Interpretation ID: nht91-4.21

DATE: June 17, 1991

FROM: Ivan Lee -- Deputy General Manager, Regulation Affairs, Hyundai America Technical Center, Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re: FMVSS 214, Side Impact

ATTACHMT: Attached to letter dated 7-23-91 from Paul Jackson Rice to Ivan Lee (A38; Std. 214)

TEXT:

We would like to request your assistance with an interpretation regarding Federal Motor Vehicle Safety Standard.

As you know, pursuant to the newly adopted side impact rule of FMVSS 214, all the light duty vehicle manufacturers are required to meet the yearly phase-in schedule, beginning with model year 1994.

To fulfill this requirement, Hyundai is making every effort to work out with the regulation as much as possible. But because Hyundai is limited carline manufacturer, we think Hyundai needs an alternative approach to comply with the requirement.

With the finalized schedule and Hyundai's alternative schedule listed in the table below, we would like to request your comments if Hyundai's alternative plan is acceptable or not.

94MY 95MY 96MY 97MY

Requirement 10 % 25 % 40 % 100 % Alternative Plan 20 % 20 % 50 % 100 % +/- % + 10 % - 5 % + 10 % 0

As you see in the table, compliance percentage of 1st year (1994) and 3rd year (1996) will exceed 10% more than requirement and 2nd year (1995) will be 5% short. However, as a whole, total compliance rate of alternative schedule is 15% more than requirement. We would appreciate if you would review Hyundai's plan and kindly provide us your opinion. Should you have any question, please feel free to contact Mr. Y.K. Moon of my staff at (313) 747-6600.