Interpretation ID: nht70-2.5

DATE: 04/29/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: David Hemenway

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of March 9, 1970, addressed to the National Highway Safety Bureau, concerning data provided pursuant to the Consumer Information regulations, 49 CFR @ 575.101, Vehicle Stopping Distance. A copy of the consumer information date for 1970 vehicles is enclosed.

You asked whether stopping distances greater than 194 feet for vehicles traveling 60 mph indicate the likelihood that such vehicles are(Illegible Word) to meet Federal Motor Vehicle Safety Standard No. 105. As you have noted, the stopping distance for a constant(Illegible Words) deceleration from 60 mph would be 194 feet. However, Standard No. 109 does not require an average deceleration rate. ((Illegible Words) up" time) of 24(Illegible Word) during the entire period of deceleration. The Standard requires only that a vehicle attain a deceleration rate of 20(Illegible Word) with a pedal force of between 15 and(Illegible Word) lbs., in a(Illegible Word) 60 mph. Consequently, the standard does not require that the stopping distance not exceed 194 feet, and consumer information data showing a stopping distance in excess of 194 feet for the 60 mph test does not indicate non-compliance with Standard No. 105.

The attached Discussion Paper indicates none of the revisions in Standard No. 105 that are under consideration. Should amendments be found desirable, a notice of proposed rule making containing the proposed revisions will be issued.

Thank you for your interest in motor vehicle safety.