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.

ID: nht87-3.54

TYPE: INTERPRETATION-NHTSA

DATE: DECEMBER 30, 1987

FROM: HERBERT E. STOEL

TO: KEN SIKKEMA -- STATE REPRESENTATIVE

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-8-90 TO HERBERT E. STOEL FROM

STEPHEN P. WOOD; (A35; STD. 108). ALSO ATTACHED TO LETTER DATED 2-1-90 TO JOHN WOMACK FROM HERBERT E. STOEL; (OCC-4406) TEXT:

SUBJECT Greater safety on our highways is needed. There are too many accidents on our highways today and now with the new 65 M.P.H. speed limit that number could increase, so it is high time that we do something about it. CONFUSION Our present method of Red Taillights and Red Stoplights on our cars is not a good system; for example, our traffic

lights at street intersections do not have two red lights for go and then add one or more to make three red lights for stop. No we have green lights for go, and red lights for stop. But on our cars, taillights and stoplights are all Red. SOLUTION RED should only mean ONE thing, that is STOP.

EXAMPLE When driving down a busy highway (especially at night) and there is a line of cars, all you can see is RED - RED - RED from all the rear lights on cars, and so when an emergency arises and the cars up front apply the brakes and one or two more red brake lights come on there is very little noticeable change for all you see is RED - RED - RED. So there is need for a better system to alert the oncoming drivers of the danger up front. In that way they have more time to brake and avoid collisions, injuries and often death. SOLUTION RED should only mean ONE thing, that is STOP.

SUGGESTION Have the taillights on cars Green and the stoplights, Red - STOP. FINALLY Inasmuch as Michigan is an Auto Industry State, why should we not be the state to introduce a better system to the

car manufacturers of the nation. With the thousands of injuries and deaths each year, why should we wait any longer to make a much needed improvement.

ID: aiam3826

Dear Mr. Clark: This is in response to your letter of March 5, 1984 in which yo request the opinion of the National Highway Traffic Safety Administration (NHTSA) regarding whether you are permitted, under the Federal Odometer law (Title IV of the Motor Vehicle and Cost Savings Act, 15 U.S.C. S1981, *et seq*.), to turn the odometers, on the restored vintage automobiles which you sell, back to zero. It is the opinion of this agency that you may not.; Section 404 of the Act, 15 U.S.C. S1984, makes it unlawful for an person to 'disconnect, reset, or alter or cause to be disconnected, reset, or altered, the odometer of any motor vehicle with intent to change the number of miles indicated thereon.' The term odometer means an instrument for measuring and recording the actual distance a motor vehicle travels while in operation. Although each motor vehicle which you sell has been restored and although each may be, as you claim, 'better than it was as a new car', the odometers must continue to reflect the actual miles which these vehicles have travelled.; The Federal odometer law also requires that a written disclosure of th mileage registered on the odometer by provided by the seller of a motor vehicle to the purchaser at the time ownership of the vehicle is transferred. If the odometer mileage is incorrect, the Act requires that the purchaser be furnished with a written statement to that effect. 15 U.S.C. 1988, 49 C.F.R. S580.4. All dealers and distributors of motor vehicles are required to retain a copy of each odometer disclosure statement which they issue or receive. These statements are to be retained for four years at their principal place of business. 49 C.F.R. S580.7.; NHTSA found, however, that the value of antique vehicles is determine not by the number of miles travelled by such vehicles, but rather by their age, condition and scarcity. The Agency therefore exempted from the odometer disclosure requirements of section 580.4, vehicles which are 25 years old or older. 49 C.F.R. S580.5(a)(3). NHTSA also exempted from these requirements, vehicles having a gross vehicle weight rating (GVW) of more than 16,000 pounds, S580.5(a)(1), and vehicles which are not self- propelled, S580.5(a)(2). Please note that these are exemptions from the odometer disclosure requirements only. They do not permit tampering with the odometer.; Before you decide whether or not to issue odometer disclosur statements for the 25 years old and older vehicles which you sell, however, you should consider that at least two Federal District Courts have declared the exemptions to be void. The courts found that NHTSA had exceeded its authority in fashioning exemptions to the odometer disclosure requirements. *Lair v. Lewis Service Center*, 428 F.Supp. 778 (D.Neb. 1977), *Davis v. Dils Motor Company*, 566 F.Supp. 1360 (S.D.W.Va. 1983). These cases did not address the validity of the exemption of 25 year old and older vehicles. They addressed instead the validity of the exemption of vehicles having a GVW of more than 16,000 pounds. Their finding, however, that the Agency lacked authority to create the exemptions, may equally apply to this case.; Their findings are not binding on other courts, and the Agenc continues too believe that the exemptions it created are valid. It is important that you consider these decisions, however, since another court could find them well-reasoned or persuasive, and follow the findings that they reached.; If you have additional questions regarding the requirements of th Federal odometer law, please call Heidi Lewis Coleman of my staff at (202) 426-2992 or write to her attention.; Sincerely, Frank Berndt, Chief Counsel

ID: 1767y

Mr. Richard L. Story, Sr.
34855 Annapolis Ave.
Wayne, MI 48184-2133

Dear Mr. Story:

This responds to your letter asking whether manufacturers are required to install rear seat lap/shoulder belts in cars originally equipped with rear seat lap belts at no additional cost to the consumer. The answer to this question is no.

The lap belts that are installed in the rear seat of your car are effective in reducing the risk of death and injury in a crash. Based on this agency's analysis of a number of crash data files, we estimate that rear seat lap belts saved about 100 lives and prevented over 1500 serious injuries in 1987 alone. These figures would have been substantially higher if more rear seat occupants used their lap belts. In fact, if everyone had worn their rear seat lap belts each time they rode, those belts would have saved about 660 lives and prevented more than 10,000 serious injuries in 1987 alone.

Even though lap belts have been proven to be effective in reducing the risk of death and injury in a crash, we agree that properly designed lap and shoulder belts have the potential to offer even greater crash protection than lap belts alone. For this reason, we have proposed to require that all new passenger cars sold in the United States be equipped with rear seat lap and shoulder belts beginning in the 1990 model year. For cars made in earlier model years, we have actively sought the car manufacturers' cooperation in providing retrofit kits to interested consumers. You indicated in your letter that Ford offers a rear seat lap and shoulder belt retrofit kit for your car, the 1988 Thunderbird.

We encourage consumers to consider having rear seat lap and shoulder belts fitted into their cars when manufacturers have made a retrofit kit available for the car, because of the additional crash protection afforded to rear seat passengers. However, NHTSA has no authority to require manufacturers to provide these retrofit kits and installation free of charge to the consumer. Thus, the individual consumer who desires the added protection of lap and shoulder belts in the rear seat will have to pay for that additional protection.

I hope this information is helpful. If you have any further questions or need additional information on this subject, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

/ref:208 d:4/3/89

ID: nht88-4.3

TYPE: INTERPRETATION-NHTSA

DATE: NOVEMBER 7, 1988

FROM: CLARENCE M. DITLOW III -- CENTER FOR AUTO SAFETY EXECUTIVE DIRECTOR

TO: ERIKA Z. JONES -- CHIEF COUNSEL-NHTSA

TITLE: NONE

ATTACHMT: DECEMBER 12, 1988 LETTER FROM JONES TO DITLOW

TEXT: Your November 1 letter refusing to question General Motors' failure to provide retrofit rear shoulder belts for 9 million cars reflects such callous disregard for human life and ignorance of the facts as to defy belief that you are doing little more than covering up for a GM policy that will kill rear seat passengers.

First, you totally ignore the fact that GM is actively discouraging consumers from installing shoulder belts in 9 million cars by telling them the shoulder belt offers no added safety protection over the lap belt alone. What possible scientific basis is there for such a statement, particularly when GM's chief seatbelt effectiveness expert, Leonard Evans, concludes that shoulder/lap belts are more than twice as effective as lap belts alone in preventing fatalities. If rear lap belts are as effective as shoulder/lap belts, then why is NHTSA proposing to require shoulder belts in rear seats?

Second, you condone GM's actions to discourage installation of rear shoulder belts by trivalizing 9 million cars as "a few of its past models." I assure you that the millions of people who ride with their lives at greater risk in the rear seats of these cars deserve far more respect than you show them.

Third, NHTSA's voluntary program to make retrofit shoulder belts available is in shambles. Not a day goes by without CAS receiving complaints from consumers about dealers refusing to install shoulder belts in rear seats. GM encourages this withholding of lifesaving shoulder belts by alleging there is research that adding shoulder belts doesn't save lives. Telling people that shoulder belts do not save lives clearly frustrates NHTSA's policy of encouraging retrofits.

Fourth, the only substantive statement in your response was that NHTSA does not have the statutory authority to mandate the availability of retrofit shoulder belts. This is nothing more than a strawman argument as my September 9 letter never said NHTSA has the statutory authority to mandate retrofit kits. But in view of the greater effectiveness of shoulder belts and the increased use of rear lap belts which cause death in some accidents, the question arises as to why NHTSA doesn't ask Congress for su ch authority?

Your substantive response to the questions raised in these letters is welcomed.

ID: 3274yy

Mr. Takashi Odaira
Chief Representative
Emission & Safety
Isuzu Technical Center of America, Inc.
46401 Commerce Center Drive
Plymouth, MI 48170

Dear Mr. Odaira:

This responds to your letter asking about the new dynamic requirements of Safety Standard No. 214, Side Impact Protection. You noted that the rear seat requirements do not apply to passenger cars which have rear seating areas that are so small that the Part 572, subpart F dummies cannot be accommodated according to the specified positioning procedure. You asked whether a test dummy should nonetheless be placed on the rear seat of such vehicles when conducting the specified dynamic test. As discussed below, the answer to your question is no.

Section S3 of Standard No. 214 includes the following language concerning the dynamic side impact requirements:

Part 572, subpart F test dummies are placed in the front and rear outboard seating positions on the struck side of the car. However, the rear seat requirements do not apply to passenger cars with a wheelbase greater than 130 inches, or to passenger cars which have rear seating areas that are so small that the part 572, subpart F dummies cannot be accommodated according to the positioning procedure specified in S7.

Reading these two sentences together, it is our interpretation that a test dummy should not be placed in the rear outboard seating position of passenger cars which have rear seating areas that are so small that the part 572, subpart F dummies cannot be accommodated according to the positioning procedure specified in S7. While the first sentence states that the test dummies should be placed in both the front and rear outboard seating positions on the struck side of the car, that provision is limited by the sentence which immediately follows. That second sentence makes it clear that the rear seat requirements do not apply to certain vehicles with small rear seating areas. Since the sole purpose for placing a test dummy in the rear outboard seating position is to measure compliance with the dynamic side impact requirements, a test dummy should not be placed in the rear seating position of a passenger car for which the rear seat requirements do not apply.

I hope this information is helpful. If you have further questions, please contact Edward Glancy of my staff at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel /ref: 214 d:1/14/92

ID: nht92-9.52

DATE: January 14, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Takashi Odaira -- Chief Representative, Emission & Safety, Isuzu Technical Center of America, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 11/7/91 from Takashi Odaira to Paul Jackson Rice (OCC 6643)

TEXT:

This responds to your letter asking about the new dynamic requirements of Safety Standard No. 214, Side Impact Protection. You noted that the rear seat requirements do not apply to passenger cars which have rear seating areas that are so small that the Part 572, subpart F dummies cannot be accommodated according to the specified positioning procedure. You asked whether a test dummy should nonetheless be placed on the rear seat of such vehicles when conducting the specified dynamic test. As discussed below, the answer to your question is no.

Section S3 of Standard No. 214 includes the following language concerning the dynamic side impact requirements:

Part 572, subpart F test dummies are placed in the front and rear outboard seating positions on the struck side of the car. However, the rear seat requirements do not apply to passenger cars with a wheelbase greater than 130 inches, or to passenger cars which have rear seating areas that are so small that the part 572, subpart F dummies cannot be accommodated according to the positioning procedure specified in S7.

Reading these two sentences together, it is our interpretation that a test dummy should not be placed in the rear outboard seating position of passenger cars which have rear seating areas that are so small that the part 572, subpart F dummies cannot be accommodated according to the positioning procedure specified in S7. While the first sentence states that the test dummies should be placed in both the front and rear outboard seating positions on the struck side of the car, that provision is limited by the sentence which immediately follows. That second sentence makes it clear that the rear seat requirements do not apply to certain vehicles with small rear seating areas. Since the sole purpose for placing a test dummy in the rear outboard seating position is to measure compliance with the dynamic side impact requirements, a test dummy should not be placed in the rear seating position of a passenger car for which the rear seat requirements do not apply.

I hope this information is helpful. If you have further questions, please contact Edward Glancy of my staff at (202) 366-2992.

ID: 86-5.8

TYPE: INTERPRETATION-NHTSA

DATE: 09/02/86

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for Erika Z. Jones; NHTSA

TO: Mr. Andrew A Kroll

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Andrew A. Kroll 1401 East Girard, 1270 Englewood, Colorado 80110

Dear Mr. Kroll:

This responds to your letter requesting an interpretation of Standard No. 109, New Pneumatic Tires Passenger Cars (49 CFR S571.109). Specifically you asked whether that standard is applicable to foam-filled passenger car tires that do not have any air in the inner tire cavity. Standard No. 109 does not apply to foam-filled passenger car tires.

Section S2 of Standard No. 109 specifies that "this standard applies to new pneumatic tires for use on passenger cars manufactured after 1948." In section S3 of the standard, the term "pneumatic tire" is defined as "a mechanical device made of rubber, chemicals, fabric and steel or other materials, which, when mounted on an automotive wheel, provides the traction and contains the gas or fluid that sustains the load" (emphasis added). Thus the relevant question is whether the foam filling the tires in question is considered a "gas or fluid". In a February 14, 1975 letter to Mr. J.F. Hutchinson, NHTSA stated that foam-filled tires "should not be considered pneumatic tires." This conclusion means that foam-filled tires for use on passenger cars are not subject to the requirements of Standard No. 109.

One result of this determination is that foam-filled tires can not be installed as original equipment on any new passenger car Standard No. 110, Tire Selection and Rims (49 CFR S571.110) sets forth requirements for new passenger cars. Section S4.1 of Standard No. 110 reads as follows: "Passenger cars shall be equipped with tires that meet the requirements of S571.109." Since foam-filled tires are not subject to Standard No. 109, they do not meet its requirements. Thus, it would be a violation of Standard No. 110 for any new passenger car to be equipped with foam-filled tires as original equipment.

You should also recognize that, even though foam-filled tires are not subject to Standard No. 109, they are still "items of motor vehicle equipment" within the meaning of section 102(4) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391(4)). Among other things, this means that, if there is a determination that the tires contain a defect related to motor vehicle safety, the manufacturer of the foam-filled tires is required to notify purchasers and dealers of the defect and remedy the defect without charge to the purchasers, if the tire was purchased less than 3 calendar years before the determination of defect was made.

If you have any further questions on this subject or need more information, please contact Steve Kratzke of my staff at this address or by telephone at (202) 426-2992.

Sincerely,

Erika Z. Jones Chief Counsel

Andrew A. Kroll 1401 East Girard, #270 Englewood, Colorado 80110 (303) 761-9227

23 April 1986

Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 7th Street, SW Washington, D.C. 20590

Dear Chief Counsel Jones,

I am requesting an interpretation of the "Code of Federal Regulation" (No. 49) Part 571, Standard 109. Presently, the standard states that a specified air pressure must be in an automotive or truck tire for on road usage. What then is the legal status of foam filled tires without any air in the inner tire cavity. These tires are in use on heavy industrial machinery, and would have security applications for automobiles.

I would very much appreciate an interpretation of this standard on how it pertains to foam filled or solid tires for on road usage.

Thank you very much for your time. I hope to hear from you soon.

Sincerely,

Andrew A. Kroll

ID: nht76-1.20

DATE: 06/16/76

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

TO: Moss Motors, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: The President has asked me to reply to your letter of February 9, 1976, concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, to replacement brake hoses for MG sports cars built from approximately 1945 to 1955.

All brake hose and brake hose end fittings manufactured on or after September 1, 1974, must meet the performance and labeling requirements of Standard No. 106-74. All brake hose assemblies manufactured on or after March 1, 1975, must meet those performance and labeling requirements in the standard that apply to assemblies and, with an exception noted below, must be constructed of conforming hose and end fittings.

The Federal motor vehicle safety standards are not applicable to classic or antique cars in the following sense: a standard applies only to a motor vehicle or item of motor vehicle equipment that is manufactured after its effective date. Thus, for example, there is no requirement that the MG's in question be retrofitted with conforming brake hose. However, any person manufacturing brake hose for use in such a vehicle must, on and after September 1, 1974, ensure that the hose conforms.

You may find some relief in S12 of the standard. To facilitate the depletion of inventories of hose manufactured before September 1, 1974, that conforms to all aspects of the standard except the labeling requirements, this provision permits the use of such hose in assemblies manufactured before September 1, 1976.

There are no Federal motor vehicle safety standards that apply to hydraulic brake system components other than Standard No. 106-74, Brake Hoses, and Standard No. 116, Motor Vehicle Brake Fluids.

Sincerely,

ATTACH.

MOSS MOTORS, Ltd.

April 14, 1976

Department of Transportation Washington, D.C.

Dear Sirs:

I am very disappointed at not having received a reply to my letter of February 9, 1976, a copy of which is enclosed herewith.

May I please have the courtesy of a prompt reply to this letter?

Yours very truly,

E. Alan Moss

Enclosure: letter copy

February 9, 1976

Department of Transportation Washington, D.C.

Dear Sirs:

I am writing to you at this time in order to attempt to clarify the present situation as regards hydraulic brake hoses as fitted to older British Sports Cars.

I have just finished reading all available information published by the Department of Transportation covering the manufacture of hose and fittings effective September 1, 1974, manufacture of brake hose assemblies March 1, 1975, and manufacture of vehicles effective September 1, 1975.

A very large part of our business is in the sales of replacement parts for the British MG sports car as built from approximately 1945 to approximately 1955. These are the models designated as TA, TB, TC, TD, TF add Y. All of these vehicles had hydraulic braking systems built by British Lockheed Corporation, from whom we have been obtaining replacement parts in the past. We are now unable to supply our customers with any brake hoses whatsoever due to the fact that Lockheed has apparently not "tooled up" to produce these hoses to your new specifications as yet and probably will not do so, at least until they can catch up with the present more popular hoses. There are 2 other companies, one in England and one in Australia, who have supplied replacement hoses in the past but I do not believe that they are labeled to meet the United States specifications.

While we are very anxious to be able to supply our customers with brake hoses in order to keep these rather elderly cars running, we certainly do not want to be party to supplying any hoses which would be unsafe or illegal, particular in light of todays very common lawsuits. I have heard, unofficially, that the DoT requirements are not applicable to older (classic or antique?) cars and would like to hear from you directly as to how we should best handle this situation.

I would also like to know if there are any regulations covering other hydraulic brake components such as cylinders, repair kits, or merely hoses and fluid.

Anxiously awaiting your prompt reply, I remain,

yours very truly,

E. Alan Moss

ID: 0533

Mr. Michael Love
Manager, Compliance
Porsche Cars North America, Inc.
P.O. Box 30911
Reno, Nevada 89520-3911

Dear Mr. Love:

We have received your letter of November 29, 1994, asking for an interpretation of 49 CFR Part 591.

Specifically, Porsche wishes to import vehicles for the Canadian market through the Port of Charleston, where certain processing activities will be performed on the cars before they are exported to Canada. The temporary importation of Canadian-market cars would be through 591.5(c) which allows importation "solely for export", provided that the vehicle is so labeled. You have asked for our concurrence in your interpretation of 591.5(c). We agree that Porsche may import and export Canadian-market cars under this section of the importation regulation.

You foresee a situation in which "a Canadian vehicle with a unique combination of options might be sought by a U.S. customer". Porsche would like to be able to convert the vehicle to comply with the U.S. Federal motor vehicle safety standards after importation and before it leaves Porsche's control. Porsche would also like to be able to re-import from Canada into the U.S. vehicles that would be converted to U.S. specifications. You have asked for confirmation that these operations would also be permissible under 591.5(c).

Importation of noncomplying motor vehicles into the United States and their subsequent conversion to the U.S. Federal motor vehicle safety standards must be accomplished through the mechanisms established by Congress in the Imported Vehicle Safety Compliance Act of 1988 (now 49 U.S.C. 30141 et seq.). First, NHTSA must have decided that the vehicle is eligible for importation pursuant to 49 CFR Part 593. Second, a vehicle intended for sale must be imported under bond by one who has been designated a Registered Importer under 49 CFR Part 592, who will undertake to bring the vehicle into compliance and to submit appropriate proof of this to NHTSA. Porsche may become a Registered Importer by filing an application under Part 592.

If a vehicle intended for the Canadian market has been temporarily imported under 591.5(c), and Porsche then wishes to convert it to U.S. specifications rather than export it to Canada, you should telephone Clive Van Orden, Office of Vehicle Safety Compliance (202-366- 2830), to apprise him of the situation. We see no problem in this as long as NHTSA has decided that the vehicle is eligible for importation and Porsche provides a compliance package, in accordance with the requirements of Parts 592 and 593.

Sincerely,

Philip R. Recht Chief Counsel ref:591#592#593 d:12/22/94