ID: nht73-6.16

DATE: 02/07/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 31, 1973, in which you asked us to confirm your "understanding that FMVSS No. 121 will not apply to fire-fighting vehicles until 1 September 1976, two years from the effective date." In general, you suggest that "we would expect to comply with FMVSS [for firefighting vehicles] within two years after the effective date or two years from the date of publication of the FMVSS, whichever date occurs later".

You have misread the relevant language of 49 CFR @571.8. That section provides that the effective date of a standard as applied to firefighting vehicles is "either 2 years after the date on which such standard or amendment is published in the Rules and Regulations section of the Federal Register, or the effective date specified in the notice, whichever is later", except as otherwise specified in the standard with reference to those vehicles. The alternatives are thus (a) 2 years after the publication date, or (b) the effective date, whichever is later -- not 2 years after the effective date, as you have read it.

Your reading would not be reasonable; since the effective date cannot be before the publication date, there would be no point to the alternative phrasing.

ID: nht73-6.17

DATE: 04/06/73

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Volkswagen of America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 2, 1973, regarding the classification of the Volkswagen Model 181 (The VW Thing) for purposes of the Federal Motor Vehicle Safety Standards.

Based on a review of your letter and its enclosures, we accept your classification of the Model 181 as a Multipurpose Passenger Vehicle.

Sincerely,

VOLKSWAGEN OF AMERICA, INC.

April 2, 1973

Francis Armstrong, Director National Highway Traffic Safety Administration

Re: N41-22GSh

This is in response to your letter of March 19, 1973 directed to Mr. Crawford Shaw in which you requested the submission of satisfactory evidence that would support our classification of the Volkswagen Model 181 (The VW Thing) as a Multipurpose Passenger Vehicle.

Upon receipt of your letter, we arranged for a meeting with you and your staff which was held in your office on March 29, 1973. At this meeting, we presented information relevant to the fact that the VW model 181 is equipped ". . . . with special features for occasional off-road operations . . . . " as is required by the definition of a Multipurpose Passenger Vehicle. The following submission enumerates the features of the VW 181.

VEHICLE HISTORY

This vehicle was originally designed in the early 1960's under contract for the German Government. A major consideration in the design concept was the requirement by the army for rough terrain operation and associated vehicle specifications. The availability of the vehicle was originally limited to the army but subsequently, after sufficient production capacity was gained, availability was extended to the general public in Europe. Most recently, the entire world production has been centralized in Mexico and vehicles are exported back to Europe and also now to the U.S.A.

2

VEHICLE FEATURES

The following is a description of the vehicle including a comparison in some respects to our VW Beetle models so as to differentiate between typical passenger car specifications.

The BODY DESIGN is both rugged and functional, void of cosmetic details, with maximum consideration given to the extremes of hard usage found off road rather than to comfort and decor. The sloping front hood provides excellent forward visibility, an aid in negotiating hill crests. Generous clearance between the fenders and the tires is provided for accommodating extreme suspension travel and preventing entrapment of foreign objects. A folding soft top, removable side curtains and a folding windshield provide for operation in extremes of weather and possibly for negotiating areas of minimal overhead clearance. The folding feature of the rear seats provide a compartment of seventeen cubic feet capacity for cargo carrying.

Special off-road features are:

1. Standard tires of 185 R 14 M & S (Mud and Snow) with tube mounted to a five inch wide rim. The coarse tread profile provides versatility on all surface types. This compares to our normal Beetle tire of 6.00x150, tubeless, mounted to a 4 1/2 inch rim.

2. Ground clearance of 8.1 inches as compared to normal Beetle dimension of 5.9". For additional comparison our VW 412 model has a ground clearance of 5.3" and typical domestic models average approximately 5.0". Ground clearance of competitive off-road vehicles is in the range of 7 to 8".

3. Angle of Approach of 36 degrees and Angle of Departure of 31 degrees gives favorable grade negotiating ability without interference in the area of the vehicle overhang. For both domestic and import passenger cars, the angle of approach is in the range of 17 degrees to 25 degrees and the angle of departure from 11 degrees to 21 degrees.

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4. An additional specification, unique to this model, is the "Wading or Fording Depth" which is 15.6 inches. This dimension constitutes the water depth through which this vehicle can be driven without danger. Typical passenger cars are not capable of such activity nor is such a dimension specified.

5. An engine protection shield is provided under the vehicle to minimize the chance of damage in the lower crankcase area. Also, an additional shield is provided for the Exhaust Gas Pecirculation filter, a part of the emission control system provided for the U.S.A. model.

6. Towing eyes are provided, mounted in the bumper, two front and two rear, for attachment of a tow line.

7. The overall Transmission/Final Drive gear ratios are lower as compared to the Beetle for improved low speed performance. Hill climbing ability is approximately 15% improved over that of the Beetle, measured on a paved roadway.

8. The chassis employed is a derivative of our platform design, however, reinforcement in the area of the suspension mounting is added. Reinforcement struts from the front torsion tubes to the chassis prevent damage in high load conditions. The front and rear axle loads are respectively 1212/1764 lb. as compared to 1080/1609 lb. of the Beetle.

9. The engine equipped is identical to that of our Beetle model except for minor changes in emission control techniques. However, the air cleaner is a very large capacity oil bath type which aids in reducing dust intake in off-road activities.

Enclosed for your information is a List of Technical Specifications (Exhibit 1) and a copy of the Owner's Manual (Exhibit 2) for the U.S.A. model 181.

4

In our meeting with you, some discussion centered around the providing of four-wheel drive in an off-road vehicle. In the VW 181 with its low curb weight (1995 lb.), rear weight bias, and four-wheel independent suspension, we find no need for four-wheel drive. In our own comparative research, we have in some instances found the 181 to have a distinct advantage over other, much heavier, four-wheel drive vehicles. Also, it is interesting to note that vehicles such as the Chevrolet Blazer, IHC Scout and the Jeep DJ-5 are available with two wheel drive standard and four-wheel drive optional at extra cost.

Additionally of interest, the National Off Road Racing Association (NORRA) is a sanctioning body of many off road race events in the U.S., including that taking place in the Baja area of Lower California. They have clearly recognized the respective capabilities of both two wheel and four wheel drive vehicles by providing competitive classes for both.

Enclosed is a copy of an article that was published in the March 1973 issue of MOTOR TREND Magazine (Exhibit 3). The thoughts of the writers illustrate the capabilities of the vehicle and only illuminate the enthusiasm that has been and will be generated by this vehicle inthe off-road, recreational vehicle market.

In a report of the National Traffic Safety Agency on the development of the initial Federal Motor Vehicle Safety Standard published in Washington, D. C. on March 17, 1967, the Agency set forth the history of its standard setting process and the specific considerations that entered into the selection of the options that were ultimately incorporated into the law. As in many other standard areas, the Agency felt that a number of options were open to it in dealing with the problems presented by special purpose vehicles. The report of March 17 records the discussions within the Agency (Exhibit 4).

It is fair to conclude, in our opinion, that by introducing the definition of MPV, the Agency recognized that some passenger type vehicles present special problem in meeting the passenger car standards and should, therefore, not be required to comply with all of them. The report also makes it clear that the Agency is thinking primarily of jeep and van type vehicle that would fall into that category since both are essentially used as passenger cars but have also features that make them suitable for "carrying of goods" or "cross-country travel over rough terrain."

5

You have also requested clarification of the text of the certification label. We have been informed by the factory that the label text does contain the proper reference to "Gross Axle Weight Rating" and "Gross Vehicle Weight Rating". We do not have a sample of the actual certification label at this time, but will forward one to you shortly. For reference at this time, page two of the enclosed Owner's Manual contains a facsimile of the certification label as it will appear in the vehicle.

In conclusion, the facts set forth herein firmly support our classification of the VW model 181 as a Multipurpose passenger vehicle, in that it is equipped with special features for occasional off-road operations. Competitive vehicles, as Jeeps, Land Rovers, and Broncos may be slightly different from the model 181 in their configurations and offer four wheel drive as an extra cost option, but are very much identical to the model 181 in terms of performance and suitability for off-road use.

We look forward to receiving your early reply and extend the invitation to completely examine an actual vehicle, at your convenience, at our facility in Englewood Cliffs. If any additional questions should arise, please contact me directly by telephone at the number below.

Sincerely yours,

Guenter Storbeck

[Enclosures Omitted.]

ID: nht73-6.18

DATE: 03/02/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Ford Motor Company

COPYEE: J. G. WOMACK; MR. TOMS; MR. HARTMAN; MR. CARTER

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 16, 1973, concerning the safety standard applicable to the sling for the upper torso belt used in Ford's 1974 model restraint system.

The schematic drawing attached to your letter shows that the sling attaches to the roof rail and serves the function of an upper torso belt anchorage. We agree with you that the sling is subject to the requirements of Standard No. 210 and not to the requirements of Standard No. 209. Although the sling is made of fabric webbing, its function is that of an anchorage and it is therefore subject to the anchorage standard.

Yours truly,

Ford Motor Company

February 16, 1973

Douglas W. Toms Administrator National Highway Traffic Safety Administration

Dear Mr. Toms:

An inquiry has been raised by certain of our suppliers with regard to one feature of Ford's 1974 model year restraint system. Ford believes an interpretative statement by the Administration would be desirable to resolve questions that now exist, or may in the future arise, with regard to this type of item.

The attached schematic shows a typical 1974 Ford restraint system. The non-detachable upper torso portion of the restraint system is looped through a "sling" attached to the roof rail of the vehicle. The "sling" is depicted in more detail in View-A of the attached drawing.

This sling is an an anchorage for purposes of Standard No. 210 for several reasons. First, Standard No. 210 defines a seat belt anchorage as the provision for transferring seat belt assembly loads to the vehicle structure. The sling clearly serves this function. Second, as the sling location determines the angle at which the upper torso restraint crosses the occupant's chest, the sling would fall within the acceptable range for upper torso anchorage locations specified in Standard No. 210.

As we have chosen to use webbing in the sling (as opposed to a cable or some such material), the concern expressed involves the question as to whether a potential conflict could arise in interpreting what requirements this sling must meet. If the sling were to be considered by an independent testing laboratory to be part of the seat belt assembly as defined in Standard No. 209, it would apply the

webbing requirements set forth in Section S4.2 of Standard No. 209 to the sling webbing. We would urge that it should not be necessary to meet these webbing requirements as the sling is part of the anchorage and meets the strength requirements of Standard No. 210.

We request, therefore, that the Administration concur in Ford's interpretation that the sling as depicted in the attached schematic is a part of the anchorage and not a part of the seat belt assembly.

Respectfully submitted,

J. C. ECKHOLD

Director

Automotive Safety Office

Attachment

(Graphics omitted)

(Graphics omitted)

FORD-MERCUPY MODEL 65 SHOWN

TORINO-MONTEGO-COUGAR

T-BIRD-MARK IV-LINCOLN

MODELS 65 TYPICAL

ID: nht73-6.19

DATE: 05/22/73

FROM: AUTHOR UNAVAILABLE; James E. Wilson; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: By petition for rulemaking dated November 15, 1973, the Ford Motor Company requested an amendment of Motor Vehicle Safety Standard No. 210 with respect to the strength required of the anchorages for the pelvic portion of a Type 2 seat belt assembly. After considering the merits of the requested amendment, we have decided to deny your petition.

As stated in your petition, the anchorages for the pelvic portion of a Type 2 assembly are presently subject to two strength requirements under Standard 210. Section S4.2.2 provides that, when tested in conjunction with the upper torso anchorage, the pelvic anchorages must withstand a force of 3,000 pounds applied through the seat belt assembly. Section S4.2.1 provides that, when tested separately from the upper torso anchorage, the pelvic anchorages must withstand a force of 5,000 pounds applied through the seat belt assembly.

It is Ford's position that the 5,000 pound requirement of S4.2.1 was intended to be applicable to anchorages used with Type 2 assemblies having detachable shoulder belts, and that it was not intended for use with integral Type 2 assemblies. Although the NHTSA would agree that the most widely used Type 2 assembly at the time of the standard's adoption had a detachable shoulder belt, the agency does not agree that the 5,000 pound requirement should be limited to anchorages used with such belts.

The 1974 model year will be the first in which integral Type 2 belts are installed in all passenger cars. We anticipate that a measurable percentage of persons riding in cars with the new belts will somehow avoid using the shoulder belt, thereby placing

the lap belt under the same potential stress as any other lap belt when used by itself. In light of this possibility, and in consideration of the fact that keeping the pelvic anchorage force at the currently required level of 5,000 pounds will not impose additional manufacturing costs on manufacturers, we do not consider it advisable to grant the requested amendment at this time.

The petition of Ford Motor Company for an amendment of S4.2.1 of Motor Vehicle Safety Standard No. 210 and for a complementary amendment to the test procedures of S5.1 of the standard is therefore denied.

November 15, 1972

Douglas W. Toms Administrator National Highway Traffic Safety Administration

Re: Petition for Amendment of Federal Motor Vehicle Safety Standard No. 210 - Seat Belt Assembly Anchorages

Ford Motor Company, with offices at The American Road, Dearborn, Michigan 48121, as a domestic manufacturer of motor vehicles, hereby submits this Petition for Amendment of Federal Motor Vehicle Safety Standard No. 210 - Seat Belt Assembly Anchorages (hereinafter "the Standard"). This Petition is filed pursuant to Section 553.31 of the procedural rules of the National Highway Traffic Safety Administration.

The purpose of this Petition is to request an amendment to S4.2.1 and S5.1 of the Standard that would eliminate the requirement of applying a 5000-pound force to the anchorages of the pelvic portion of a Type 2 seat belt assembly with a non-detachable upper torso portion. Sections S4.2.2 and S5.2 of the Standard adequately cover the anchorage loading for such a Type 2 seat belt assembly. This 5000-pound test criteria was developed originally for seat belt restraint systems that were independent of upper torso restraints and is still applicable to such systems as well as those that include a detachable upper torso belt system.

Ford Motor Company plans to incorporate non-detachable upper torso straps as required by S4.1.2.3 of Federal Motor Vehicle Safety Standard 208 in its 1974 model vehicles. The present requirements of Federal Motor Vehicle Safety Standard 210 cause the restraint system to be dismantled before it can be tested, resulting in redundant and unnecssary tests and, therefore, are not practicable for this type of restraint system.

Ford test and development programs for these vehicles are now at that point where prototype bodies incorporating 1974 restraint system component designs are available for tests according to Federal Motor Vehicle Safety Standard 210 demonstration procedures to determine that design levels are appropriate for production tooling. We urge your prompt attention to this matter to assure that our current product programs are not affected.

Respectfully submitted,

J. C. Eckhold

Director, Automotive Safety Office

ID: nht73-6.2

DATE: 03/01/73

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Michigan Law Review

COPYEE: MR. VINSON

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your undated letter to the National Highway Safety Bureau (since December 31, 1970, the National Highway Traffic Safety Administration) concerning Federal motor vehicle safety standards intended to protect the pedestrian and cyclist.

You ask when Standard No. 211 Wheel Nuts, Wheel Discs and Hub caps was proposed and enacted. This standard was one of the Initial Federal standards proposed late in 1966 and issued in late January 1967 effective January 1, 1968, as to original and replacement equipment. This date is almost four months earlier than the date of the accident in Passwaters v. General Motors Corp., 454 F. 2d 1270 (1972) and thus there is no connection between the two. Standard No. 211 derives from a Swedish standard on vehicle exterior protrusions. Eventually we hope to have a definitive standard on exterior protrusions (incorporating Standard No. 211) intended to prevent serious injury to a pedestrian during the initial impact with the vehicle and to control his trajectory to reduce the severity of secondary impacts. The rule would specify impact force distribution and response requirements for exterior vehicle surfaces.

Our initial rulemaking effort in this area was the issuance of an advance notice of proposed rulemaking establishing Docket No. 2-5, published October 14, 1967, (32 F.R. 14278) asking for general comments on size, shape, location, and sharpness of vehicle corners and edges. At the present time, proposals for research to establish threshold-of-injury data and to investigate techniques for reducing injury are being developed. On the basis of this data we will propose a standard on pedestrian protection. Under our current plans, the final standard would be issued late in 1975 with an effective date of September 1, 1990. We also plan to issue a standard on motorcycle rider protection systems around February 1, 1974, with an effective date of January 1, 1975. The agency's standard on motorcycle headgear, under current plans, will be issued around June 1, 1973, with an effective date of September 1, 1974.

ID: nht73-6.21

DATE: 02/15/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 4, 1973, concerning your continuing uncertainties about the intent of sections S4.3.1.1 and S4.3.1.3 of Standard 210.

In your figure 1, assuming the seat is not adjustable, the contact points would be (b) in the first drawing and (c) in the second. However, a rigid attachment of the length shown in the second drawing would appear to violate the intent of S4.3.1.1 that the angle formed by the webbing in passing from the hardware to the seating reference point should be a forward angle.

In your figure 2, if the bracket can be rotated so that an extension of its centerline would pass through the seating reference point, we would consider point (p) to be the nearest contact point for purposes of S4.3.1.1 and S4.3.1.3.

With respect to the proposed used of a flexible wire, as shown in figure 3, the ability of the wire to move with reasonable freedom removes it from the category of rigid hardware. We would consider the points shown as (c) and (f) to be the appropriate contact points for purposes of S4.3.1.1 and S4.3.1.3.

January 4, 1973

Lawrence Schneider National Highway Traffic Safety Administration

Although we have received and appreciated your interpretation of MVSS 210, S4.3.1.1, and S4.3.1.3, Seat Belt Anchorages, this matter remains rather vague to us. Please permit us to restate the situations in question.

We would like to use the seat belt system in which the buckle is attached to the floor panel (tunnel) or seat structure by a rigid bracket as indicated in the enclosed Figure 1. In this situation, please advise us of the correct nearest contact point and angle in each of the attached drawings.

If the rigid bracket with buckle is able to rotate about point "P", as shown in Figure 2, please advise us where we should consider the nearest contact point and angle.

We are also considering using another type of seat belt system, as shown in Figure 3, in which the buckle is attached to the floor panel through the flexible wire. Again, please indicate the exact nearest contact point and angle.

Thank you for your kind assistance.

Tatsuo Kato Engineering Representative Liaison Office in USA Enclosures

The nearest contact point: (A) or (B)?

The angle: 20 degree SEATING REFERENCE POINT

WEBBING

HORIZONTAL LINE

TONGUE

BUCKLE

RIGID BRACKET FIXED TO FLOOR PANEL OR SEAT STRUCTURE

SEATING REFERENCE POINT

THE NEAREST CONTACT POINT: (C), (D) or The angle: 20 degree [Graphics Omitted]

FIGURE 1

RIGID BRACKET

POINT "P"

[Graphics omitted]

FIGURE 3

The nearest contact point: (A), (B) or (C)? The angle: 20 degree SEATING REFERENCE POINT

BUCKLE

FLEXIBLE STEEL WIRE

[Graphs Omitted]

BUCKLE

SEATING REFERENCE POINT The nearest contact point: (D), (E), or (F)? The angle: 20 degree <ODY>

ID: nht73-6.22

DATE: October 26, 1973

FROM: Richard B. Dyson -- Assistant Chief Counsel, NHTSA

TO: Brian Gill -- Assistant Manager, Safety & Environmental Activities, American Honda Motor Company

TITLE: None

ATTACHMT: Attached to letter dated 12-24-90 to Stanley S. Zinner from Paul Jackson Rice (A37; Std. 123); Also attached to letter dated 12-4-90 to Paul Jackson Rice from Stanley S. Zinner (OCC 5479); Also attached to letter dated 2-16-82 to Brian Gill from Frank Berndt (Std. 123)

TEXT:

This is in reply to your letter of 0ctober 9, 1973, to Mr. Vinson of this office asking whether S5.2.5 of Standard No. 123 requires footrests to fold automatically when not in use.

The standard does not require automatic folding. S5.2.5 states only the direction in which footrests shall retract, so that if they are inadvertently left down when not in use they will fold rearward and upward should they hit an obstacle while the motorcycle is travelling forward.

ID: nht73-6.23

DATE: December 10, 1973

FROM: Richard B. Dyson -- Assistant Chief Counsel, NHTSA

TO: Robert R. Aronson -- President, Electric Fuel Propulsion Corp.

TITLE: None

ATTACHMT: Attached to letter dated 11-26-73 from Robert R. Aronson to Lawrence Schneider (Chief Counsel, NHTSA)

TEXT:

This is in reply to your letter of November 26, 1973, inquiring about the applicability of Standard No. 301 to your vehicles' gasoline-powered water heaters.

Standard No. 301 was promulgated in order to reduce the incidence of deaths and injuries resulting from fuel-related fires. The standard seeks to accomplish this end by specifying performance requirements which must be met by a motor vehicle's fuel system. Although the fuel systems primarily regulated by the standard are those which propel the vehicle, nothing in the standard limits its application to those systems. A fuel system which powers another aspect of the vehicle's operation, such as the gasoline- powered Stewart Warner Water Heater, is susceptible to the same hazards as the more commonly encountered fuel system, and thus they must be regulated in the same manner in order to fulfill the purposes of Standard No. 301.

In summary, the 2-quart fuel tank to which you refer is subject to the requirements of Standard No. 301.

ID: nht73-6.24

DATE: November 26, 1973

FROM: Robert R. Aronson -- President, Electric Fuel Propulsion Corp.

TO: Lawrence Schneider -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12/10/73 from Richard B. Dyson to Robert R. Aronson

TEXT:

In reference to FMVSS 301, our electric cars are equipped with a 2-quart gasoline tank which powers a Stewart Warner Water Heater for heating and defrosting cars. The location of the gas tank and heater is in the rear of the car.

Please let us know if Standard 301 applies to this gas tank.

ID: nht73-6.3

DATE: 11/14/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Rolls-Royce Motors Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 16, 1973, requesting a clarification of S7.2 of Federal Motor Vehicle Safety Standard No. 301 (9-1-75) (Docket No. 70-20; Notice 2).

As you are aware, a proposed amendment to Federal Motor Vehicle Safety Standard No. 301 (9-1-75) was published on August 20, 1973 with an anticipated September 1975 effective date (Docket No. 73-20; Notice 1). In the event that the proposed amendment of loading conditions is adopted, the present passenger car requirement, that the vehicle be at its GVWR during testing, will be superseded by the requirement that the passenger car be loaded "to its unloaded vehicle weight plus its rated cargo and luggage capacity weight, secured in the luggage area, plus the weight of the necessary dummies." Under these specifications, rear seat occupant weight will not be a factor of the test load condition unless a specific test requirement calls for dummies to be placed in designated rear seating positions. The proposed amendment would also make it unnecessary to firmly fix the dummies to the vehicle as is presently the case under S7.2.

We have also noted your views on luggage capacity weight and are placing your letter in Docket No. 73-20 as a comment to be considered.

If you require any further clarification, please do not hesitate to let us know.

OCTOBER 16, 1973

The Administrator National Highway Traffic Safety Administration,

Dear Sir,

49 CFR, PART 571 Docket No. 70-20; Notice 2 Standard No. 301 - Fuel System Integrity

Rolls-Royce Motors Limited seeks clarification on the meaning of S 7.2 as published in the Federal Register 38 FR 22397, dated August 20, 1973.

S 7.1 requires the vehicle under test to be loaded to its GVWR and S 7.2 requires weight in excess of the unloaded vehicle weight to be firmly fixed to the vehicle so that it absorbs no significant portion of the vehicle's Kinetic energy.

It seems to us that the only way in which the added weight can absorb the vehicle's Kinetic energy is by actual deformation of the weight itself. Thus, it would be unacceptable to apply added weight which would reinforce the front structure of the vehicle. This would be entirely logical with a front engined vehicle, but would pose serious problems with a rear engined vehicle in which the luggage compartment was at the front of the vehicle. Would there not be practical difficulties in achieving the correct weight distribution, and is it not reasonable for the designer to intend the luggage in these circumstances to absorb some of the vehicle's Kinetic energy, particularly that due to its share of the total mass, when the vehicle is loaded to its GVWR?

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Rolls-Royce Motors Limited does not make vehicles with luggage stowage capacity at the front, so that particular problem is of no immediate concern to us at this moment. We would, however, be very concerned if the conditions of S 7.2 were to be applied to any future rear barrier crash test, and hence our interest in seeking clarification. Our own suggestion would be to omit the luggage weight from the vehicle test weight, while a specification is drawn up for inexpensive test pieces representing more closely the density and crush characteristics of real life passenger luggage. Such test pieces would be stowed in the luggage compartment but not secured to the vehicle structure, again representing more closely real life conditions.

Docket No. 73-20, Notice 1. proposes an amendment to Standard No. 301, effective September 1975, which would permit the installation of dummies in the front outboard seating positions. It is not clear to us how the weight of the rear seat occupants is to be provided when ballasting the vehicle up to its GVWR. We sincerely hope that S 7.2 of Docket No. 70-20, Notice 2, will not be interpreted to mean that the added weight due to rear seat passengers must be rigidly attached to the vehicle. For obvious economic reasons, which are of vital importance to the low volume manufacturer, we would want to combine testing against Standard No. 301 with testing against other Standards, such as No. 208, and S 5.1 of Standard No. 208 requires anthropomorphic test devices to be installed at each designated seating position. The restraint systems used for these dummies to demonstrate compliance with Standard No. 208 could not be described as rigid.

We should, therefore, be most grateful if you could clarify the requirements of S 7.2 of Standard No. 301 regarding the means to be used for installing additional weight to bring the test vehicle up to its GVWR.

Yours faithfully,

J. B. H. Knight Chief Development and Car Safety Engineer

Copies to: Trevor Williams Rolls-Royce Motors Inc. New Jersey.

K. B. Barnes The Society of Motor Manufacturers & Traders Ltd. London.