Interpretation ID: nht72-2.7

DATE: 10/16/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: North American Rockwell Automotive Technical Center

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of September 28, 1972, requesting an extension of the time allowable to petition for reconsideration of Federal Motor Vehicle Safety Standard No. 105a, Hydraulic Brake Systems.

You base your request upon the alleged necessity for testing to determine front axle capability under paragraph S5.1.16, Spike stops. This paragraph is substantially similar to paragraph S4.13 in the proposal published on November 11, 1970. You did not indicate in your comments to Docket No. 70-27 dated February 1, 1971, that the spike stop proposal needed further time for your evaluation. In our view, the 22 months that elapsed between issuance of the proposal and the final rule should have afforded you ample opportunity for testing. In any event, the time allowed for filing of petitions for reconsideration is fixed at 30 days by 49 CFR @ 553,35(a), and we generally do not extend this time.

We will, however, consider the substantive comments you submitted concerning paragraph S5.4.2 and respond to them in due course.