Interpretation ID: 77-3.31
TYPE: INTERPRETATION-NHTSA
DATE: 07/19/77
FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA
TO: Bankhead Enterprises, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your June 7, 1977, question whether the trailer portion of an auto transporter must comply with Standard No. 121, Air Brake Systems, if it is manufactured after the current September 1, 1977, termination date for the exclusion of auto transporters from the standard.
As stated in a telephone conversation between you and Mr. Herlihy of this office, the current exclusion for auto transporters terminates September 1, 1977, and either portion of an auto transporter manufactured after that date must comply. Recently, the NHTSA proposed extension of the auto transporter exclusion from September 1, 1977, to January 1, 1979 (copy of proposal enclosed). The comment closing period ended July 11, 1977, and the agency hopes to reach a decision on the proposal in the near future.
SINCERELY,
BANKHEAD ENTERPRISES, INC.
June 7, 1977
Joan Claybrooks Administrator National Highway Safety Administration
Enclosed find copy of a letter from one of our customers asking us to quote on 80 new car hauling trailers for delivery after current expiration of S-121. Please note that trucks furnished by customer will be manufactured prior to Sept. 1 and without the S-121 brakes. Customer is asking if we can produce the trailer without S-121. Out current design will not accept the components for S-121. Engineering drawings will be furnished under separate cover.
It is of utmost importance that a ruling on extension of S-121 is rendered. Your prompt attention is very much appreciated.
Glenn Taylor President
May 10, 1977
Mr. Glenn Taylor, President Bankhead Enterprises
This is your invitation to bid on 80 trailers and headracks. The tractors will be conventional cab GMC's, 9500 series with tilt hoods. Specifications include 6V-92 TT engines, GMC air suspensions, tandem axle drives and disc wheels with 1122.5 tires. You should outline in your quotation the number of imports, A-bodies, B-bodies, C-bodies, compacts, pickups, vans and variations of other combinations your unit will carry. This quotation should include tractor wheelbase, also itemized price of trailer, headrack, excise tax and freight f.o.b. Dallas, Texas.
GMC has advised the tractors will be produced prior to September 1st. This will enable us to beat the deadline on 121. As the units are ready they can be shipped to your plant. However, we do not want to start putting these units in service until January 1, 1978. We would like to know if you can produce your trailers so they also will not have the 121 brake system. Equipment must comply with all federal and state regulations.
We would appreciate receiving the above information at your earliest convenience. Specification sheets are enclosed. Should there be any questions, please contact my office.
UNITED TRANSPORTS, INC.
Karon W. Thomas Director of Maintenance and Equipment
cc: RAYMOND E. SIMMONS -- UT