ID: nht73-2.45

DATE: 01/18/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 8, 1973, asking us to confirm your understanding of paragraph S4.3.1 of Standard 210.

It is our opinion that each of the three drawings attached to your letter correctly indicates the "nearest contact point of the belt with the hardware" for the respective belt anchorage systems.

Yours truly,

NISSAN MOTOR CO., LTD.

January 3, 1973

Lawrence Schneider National Highway Traffic Safety Administration

Dear Mr. Schneider:

This is to ask whether our understanding of MVSS 210 S4.3.1 is correct according to your interpretation.

We understand "the nearest contact point of the belt with the hardware" stipulated in MVSS 210, S4.3.1, exists at the point, as illustrated in the enclosed figures, when the retractor spool is considered to be the hardware.

CASE 1

Seatbelt webbing is directly in contact with the retractor spool when the webbing is extended to fit the 95 percentile male.

In this case, the nearest contact point exists at the point of contact of webbing and spool as shown in Figure 1.

CASE 2

Seatbelt webbing is directly in contact with the retractor spool through the underlying webbing when the webbing is extended to fit the 95 percentile male.

In this case, the nearest contact point exists at the point of contact of the most outside webbing and the next webbing as shown in Figure 2.

CASE 3

Seatbelt webbing is extended through the guide which meets the anchorage strength requirement of S4.2.

In this case, the nearest contact point exists at the point of contact of webbing and guide as shown in Figure 3.

Your prompt reply would be greatly appreciated.

Very truly yours,

Satoshi Nishibori Engineering Representative Liaison Office in USA

Enclosure

FIG 1

(Graphics omitted)

FIG 1

FIG 2

(Graphics omitted)

(Graphics omitted)

ID: nht73-2.46

DATE: 12/10/73

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

TO: Hyattsvile Auto Glass

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your November 29, 1973, request to know if urethane bonding material must be used in the installation of windshields in new motor vehicles not yet sold to a first purchaser for purposes other than resale.

Standard 212, Windshield mounting, is a performance standard for new motor vehicles. We do not require the use of specific bonding materials such as urethane, but only that the vehicle conform to Standard 212, whatever material is used. The New York suit you mentioned may involve a question of due care in the installation of the windshield, separate from the question of meeting a Federal minimum performance standard.

YOURS TRULY,

IHyattsville Auto Glass

NOVEMBER 29, 1973

ROBERT DYSON ASST. CHIEF COUNSEL NATIONAL HWY. SAFETY STANDARDS

DEAR MR. DYSON:

AFTER TALKING WITH YOU BY TELEPHONE ABOUT A STATEMENT MADE BY GENERAL MOTORS IN ONE OF THEIR BULLETINS ON THE USING OF URETHANE TO INSTALL WINDSHEILDS, I WAS TOLD OF A GLASS SHOP IN NEW YORK THAT IS BEING SUED BECAUSE THEY DIDN'T USE URETHANE IN THE INSTALLATION OF A WINDSHEILD OF A 1974 MODEL VEHICLE THAT WAS INVOLVED IN AN ACCIDENT.

I UNDERSTAND THAT SAFETY STANDARD 212 ONLY PERTAINS TO NEW VEHICLES NOT HAVING BEEN SOLD, AS WAS EXPLAINED IN YOUR LETTER OF JULY 20, 1972. IS THERE ANY REGULATION THAT SAYS THAT A WINDSHEILD BEING INSTALLED IN A NEW 1974 MODEL VEHICLE (ONE NOT SOLD TO A FIRST PURCHASER) HAS TO BE INSTALLED WITH URETHANE BONDING MATERIAL? OR ARE WE STILL ALLOWED TO USE THE BONDING MATERIAL OF OUR CHOICE AS LONG AS IT CONFORMS TO STANDARD 212?

I WOULD APPRECIATE ANY FURTHER ASSISTANCE YOU CAN GIVE US BECAUSE OF THE APPARENT HAZARDS AND LENGTH OF CURING TIME WE DON'T WANT TO USE URETHANE UNLESS WE ARE REQUIRED TO BY YOUR DEPARTMENT.

AGAIN I WOULD LIKE TO THANK YOU FOR THE ASSISTANCE YOU HAVE GIVEN US IN THIS AS IN PREVIOUS MATTERS.

SINCERLY YOURS

ROBERT WOOD PUBLIC RELATIONS

ID: nht73-2.47

DATE: 12/14/73

FROM: AUTHOR UNAVAILABLE; A. G. Detrick; NHTSA

TO: Streamline Division

TITLE: FMVSR INTERPRETATION

TEXT: This is in acknowledgement of your Defect Information Report, in accordance with the defect reporting regulations, Part 573.

The Defect Information Report involves: 41 - 1973 SL, Regency, Imperial, and Crown Imperial Travel Trailors. Possibility that the 3/8" copper tube lines from the gas manifold to all appliances may have a defect thereby causing gas leakage, which may allow for a possible fire hazard.

The following National Highway Traffic Safety Administration identification number has been assigned to the campaign 73-0224. The first quarterly status report for this campaign is required to be submitted by February 5, 1974.

Please refer to the above number in all future correspondence concerning this campaign.

In addition, the letter which you have sent to the first purchasers does not meet the requirements of 49 CFR Part 577 (copy enclosed) in the following respects. It does not contain the specific statements required by sections 577.4(a) and (b)(1). Your reference to a "possible" safety hazard, moreover, is not permitted under paragraph 577.4(b)(1). We do not consider your letter to adequately describe the malfunction, as required by sections 577.4(c)(1) and (c)(2). You do not, for example. Indicate the effect or possible consequence of an "improper flare" on

a gas line. Nor do you state any precautions the owner can take to reduce the likelihood of the malfunction occurring as required by 577.4(c)(4). Your letter fails completely to evaluate the risk to traffic safety as required by section 577.4(d). Finally, we consider your reference to "no reported related failures" to be a disclaimer prohibited by section 577.6.

It is necessary for you to revise this letter as we have indicated and to provide this office and the owners with a copy of the revised letter.

Failure to comply with this regulation can result in the imposition of civil penalties and injunctive sanctions.

If you desire further information, please contact Messrs. James Murray or Marx Elliott of this office (202) 426-2840.

Enc.

ID: nht73-2.48

DATE: 12/21/73

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

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your November 8, 1973, request for an interpretation of the warning signal requirements of Standard No. 121, Air brake systems.

S5.1.5 of that standard states:

A signal, other than a pressure gauge, that gives a continuous warning to a person in the normal driving position when the ignition is in the "on" or "run" position and the air pressure in the service reservoir system is below 60 psi. The signal shall be either visible within the driver's forward field of view, or both audible and visible.

A warning that "the air pressure in the service reservior system is below 60 psi" is intended to mean that a warning device's sensor could be located in the system you described in your letter between the source of air pressure and the check valve(s) required by S5.2.1.5. As you pointed out, this location would sense pressure below 60 psi anywhere from the compressor through the entire service reservior system. A single warning installed before the check valves in a split service brake system would fulfill the requirements of S5.1.5 as long as it is positioned to sense pressure below 60 psi in any part of the split service reservior system.

P2 Your interpretation of the signal requirements is correct. The signal must be both audible and visible, or it must be visible within the driver's forward field of view. A simple audible signal is insufficient, as is a simple visible signal which is not within the driver's forward field of view.

Yours Truly,

November 8, 1973

Richard Dyson Assistant Chief Council NHTSA

Dear Mr. Dyson:

We have several questions relating to FMVSS 121, S5.1.5, warning signal.

Our interpretation of S5.1.4 and S5.1.5 is that a gauge and a signal are required on each service reservior system. Neither a gauge nor a signal are required on the "wet tank" which is between the service tanks and the compressor and is separated from the service tanks by check valves. It seems to us that a signal on the "wet tank" in lieu of on the service tanks might be more effective in warning the operator of the system malfunction. Our reasoning is as follows: If there is no signal on the "wet tank", a failure of any of the components shown in red on the attached sketch would not be known to the operator until the pressure in the service tanks dropped below 60 psi. With a signal on the "wet tank", the operator would immediately be aware of a failure in any of the components from the compressor through the service system.

Will a warning signal on the wet tank in lieu of a signal on each service tank meet the requirements of FMVSS 121? If not, would NHTSA consider such an amendment?

Also, a major brake manufacturer has supplied us with their written interpretation of FMVSS 121, S5.1.5. Their interpretation would allow warning signals to be visible or audible or both. This is in conflict with our understanding of S5.1.5 which says ". . . the signal shall be either visible. . . or both audible and visible." Which is correct?

Thank you for your early reply.

W. G. Milby Project Engineer

cc: Ben Newberry Dave Phelps

(FLOW CHART OMITTED)

ID: nht73-2.49

DATE: 12/21/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Crisp & Henderson, Attorneys at Law

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 19, 1973, inquiring whether there are Federal or State regulations that contain labeling requirements for rubber used in retreaded tires.

There are to our knowledge no Federal regulations that either establish quality levels or require labeling for rubber used in retreaded tires.

Yours Truly,

CRISP & HENDERSON GREENVILLE, NORTH CAROLINA

November 19, 1973

Federal Department of Transportation Consumer Affairs

RE: Tire rubber specifications for recapping tires

I have a client with a special problem for which I need your assistance. I would like to briefly outline the problem.

A manufactures tire rubber in sheets which he sells to B in a small town in Eastern North Carolina. B wanted one quality of rubber for recapping, but did not want to pay the asking price. A deal was made so that B got what he thought was the higher quality rubber because the sheets of rubber were stamped with a higher quality label. Actually A was supplying B with lower quality sheets of rubber, but with a higher quality label. This means that B might be putting a quality made for farm tires or passenger car tires into truck tires. B now realizes that a substitution has been made in the quality of rubber he has been receiving.

I would like to know what state and federal regulations apply to labeling rubber which is used for recapping tires. Both A & B in my problem are located in North Carolina. I would appreciate your assistance in advising me of this information or of the appropriate agency for me to write.

Thank you for your assistance in this matter.

Deborah A. Henderson Attorney at Law

ID: nht73-2.5

DATE: 08/09/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Body and Equipment Association Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 6, 1973, forwarding to us a letter from Mr. Jim Finley of the Hughes Tool Company. Mr. Finley describes two situations, requesting an opinion on the applicability of NHTSA requirements to each of them.

The first question is whether an earth auger body that is mounted on a crane carrier will conform to the Certification regulations (49 CFR Part 567) if the vehicle exceeds its stated weight ratings when a derrick is mounted on the vehicle but a permanent metal plate is also affixed to the vehicle which states: "The GVWR and GAWR require that the derrick be removed before operating this vehicle upon a public highway."

We do not believe such a label may be used to bring a vehicle into conformity with the Certification regulations. Both "gross vehicle weight rating" and "gross axle weight rating" call for a rating set by the manufacturer, but each is intended to reflect a fully-loaded vehicle or axle condition as a vehicle is likely to be used. Although your letter is not explicit in this regard, if it is a reasonable expectation that the vehicle will be operated on the public highways with the derrick mounted on it (but for the label), even though the derrick is "removable", we would not consider the weight ratings to be consistent with the regulations if they do not take into account the weight of the derrick.

Similarly, the components used in the manufacture of the vehicle should be of sufficient strength to carry the derrick when the vehicle is in motion. On the other hand, if it is unreasonable to expect the derrick to be attached to the crane carrier when the carrier is operated on the highway, the weight ratings need not take into account the weight of the derrick. In neither case, however, would the label you illustrate affect the conformity of the vehicle to the regulations; in the former case the label does not correct the incorrect weight ratings, and in the latter case, the label is unnecessary.

Your second question is whether Federal regulations regarding lighting may be met if the rear lights of a truck-mounted earth auger utilize hinged covers that are intended to protect the lights during boring operations. You state that when the vehicle is operated, the cover is secured to expose the lights. You ask if we recommend the use of a warning sticker in the cab to remind the driver to open the covers.

The use of these covers is not prohibited by the Federal lighting standard, Federal Motor Vehicle Safety Standard No. 108, "Lights, Reflective Devices, and Associated Equipment" (49 CFR 571.108). We think the idea of a warning sticker in the cab is nonetheless a good one.

Yours truly, TRUCK BODY AND EQUIPMENT ASSOCIATION, INC.

July 6, 1973

Richard B. Dyson -- Assistant Chief Counsel, National Highway Traffic Safety Administration, U. S. Department of Transportation

Dear Dick:

I would appreciate your response to the attached two questions submitted by Hughes Tool Company, a member of the Truck Body and Equipment Association, at your earliest convenience.

Best wishes,

Stan Haransky -- Associate Director

HUGHES TOOL COMPANY

June 6, 1973

Stan Haransky, Associate Director -- TBEA

RE: Follow-up on Hot Line Questions

Dear Mr. Haransky:

Question No.1:

Hughes Tool Company designs, builds, and mounts earth auger bodies on crane carriers. With the derrick mounted on the vehicle, the front axle weight and the total vehicle weight on some models exceeds the crane carrier's GAWR and GVWR. Removing the derrick produces weights well within the GAWR and GVWR. On such models we permanently mount a metal plate with the following inscription:

CAUTION

The GVWR and GAWR require that the derrick be removed before operating this vehicle upon a public highway.

If this statement is not followed by the vehicle owner, is he or this company likely to be penalized? If so, what would the penalty be?

Question No.2

Most boring operations with a truck-mounted earth auger are performed at the rear of the carrier. The spoil is removed from the boring tool by rotating it at high speed. Often rocks are thrown at the rear lights with sufficient force to break the lenses. To protect the lights during boring operations, a hinged cover is swung down to conceal the lights. When the vehicle is to be driven on a public road, the cover is secured in the open position to expose the lights.

It is obvious that the driver would be penalized for forgetting to open the covers before driving on a public road, but you can this company be penalized for providing this feature? If so, would you recommend that we place.(Illegible Word) sticker in the cab to remind the driver to open the covers?

Very truly yours,

Jim A Finley

ID: nht73-2.50

DATE: 12/03/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Car Credit Corporation

TITLE: FMVSR INTERPRETATION

TEXT: The National Highway Traffic Safety Administration has received a complaint from Mr.(Illegible Words) of South Forest Street, Chicago, Illinois, that a 1967 Chrysier may have been sold to him with an altered odometer and an incomplete odometer disclosure statement.

This agency administers the Motor Vehicle Information and Cost Savings(Illegible Word) which(Illegible Word) the alteration, disconnection, or resetting of customers are requires a transferer to make a mileage Requirements. Copies of the law and regulations are enclosed. Under the law(Illegible Words) may have a civil action for damages of $ 1.500 or more and attorney's fees.

The U. S. Attorney General is authorized to seek injunctive relief against persons who violate the Act. If we received continued Modification of(Illegible Words) by the Car Credit Corporation, we will ask the U. S. Attorney to investigate the matter and to take appropriate action.

ENC.

ID: nht73-2.6

DATE: 05/18/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Femco Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 16, 1973, inquiring whether any Federal laws apply to your building and installation of a man-lift (pictures of which you enclose) in a completed pick-up truck. You state you understand that if the man-lift is installed on a completed vehicle, you are not considered the final-stage manufacturer.

Based on the information you have provided us, we believe your interpretation to be correct. It does not appear that you have altered the pick-up truck in a way that would make your company responsible for conformity with Federal safety standards or regulations.

The NHTSA has proposed certain requirements for vehicle alterers (copy enclosed). These requirements would very likely apply to you, when effective, if the addition of the man-lift occurs before the purchase of the pick-up truck for a purpose other than resale.

ID: nht73-2.7

DATE: 08/07/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Sebring Vanguard Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 30, 1973, requesting further information about the relationship of the Federal motor vehicle safety regulations to the Vanguard electric vehicle.

You ask the following questions:

"1. Would prior commitments made before May 16, 1973, be sufficient for a temporary exemption?"

Previously-existing commitments for parts that do not conform to systems covered by Federal motor vehicle safety standards may be presented to support the argument that compliance as of January 1, 1974, would cause substantial economic hardship. No temporary exemption has ever been requested on this basis alone, however, and whether an exemption would be granted solely on this basis would depend upon other facts in the case.

"2. Can VANGUARD be classified as a multipurpose passenger vehicle and what relief would that give us from adhering to federal safety standards?"

As you know, a "multipurpose passenger vehicle" (MPV) is defined in part as a vehicle "with special features for occasional off-road operation." Intent for incidental off-road use is insufficient to qualify a passenger car as an MPV. The manufacturer makes the initial determination whether a vehicle is a passenger car or whether it is a MPV, incorporating "special features" for occasional off-road operation not normally found on a passenger car. If he asks our views, we will provide them. If he does not, we are not precluded from questioning his vehicle categorization at a later date if it appears erroneous to us. The Vanguard appears to be a passenger car, but we would be willing to consider the matter further if you think it possesses unique off-road features.

"3. How can we incorporate safety improvements in our vehicles prior to January 1, 1974, that may put us over the weight limit without violating law?"

When you have completed a definitive review of your compliance problem areas you may apply for such exemptions as appear necessary. If safety improvements result in a vehicle weight that exceeds 1,000 pounds, you may legally market a vehicle if it has been exempted before January 1, 1974.

We appreciate your keeping us informed of your program with the Vanguard.

Sincerely,

SEBRING VANGUARD INC.

July 30, 1973

Lawrence R. Schneider -- Chief Counsel, U.S. Department of Transportation, NHTSA

Dear Mr. Schneider:

This is in reply to your letter of May 31, 1973, which indicated that you are willing to meet with us to explore various alternatives to federal safety regulations in connection with the VANGUARD Electric Sport Coupe. (49 CFR Part 571) We are pleased of the position you have taken.

We wish to bring you up to date on recent developments, VANGUARD VEHICLES, INC. of Kingston, N. Y. has purchased the right, title and interest in the manufacturing of these vehicles from CLUB CAR, INC. of Augusta, Georgia.

A new corporation; SEBRING-VANGUARD, INC. of Sebring, Florida has completed licensing negotiations with the New York company to manufacture VANGUARDS. A proposed production schedule is enclosed.

Certain component lead-time commitments were entered into prior to the May 16th ruling removing the 1000 pound exemption. In order to facilitate actual marketing of a low-emission vehicle in conjunction with an active program of research and development, we are considering petitioning for a temporary exemption under Part 555 to avoid the economic hardship of non-utilization of the above commitments.

As far as we can determine this is the first company organized solely for the purpose of mass-producing electric on-the-road vehicles since the early 1900's. Competent and experienced personnel are in Sebring now operating, as a team. Companies such as Gould, Prestolite, ESB, Bendix and GE have sent engineers to assist our start-up. A sophisticated electric vehicle laboratory is in operation under the direction of Ronald Gremban, who helped build, and drove Cal Tech's successful entry in "The Great Electric Car Race" between that institution and M.I.T. a few years ago. Our Mechanical Engineering department is headed by Robert Rice of Detroit, who built many of Electric Fuel Propulsion's early experimental vehicles. Our company is well financed and two members of our board are currently chairman of New York Stock Exchange listed firms.

The May issue of Reader's Digest (reprint enclosed) had an article entitled "Is The Electric Car Coming Back?" VANGUARD was featured. The current issue of True magazine has a large photo of VANGUARD on Page 18. As a result of articles such as the above, we have received over 1000 phone calls and over 5000 written requests for more information from interested citizens and companies here and abroad. Negotiations for export to Germany, Japan and Bermuda are underway.

Our staff has made a review of standard numbers 101 through 121. Preliminary opinion indicates standard 103, and part of 104, 105 and 114 may be our only problem areas. Further study will determine if we specifically request your guidance on aspects of the above mentioned standards that could hinder our ability to produce and market.

We request that NHTSA carefully consider any variance from standards which we ask because of inherent limitations of our basic energy source; the lead-acid battery. Any added excess weight seriously diminshes effective utilization of the electricity stored in our vehicles. We believe NHTSA is aware of this. It is our opinion that the most abundant and inexpensive source of energy remaining for personal transportation is the combination of lead and sulphuric acid. Its vast potential to this end should be judiciously used.

One other area we wish to explore is VANGUARD'S classification. The following are various purposes for which VANGUARD is currently used:

Mr. and Mrs. S. E. Cronquist of the Swedish Embassy of Washington, D. C. used their VANGUARD as a family second car.

The Winged-Foot Country Club of Westchester County, New York is using a VANGUARD with specially equipped tires for transportation for the head grounds keeper's transportation around its huge fairways and other acreage.

The City of Ft. Lauderdale, Florida recently purchased a VANGUARD for experimental use by City Meter Maids.

Mr. Sam Kelly of Dearing, Georgia purchased a VANGUARD in April of this year. Mr. Kelly is partially paralyzed on the left side of his body and could not operate a conventional auto. The VANGUARD is currently making his life richer.

Mr. John Paynter of Vineyard Haven on Martha's Vineyard in Mass. uses his VANGUARD to deliver parts from his marina to boat owners and occasionally tows light weight boats from dock to dock.

The U.S. Dept. of Commerce has used a VANGUARD at the National Weather Observatory in Sterling, Virginia, for over six months to gather data from the various buildings at the sight. They have recently submitted a bid for two more vehicles.

Rockland Power and Light purchased two VANGUARDS. One for carrying a plant manager around the plant site which enables him to get into areas conventional cars could not, including off-the-road critical areas for occasional surveillance. The other vehicle is being used for multi-purposes including electric meter reading.

Ieland F. Bunch, Sr., of Huntington, W. Va. uses his VANGUARD to show clients various real estate parcels.

A businessman in New Martinsville, W. Va. has a 25 year old son with a hearing impediment. The boy refused to drive a conventional car because of this. He now drives a VANGUARD and his father has written us a thank you letter indicating his son has "come out of his shell".

We have been contacted for further information for potential usage is such diverse activities as Zoo oatrol, pizza deliveries, airport usages and a host of other purposes both on-the-road and off-the-road.

The above leads us to believe that use of our vehicle is so divergent and difficult to categorize that it could indeed be considered a "multi-purpose" vehicle. If this should be the case, Mr. Schneider, who determines if it is so and what is the procedure to classify VANGUARD as "multi-purpose"?

There is one final point we wish to discuss. We are anxious to make our vehicle as safe as possible. Current law may preclude this in that certain safety features we may be able to add prior to the January 1, 1974, deadline may put us slightly over the 1000 pound weight limit. Severe economic hardship could occur if we can't deliver cars prior to January 1, yet under existing law we would be in violation if we don't meet all safety standards and our weight is over 1000 pounds. We would sincerely appreciate any comments you could make concerning this problem.

In summary we would like to know:

1. Would prior commitment made before May 16, 1973 be sufficient for a temporary exemption?

2. Can VANGUARD be classified as a multi-purpose vehicle and what relief would that give us from adhering to federal safety standards?

3. How can we incorporate safety improvements in our vehicle prior to January 1, 1974 that may put us over the weight limit without violating law?

May we hear from you at your earliest convenience?

Sincerely yours,

Robert G. Beaumont -- President

Enclosures

CC: James E. Wilson; Senator James L. Buckley; Senator Jacob Javits

(registered) Vanguard electric car

SPECIFICATIONS for the VANGUARD SPORT COUPE

LENGTH: 96" WIDTH: 45 1/2" WHEEL-BASE: 65" WEIGHT: 980 lbs. CONTROLLER: Vanguard variable voltage speed control. TRANSMISSION: Double reduction gear drive. SUSPENSION: leaf springs; Front & Rear. BODY: Triple-thick fiberglass (rust and corrosion proof). FRAME: Extruded aluminum I-beams (rust and corrosion proof). BRAKES: Hydraulic on both rear wheels plus emergency. SPEED: Maximum and cruising 28 mph. RANGE: 40-60 miles with infinite stops/starts depending on temperature and terrain. ACCELERATION: 0-10, 2.1 secs. -0-15, 4.5 secs. 0-25, 11.6 sec. STANDARD EQUIPMENT: Signal lites, brake lites, stop lites, windshield wiper, headlites, parking lites, emergency flashers, side view mirror, rear view mirror, license plate lite, horn, house current battery charger, AS-1 laminated safety glass windshield, fuel gauge, amp-draw gauge, six 6 volt 106 minute batteries. Available body colors: red, blue, yellow, turquoise & cinnamon.

OPTIONAL EQUIPMENT: Two-tone paint (white top), Wheel covers (set of 4), Heater (catalytic), Defroster (electric), Radio and antenna (transistor).

See at: POWR STOP(trademark)

330 South Nevada Colorado Springs, Colorado

Phone: (303) 471-POWR SEBRING Vanguard INC.

July 20, 1973

Charles Zegers -- Electric Vehicle Council

Dear Mr. Zegers:

Bob Beaumont handed me the enclosed Electric Auto Association Newsletter and requested that I write to you for some assistance from your office.

Although you may already have read the newsletter, we do want to bring attention to the circled paragraph regarding cancellation of three show dates. As the article reads, P.S. & F., a Co-sponsor of three shows high-lighting electric cars, dropped out of the program because it felt that the electric vehicle in some way conflicted with the energy crisis.

We would appreciate anything you can do to change this decision or at least clear up what appears to be a serious misunderstanding on the part of P.G.&E and the consumer. In view of the nature of the electric vehicle, popular use of this means of transportation would actually help alleviate the energy crisis. We have seen estimates, confirmed by experts, that it takes less than one gallon of low-grade fossil fuel to generate the electricity necessary to charge the batteries of a VANGUARD Electric Sport Coupe to propel it forty to sixty miles. This figure compares to as many as six or seven gallons of refined fuel to propel a conventional automobile the same distance. However, this figure assumes that liquid fossil fuels are being used to generate the electricity; if all or part of the energy comes from hydroelectric generators or nuclear reactors which do not pollute, the energy demand on our resources is even less. Furthermore, there is no energy crisis from the burning of coal or shale since it is estimated that that source of energy could accomodate us for another one or two thousand years. All of this means that more electric vehicles equals fewer conventional automobiles. Hence, the demand for highly-refined fossil fuel slows down and assures us a longer lasting supply of that particular energy resource.

Another point to convey to the decision-makers at P.G. & E. and consumers is that most electric vehicles are charged during the nights and early morning hours when demand for energy is little. This fact is significant in several ways. With minimal demand for electricity during part of the twenty-four hour day, the power generating facilities are obliged to slow down to a virtual crawl and then work back to a high output capacity when the demand reaches its peak. In the same way that an automobile uses more gasoline in start-stop traffic, so also does a generating power plant run inefficiently. A wide use of electric vehicles would obviously save the power plants and consumer money and natural resources because this start-up slow-down pattern would be minimized.

To reiterate, generating equipment, which represents a huge capital outlay for the utility company and hence a considerable chunk of the consumers electric bill would be used more steadily and efficiently if electric vehicles were charged at night. Continuing the analogy of the automobile, in the same way that a Chevrolet registers better gas-milage in highway driving, so also does a generator get better fuel-power if it is run at a constant rate over a twenty-four hour period, and while the efficiency improves, the utility revenues increase, thus permitting a substantial cut-back in utility rates and an additional savings to the consumer.

With these points in mind, F.G.&.E. might raise another campaign for the electric vehicle. The consumer should also understand these cost comparisons. With the help of your office, we can accomplish this goal.

Sincerely yours,

Robert M. Stone II -- Assistant to the President

CC: Director of Public Relations -- Pacific Gas and Electric; Morley G. Molden -- American Electric Power Corp.

Electric Auto Association news Letter

VOL. IV No. 4

CANCELLATION OF THREE SHOW DATES

We regret to announce that the co-sponsor, PG&E, felt that they should not be urging a greater use of electric power during this time when there is a serious potential power shortage. These displays were to have been during three days each month during July, August and September.

It is hoped that each chapter will be able to utilize this time to organize a local display in shopping centers, or county fairs. Try to get adequate publicity to tell the public of available alternatives for personal transportation while there is the gasoline shortage.

Here is a good chance for electric car enthusiasts to encourage others to join us and to think about building, showing, and using electric cars.

A Reader's Digest

Reprint

Condensed from Discovery Harland Manchester

Is the Electric Car Coming Back?

Clean and quiet, but too poky for the highway, the electrics may yet catch on for short-haul, stop-and-go work in the world's pollution-choked cities

Vanguard electric

Prototype Battronic delivery van

At Kingston, N.Y., I recently poked around the streets in a snappy little automotive midget that had just room enough for two people. It had a top speed of about 28 miles per hour, no carburetor or radiator, and it gave off no exhaust and was almost silent. The car was a Vanguard electric, with which its producer hopes to invade the suburban second-car market.

A few days later, at Boyertown, Pa., I rode in another battery- powered vehicle a prototype of a fleet of 100 to be market-tested as delivery vans.

On a Miami Beach shopping mall, where gas-belching cars are banned, I paid a dime for a ride in an electric surrey with a fringe on top. In a Tampa retirement colony, I borrowed a battery-powered buggy to visit friends. And throughout the country, I've seen electric-powered golf carts used for such non-sporting purposes as delivering papers, transporting, VIPs at airports, and ferrying major-league baseball pitchers to the dugout.

Every now and then someone asks, "Is the electric car coming back?" The answer seems to be: "It's already here." The poky-paced electric doesn't belong on superhighways, but many short-trip drivers who like economy and clean air are finding the relaxing and pleasant vehicle to be just what the doctor ordered.

The Vanguard electric looks a little like a jeep in a ten-gallon hat. It has a body of colored fiber glass, weighs about 980 pounds, and its makers promise a range, between battery charges, of 40 to 60 miles, depending on temperature and terrain. Its charger can be plugged into any household circuit at home or on the road. Recharging its lead-acid batteries takes five to seven hours and costs about 21 cents. The Vanguard's developer, 40-year-old Robert G. Beaumont, used to run an automobile agency. Five years ago, he caught the electric bug, teamed up with a Georgia manufacturer of golf carts and is now turning out the Vanguards at a price of $ 1986.

Beaumont's buggy is likely to have plenty of competition. Thirty companies, including Ford, General Motors, Westinghouse and General Electric, are reported to have short-range, low-speed electric vehicles either in the prototype or limited production stage. A 1972 survey by the Electric Vehicle Council indicated that 55 million Americans would be interested in buying such a vehicle if it were available for under $ 2000. Curiously, the 18-to-29-year-olds showed the greatest interest of any age group.

This surge of interest in electric vehicles comes at a time when the internal combustion engine used in most of today's cars faces a Washington ultimatum to cut down on emissions. Many experts frankly despair of cleaning up the old "I.C.," and scientists and engineers are studying substitutes. The Wankel, * the gas turbine, the steam engine, the stratified-charge engine, the electric and others have their advocates. But none of them is without serious drawbacks. Meanwhile, every day 12,000 additional cars join the polluting procession on our nation's roads.

* See "Watch Out for the Winkel!" The Reader's Digest, January '72.

No magic wand will solve the problem, but there is some hope for a piecemeal approach. Exhaust pollution is by no means geographically uniform. Walk through the commercial streets of any city when trucks are making deliveries and you will inhale exhaust fumes at their worst. At low speeds and when idling, internal combustion engines pour out far more gaseous garbage than they do at high speeds on the open road. Thus a serious auto pollution problem is caused by the millions of short-trip urban vehicles -- delivery vans, buses, mail trucks, refuse trucks, taxis -- that travel less than 100 miles a day at average speeds of less than 30 m.p.h. Why should these city-confined vehicles have the capability, never used by most of them, of barging hundreds of miles non-stop over superhigh-ways at 75 miles an hour?

All cars and all trucks need not be alike. The Battronic Truck Corp. of Boyerton, Pa., is now building 100 electric work vehicles adaptable for either passengers or cargo. The program is sponsored by the Electric Vehicle Council, and 57 cooperating utility companies will buy and test the vehicles under various conditions to obtain operating data. The Post Office, the government, the bread man, the dry cleaner, the parcel-delivery company, the TV-repair man are considered prime candidates for this work horse. Gasoline vehicles on such runs spend up to 85 percent of their time idling. Electric cars do not idle; when you take your foot off the pedal, the power cuts off.

Depending on speed, the new trucks will run from 30 to 68 miles on one battery charge. Actually, however, their range is unlimited because of an ingenious, self-contained, multi-battery pack that slides out of the truck-bed like a bureau drawer. A man with a special carrier can put in a fresh, fully charged pack in five minutes.

Such battery-powered vans are already in regular service in Great Britain, where about 60,000 are registered. A London dairy firm which used hundreds of horse-drawn carts before World War II now operates a fleet of about 4000 specially designed electrics in the Greater London area. Some of the trucks have been in service for 25 years, and are said by the firm to surpass gasoline-fed trucks in low maintenance costs and reliability. And, according to customers who appreciate their early-morning quietness, they "travel on stocking feet."

On the Continent, about 10,000 electric cars are on the road, most of them delivery vans. A prominent German utility firm, RWE, is sponsoring the development of electric vehicles for use in congested urban areas. The goal: for 10 to 20 percent of all new vehicles in Germany to be electric by 1980. Volkswagen, the first big automobile firm to build modern electrics, is supplying part of the trial fleet. In Japan, too, where urban air pollution is probably the world's worst, a program to build electric cars for various uses is under way, sponsored by the government.

The electric car may seem like a radical innovation; actually, it was in use before the internal combustion engine. A primitive battery-driven car appeared in England in 1837; improved electrics were in use in Boston and Des Moines in the late 19th century; and by 1899 several hundred electric taxicabs were operating in New York City. Before World War I, "bird-cage" electric carriages piloted by elegant ladies were a familiar sight in many American towns. More than 100 manufacturers of that era sold a total of some 10,000 electrics a year. As late as the 1930s, many battery-driven panel delivery trucks were in use in American cities. But the range of all these electrics was short, their speed low, their batteries heavy, and they could not compete with the burgeoning gasoline engine.

Batteries that limit speed and range remain the bugaboos of today's electric vehicles. Engineers throughout the world are working on substitutes for today's lead-acid variety, but nothing satisfactory has yet been found. A few years ago, I rode in a car equipped with silver-zinc batteries. It had fast acceleration and cruised at 60 miles an hour. But the silver in its batteries cost $ 20,000. (The electric cars used by the astronauts on the moon also had silver-zinc batteries -- and cost more than $ 12 million apiece, including research and development.) If a superior battery of reasonable cost can be developed, the electric vehicle may indeed become a highway car. Meanwhile, as pollution's fetid miasma spreads in widening circles, some 20 million short-trip vehicles in cities and suburbs could be replaced by the kinds of electric cars now available.

ID: nht73-2.8

DATE: 01/18/73

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

TO: Fire Equipment Manufacturers' Association Inc.

TITLE: FMVSR INTERPRETATION