Interpretation ID: nht91-5.3

DATE: July 19, 1991

FROM: Charles Lombard -- Lombard Industries

TO: Rick Iderstiene -- NHTSA

TITLE: Safety Standard #211

ATTACHMT: Attached to letter dated 9-12-91 from Paul Jackson Rice to Charles Lombard (A38; Std. 211); Also attached to letter dated 11-13-87 from Erika Z. Jones to William J. Maloney

TEXT:

Please send me a letter of your approval to market my new wheel and/or hubcap design at your earliest convenience.

I have worked hard and am fighting cancer. I've put in nine years in the making of this product with safety always in mind. I have worked with General Motors and Ford Motor Company for 40 years in general management positions, always making everything to be safe and clean. I have 40 years with a perfect record. I've received many awards.

The design will be a little deeper and inwards. The TIRE will ALWAYS HIT THE CURB FIRST. It's one piece and has nothing to do with holding the wheel, or rather the design has nothing to do with holding the wheel on the car or truck. It just has a sparkle affect and will keep the wheel cooler, eliminating brake fade (a good safety factor).

As you can see, the wheel will still be held on by 4, 5 or 6 lug nuts. You can see we threw weeds, cloth and other debris directly into it, and the design will not catch it. It is DEFINITELY NOT a true knock-off with sharp ends. The pictures enclosed will show a better idea of how it is held on. It is definitely stronger and much more safe than anything that the auto factories are building today.

Enclosed are some pictures of many other makes and models. Much of mine will be molded and poured in appearance only (strong and safe). The lug nuts and the outer edge of the hub are safe and much more leaning toward the safety factor than many that are on the market today. I have many factory awards for marketing all types of vehicles.

We found by throwing cloths or debris into the wire wheels of today, they will catch more than any other design and will break the spokes. The knock-off hubs and prongs I know have been outlawed many years ago. My wheel and hubcaps were studied by the marketing professosr and students of the University of Arizona three years ago. Compared to some market studies, my design was much stronger and safe, and the wheel made of steel and chrome NEVER has to be retourqued like aluminum.

I hope I pass your specifications and endorsement. Thank you so much.

Attached to drawings of wheel rims and hub caps. (Graphics omitted)