Interpretation ID: nht88-3.76

TYPE: INTERPRETATION-NHTSA

DATE: OCTOBER 21, 1988

FROM: BRADLEY J. BAKER -- PRESIDENT, CLASSIC MANUFACTURING, INC.

TO: TAYLOR VINSON -- LEGAL COUNCIL, U.S. DEPT. OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO AUGUST 31, 1989 LETTER FROM STEPHEN P. WOOD, NHTSA, TO BRADLEY J. BAKER, CLASSIC MANUFACTURING, INC.; [A34; STD. 108]

TEXT: Our company currently manufactures a Recreational car dolly used to tow a vehicle behind motorhomes. It is also used by car dealerships to retrieve cars and trucks.

We have a question regarding the 3 bar light cluster on the back of this unit. Is it a necessity? So far, we have to guess at our interpretation of the Federal laws. We don't know if this is considered a motor vehicle under FMVSS 108; 49 CFR 571.108. The National Truck Equipment Association could not answer this question and recommended we write to you.

We would appreciate your opinion on this matter. I can be reached at the following address:

Classic Manufacturing, Inc. 21900 W. U.S. 12 Sturgis, Mi 49091 Attn: Brad Baker (616) 651-9319 Fax No.(616) 651-2921

Thank you for your help in advance

Sincerely