Interpretation ID: nht95-3.18

TYPE: INTERPRETATION-NHTSA

DATE: June 16, 1995

FROM: Michael J. Wirsch -- Manager, Electric Transportation Dept., Ride Electric, Sacramento Municipal Utility District

TO: Chief Counsel, NHTSA

TITLE: Subject: Disposition Of Vehicles Following Demonstration, Training And Studies Period; Sacramento Municipal Utility District (SMUD); Reference: (1) NHTSA File 9207-1, (2) Letter dated 11/18/92, Robert F. Hellmuth of NHTSA to Niels Skjodt of CityCo m A/S (copy attached).

ATTACHMT: ATTACHED TO 7/26/95 LETTER FROM JOHN WOMACK TO MICHAEL J. WIRSCH (PART 591)

TEXT: As indicated in the referenced November 18, 1992 letter from NHTSA, we obtained permission to demonstrate, test and evaluate for the allowed three year period, sixteen CityCom vehicles produced in Denmark. The subject vehicles are limited performance th ree wheel electric vehicles (EVs) known as the "City-El."

At the time they were imported, there was a possibility of producing the same or similar vehicle in the United States. The test and evaluation was directed toward determining whether this was possible, on a cost competitive and cost effective basis. Th e possibility still exists for development of a design based on similar materials and production techniques, but of an entirely different configuration.

The evaluation period is coming to an end in November, 1995. The approval by NHTSA for evaluation of the vehicles stated that at the end of the evaluation period the vehicles would be modified to comply with the applicable standards or returned to Denma rk. A third alternative is now preferrable to both SMUD and Sacramento's McClellan Air Force Base (McClellan).

The most attractive option for disposing of the sixteen vehicles is transferring ownership directly to McClellan for their use on base, with your permission to do so. The vehicles would be controlled to restrict their use to base property, and therefore not on public streets. Since McClellan can place these vehicles into service that does not need public road access, they would not be registered for use on public streets, not require compliance and need only be controlled as other similar off road veh icles McClellan now has on base.

For the last three years, SMUD has been actively involved with joint Electric Transportation Program activities with McClellan. Nearly identical to the City-El vehicles imported in 1992 are another group of twenty-five vehicles McClellan has been testin g and demonstrating since late 1993, with which they have gained the necessary maintenance and operation experience.

McClellan has indicated an interest in taking over the subject vehicles, and we therefore are pursuing this issue with your agency. Thus, we hereby request authorization to retain the sixteen City-El vehicles in the United States, for the express purpos e of transferring ownership and operation to McClellan Air Force Base. Any action we must take to gain your approval may be communicated directly to me at the following address:

Michael J. Wirsch, Manager Electric Transportation Department P.O. Box 15830 - MS 30A Sacramento, CA 95852-1830

Please provide me with your opinion regarding this approach at your earliest convenience, so that we can take other actions on alternate methods of disposition should your opinion not be favorable. You may contact me by telephone at (916) 732-6754, or b y FAX at (916) 732-6839.

Thank you in advance for any consideration you can give to this request.

Attachment Letter dated 11/18/92 FROM ROBERT HELLMUTH TO NIELS SKJODT (OMITTED)