Interpretation ID: nht71-2.5

DATE: 02/11/71

FROM: AUTHOR UNAVAILABLE; Roger H. Compton; NHTSA

TO: Midway Products Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 27, 1971, to this Administration requesting an interpretation on Federal Motor Vehicle Safety Standard No. 108 as it applies to your motorcycle carriers.

Your Model T-400-1 and T-400-2 carriers confom to the definition of "Trailer" as contained in the Federal Motor Vechile Safety Standards, and must, therefore, comply with the requirements of Standard No. 108 as applicable to trailers less than 80 inches in overall width. This Administration has no authority to provide exemption from these requirements.

Your comments on the special design and functional features of your vehicles are of interest to us and will be considered in future rule making actions. In the meantime, of course, you have the right to petition for an amendment of the definition of a trailer or of Standard No. 108 it you feel these provisions impose requirements which are not reasonable, practicable, or appropriate for the types of vehicles you manufacture, pursuant to 49 CFR 533.31.