Interpretation ID: nht90-4.40

TYPE: Interpretation-NHTSA

DATE: October 11, 1990

FROM: Robert H. Jones -- President, Triple J Enterprises, Inc.

TO: Ben Blaz -- Congressman

TITLE: Re Ref: C-3J0039

ATTACHMT: Attached to letter dated 7-6-89 from Bob Jones to Ben Blas; Also attached to letter dated 7-5-90 from Robert H. Jones to Director, Office of Vehicle Safety Compliance Enforcement, NHTSA; Also attached to letter dated 3-11-91 from Paul Jackson R ice to Robert H. Jones (A37; VSA Sec. 103(8)); Also attached to letter dated 1-22-91 from Robert H. Jones to Clive Van Orden (OCC 5733); Also attached to letter dated 12-11-90 from Robert H. Jones to Clive Van Orden

TEXT:

Thank you for your letter of October 4th. I fully understand the need for you to communicate with Governor Guerrero and Representative Juan Babauta about your assistance with FMVSS and FMCSR regulations.

I believe they are working on this problem at this very moment. Just yesterday, I received a call from Governor Guerrero's legal counsel Tim Bruce Esq. I believe they will develop a position that the DOT regulations should not apply to the CNMI. I agr ee with this position which has been consistent with past administrations. This, in my view, would be the best outcome for all concerned. These regulations cost 3 to 4 hundred dollars extra per vehicle in specialized equipment.

The DOT regulations are great in areas like Los Angeles, where there is a real smog problem and where the average speed limit is 50 to 60 miles per hour on the freeways. I doubt that the people in the CNMI, or of any Island in Micronesia get their monie s worth for these regulations. As you know, most speed limits are 25 to 35 miles per hour and smog is the least of their problems.

Congressman, the bottom line however, is that the CNMI position and the Federal Governments position should be consistent if we are to solve our problems. If the Federal Government insists on taking a different position than the CNMI Government, then th e Federal Government should do their job and enforce their own position.

Then, and only then, will all the Distributors and Dealers of Automobiles and the people of the CNMI know what the ground rules are.