Interpretation ID: nht71-4.14

DATE: 09/20/71

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Automobiles, Peugeot

TITLE: FMVSS INTERPRETATION

TEXT: We appreciate the opportunity to further discuss the questions you raised during our visit of June 9 and 10. I will try to answer each question as fully as possible.

1. It would be unfortunate if the effect of our standards on domestic passenger car production in Europe is to raise costs to the point where significant numbers of people are forced to rely on cheaper and more dangerous vehicles such as motor driven cycles. However, we do not think this result likely in the light of the continuing demand for inexpensive passenger cars and in the absence of legislation by the European nations to compel adoption of the costlier safety features.

2. We are aware of the concern of foreign manufacturers with the effects of the standards. The National Highway Traffic Safety Administration will attempt to be as flexible as possible, consistent with its mandate to insure the safety of vehicles sold in the United States. The discretion allowed the agency to exempt vehicles from a standard is a matter that Congress will have to decide. At the present time, the exemption authority given the National Highway Traffic Safety Administration by the 1966 Act has expired, and we are therefore unable to agree to any exemptions unless Congress chooses to recreate the exemption authority in some form.

3. In the development of standards, the National Highway Traffic Safety Adminstration attempts to evaluate their effects on foreign as well as domestic manufacturers. As you are aware, it is sometimes not possible to reconcile all points of view on a standard, but we would urge you to make every effort to set forth your position on proposed rules during the comment period.

4, 5. Your comments on the proper height for bumpers and the problem of the license plate location have been considered in the context of the rulemaking on Standard No. 215. The amendment issued on June 22, 1971, should serve to lessen the height problem to some degree, and on the basis of present data we regard the height thereby established as reasonable for the overall vehicle population. The share of the license plate itself is determined by the individual states and is not within our authority.

6. The crash characteristics which you suggest for a vehicle's front end seem reasonable, but because they fall beyond the scope of the present rulemaking on Standard No. 215, any consideration of them will have to be deferred. Although we realize that the front seats can supplement the side structure of a car in a side impact, the question as to whether the seats should be retained was considered in the development of the final version of Standard No. 214, and it was determined at that time that the standard would provide a more reliable measure of side strength if the tests were conducted with the seats removed.

The National Highway Traffic Safety Administration is still of that opinion, although it would consider any additional information presented in support of a petition to amend the standard to allow retention of the seats.

7. On the subject of prospective standards, the National Highway Traffic Safety Administration is currently preparing a new version of the program plan for motor vehicle safety standards. The plan is intended to map the course of rulemaking for the next several years, and should serve to answer most of your questions on timing. We expect to announce the new plan in the very near future.

I hope this letter has been responsive to your questions. If not, or if additional questions arise, do not hesitate to ask us.