Interpretation ID: nht93-2.15

DATE: March 12, 1993

FROM: Scott R. Dennison -- Vice President, Production, Excalibur Automobile Corporation

TO: Robert Hellmuth -- Director, Office of Vehicle Safety Compliance, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-19-93 from John Womack to Scott R. Dennison (A41; Part 555)

TEXT: I am writing on behalf of the Specialty Car Industry in general and Excalibur in particular to offer my input and assistance regarding the alleged debate over the treatment of vehicles replicating pre-safety standard vehicle designs and their compliance with current Federal Motor Vehicle Safety Standards. This has long been a difficult area for the industry to understand since most of the manufacturers of these vehicles are ultra low volume manufacturers. I was briefly involved with the limousine industry in 1989 when NHTSA began to work cooperatively with them to achieve practical compliance and would like to see the our industry and NHTSA do the same.

As you are aware, the Environmental Protection Agency has created a very specific set of guidelines for the specialty car industry to allow them to produce compliant automobiles without the need for "legitimate" FTP-testing. It is my opinion that the same type of policy is possible to bring the specialty cars up to an acceptable standard where there are those who now fall short. I also believe that we, as a $100 million plus industry, can internally weed out the undesirable, poor quality builders and manufacturers and essentially police ourselves, not unlike the limousine converters. The biggest hurdle this industry faces is a way to interpret and apply the "rules" in a cost effective manner which will allow us to remain in business.

I am aware that the "Hot Rod" industry is heavily engaged in the same type of effort at this time. However, they have an advantage that we do not have as most hot rods and muscle cars were produced by major "legitimate" manufacturers and were "real" cars at one time. Even though we may build a car replicating a 1934 Mercedes or a 1966 Cobra, we are still building a 1993 vehicle requiring 1993 compliance. In most cases, the original body style necessary for marketing reasons does not readily lend itself to current compliance regulations. Ergo, our dilemma.

I would like to hear your opinion and would look forward to participating in the decision making process wherever possible. Please let me know what I can do to assist. I am looking forward to your response.