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Interpretation ID: nht74-5.24

DATE: 04/10/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Mr. Jesse R. Hollins

COPYEE: T. W. HERLIHY

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 23, 1974 request for an explanation of why Docket 69-7; Notice 26 was sent to you in response to your February 15, 1974, telegram request for the reasons or needs for such a (alternative interlock) proposal or amendment."

The Notice 26 preamble states in the fourth paragraph appearing on page 9831 of Volume 38 of the Federal Register the "reasons or needs" for proposing an alternative interlock system: that "it may prove desirable for some manufacturers". The proposal would allow greater freedom in the design of a belt interlock system while preserving the direct use incentive of the present sequential ignition interlock system. The Automotive Need conclusion to which you refer, that one effect of the alternative interlock would be to permit operation of the vehicle in reverse, was not a reason cited or relied on by the National Highway Traffic Safety Administration in making the proposal.

I hope I have made clear why Notice 26 was sent to you. I have enclosed Notice 31 for your information.

March 23, 1974

Lawrence R. Schneider, Esq. Chief Counsel National Highway Traffic Safety Administration

Dear Sir:

Re: N40-30 (TWH)

I acknowledge the receipt of a copy of Docket 69-7; Notice 26 which was enclosed with your letter as per above reference number.

My telegram of February 14th. 1974 to the attention of Robert L. Carter, Assistant Administrator of NHTSA asked for certain information specifically pertaining to Docket 69-7; Notice 31.

I am at a loss to understand your reason for submitting Notice 26 to me.

Can you explain this?

Thanking you, I am

Very truly yours

JESSE R. HOLLINS