Interpretation ID: nht76-5.24

DATE: 03/08/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Steam Power Systems

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 22, 1976, requesting confirmation that your company's Paratransit Vehicle would be classified as a "multipurpose passenger vehicle" for purposes of the Federal motor vehicle safety standards and regulations.

Your letter states that the Paratransit Vehicle is designed primarily to carry wheel-chair-confined passengers in a Dial-a-Ride or jitney type of service, and that the vehicle is of the forward control configuration, constructed with a custom chassis-body structure.

Based upon the facts presented in your letter, the description and specifications contained in the attached SAE design paper, and the National Highway Traffic Safety Administration's previous interpretation of the classification, we would conclude that the Paratransit Vehicle does qualify as a "multipurpose passenger vehicle."

Please contact us if we can be of any further assistance.

Yours truly,

ATTACH.

Steam Power Systems

January 22, 1976

Office of Chief Council -- National Highway Traffic Safety Administration, U. S. Department of Transportation

Dear Sir:

Steam Power Systems, Inc. (SPS) is currently constructing a prototype Paratransit Vehicle (PTV) for the Urban Mass Transportation Administration of the D.O.T. The PTV is designed primarily to carry wheelchair confined passengers in a Dial-a-Ride or jitney type of service. The SPS prototype vehicle is of the forward control configuration and is constructed with a custom chassis-body structure. The vehicle design is discussed in some detail in the accompanying SAE paper.

SPS plans to certify that the vehicle meets all applicable FMVSS for a Multipurpose Passenger Vehicle (MPV). SPS has been in touch with Mr. Joseph O'Gorman of the Office of Standards Enforcement of NHTSA, and he feels our vehicle should be classified as a MPV, but he suggested that we request an interpretation from the Office of Chief Council that would classify the paratransit vehicle as a multipurpose vehicle.

SPS would appreciate it if you could review the vehicle design and intent and let us know whether the PTV is legally considered to be an MPV. Thank you for your cooperation.

Sincerely,

Phil Schneider -- PTV Project Supervisor

[Enclosure Omitted.]