Interpretation ID: nht68-4.15

DATE: 09/11/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Ashton Martin Lagonda Ltd.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 27 and your cable of September 5.

You have written me with respect to the possibility of crash-testing an 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 crash 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 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 standards 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. @ 255.11 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 do 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 cars 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. 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.

Robert M. O'Mahoney, Esq., Assistant Chief Counsel, US Department of Transportation,

August 27, 1968

We are arranging very shortly to crash one of our DBS cars in 6 cylinder form, on your instructions and as we previously agreed to do, and this will be done during mid September.

As if this is not worrying enough, we are wondering if we may get some concession or help on a further aspect which could cause much financial calamity later on. This is that we may, in the future at a date not yet decided, be in the position to offer an alternative engine capacity of V8 formation in the same chassis.

Basically, this engine will only weigh 40 lbs more than the existing 6 cylinder installation and all mounting points and other fittings will be, to all intents and purposes, identical.

Could you please let me know, as soon as possible, whether or not this alternative will make it necessary for us to crash yet another car; or can it be considered that the minor weight variation would not affect the aspects for which the crash has been organised, i.e. the steering wheel penetration and fuel tank installation.

As a further alternative, might it be possible for us to add this extra weight, in some form to be defined by you, to the existing 6 cylinder engine on our forthcoming crash test in September.

We would be grateful if this particular concession could be made, as quite frankly we had serious thoughts about continueing with the US market when it came to smashing one car, which represents our profit margin for a complete year. The thought of having to smash cars every time there is a change in specification is horrifying and would mean financial penalties which are too heavy for us to bear.

Could I please trouble you for a very prompt reply in view of the possibility of the extra weight 'concession' we have requested to simulate the V8 unit, and the time needed to organise this prior to the crash test of the 6 cylinder car.

D.C. Gerston. Director of Engineering ASTON MARTIN LAGONDA LTD.