Interpretation ID: nht73-2.27

DATE: 04/04/73

FROM: RICHARD B. DYSON -- NHTSA ASSISTANT CHIEF COUNSEL

TO: PAUL K. WILSON -- TRUCK TRAILER MANUFACTURERS ASSOCIATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/10/81, FROM FRANK BERNDT -- NHTSA TO DONALD W. VIERIMAA, NOA 30, REDBOOK A22, STANDARD 108; LETTER DATED 02/09/81 FROM DONALD W. VIERIMAA TO FRANK BERNDT -- NHTSA, EXCLUSION OF THE TOWBAR OF A PERMANENT TRAILER DOLLY FROM THE FMVSS 108 LENGTH CRITERIA

TEXT: Dear Mr. Wilson:

This is in reply to your letter of March 19, 1973, asking whether a towbar dolly must be included in determining the overall length of semitrailers for compliance with Federal Motor Vehicle Safety Standard No. 108.

The answer is no. Standard No. 108 is a manufacturing standard, and semitrailers are not manufactured with dollies attached. 49 CFR S390.7, to which you refer, is a definition of the Bureau of Motor Carrier Safety which regulates the operation of certain motor vehicles, and since trailers often use converter dollies, it is understandable that that agency would deem a trailer with a dolly a "full trailer."

Yours truly,

[DIAGRAMS OMITTED]