ID: 14668.ztv

Mr. Tommie Matthews
347 South Mountain Road
Fruit Heights, UT 84037

Dear Mr. Mathews:

This is in reply to your letter of March 31, 1997, to Taylor Vinson of this Office, asking how this agency would classify "a Velo Solex 'pedal assisted' bicycle."

As you describe it, the Velo Solex is equipped with a small internal combustion engine. The vehicle can be operated as a bicycle driven solely by muscular power, "by leaving the motor in the 'pulled back' position." If the rider wishes to use the assist, the engine will not start until the vehicle reaches a speed of about 5 mph. If the rider stops pedaling, the vehicle will eventually come to a halt as the power of the engine alone is insufficient to keep the vehicle moving.

This agency is authorized by Congress to regulate "motor vehicles". In part, a "motor vehicle" is defined as a vehicle driven by mechanical power (49 U.S.C. 30102(a)(6)). It is evident from your description that the primary driving force of the Velo Solex is muscular power, and that the mechanical power of the engine is not operative at all times the bicycle is in motion and only supplements the primary driving force. We have therefore concluded that the Velo Solex is not a "motor vehicle" subject to the regulation of this agency. The Federal agency that has jurisdiction over bicycles is the Consumer Product Safety Commission.

If you have further questions, you may refer them to Taylor Vinson (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
ref:571
d:5/15/97

ID: 14669a.drn

Ms. Carol Zeitlow, Engineering Quality Manager
Oshkosh Truck Corporation
2307 Oregon St.
Oshkosh, WI 54904

Dear Ms. Zeitlow:

This responds to your request for an interpretation whether your company must retain the vehicle identification numbers (VINs) that were assigned to Medium Tactical Vehicles (MTVRs), that your company will refurbish for the U. S. Marine Corps (USMC) and the U.S. Army. The National Highway Traffic Safety Administration (NHTSA) does not require the VINs to be retained because they were not required for military vehicles. However, Federal criminal legislation enacted in 1992, administered by the Justice Department, proscribes persons from knowingly removing an identification number from a motor vehicle.

Your letter describes your company's work on the MTVRs as replacing the engine, axles, transmission, and frame with updated parts. Oshkosh will also be retaining and reworking the cargo body and the cab along with other components. The vehicles you are working on were built for the U.S. Armed Forces for military purposes, and will be used for military purposes after refurbishment. In a telephone conversation with Dorothy Nakama of my staff, you stated that because Oshkosh did not originally manufacture the vehicles, you do not know why the vehicles were assigned VINs.

A required VIN generally must be retained on a vehicle throughout the life of the vehicle. However, military vehicles are not required by NHTSA to have VINs. NHTSA's regulations at 49 CFR 571.7(c), Military vehicles, states:

No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.

While the VIN requirements are now in 49 CFR Part 565, Vehicle Identification Number Requirements, rather than in a Federal Motor Vehicle Safety Standard (FMVSS), we interpret Part 565 not to apply to military vehicles.

The requirement that vehicles have VINs was in a FMVSS, Standard No. 115 Vehicle Identification Number - Basic Requirements, until recently. In 1996, Standard No. 115 was consolidated with Part 565, as part of an effort to simplify the VIN requirements. 61 FR 29031;

June 7, 1996. NHTSA indicated in consolidating the requirements that it did not intend to make any substantive changes to the VIN requirements. Thus, this consolidation did not have the effect of requiring that military vehicles have VINs. The consolidation took effect on July 8, 1996.

Accordingly, nothing in Part 565 or in any other NHTSA regulation would require Oshkosh to retain the old VIN or (in the event Oshkosh is manufacturing a new vehicle) to assign new VINs. When originally manufactured, since the MTVRs were manufactured for, and sold to, the U.S. Armed Forces in conformity with military specifications, the MTVRs were not required by NHTSA to have VINs. In Oshkosh's "remanufacture" of the MTVRs, since the MTVRs will be built for, and sold to the U.S. Armed Forces "in conformity with contractual specifications," NHTSA would not require the newly manufactured vehicles to have VINs.

Nevertheless, since VINs have already been assigned to the MTVRs, the following provision under Federal criminal statutes may apply. Section 511, Altering or removing motor vehicle identification numbers, was added to Title 18 of the United States Code by the "Anti Car Theft Act of 1992." That section states that whoever knowingly removes, obliterates, tampers with, or alters an identification number for a motor vehicle or motor vehicle part, for purposes other than repair, shall be fined not more than $10,000 or imprisoned not more than five years, or both. Since the U.S. Department of Justice administers Section 511, you should contact that agency for further information about the provision.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
ref:565
d:6/10/97

ID: 14714.ztv

Mr. Reggie Lawrence
Intelligent Safety
P.O. Box 8618
Midland, TX 79708-8618

Dear Mr. Lawrence:

This is in reply to your letter of April 4, 1997, telling us about your "Brake Light Delay System" and "Blinker Delay System", and asking for an opinion "regarding the legality and use of these systems."

The "Brake Light Delay System" is spliced into the wiring of the stop lamp switch and has the effect of delaying deactivation of the stop lamps for approximately 6 seconds after the operator's foot is removed from the brake pedal. You envision installation of the System on a truck tractor-trailer combination so that when the truck tractor begins to accelerate after it has turned, the delayed stop lamp will indicate to a driver following that (s)he must continue to exercise caution

I am sorry to tell you that Federal law does not allow installation of the "Brake Light Delay System", either as original or aftermarket equipment. Under paragraph S5.5.4 of Motor Vehicle Safety Standard No. 108, stop lamps must be activated upon application of the service brakes. We have interpreted this to mean activation only upon application of the service brakes. Thus, continued activation of the stop lamps after application of the service brakes has ceased would result in a vehicle's failure to comply with paragraph S5.5.4. We appreciate your offer to provide one of these systems for evaluation, but because Federal law does not allow the system, we must decline your offer.

I remarked above that your System cannot be installed in the aftermarket. The regulations of the Federal Highway Administration (FHWA) for commercial vehicles operated in interstate commerce prohibits motor carriers from installing your system if it results in a noncompliance with Standard No. 108. The FHWA requires that commercial motor vehicles manufactured on or after March 7, 1989, meet the requirements of Standard No. 108 in effect at the time the vehicle was manufactured. The FHWA also prohibits the use of additional equipment or accessories that are inconsistent with its regulations. Therefore, your system may not be installed on commercial motor vehicles manufactured before March 7, 1989.

Please note that State laws for interstate commercial motor vehicles are consistent with, if not identical to, the FHWA's requirements. Also, the States are required to have intrastate safety regulations that fall within the FHWA's Tolerance Guidelines. Under this circumstance, the legality of the use of your system on commercial motor vehicles operated exclusively in intrastate commerce would be determined by the laws of the States in which the System would be used. We are unable to provide you with an interpretation of relevant State laws and suggest that you consult the Department of Motor Vehicles of the various States.

Your "Blinker Delay System" is intended to prevent the automatic cancellation of the turn signal system for 3 to 4 seconds after the front wheels of a towing vehicle have been straightened, again to indicate that a turn has not been completed. You note that "most tractor trucks have a blinker system that must manually be switched off to deactivate the blinker," and that the "Blinker Delay System" is intended for other trucks. Under paragraph S5.1.1.5, turn signals on all motor vehicles less than 80 inches in overall width must be self-canceling by steering wheel rotation. Thus, installation of this device would also create a noncompliance with Standard No. 108. For the same reasons, and with the same exception, noted above, this device would not be acceptable as either original or replacement equipment on motor vehicles required to comply with paragraph S5.1.1.5.

If you have further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d:5/30/97

ID: 14834.mls

Mr. Scott Slaughter
Pitts Enterprises, Inc.
5734 Highway 431
P.O. Box 155
Pittsview, AL 36871

Dear Mr. Slaughter:

This responds to your inquiry about whether a logging trailer known as the "knuckle boom loader trailer" needs to comply with new regulations by the National Highway Traffic Safety Administration (NHTSA) that require trailers manufactured after January 26, 1998, to be equipped with rear underride protection and that require medium and heavy-duty trucks and trailers manufactured after March 1, 1998 to be equipped with antilock brakes.

In a February 2, 1994 interpretation from me to you, I stated that it "appear[ed] that your trailer is not a "motor vehicle" within the meaning of the Safety Act." This opinion was based on the fact that your equipment spends extended periods of time at a single construction site and only uses the public roads infrequently to move between job sites. I have no new information to warrant changing this initial interpretation. Accordingly, since your trailer continues not to be a motor vehicle, it would not be subject to any Federal Motor Vehicle Safety Standards, including standards requiring rear impact underride protection and antilock brakes.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
ref:VSA
d:5/14/97

ID: 14836.ztv

Mr. Paul G. Scully
Consultant
525 Lasher Drive
Seymour, IN 47274

Dear Mr. Scully:

We have received your letter of April 8, 1997, bringing to our attention the possibility that certain trailer manufacturers may not be mounting identification and clearance lamps "as close to the top as practicable" as required by Federal Motor Vehicle Safety Standard No. 108. You sent copies of this letter to representatives of the Office of Safety Performance Standards and the Office of Vehicle Safety Compliance as well.

Representatives of these Offices and mine have met to consider your letter. We appreciate your informing us about this matter, and we shall look into it further.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d:5/22/97

ID: 14891.ztv

Mr. Guy E. Koelling
Manager, Office of the Chairman
SANYO North America Corporation
2055 Sanyo Avenue
San Diego, CA 92173

Dear Mr. Koelling:

This is in reply to your letter of April 16, 1997, about the Sanyo "Enacle" pedal assist bicycle.

You refer to the agency's interpretation letter of February 16, 1993, to J.C. Townley in which we advised him of our conclusion, on the basis of the facts in his letter, that the Yamaha pedal assisted bicycle is not a "motor vehicle" required to comply with the Federal motor vehicle safety standards. You state that Sanyo Electric Co., Ltd. produces a very similar product that "is operated on the same principle as the Yamaha product, i.e. a torque sensor that activates when muscular effort is applied. In other words, just as with the Yamaha product, the Enacle will not operate on its own, in the absence of muscular assist." You ask for confirmation that, for the same reasons as set forth in the Townley letter, the Enacle would not be classified as a motor vehicle.

We confirm that interpretation. Pedal assisted bicycles whose power assist is insufficient alone to drive the bicycle are not "motor vehicles" subject to our jurisdiction, but instead are under the jurisdiction of the Consumer Product Safety Commission.

Noting that your letter is headed "confidential" we asked you for a clarification. On May 14, 1997, you asked us to disregard the "Confidential" letterhead on which your letter was typed. Therefore, a copy of our response to you will be included in the agency's public interpretations file.

If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
cc: Consumer Product Safety Commission
ref:5/28/97

ID: 14896-4.pja

Mr. Charles Jandecka
4481 Dover Center Road
North Olmsted, Ohio 44070

Dear Mr. Jandecka:

I apologize for the delay in responding to your letter requesting a reevaluation of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205), as it relates to tinting of windows. Specifically, you expressed concern about the increase in the number of vehicles with dark-tinted windows.

As you know, Standard No. 205 requires vehicle windows that are "requisite for driving visibility" to meet a 70 percent light transmittance requirement. Darker windows are currently allowed in the rear and rear side windows on trucks, buses, and multi-purpose vehicles (MPVs) because the agency has issued an interpretation stating that these windows are not requisite for driving visibility.

You would like the National Highway Traffic Safety Administration (NHTSA) to prohibit dark-tinted windows in light trucks, MPVs, and vans. You disagree with the conclusion of the agency's interpretation that these windows are not requisite for driving visibility. In addition, you argue that sport utility vehicles and vans should not be relieved of the light transmittance requirement by the interpretation because they do not meet the definition of an MPV. An MPV is ". . . constructed either on a truck chassis or with special features for occasional off-road operation." 49 CFR 571.3.

I will first address your argument regarding classification of vehicles. In contending that these vehicles are not MPVs, you argued that sport utility vehicles were not "off-road vehicles," which you found defined in Executive Order No. 11644 and 16 USC 670. We note that these authorities are not relevant to our regulations. But more importantly, this argument fails to recognize the distinction between a "vehicle with features for occasional off-road operation," and a more capable "off-road vehicle." The definition for off-road vehicles, such as the Humvee, is not relevant to whether vans and sport utility vehicles are MPVs.

Sport utility vehicles clearly meet the MPV definition. They have "special features for occasional off-road operation" such as four-wheel drive, large all purpose tires, large suspension excursions, and high ground clearances. The fact that they offer interior amenities and are often not driven off-road by their owners does not nullify these special features. The classifications are based on design, because ultimate use is something the manufacturer generally does not know. The presence of some of these features on vehicles certified as passenger cars also does not nullify their presence on sport utility vehicles.

Some vans and minivans meet the definition of trucks. Most cargo vans are classified as "trucks" under our safety standards. A truck is defined in 49 CFR 571.3 as being ". . . designed primarily for the transportation of property or special purpose equipment." Many full-size vans are designed on a chassis that may be fitted with any number of body types and is designed and used primarily for carrying cargo.

Most passenger vans and minivans are classified as "multipurpose passenger vehicles," because they are considered by their manufacturers to be "constructed on a truck chassis." Some manufacturers may classify them as MPVs because of heavier running gear, front suspensions, and rear leaf springs, for greater load-carrying capacity. In addition, the rear seats are often removable for carrying large cargo rather than passengers, supporting a colloquial definition of "multi-purpose" vehicles.

Generally speaking, designation of the vehicle type is up to the manufacturer. The definitions of trucks and MPVs overlap somewhat. NHTSA's main concern is that all vehicles meet the standards applicable to the type of vehicle as which they are certified. The agency is aware that in recent years changes in the construction of minivans and sport utility vehicles have tended to blur the line between these vehicles and passenger cars. There has been a convergence in the safety standards applicable to these vehicles and the standards applicable to passenger cars. NHTSA has not tried to create a complex distinction between these vehicle types, but has instead allowed the industry to produce innovative designs that meet the demands of the marketplace.

Moreover, the manufacturers have for many years continued classifying vans and minivans as light trucks for the purpose of complying with the Corporate Average Fuel Economy (CAFE) requirements. The vehicle classification requirements in 49 CFR 523.5(a)(5) allow manufacturers to properly classify vans and minivans with removable seats as light trucks for that purpose. It is doubtful the industry could comply with the CAFE standards if NHTSA suddenly restricted classification capabilities. Therefore, given the industry's longstanding reliance on NHTSA's interpretation and regulation in this area, this office cannot make a such a drastic change in the context of an interpretation letter.

Turning now to your question of whether the rear and rear side windows of sport utility vehicles and vans should be considered "requisite for driving visibility," we continue to believe that they should not be. You correctly identified a change in the agency's opinion between the July 16, 1973 interpretation of Richard Dyson and the April 4, 1985 interpretation of Jeffrey Miller, which first announced the conclusion that these windows were not requisite for driving visibility. However, you are incorrect to conclude that either the January 9, 1990 interpretation by Stephen Wood, or any of the subsequent interpretations you cited represent a change in the agency's position on the matter. Mr. Miller's interpretation still represents the agency's position.

The reasoning behind the Miller interpretation is that these vehicles are often sold in configurations without windows or with small windows to the rear of the driver (e.g., a panel van). Even if the windows to the rear of the driver are large enough, these vehicles may frequently carry loads that block the view out of them. Logically, it is impossible to argue that these windows are requisite for driving visibility when they do not even exist on the next van on the lot. In addition, most minivans and sport utility vehicles today, (even those with larger side windows and without a vision-blocking load) have rear side windows that are too high to rely on for lane changes. Vehicle manufacturers provide right-side rear view mirrors on these vehicles which assist in lane changes.

If these windows were requisite for driving visibility, one might expect that vehicle types with darker glass in those locations would be more involved in crashes, but the data do not show this to be true. Some analyses have shown that they are generally less involved in crashes than passenger cars, and that they are even under-involved in lane change crashes. This indicates that the existing window and mirror systems are meeting the minimum needs for driving visibility.

On January 22, 1992, NHTSA proposed, among other things, transmittance requirements for the windows to the rear of the driver in these vehicles. The proposed requirements would permit windows darker than those in passenger cars, but would require these windows to be lighter than the "privacy glass" currently being sold on some minivans and sport utility vehicles. Comments on the proposal were overwhelmingly negative. The law enforcement community was divided on the issue. Final action on this rulemaking is anticipated soon.

I hope this information is helpful. If you have any further questions, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
ref:205
d.3/10/98

ID: 14907a.jeg

Mr. James Sanders
President
Automotive Innovations, Inc.
4 First Street
P.O. Box 474
Bridgewater, MA 02324

Dear Mr. Sanders:

This responds to your letter concerning modifications that your company makes to vehicles to accommodate persons with physical disabilities. I apologize for the delay in this response. You ask for clarification of a matter concerning our prohibition against making inoperative safety devices or elements of design in motor vehicles that have been sold to the end user.

You explain that some of the adaptations and modifications you perform are funded by your state vocational rehabilitation agency, the Massachusetts Rehabilitation Commission (MRC). MRC is requiring you to write to our office every time you contract with MRC to adapt a vehicle for a driver, prior to performing these adaptations or modifications, "to get a ruling on whether we are violating Federal law and whether or not we would be prosecuted under 49 U.S.C. section 30122." You state that it is your understanding that you are currently allowed to perform certain modifications to a vehicle, such as disconnecting the air bag if a person is driving from a wheelchair, or modifying the OEM lap/shoulder belt assembly to accommodate a person with physical disabilities, without having to obtain a ruling from NHTSA. You ask for help in clarifying the matter.

In general, modifiers are permitted to modify vehicles without obtaining permission from the National Highway Traffic Safety Administration (NHTSA) to do so, but are subject to certain statutory limits on the type of modifications they may make.

NHTSA is authorized to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. Manufacturers are required to certify that their products conform to our safety standards before they can be offered for sale. If a certified vehicle is modified, other than by the addition, substitution, or removal of readily attachable components, prior to its first retail sale, the person making the modification is an alterer and is required to certify that, as altered, the vehicle continues to conform to all applicable safety standards.

After a vehicle is sold at retail, Federal law limits the modifications made to it by manufacturers, distributors, dealers, and repair businesses. These entities are prohibited under 49 U.S.C. section 30122 from "knowingly making inoperative" any device or element of design installed on or in a motor vehicle in compliance with an applicable safety standard. In general, the "make inoperative" prohibition would require a business which modifies motor vehicles to ensure that they do not remove, disconnect, or degrade the performance of safety equipment installed in compliance with an applicable safety standard. Violations of this prohibition are punishable by civil fines up to $1,100 per violation.

As to your understanding that "we are currently allowed to perform certain modifications such as disconnecting the air bag if a person is driving from a wheelchair, or modifying the OEM lap/shoulder belt assembly to accommodate a person with physical disabilities," we believe you are referring to the effect of an exclusion⁽¹⁾ from the dynamic test and automatic crash protection requirements set forth in Standard No. 208, Occupant Crash Protection, for light trucks and vans "manufactured for operation by persons with disabilities." Instead of meeting the dynamic test and automatic crash protection requirements, these vehicles may instead be equipped with a Type 2 manual belt (integrated lap and shoulder belt) or Type 2A manual belt (separate lap and shoulder belts) at the front outboard seating positions.

You do not need to write to NHTSA for a determination that the modification qualifies for this exclusion. However, to qualify for this exclusion, the vehicle must:

• be a light truck or van manufactured before September 1, 1997,
• incorporate a level change device (e.g. lift or ramp) for on loading or off loading an occupant in a wheelchair,
• have an interior element of design intended to provide the vertical clearance necessary to permit a person in a wheelchair to move between the lift or ramp and the driver's position or to occupy that position (such as a raised roof, or dropped floor), and
• have either an adaptive control or special driver seating accommodation (examples are an easily removable driver's seat for driving from a wheelchair, or a power seat base for those who transfer) to enable persons who have limited use of their arms or legs to operate the vehicle.

If you modify a used light truck or van originally certified to Standard No. 208's dynamic test and automatic protection requirements, and do so in a manner that it would have qualified for the exclusion cited above, it would not be a violation of the "make inoperative" provision if you disconnected the air bag or modified the OEM lap and shoulder belts within the scope of that exclusion. In other words, at the end of such modification, instead of meeting the dynamic test and automatic crash protection requirements, such a vehicle may instead be equipped with a Type 2 manual belt (integrated lap and shoulder belt) or Type 2A manual belt (separate lap and shoulder belts) at the front outboard seating positions. Because Standard No. 208 would have permitted the vehicle to be manufactured in this manner when new, there would neither be a violation of the 30122 "make inoperative" provision or any need for this agency to consider granting an exception from that provision.

In situations involving a potential violation of 30122, where a vehicle must be modified to accommodate the needs of a particular disability, we have, where appropriate, been willing to consider certain unavoidable violations of the "make inoperative" prohibition as purely technical ones justified by public need. However, it is often possible to make modifications in a way that does not degrade the performance of safety equipment installed in compliance with an applicable standard.

If you believe that certain modifications must be made to accommodate the needs of a particular disability, and that the modifications cannot be made without violating the "make inoperative" provision discussed above, you may write to us and request a letter stating that we will not enforce that provision. The letter should identify the specific facts at issue and why you cannot avoid violating that provision. It should also demonstrate the that proposed modifications minimize the safety consequences of the noncompliances.

For your information, NHTSA is considering proposing a regulation establishing conditions under which a vehicle may be modified to accommodate a person's disability so that the modifier will not be subjected to the make inoperative requirements of 30122. Enclosed is a copy of page 22101 of the agency's April 25, 1997 regulatory agenda where this possible rulemaking is described (entry number 2266).

I hope this information is helpful. If you have any further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
Enclosure
ref:VSA
d.9/29/97

1. This exclusion is only available for vehicles manufactured before September 1, 1997.

ID: 14937.ztv

The Honorable Ted Stevens
Chairman, Committee on Appropriations
United States Senate
Washington, DC 20510-6025

Dear Mr. Chairman:

Thank you for your recent letter to the Department on behalf of your constituent, Brad Brown of Anchorage. Mr. Brown ordered a Chevy Suburban and discovered that it was made in Mexico. He believes that the law on motor vehicle content labeling should be amended to require dealers to disclose the country of origin when a vehicle is ordered. I appreciate the opportunity to address this issue.

By way of background information, the National Highway Traffic Safety Administration's regulations on motor vehicle content labeling were issued pursuant to the American Automobile Labeling Act. This Act has been codified at 49 U.S.C. section 32304. The law requires that new Chevy Suburbans and other passenger motor vehicles have affixed an informational label that includes, among other things, the city and country of the final assembly plant of the vehicle (49 CFR 583(a)(3)). Thus, in the case of a vehicle which is ordered, the purchaser would not see the label until delivery of the vehicle.

While we appreciate Mr. Brown's concern, we do not believe it would be practicable to change the law to require dealers to disclose the country of origin when a vehicle is ordered, since many vehicle models today are assembled in more than one location. The Chevy Suburban, for instance, is also produced in Janesville, Wisconsin. It is our understanding that dealers do not place orders with specific assembly plants. Unless a vehicle model is assembled in a single location, the dealer would not know from which assembly plant the ordered vehicle will be delivered.

It is probable that the most a dealer could do is to inform a prospective purchaser of the location of the assembly plants for the model desired, and that the vehicle will come from one of these. However, a prospective purchaser could likely obtain this information now from a dealer simply by asking. I note that although the prospective purchaser might be able to examine the

domestic content label on similar new vehicles on the dealer's lot to determine their country of origin, this would not necessarily mean that his or her vehicle would be assembled in the same location.

I hope this information is helpful. If you or your staff have any further questions, please feel free to contact me at (202) 366-5265.

Sincerely,
John Womack
Acting Chief Counsel
ref:583
d:5/22/97

ID: 15-004254 WayRay Glazing_sb_3