Interpretation ID: nht94-3.80

TYPE: INTERPRETATION-NHTSA

DATE: July 25, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: William R. Willen, Esq. -- Managing Counsel, American Honda Motor Co., Inc.,

TITLE: None

ATTACHMT: Attachment dated 6/28/94 Letter from William R. Willen to administrator, NHTSA (6335)

TEXT:

We have received your "Petition for Honda Electric Vehicles in accordance with FMVSS @ 555.6(c)" (correctly, 49 CFR @ 555.6(c)), dated June 28, 1994.

The petition is incomplete in certain respects. It fails to provide the public interest and traffic safety arguments required by @ 555.5(b)(7). Section 555.6(c)(2)(iii) requires the submission of "the results of any tests conducted on the vehicle that demonstrate its failure to meet the standard, expressed as comparative performance levels." You have provided this information with respect to your request for exemption from Standard No. 103 but not with respect to the eight interior components that acc ompany your request for exemption from Standard No. 302. If you have conducted tests on these components, you are required to submit them as part of your petition.

In addition, the petition does not state whether the period for which exemption is requested is for one or two years (you may need the latter if the manufacture of the 20 electric vehicles is not completed within a year from the date of grant of the peti tion).

If the vehicles are manufactured outside the United States, Honda may wish to avail itself of the provisions of 49 CFR 591.5(j) which allows a manufacturer to import noncomplying vehicles for purposes of research, investigation, and studies for a period of up to three years (when the temporary

importation bond must be paid). After payment of the bond, a manufacturer may request NHTSA for an extension if it requires further time to complete its tests and evaluations.

We shall hold your petition in abeyance until we hear further from you.