Interpretation ID: nht67-1.11

DATE: 08/25/67

FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA

TO: Honda of New York

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 4, 1967, to Mr. Donald H. Schwentker in which you request confirmation that the Japanese-made CONY Models AF-11SVH and AF-7SVH compact trucks are multipurpose passenger vehicles under the new Federal Motor Vehicle Safety Standards.

You state that the CONY line is primarily a line of commercial truck-type vehicles and that the Models AF-11SVH and AF-7SVH, although providing for four persons, are built on the same truck chassis as the purely commercial models.

A "multipurpose passenger vehicle" is defined in section 255.3 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."

Therefore, the CONY Models AF-11SVH and AF-7SVH are multipurpose passenger vehicles, since they are designed to carry 10 persons or less and are constructed on a truck chassis.

Sincerely,

ATTACH.

August 4, 1967

Donald M. Schwentker -- National Highway Safety Bureau, Federal Highway Administration

Dear Mr. Schwentker:

As you suggested in our recent telephone conversation, this is in the nature of a request to your office to confirm two models of the Japanese-made CONY brand of compact trucks which we import, as multi-purpose passenger cars, rather than as passenger cars, for the purpose of classifying them under the new national motor vehicle safety standards.

The basis of this request rests on the facts that (1) the CONY line is primarily a commercial truck type of vehicle and (2) the two models in question AF-11SVH and AF-7SVH, although providing for four persons, are convertable to exclusively cargo space (the rear seat folds down to the floor) and are built upon the same truck chassis as is employed for the purely commercial models.

I am herewith enclosing brochures describing the entire line of eight vehicles of the CONY brand (only two of which are expressly built for passenger-carrying) and have checked and marked the two models thereon.

Inspection of the drawings, photographs and specifications will show only the slightest differences existing among the eight models in size, design and performance and for all practical purposes, each model has a majority of the engineering characteristics of all the other models.

We would appreciate your earliest interpretation for the benefit of our manufacturer who must consider the necessary modifications for 1968 models.

May I also reiterate my appreciation for the information and advice you have already tendered.

Very truly yours,

John J. Paxton -- HONDA OF NEW YORK