Interpretation ID: nht72-4.5

DATE: 03/10/72

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Dockets

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: Conversation with Jensen Motors representative on Monday February 7, 1972

Howard D. Panton, Chief Designer for the Jensen Motors Company, met with representatives of NHTSA to discuss rulemaking actions of concern to his company. Representing the NHTSA were Robert Crone, Office of Crashworthiness, and John Womack, Office of Chief Counsel.

The major areas of concern to Jensen are Standard 206, 208 and 214, and the proposed rulemaking on Standard 201.

Standard 206 bears on Jensen's plans to develop a car with gull-wing doors. Their problems with the test procedure are similar to those expressed by Mercedes and they were invited to submit suggestions for changes in the test procedure.

Standard 214 also affects the gull-wing car, which would have a very high sill. The company feels that a test with the ram five inches above the bottom of the door would require then to have an unsatisfactory height for the door structure, with corresponding reduction in the glass area. It was indicated that Jensen's problem could not be met by an interpretation of the standard, and that they would have to seek an amendment of the procedure. Panton indicated that the company would consider doing this.

Standard 208 is of particular concern due to the apparent need for impact testing of several cars. This is said to be a serious problem for a small company (1000 cars a year) with a high cost per car ($ 10,000 plus). The NHTSA representatives indicated that the agency was aware of the problem. On the question of exemption authority, which Jensen considered to be a possible remedy, they were told that the agency no longer has exemption authority but that if such authority were returned to the agency it might be used to give the smaller manufacturers additional time on complex standards if they can establish the need for delay.

The current proposal on Standard 201 concerns Jensen in several ways, most notably with respect to the proposed changes in the windshield header location. They were advised that this requirement is undergoing careful review and that any detailed comments they could make would be welcome.