Interpretation ID: nht95-2.81

TYPE: INTERPRETATION-NHTSA

DATE: May 17, 1995

FROM: Douglas C. Helbig -- Vice President, SPENCER TESTING SERVICES, Inc.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 6/7/95 LETTER FROM JOHN WOMACK TO DOUGLAS C. HELBIG (A43; STD. 304)

TEXT: Dear Mr. Womak:

I am writing in reference to a telephone conversation I had with Marvin Shaw of NHTSA on May 16, 1995 regarding written verification of NHTSA's power to regulate the re-inspection of Compressed Natural Gas (CNG) containers used as fuel tanks on Altern ative Fuel Vehicles.

It is our understanding that NHSTA does not have any regulatory authority to require periodic reinspection of CNG containers used as a vehicle fuel container. We have been told this by several NHSTA personnel over the phone but they are unwilling to give this to us in writing. Our inability to obtain this in writing has led to considerable confusion for our clients who need to know if D.O.T. or NHTSA does indeed regulate this periodic reinspection.

Simply stated, we need in writing, a letter stating that NHTSA does not have any authority to require periodic inspection of CNG containers used as fuel cells on alternative fuel vehicles.

We thank you for your prompt attention to our request and if you have any questions please do not hesitate to call.