Ari Scott, Chief Council, Legal Interpretations, Low Speed Vehicles for the NHTSA.

[SandBlasted]

Sent to all parties at the DMV and my Reps....

The last issue the Nevada DMV gave me was that under fereral law you cannot convert an off road vehicle into an on road vehicle.

The real story is, under federal law , if you convert an off road vehicle to an on road vehicle, it much conform to the vehicle standards for the type of vehicle. For LSV's it is pretty simple.

Hello everyone

I heard back from Ari Scott, Chief Council, Legal Interpretations, Low Speed Vehicles for the NHTSA. Per a phone conversation, he has stated what we want to do as far as converting Side By Sides and Golf Carts to LSV’s is legal as far as the Federal Government is concerned. We explained exactly how we plan to modify Rhinos. We explained how we were going to do it as far as the speed issue, and basically speed can’t be controlled by something similar to placing like a block of wood under the foot pedal. Our new CDI which limits the Vehicle at 25 MPH is permissible. According to Mr. Scott, this is being done by other manufactures in the country.

As far as the owners of Side By Sides or Golf Carts modifying their own vehicles, from his words, it is not illegal for an owner to modify his own vehicle. He can remove the air bags, cut out the seat belts and it is not a federal crime. It may be in violation of State Law but no federal law. When an owner converts a vehicle to a LSV, they become the manufacture and are responsible for certification but there is nothing they have to do through the Federal Government.

He does want me to submit a letter for interpretation on another request we had that we sell the complete kit to the customer, and certify it after the owner modifies the vehicle if that would be allowed. He said that is new territory and needs time for this request. This interpretation is only on this one issue.

The question is if we sell the kit, and the owner modifies it, can we certify it after the owner does his own modifications? As it stands right now we can only sell the kit and the owner is responsible for meeting certification which can be done in my opinion with the RD-64 Form.

I have downloaded all the forms to be a manufacture with the state of Nevada. At this time I really don’t want to be a manufacture.

We have NRS 490.060 which states:

NRS 490.060 “Off-highway vehicle” defined.

1. “Off-highway vehicle” means a motor vehicle that is designed primarily for off-highway and all-terrain use. The term includes, but is not limited to:

(a) An all-terrain vehicle;

(B) An all-terrain motorcycle;

© A dune buggy;

(d) A snowmobile; and

(e) Any motor vehicle used on public lands for the purpose of recreation.

2. The term does not include:

(a) A motor vehicle designed primarily for use in water;

(B) A motor vehicle that is registered by the Department of Motor Vehicles; or

© A low-speed vehicle as defined in NRS 484.527.

Here is my proposal.

I will have one of our officers radar the unit for the speed test and sign off on it as complying with the speed requirements. I will have the RD-64 form completed either by the DMV or by a garage allowed to complete the RD-64 form. This is a simple visual inspection that the DMV does all the time with kit cars, home built units and dirt bike conversions.

Providing I pass all inspections, you issue our registration, or I am open to other suggestions you may have.

Thank you.

Craig Castleberry

eXtreme Outdoors ( www.xopco.com )

728 Canyon Rd

Boulder City, NV. 89005

702-987-0202

Toll Free Order Line 888-481-9852

E-Mail extremeoutdoors@xoatv.com

Fax 775-628-6371

Edited September 12, 2008 by SandBlasted