Interpretation ID: nht93-8.2

DATE: November 8, 1993

FROM: Andrew Tweddle -- AV Technology Corporation

TO: Walter K. Myers -- Attorney-Advisor, Office of the Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/17/94 from John Womack to Andrew Tweddle (A42; Part 571.7(c))

TEXT:

AV Technology is in the process of responding to a Department of the Army draft specification for an armored security vehicle. AV Technology will be proposing its combat vehicle, the Dragoon ASV. Our fully armored vehicle will be equipped with the AV Technology manufactured UGWS weapons station, which carries a 40mm grenade launching machine gun, a .50 caliber machine gun, as well as a matched bank of smoke grenade launchers. The Dragoon is capable of being fitted with weapons as heavy as a 105mm anti-tank gun. The dragoon has the capability to defeat Main Battle Tanks, with more agility, and speed than many MBTs in service today. Based on the capabilities of the Dragoon ASV combat vehicle we would like to request that the National Highway Traffic Safety Administration consider it for exclusion from federal motor vehicle safety standard and requirements.

The Dragoon is constructed of high hardness armor, and includes a permanently mounted weapons station. In addition to its armor and weapons capabilities, the Dragoon features a powerpack system, a configuration usually found only on main battle tanks. Because of these features, as well as the army's own definition of this vehicle as a combat vehicle rather than a tactical vehicle, (ref: Tacom Specification, Sept. 20, 1993 Pg. 12, 21), we feel there are sufficient grounds for exemption.

In a letter addressed to Verne Corporation, a division of AV Technology, dated August 7, 1989 your office stated, "If the vehicle is a motor vehicle that has been manufactured for and sold directly to the armed forces in conformity with contractual specifications, it is not required to conform to the Federal motor vehicle safety standards." In reference to past vehicles sold to the U.S. Armed Forces, the letter states, "This means that the ASVs sold to the armed forces have not been required to conform to the federal standards." Because of the limited number of the Dragoon ASVs to be manufactured for this contract, its role as a combat vehicle, and past precedent set by Verne Corporation, AV Technology expects compliance with MIL-STD-1180, which mirrors the federal motor vehicle specifications in many respects, is adequate to meet the need for on road safety.

If you require any additional information or details on our combat vehicle please don't hesitate to contact us. Thank you for considering the Dragoon armored combat vehicle for exclusion from federal safety standards and regulations, we look forward to hearing from you soon.

ATTACHMENT Dragoon Armored Security Vehicles (ASV) brochure. (Text omitted.)