Interpretation ID: nht94-6.36

DATE: April 12, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: J. Roberts -- John H. Roberts Well Drilling Co. (Brighton, MI)

TITLE: None

ATTACHMT: Attached to letter dated 3/7/94 from J. Roberts to John Womack (OCC 9780)

TEXT:

This responds to your letter of March 7, 1994. You ask for clarification of the agency's position on HMMMV vehicles, as expressed in our letter to Senator Nunn, a copy of which I sent you on February 28.

Specifically, you ask for "the list of the specific objections your department based its recommendation on." As we explained to Senator Nunn, this agency has specifically exempted military motor vehicles from the statutory requirement that all motor vehicles be manufactured to conform to all applicable Federal motor vehicle safety standards. The standards that would otherwise cover HMMMV vehicles are those that apply to "multipurpose passenger vehicles" or to "trucks", depending upon the end configuration of any specific HMMMV vehicle.

Thus, our objection was based on the fact that military HMMMVs are not manufactured to meet the Federal motor vehicle safety standards. We have no knowledge of the specific standards that military HMMMVs do and do not meet, since we have never asked its manufacturer to provide this information.