Interpretation ID: aiam2791
33 Garland Way
Lyndhurst
NJ 07071;
Dear Mr. Arquin: This responds to your recent letter asking what loading conditions ar applicable for purposes of measuring the wheelbase of passenger cars, under the new phased-in passive requirements of Standard No. 208, *Occupant Crash Protection*. Apparently, the wheelbase of one of Peugeot's vehicles having an independent rear suspension varies as a function of the vehicle loading.; The phased-in passive requirements of Standard No. 208 were based on determination of the lead time necessary to engineer passive restraints into each size class of automobile. Wheelbase was chosen as a measure to delineate the phasing requirements because it is directly related to vehicle size and because it is a well-defined quantity that does not vary significantly within a given car line.; For purposes of measuring wheelbase, the vehicle is loaded according t the general test conditions of Standard No. 208. These test specifications, including loading, are meant to approximate the likely condition of the vehicle under normal driving circumstances. Since a vehicle having a variable wheelbase will generally carry the same weight as the average automobile of its size, it is appropriate that the wheelbase on such a vehicle be determined under the loading conditions specified under Standard No. 208. Therefore, Peugeot should measure the wheelbase of its vehicle under the loading conditions specified in paragraph S8.1.1(a) of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel