Interpretation ID: nht76-5.23

DATE: 06/02/76

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood; NHTSA

TO: American Honda Motor Co. Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your May 6, 1976, request for confirmation that the Honda "MPV" qualifies as a multipurpose passenger vehicle although it is constructed on a "modified" truck chassis.

In our letter to you of April 30, 1976, we concluded that the Honda "MPV" would be classified as a multipurpose passenger vehicle, based upon the assumption that the "MPV" is constructed on a truck chassis. You responded that the "MPV" is constructed on a "modified" truck chassis, and questioned whether the National Highway Traffic Safety Administration considered this fact in its previous interpretation.

The reference to "truck chassis" in the definition of multipurpose passenger vehicle, 49 CFR Part 571.3(b), is intended to include chassis that were designed and developed for trucks, but which have been produced in a version for use in passenger carrying vehicles. According to your letter and drawings of March 1, 1976, the Honda "MPV" is a passenger version of the Honda TN500 light truck. Since the modification of the chassis in the production of the "MPV" does not appear to be so great that the major characteristics of the truck chassis are destroyed, we confirm our previous determination that the Honda "MPV" qualifies as a multipurpose passenger vehicle.

Sincerely,

ATTACH.

AMERICAN HONDA MOTOR CO. INC.

May 6, 1976

Stephen P. Wood -- Assistant Chief Counsel, U. S. DEPARTMENT OF TRANSPORTATION, National Highway Traffic Safety Administration

Dear Mr. Wood:

Your Ref: N40-30

Thank you for your letter of April 30, regarding the Honda "MPV."

I would like to point out that the chassis upon which the "MPV" is constructed is a modified truck chassis. This is clearly shown in the drawings which I sent to you.

I would like to confirm that this fact was considered in your assumption that the "MPV" is constructed on a truck chassis, and if not does it make any difference to your opinion.

Please call me at the telephone number shown above if you have any questions about this matter.

I look forward to your early response.

Yours truly,

Brian Gill -- Assistant Manager, Safety & Environmental Activities