a manufacturer has only two years of production, the manufacturer should calculate its base period average based on the number of vehicles produced during those two years. To provide manufacturer's with additional flexibility is calculating the number of passenger cars which must be equipped with automatic restraints, NHTSA proposed, on April 12, 1985 (50 FR 14509), an amendment to Standard No. 208 which would give manufacturers the option of using either a three year average or the actual production for the model year in question. We expect to issue shortly a final rule on this subject. You also asked for another clarification of S4.1.3.1.2. You asked if the required number of vehicles can be produced anytime between september 1, 1986 and August 31, 1987. S4.1.3.1.2 does not require that the automatic restraints be installed at any specific time during that period. Thus, you are correct that the installation of automatic restraints does not have to be evenly distributed throughout that 12 month interval. I hope this information is of assistance to you. If your have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Leon E. Panetta

TITLE: FMVSS INTERPRETATION

TEXT:

This responds to your request that we review the concerns expressed by one of your constituents, Mr. Joseph Loschiavo, about certain van seats. According to Mr. Loschiavo, the Monterey County Van Program for senior citizens uses vans with seats that are very low and close together, making it difficult for persons to get up out of the seats. He suggested that either the seats be raised about eight inches or that special seats be provided for persons who have problems with the present seats.

The National Highway Traffic Safety Administration (NHTSA) issues motor vehicle safety standards. Federal Motor Vehicle Safety Standard No. 207, Seating Systems, establishes requirements to minimize the possibility of seat failure during vehicle collisions. However, NHTSA does not have any standards concerning the height or spacing of van seats.

The Monterey County Van Program has several options in obtaining vans with appropriate seating. In purchasing new vans, the program may either select from among the variety of vans offered by the major vehicle manufacturers, or go to one of a number of companies that customize vans to purchasers' specifications. A number of companies also modify used vehicles.

We note that new vans, including vans which are modified prior to first sale, are required to be certified to comply with applicable Federal motor vehicle safety standards. The specific certification requirements are set forth at 49 CFR Part 567, Certification. If a used vehicle is modified by a business such as a garage, the business is not required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative the compliance of the vehicle with any safety standard. This is required by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. Thus, if a business replaced a van's existing seats with higher seats, it would need to make sure that it was not rendering inoperative the vehicle's compliance with Standard No. 207 or any other Federal motor vehicle safety standard.

I hope this information is helpful.

Sincerely,

Erika Jones Chief Counsel

TO: Mr. Joseph A. LaSala Office of Congressional Affairs Department of Transportation 400 Seventh Street, S.W., Room 10506 Washington, D.C. 20590

ENCLOSURES FROM:

Mr. Joseph Loschiavo

RE: Would you please review the attached and provide me with a written report addressing the concerns this constituent has expressed?

Thank you for your assistance.

I would appreciate your attention to the attached correspondence. Please direct your reply to the address below.

Thank you very much for your attention to this matter.

Sincerely,

LEON E. PANETTA Member of Congress

Please respond to:

380 Alvarado Street Monterey, California 93940 (408)649-3555

Attention: Ken Christopher; (408) 429-1976

ID: 86-1.26

TYPE: INTERPRETATION-NHTSA

DATE: 02/07/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Lewis Quetel

TITLE: FMVSS INTERPRETATION

TEXT:

February 7, 1986 Mr. Lewis Quetel PMI Inc. 1391 Wright Blvd. Schaumburg, IL 60193 Dear Mr. Quetel: This is in response to your telephone call on October 22, 1985, to Robert Nelson of this agency asking how our regulations would affect a product you intend to sell. The product, which you call a "Kumfi-Klip" safety belt comfort device, consists of a plastic device which attached to the upper torso belt anchorage. A belt user can then pull the webbing through the open wedge to introduce slack into the shoulder portion of the belt. As background information, let me explain that the agency does not have the authority to approve or endorse items of motor vehicle equipment, such as your device. We do have the authority to issue Federal Motor Vehicle Safety Standards that set performance requirements for motor vehicles and items of motor vehicle equipment. Manufacturers of vehicles or equipment covered by our standards must certify that their product complies with all of the applicable standards. Your particular aftermarket product is not covered by any of our safety belt or other standards. However, as a manufacturer of an item of motor vehicle equipment, you do have certain responsibilities concerning possible safety-related defects you do have certain responsibilities concerning possible safety-related defects you or the agency discover in your product. Those responsibilities are set out in sections 152-160 of the National Traffic and Motor Vehicle Safety Act. I have enclosed an information sheet on our defect and other regulations for your review. The agency is concerned that a belted occupant could inadvertently use your product to introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of the belt. The instructions you provide with the "Kumfi-Klip" do warn users not to introduce excessive slack, but the instructions provide no information to guide a user on what is an excessive amount of slack. We encourage you to provide more detailed guidance. If you have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosure

ID: 86-1.27

TYPE: INTERPRETATION-NHTSA

DATE: 02/10/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M. Iwase -- Manager, Technical Administration Dept., Koito Mfg. Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. M. Iwase Manager, Technical Administration Dept. Koito Mfg. Co. Ltd. Shizuoka Works 500 Kitawaki Shimizu-shi, Shizuoka-ken JAPAN

This is in reply to your letter of August 30, 1985, to Jere Medlin, Office of Rulemaking, asking for an interpretation of the recent amendment to Motor Vehicle Safety Standard No. 108 allowing motorcycles to be equipped with modulating headlamp systems.

In your first question, you asked for confirmation of your understanding of the modulation cycle and maximum power. We confirm that your interpretation is correct. Please note that the value of A on the modulation cycle of your diagram may be equal to or less than the value of D. However, the requirement relates to C/D rather than C/A, and it is the value of C/D that must be at least 0.17.

With reference to the electrical wiring diagram that you provided, you have asked whether the voltage drop maximum of 0.45 volt in S4.6.1(g) applies to condition (a) (when the modulator switch is "on") or condition (b) (when the modulator switch is "off"). The maximum voltage drop applies to both conditions (a) and (b), i.e., when the modulator is operating and when the headlamp is on. Paragraph S4.6.1(g) states "When tested in accordance with the test profile shown in Figure 9, the voltage drop across the modulator when the lamp is on at all test conditions ....shall not be greater than .45 volt." This not only includes the period of time when the modulator is operating, but also the period when the headlamp is on without the modulator. Paragraph S4.6.1(e) requires that both the upper and lower beams remain operable in the event of a modulator failure, and thus the agency views headlamp operation without modulator as one of the test conditions included in the term "test conditions" in S4.6.1(g). We would like to comment further that when the modulator is turned on, during the test profile of Figure 9, it should be activated when the headlamp is on, since most manufacturers of motorcycles wire their vehicles so that the headlamp is on when the ignition switch is on.

Your next question concerns the acceptability of three types of modulator switch systems which you have diagrammed. All your designs appear consistent with the requirements of Standard No. 108. The modulator must be capable of being switched out of the circuit if it fails, in which case upper and lower beams could be used im a steady-burning mode. This does not necessarily mean another switch, other than the Hi-low beam switch, however.

In response to your final question, you may write Herbert Thrower, Jr., President, Dotech Inc., P.O. Box 3322, Charlotte, N.C. 28210.

Sincerely,

Erika Z. Jones Chief Counsel

SUBJECT: ACTION: Request for Interpretation of Motorcycle Modulating Headlamp Requirements (FMVSS No. 108) by Koito

FROM: Barry Felrice Associate Administrator for Rulemaking

TO: Jeffrey Miller Chief Counsel

Rulemaking received the attached request for an engineering interpretation of the intent of certain requirements for motorcycle headlamp modulators.

Herein is the engineering interpretation of the requirements in question. Please prepare the official response to Koito based on this information.

In response to question 1:

1. Yes, 0.21 < y < 0.30 sec., as suggested by koito, is correct.

2. Yes, x/y = 50 to 70%, as suggested by Koito, is correct.

3. The value of A may be equal to or less than the value of D. However, the requirement relates to C/D rather than C/A. It is the value of C/O that must be at least 0.17.

In response to question 2:

The intent of the requirement in S4.6.1 is to assure that less than 0.45 volts is lost as a result of the addition to a headlamp circuit for the purpose of modulating the headlamp. The 0.45 volts is for night operation condition of the headlamp (i.e. condition "b" in Koito's letter).

In response to question 3.

We do not approve designs, but offer the following comments on the intent of the rule. The modulator should be capable of being switched out of the circuit if it fails, in which case upper and lower beams could be used in a steady burning mode. This does not necessarily mean another switch, other than the Hi-low beam switch, however. All your designs appear to be consistent with the requirements of the standard, however some appear more desirable, based on number of switches, case of use, etc., than others.

In response to your request for the address of Dotech, a modulator manufacturer, the following information is furnished:

Mr. Herbert Thrower, Jr.. President Dotech Inc. P.O. Box 3322 306 Clanton Road Charlotte, N.C. 28210 Tel. No. (704) 523-6727

Attachment