WA state cancelling MV titles

swiss

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If you change the laws of the state you can properly register military vehicles. I spent a year getting the laws changed in Georgia working with local legislators and some members on this site back in 2014. It was a long process, but the basics of what I put together is outlined below and in the attached bill. This is the template for every state.

Swiss

2013-2014 Regular Session - SB 392
Motor Vehicles; provide additional definition; acceptance of applications for registration; not in compliance with federal emission standards

BACKGROUND

Within the state of Georgia there is a thriving community of hobbyist and owners that collect restore and operate military vehicles previously owned by the United States Military and other foreign countries. These vehicles are used for many purposes such as Veterans Day and Memorial Day Parades, Boy Scouts, camping, farming, construction and logging along with many other uses.

In the fall of 2013 a fellow hobbyist was denied registration of a newly acquired M923A2 BMY Harsco Military Cargo Truck by the Department of Revenue on the grounds that the vehicle does not meet O.C.G.A 40-3-30 and 40-2-27.


SB 392 corrects problems with Title 40 of the Official Code of Georgia. This amendment would also bring the O.C.G.A into compliance with The Federal Code of Regulations. The following points summarize the changes to Title 40 that comprise SB 392.

  • Creates a new definition for “Former Military Vehicle” that is consistent with other states that have similar laws. Specific examples are Florida, Texas and Wisconsin.
  • Corrects the O.C.G.A to properly reflect that all vehicles 25 years or older are exempt from Federal Motor Vehicle Safety Standards, FMVSS. This is outlined in US Code 49 U.S.C. 30112(b)(9)
  • Corrects the O.C.G.A to properly reflect that vehicles newer than 25 years of age and manufactured for use by the United States Armed Forces are exempt from FMVSS and Emissions Standards per rulings by the National Highway Traffic Safety Administration (NHTSA) and Federal Code.
 

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KN6KXR

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I'm fairly certain this is not entirely accurate, I am not saying that MV's comply with the FMVSS, I am saying they comply with Mil-STD-1180B, which specifies MV's shall comply with applicable FMVSS standards. Wi TR-11-0016 precedent and the AM General NHTSA Letter both agree with this. Re Crash ratings, seatbelts etc Mil-STD-1180 explicitly references FMVSS as the governing standard (specificaly standard no 201 207, 208, 209, 210).

I think the key here is section 1.2 and 5.4 of Mil-STD-1180B, Excerpts below.

Re lighting, Oshkosh Mv's with blackout lights have an FMVSS compliance decal on the door stating compliance. PM me if you want to chat more on this or have concerns with my approach affecting others

"1.2 Purpose. The purpose of this standard is to establish uniform requirements for incorporating Federal Motor Vehicle Safety Standards into military ground vehicles consistent with their military characteristics. This standard establishes uniform requirements which satisfy the intent of, and are identifiable with comparable Federal Motor Vehicle Safety Standards. The provisions of this standard shall not be construed to be the only safety requirements applicable to military ground vehicles."

"5.4 Application of FMVSS. The application of specific requirements within the FMVSS’S, military wheeled vehicles designed to (a) carry 10 passengers or less and (b) have a gross vehicle weight rating (GVWR) of less than 10 000 pounds, shall comply with those requirements which apply to “passenger cars”. Military wheeled vehicles designed to carry more than 10 passengers, shall comply with those requirements which apply to “buses”. Military wheeled vehicles which have a GVWR equal to or greater than 10,000 pounds, shall comply with those requirements which apply to “trucks”.

edit - an extra 0
I wasn't aware they started doing this (after my time and I own older stuff). Thanks for the correction.

To some extent it'll still be "fuzzy" though. In the USCG we did COI for MSC because they "wanted to comply" per their directive but very much let us know they didn't "have" to. The same with the VA doing local and state permitting for emergency power systems. They want to get the CARB permits but don't have to. So it's just a strange area the rules aren't as firm as one might think.

I'd be interested to know which series of vehicles and/or implementation dates FMVSS compliance started to occur this would help me if I wanted a newer vehicle in my state. CA seems to be the pickiest I would want to know before I bought something.
 

rawr

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washington
I wasn't aware they started doing this (after my time and I own older stuff). Thanks for the correction.

To some extent it'll still be "fuzzy" though. In the USCG we did COI for MSC because they "wanted to comply" per their directive but very much let us know they didn't "have" to. The same with the VA doing local and state permitting for emergency power systems. They want to get the CARB permits but don't have to. So it's just a strange area the rules aren't as firm as one might think.

I'd be interested to know which series of vehicles and/or implementation dates FMVSS compliance started to occur this would help me if I wanted a newer vehicle in my state. CA seems to be the pickiest I would want to know before I bought something.
Mil STD 1180 B came about in 1986, so I think my rational doesnt apply for anything before than (but I have not read through previous revisions of the standard)
 

rawr

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Location
washington
I wasn't aware they started doing this (after my time and I own older stuff). Thanks for the correction.

To some extent it'll still be "fuzzy" though. In the USCG we did COI for MSC because they "wanted to comply" per their directive but very much let us know they didn't "have" to. The same with the VA doing local and state permitting for emergency power systems. They want to get the CARB permits but don't have to. So it's just a strange area the rules aren't as firm as one might think.

I'd be interested to know which series of vehicles and/or implementation dates FMVSS compliance started to occur this would help me if I wanted a newer vehicle in my state. CA seems to be the pickiest I would want to know before I bought something.
I left CA and bought one cause I thought it would be easier in WA :(
 

KN6KXR

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Mil STD 1180 B came about in 1986, so I think my rational doesnt apply for anything before than (but I have not read through previous revisions of the standard)
Huh. My wrecker is a '90 by serial number but was MI titled as an '86 so that's what CA thinks. No FMVSS to be found. Think this was just for the actual vehicles that entered production? Thinking LMTV, FMTV, HEMMT, etc.... The new Oshkosh stuff and whatnot.
 

simp5782

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Huh. My wrecker is a '90 by serial number but was MI titled as an '86 so that's what CA thinks. No FMVSS to be found. Think this was just for the actual vehicles that entered production? Thinking LMTV, FMTV, HEMMT, etc.... The new Oshkosh stuff and whatnot.
HEMTTs entered production in 1982. They still have it on their doors.


You can buy a steel data plate for the doors that says the FMVSS on it etc and just rivet it on.

 

juanprado

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Lostchain

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I'm fairly certain this is not entirely accurate, I am not saying that MV's comply with the FMVSS, I am saying they comply with Mil-STD-1180B, which specifies MV's shall comply with applicable FMVSS standards. Wi TR-11-0016 precedent and the AM General NHTSA Letter both agree with this. Re Crash ratings, seatbelts etc Mil-STD-1180 explicitly references FMVSS as the governing standard (specificaly standard no 201 207, 208, 209, 210).

I think the key here is section 1.2 and 5.4 of Mil-STD-1180B, Excerpts below.

Re lighting, Oshkosh Mv's with blackout lights have an FMVSS compliance decal on the door stating compliance. PM me if you want to chat more on this or have concerns with my approach affecting others

"1.2 Purpose. The purpose of this standard is to establish uniform requirements for incorporating Federal Motor Vehicle Safety Standards into military ground vehicles consistent with their military characteristics. This standard establishes uniform requirements which satisfy the intent of, and are identifiable with comparable Federal Motor Vehicle Safety Standards. The provisions of this standard shall not be construed to be the only safety requirements applicable to military ground vehicles."

"5.4 Application of FMVSS. The application of specific requirements within the FMVSS’S, military wheeled vehicles designed to (a) carry 10 passengers or less and (b) have a gross vehicle weight rating (GVWR) of less than 10 000 pounds, shall comply with those requirements which apply to “passenger cars”. Military wheeled vehicles designed to carry more than 10 passengers, shall comply with those requirements which apply to “buses”. Military wheeled vehicles which have a GVWR equal to or greater than 10,000 pounds, shall comply with those requirements which apply to “trucks”.

edit - an extra 0
This is the exact approach I was going to take with the OR dmv, however simply re-applying at a rural DMV dodged the bullet for me and I never had to pull this out. I am very interested to hear the response to this, In my opinion, this is a pretty clear indication they were built to adhere to the FMVSS.
 

rawr

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washington
This is the exact approach I was going to take with the OR dmv, however simply re-applying at a rural DMV dodged the bullet for me and I never had to pull this out. I am very interested to hear the response to this, In my opinion, this is a pretty clear indication they were built to adhere to the FMVSS.
Sent a letter, we'll see what happens
 

rawr

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washington

jerretbotch

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Seattle
I'm having the same problem. Ive been requested to take a photo of the data plate and got denied because it and my S&97 didn't specifically state that it met fed standards. I'm super interested to hear what ppl work out. Thx for the info!!
 

jerretbotch

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Does the state tell you what parts of the FMVSS the truck fails? Is it lighting? Or something else?
No the DMV was incredibly terse, which is because they don't understand what to even look for. They're following some protocol from dept headquarters in Oly. I was told, that even with an SF97 and a pic of the data plate that the DMV still has to call for further approval from dept heeadquarters.
 

Mullaney

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Is it something about these specific models or did only certain manufacturing runs of HMMWV get these plates? I can't find examples of any AMG plates that pass.
.
Don't believe any of them would pass. It wasn't part of the specifications.

Notice too that when you are ripping down the highway and overtake a military convoy - they are riding on the same roads that you do. They don't have to comply and don't care.
 

cwc

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I'm fairly certain this is not entirely accurate, I am not saying that MV's comply with the FMVSS, I am saying they comply with Mil-STD-1180B, which specifies MV's shall comply with applicable FMVSS standards. Wi TR-11-0016 precedent and the AM General NHTSA Letter both agree with this. Re Crash ratings, seatbelts etc Mil-STD-1180 explicitly references FMVSS as the governing standard (specificaly standard no 201 207, 208, 209, 210).

edit - an extra 0
MIL-STD-1180B was updated in 1991. You can find it by search: MIL-STD-1180B August 1991. Subscription service techstreet.com shows the 1991 revision but not any others; as far as I know the 1991 revision is the latest.

I came across the attached timeline for the introduction of FMVSS provisions, which may be useful. When we were working on passing the MV law in KY several years ago, part of the argument was that MVs comply with the FMVSS provisions that affect other vehicles on the road...
 

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