Interpretation ID: nht72-4.2

DATE: 01/28/72

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Docket 69-7

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: CONVERSATION WITH VOLKS WAGEN REPRESENTATIVE

On Tuesday, January 25, 1972, I received a telephone call from Joseph Kennebeck of Volkswagen of America, Inc., concerning the determination of "rated cargo and luggage capacity weight" under section S8.1.1(a) of Standard 208. Volkswagen determines its cargo and luggage capacity by multiplying the number of designated seating positions by the average occupant weight and subtracting this weight from the gross vehicle weight rating. His question was whether the cargo weight determined in this fashion would be the cargo weight used in those tests in which some seating positions are not occupied. In particular, the third option available to passenger cars between January 1, 1972, and August 15, 1973, provides for a test with occupants only at the front outboard positions, (S4.1.1.3.1), and he asked whether the cargo weight would be as indicated above or some larger weight.

I informed him that Volkswagen could use the cargo capacity as determined with a fully occupied vehicle for all tests in which the vehicle is less than fully occupied, as in S4.1.1.3.1.