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It's ALWAYS a good idea to read the actual LAWS that these Bureaucrats are misinterpretting. Once you "arm yourself" you can intelligently "argue" your case against their misunderstanding.I think this may be the letter mentioned above. May help with the DMV folks.
TO: John M. Tolliday -- President, Dayman USA Inc. (Bedford, VA) , FROM: John Womack -- Acting Chief Counsel, NHTSA
The LETTER linked above references the "CFR" (Code of Federal Regulations). This link gets you there....
PART 571—FEDERAL MOTOR VEHICLE SAFETY STANDARDS :: PART 571--FEDERAL MOTOR VEHICLE SAFETY STANDARDS :: CHAPTER V--NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION, DEPARTMENT OF TRANSPORTATION :: Title 49 - Transportation :: Code of Federal Regul
The specific paragraph that is cited is quoted below....
§ 571.7 Applicability.
(a) General. Except as provided in paragraphs (c) and (d) of this section, each standard set forth in subpart B of this part applies according to its terms to all motor vehicles or items of motor vehicle equipment the manufacture of which is completed on or after the effective date of the standard.
(b) [Reserved]
(c) Military vehicles. No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.
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Good luck with your challenges.
John