Interpretation ID: nht92-8.15

DATE: March 29, 1992

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: R. H. Munson -- Director, Automotive Safety Office, Environmental and Safety Engineering Staff, Ford Motor Company

TITLE: None

TEXT: I enclose an order of the Acting Administrator that grants much of Ford's petition for temporary exemption of its Ecostar van from compliance with the Federal Motor Vehicle Safety Standards. The order, however, denies the petition with respect to Standard No. 106 and S7.3 of Standard No. 208.

Even though Ford does not intend to sell the Ecostars but only to lease them, 49 CFR Part 567 nevertheless requires that every motor vehicle bear its manufacturer's certification of compliance. Therefore, in accordance with 49 CFR 555.9(a), we ask that Ford provide the agency with a sample of the vehicles. The windshield label required by section 555.9(b) may be removed when the lessee takes possession of the vehicle.