Interpretation ID: nht94-5.4

TYPE: INTERPRETATION-NHTSA

DATE: December 8, 1994

FROM: Kenneth Sghia-Hughes -- Research Engineer, Solectria Corporation

TO: Chief Counsel -- NHTSA

TITLE: NONE

ATTACHMT: Attached to 2/2/95 from Philip R. Recht to Kenneth Sghia-Hughes (A43; Part 301; Std. 102)

TEXT: Dear Sir/Madam:

Solectria Corporation produces electric vehicles (EV's) on the chassis of existing new vehicles and is currently developing a ground-up electric vehicle. In the course of reviewing NHTSA's regulations covering vehicle manufacturers, we have identified qu estions regarding the application of specific standards and regulations to our electric vehicles. Solectria Corporation requests a formal interpretation of these regulations with regard to the following issues:

1. 49 CFR 571.301, FMVSS #301 -- Fuel system integrity

Opinions vary as to the applicability of this standard to electric vehicles with no petroleum-based fuel source. The stated purpose of the standard is "to reduce deaths and injuries occurring from fires that result from fuel spillage. . . . and resul ting from ingestion of fuels during siphoning." The standard states that it applies to "passenger cars, and to multipurpose passenger vehicles, trucks and buses that have a GVWR of 10,000 pounds or less and use fuel with a boiling point above 32 degrees F. . . . .", implying that it applies to all passenger vehicles, but to only those trucks with GVWR of 10,000 pounds or less and that use fuel with a boiling point above 32 degrees F. On the face of it, this standard appears not to apply to electric veh icles with no liquid fuel, but enough doubt as to NHTSA's interpretation of this standard with respect to EV's exists that Solectria requests an official interpretation from NHTSA.

2. 49 CFR 571.102. FMVSS #102 -- Transmission shift lever sequence, starter interlock, and transmission braking effect

This standard is written so that it literally only applies to vehicles with manual or automatic transmission. Most of our vehicles delivered to date and all of the models currently in production have a single speed transmission which requires no shif ting, either manual or automatic. Solectria vehicles nevertheless meet the requirements of this standard for automatic transmission vehicles, in keeping with what Solectra believes is the intent, if not the letter, of the regulation. Solectria requests a clarification of this standard with regard to single speed transmissions, as commonly encountered in electric vehicles. If deemed applicable to single speed transmission vehicles. Solectria requests that S3.1.3 Starter interlock, be rewritten or inte rpreted to include the initial activation of EV motor controllers as well as engine starters.

Please feel free to contact me for any additional information.

Sincerely,