Interpretation ID: nht73-2.10

DATE: 09/25/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Sebring Vanguard Inc.

TITLE: FMVSR INTERPRETATION

TEXT: We have received your letter of September 7, 1973, to Mr. Vinson with its enclosures and appreciate your providing them.

In your "memo" on purchase orders you state that Sebring Vanguard "has decided that our vehicles are multi-purpose vehicles." The Vanguard, however, is not for purposes of the safety standards a multipurpose passenger vehicle, defined as "a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation." (In a recent notice, copy enclosed, we have proposed a change in this definition that would make it more restrictive.)

The Vanguard as we understand it is a "passenger car", defined as a vehicle designed for carrying 10 passengers or less, other than a multipurpose passenger vehicle, motorcycle, or trailer. Vehicle design, rather than actual usage, is the definitional determinant, and the fact that some purchasers of a Vanguard may use it off-road or as a replacement for MPV's does not change its category.

ENC.

SEBRING VANGUARD INC.

September 7, 1973

Taylor Vinson, Attorney NHTSA

In our continuing effort to keep N.H.T.S.A. informed of our development program concerning the VANGUARD line of electric vehicles, enclosed please find some new data.

You will note our initial vehicle, the CitiCar, does not resemble the fifty VANGUARD Sport Coupes that have been merrily humming around the nation. We will shortly petition the N.H.T.S.A. for an amendment to standards 204, 206 and 208. As I mentioned on the phone today, we also intend to petition for the commencement of the writing of new standards more appropriate for light-weight vehicles in connection with structural strength and crush distance.

You and your associates are cordially invited to our display at the National Transportation Defense Associations Conference at the Washington Hilton starting Sunday, 23 September through Noon of the 26th. We will be happy to provide you with additional new information at that time.

Sincerely, Robert G. Beaumont President

Encls.

(Graphics omitted)

September 7, 1973

TO: Taylor Vinson

FROM: Robert G. Beaumont

SUBJECT: Copies of Purchase Orders enclosed in the letter of 9/7/73

After careful determination our company has decided that our vehicles are multi-purpose vehicles.

Hawaiian Electric Co. . . This vehicle is used at the Waiau Guard House for security in and around the penal institution's site.

Smithtown High School . . . These two vehicles will be used strictly off-road by security guards for patrol at the two high school complexes.

Post Office Dept. . . . Information concerning this bid has come to us that indicates for a varity of reasons that we will be awarded it. Specific usage of these vehicles will be postal security both on-the-road and off-road, inside the Jersey City complex and outside the complex.

Department of Commerce . . . (see attached letter from Test and Evaluation) This is a reorder, clearly specified on the Purchase Order "special purpose." As the letter indicates, it is replacing a jeep which is a multi-purpose vehicle.

Modern Metal Magazine, August 1973. Please read exciting article on electric cars.

U.S. DEPARTMENT OF COMMERCE National (Illegible Word) and Atmospheric Administration

August 14, 1971

Robert C. Beaumont -- Vanguard Vehicles, Inc.

Dear Mr. Beaumont:

Here's the answer to your question on vehicle replacement:

The Vanguard electric car we purchased last December has been used in place of a jeep (4 wheel drive, 4 cylinder, (Illegible Words) He returned the jeep to our vehicle group with the recommendation it be junked.

The other two Vanguards we expect to get this month will replace (Illegible Words) from the General Services Administration. One is a Ford (Illegible Words) other is a Ford station wagon which will be (Illegible Words) special project requiring many trips on high speed highways.

I know you're aware that I can't publicly endorse a product by (Illegible Word). I can say however with no problem that your vehicle meets our requirements better than any we have found so far. For the many short trips our 35 people make around our (Illegible Words) have tried pick-up trucks, (Illegible Words) bicycles, in addition to jeeps, vans and station wagons. (Illegible Words) has come so close to meeting our need (Illegible Words) (Illegible Lines)