Interpretation ID: nht72-1.2

DATE: 02/23/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Petro Electric Motors, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in further response to your letter of December 16, 1971, requesting interpretations of several Federal motor vehicle safety standards as they apply to electric vehicles.

The engine retardation braking effect of Standard No. 102 applies only to vehicles equipped with automatic transmission, and not to an electric vehicle that has no transmission.

Standards Nos. 201 through 204 do not apply to trucks. You have stated that your electric vehicle is designed so that "the rear . . . will normally be used for tools, service equipment, spare parts, etc., as would be required in a service vehicle as used by an electric utility company for going out and making repairs." You have also stated that the back area could be converted to a seating area for two passengers, but that this would be "unusual and occasional." On the basis of this information we have concluded that your vehicle is a "truck" and need not meet Standard Nos. 201-204.