Interpretation ID: nht73-6.17

DATE: 04/06/73

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Volkswagen of America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 2, 1973, regarding the classification of the Volkswagen Model 181 (The VW Thing) for purposes of the Federal Motor Vehicle Safety Standards.

Based on a review of your letter and its enclosures, we accept your classification of the Model 181 as a Multipurpose Passenger Vehicle.

Sincerely,

VOLKSWAGEN OF AMERICA, INC.

April 2, 1973

Francis Armstrong, Director National Highway Traffic Safety Administration

Re: N41-22GSh

This is in response to your letter of March 19, 1973 directed to Mr. Crawford Shaw in which you requested the submission of satisfactory evidence that would support our classification of the Volkswagen Model 181 (The VW Thing) as a Multipurpose Passenger Vehicle.

Upon receipt of your letter, we arranged for a meeting with you and your staff which was held in your office on March 29, 1973. At this meeting, we presented information relevant to the fact that the VW model 181 is equipped ". . . . with special features for occasional off-road operations . . . . " as is required by the definition of a Multipurpose Passenger Vehicle. The following submission enumerates the features of the VW 181.

VEHICLE HISTORY

This vehicle was originally designed in the early 1960's under contract for the German Government. A major consideration in the design concept was the requirement by the army for rough terrain operation and associated vehicle specifications. The availability of the vehicle was originally limited to the army but subsequently, after sufficient production capacity was gained, availability was extended to the general public in Europe. Most recently, the entire world production has been centralized in Mexico and vehicles are exported back to Europe and also now to the U.S.A.

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VEHICLE FEATURES

The following is a description of the vehicle including a comparison in some respects to our VW Beetle models so as to differentiate between typical passenger car specifications.

The BODY DESIGN is both rugged and functional, void of cosmetic details, with maximum consideration given to the extremes of hard usage found off road rather than to comfort and decor. The sloping front hood provides excellent forward visibility, an aid in negotiating hill crests. Generous clearance between the fenders and the tires is provided for accommodating extreme suspension travel and preventing entrapment of foreign objects. A folding soft top, removable side curtains and a folding windshield provide for operation in extremes of weather and possibly for negotiating areas of minimal overhead clearance. The folding feature of the rear seats provide a compartment of seventeen cubic feet capacity for cargo carrying.

Special off-road features are:

1. Standard tires of 185 R 14 M & S (Mud and Snow) with tube mounted to a five inch wide rim. The coarse tread profile provides versatility on all surface types. This compares to our normal Beetle tire of 6.00x150, tubeless, mounted to a 4 1/2 inch rim.

2. Ground clearance of 8.1 inches as compared to normal Beetle dimension of 5.9". For additional comparison our VW 412 model has a ground clearance of 5.3" and typical domestic models average approximately 5.0". Ground clearance of competitive off-road vehicles is in the range of 7 to 8".

3. Angle of Approach of 36 degrees and Angle of Departure of 31 degrees gives favorable grade negotiating ability without interference in the area of the vehicle overhang. For both domestic and import passenger cars, the angle of approach is in the range of 17 degrees to 25 degrees and the angle of departure from 11 degrees to 21 degrees.

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4. An additional specification, unique to this model, is the "Wading or Fording Depth" which is 15.6 inches. This dimension constitutes the water depth through which this vehicle can be driven without danger. Typical passenger cars are not capable of such activity nor is such a dimension specified.

5. An engine protection shield is provided under the vehicle to minimize the chance of damage in the lower crankcase area. Also, an additional shield is provided for the Exhaust Gas Pecirculation filter, a part of the emission control system provided for the U.S.A. model.

6. Towing eyes are provided, mounted in the bumper, two front and two rear, for attachment of a tow line.

7. The overall Transmission/Final Drive gear ratios are lower as compared to the Beetle for improved low speed performance. Hill climbing ability is approximately 15% improved over that of the Beetle, measured on a paved roadway.

8. The chassis employed is a derivative of our platform design, however, reinforcement in the area of the suspension mounting is added. Reinforcement struts from the front torsion tubes to the chassis prevent damage in high load conditions. The front and rear axle loads are respectively 1212/1764 lb. as compared to 1080/1609 lb. of the Beetle.

9. The engine equipped is identical to that of our Beetle model except for minor changes in emission control techniques. However, the air cleaner is a very large capacity oil bath type which aids in reducing dust intake in off-road activities.

Enclosed for your information is a List of Technical Specifications (Exhibit 1) and a copy of the Owner's Manual (Exhibit 2) for the U.S.A. model 181.

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In our meeting with you, some discussion centered around the providing of four-wheel drive in an off-road vehicle. In the VW 181 with its low curb weight (1995 lb.), rear weight bias, and four-wheel independent suspension, we find no need for four-wheel drive. In our own comparative research, we have in some instances found the 181 to have a distinct advantage over other, much heavier, four-wheel drive vehicles. Also, it is interesting to note that vehicles such as the Chevrolet Blazer, IHC Scout and the Jeep DJ-5 are available with two wheel drive standard and four-wheel drive optional at extra cost.

Additionally of interest, the National Off Road Racing Association (NORRA) is a sanctioning body of many off road race events in the U.S., including that taking place in the Baja area of Lower California. They have clearly recognized the respective capabilities of both two wheel and four wheel drive vehicles by providing competitive classes for both.

Enclosed is a copy of an article that was published in the March 1973 issue of MOTOR TREND Magazine (Exhibit 3). The thoughts of the writers illustrate the capabilities of the vehicle and only illuminate the enthusiasm that has been and will be generated by this vehicle inthe off-road, recreational vehicle market.

In a report of the National Traffic Safety Agency on the development of the initial Federal Motor Vehicle Safety Standard published in Washington, D. C. on March 17, 1967, the Agency set forth the history of its standard setting process and the specific considerations that entered into the selection of the options that were ultimately incorporated into the law. As in many other standard areas, the Agency felt that a number of options were open to it in dealing with the problems presented by special purpose vehicles. The report of March 17 records the discussions within the Agency (Exhibit 4).

It is fair to conclude, in our opinion, that by introducing the definition of MPV, the Agency recognized that some passenger type vehicles present special problem in meeting the passenger car standards and should, therefore, not be required to comply with all of them. The report also makes it clear that the Agency is thinking primarily of jeep and van type vehicle that would fall into that category since both are essentially used as passenger cars but have also features that make them suitable for "carrying of goods" or "cross-country travel over rough terrain."

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You have also requested clarification of the text of the certification label. We have been informed by the factory that the label text does contain the proper reference to "Gross Axle Weight Rating" and "Gross Vehicle Weight Rating". We do not have a sample of the actual certification label at this time, but will forward one to you shortly. For reference at this time, page two of the enclosed Owner's Manual contains a facsimile of the certification label as it will appear in the vehicle.

In conclusion, the facts set forth herein firmly support our classification of the VW model 181 as a Multipurpose passenger vehicle, in that it is equipped with special features for occasional off-road operations. Competitive vehicles, as Jeeps, Land Rovers, and Broncos may be slightly different from the model 181 in their configurations and offer four wheel drive as an extra cost option, but are very much identical to the model 181 in terms of performance and suitability for off-road use.

We look forward to receiving your early reply and extend the invitation to completely examine an actual vehicle, at your convenience, at our facility in Englewood Cliffs. If any additional questions should arise, please contact me directly by telephone at the number below.

Sincerely yours,

Guenter Storbeck

[Enclosures Omitted.]