Interpretation ID: nht73-1.8

DATE: 08/20/73

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

TO: Renault, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 1, 1973, asking for clarification of S5.2.1 and S6.9 of Standard No. 105a.

You interpret the parking brake test as allowing "the vehicle to slide down the 30% incline (because of its weight) as long as the wheels remain locked". The parking brake must hold the vehicle on a 30% grade for 5 minutes. If vehicle weight distribution is such that the limit of traction is exceeded and the vehicle slides down the incline, no noncompliance would be indicated unless the parking brake failed to lock the wheels.

No skid number is specified for the "clean, dry, smooth, portland cement concrete" incline surface specified in S6.9.

Yours truly,

August 1, 1973

Lawrence R. Schneider -- Chief Counsel, Nat. Highway Traffic Safety Admins.

SUBJECT: FMVSS 105a - Docket 70-27, Notice 8

Dear Mr. Schneider:

Regie Nationale des Usines Renault would like to request a clarification regarding section S.5.2.1. and S.5.2.2.1 of the above Docket.

It is our understanding that in order for the parking brake to comply with these paragraphs, the wheels of the vehicle must remain locked, but the vehicle may slide down the 30% incline (because of its weight) as long as the wheels remain locked.

We would appreciate receiving a written confirmation of our interpretation.

In addition, we would appreciate the NHTSA informing us of the skid number of the "clean, dry, smooth, Portland cement concrete" referred to in paragraph S.6.9.

Thank you for your cooperation and consideration.

Very truly yours,

RENAULTINC --[Illegible Words] for Francois Louis, Manager, Technical Standards Dept.