Interpretation ID: aiam1254
President
Sebring Vanguard
Inc.
P.O. Box 1479
Sebring Air Terminal
Sebring
FL 33870;
Dear Mr. Beaumont: We have received your letter of September 7, 1973, to Mr. Vinson wit its enclosures and appreciate your providing them.; In your 'memo' on purchase orders you state that Sebring Vanguard 'ha decided that our vehicles are multi- purpose vehicles.' The Vanguard, however, is not for purposes of the safety standards a multipurpose passenger vehicle, defined as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' (In a recent notice, copy enclosed, we have proposed a change in this definiton (sic) that would make it more restrictive.); The Vanguard as we understand it is a 'passenger car', defined as vehicle designed for carrying 10 passengers or less, other than a multipurpose passenger vehicle, motorcycle, or trailer. Vehicle design, rather than actual usage, is the definitional determinant, and the fact that some purchasers of a Vanguard may use it off-road or as a replacement for MPV's does not change its category.; Sincerely, Lawrence R. Schneider, Chief Counsel