Interpretation ID: nht74-4.12

DATE: 07/10/74

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

TO: Flyer Industries Limited

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 5, 1974, question whether electric trackless trolley coaches are motor vehicles under the National Traffic and Motor Vehicle Act of 1966, and if so, whether Standard No. 121, Air brake systems, or any other special requirements must be met by this type of vehicle. Section 102(3) of the Act defines motor vehicle:

"Motor vehicle" means any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.

An electric trackless trolley coach is a motor vehicle under this definition, and Standard No. 121, Air brake systems, applies to a coach equipped with an air brake system. No special requirements apply to trackless trolley coaches. Standard No. 121, Air brake systems, requires stopping distance performance which must be met by any bus equipped with air brakes, whether or not it is equipped with supplementary dynamic braking means. In evaluating a vehicle's compliance with the stopping distance performance requirements of S5.3 and S5.7.2.3, auxiliary braking devices may be utilized in making the stops provided such devices are engaged by means of the same service brake pedal or parking brake control that operates the air brakes. It should be noted, however, that these stops must be made with the transmission selector control in neutral or the clutch disengaged (S6.1.3).

FLYER INDUSTRIES LIMITED

June 5, 1974

Department of Transportation

Att: Office of Legal Information

ELECTRIC TRACKLESS TROLLEYS

File: 600 E13, E75/50

Dear Sir,

We are currently in the negotiation stages for an order to manufacture a number of electric trackless trolley coaches for a number of U.S. transit properties.

These vehicles are similar to standard diesel buses in that they are fitted with air brakes, cir suspension, and power steering. Coaches also have electrical braking of the rear wheels.

We would be interested to know if HVSS 121, Air Brake Systems Trucks, Buses and Trailers, is applicable to electrically driven vehicles operating from overhead wires. Are there any other special regulations that must be met by this type of vehicle?

Yours very truly,

A. Deane

Director of Engineering