Interpretation ID: aiam0109
Director of Engineering
Aston Martin Lagonda Ltd.
Newport Pagnell
Buckinghamshire
England;
Dear Mr. Gershon: This is in response to your letter of August 27 and your cable o September 5.; You have written me with respect to the possibility of crash-testing a Aston Martin with weight added to the 6 cylinder engine so as to approximate the weight of a V8 engine which you may introduce in the future.; I am puzzled by your opening statement 'We are arranging . . . to cras one of our DBS cars . . . on your instructions and as we previously agreed to do . . ..' A review of the correspondence between the Federal Highway Administration/National Highway Safety Bureau and Aston Martin Lagonda does not disclose either our instructing you, or you (sic) agreeing, to crash test any motor vehicle. Generally, this correspondence has concerned the limited production vehicle problem and Public Law 90-283.; Since the demonstration procedure set forth in certain of the standard involves a crash test, an actual crash test seems the best way for a manufacturer to verify conformance with these standards. The standards, however, do not *per se* require a crash test, and 23 C.F.R. S255.11 specifically states that 'As approved equivalent may be substituted for any required destructive demonstration procedure.'; With respect to your planned test for September 13, our engineers d not view the 40 pound weight differential as significant, and, assuming no further modifications to the DBS, crash testing a 6 or a V8 simulation would be sufficient to demonstrate compliance for the current 6 or projected V8 model.; I understand your concern with the 'thought of having to smash car every time there is a change in specification', but you will have to face this issue every time a new Federal standard appears with a crash demonstration procedures (sic). You may not know of newly issued Standard No. 212 (Windshield Mounting - Passenger Cars), requiring a barrier collision test, and I enclose a copy for your information.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations