YES! Sportscars; Response to Application for a Temporary Exemption From the Advanced Air Bag Requirements of FMVSS No. 208, 68888-68892 [E6-20091]
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information technology, e.g. permitting
electronic submission of responses.
In compliance with these
requirements, NHTSA asks for public
comments on the following proposed
collections of information:
(1) Title: Air Bag Deactivation.
OMB Control Number: 2127–0588.
Affected Public: Private individuals,
fleet owners and lessees, motor vehicle
dealers, repair business.
Abstract: If a private individual or
lessee wants to install an air bag on-off
switch to turn-off either or both frontal
air bags, they must complete Form OMB
2127–0588 to certify certain statements
regarding use of the switch. The dealer
or business must, in turn, submit the
completed forms to NHTSA within
seven days. The submission of the
completed forms by the dealers and
repair business to NHTSA, as required,
will serve the agency several purposes.
They will aid the agency in monitoring
the number of authorization requests
submitted and the pattern in claims of
risk group membership. The completed
forms will enable the agency to
determine whether the dealers and
repair business are complying with the
terms of the exemption, which include
a requirement that the dealers and
repair businesses accept only fully
completed forms. Finally, submission of
the completed forms to the agency will
promote honesty and accuracy in the
filling out of the forms by vehicle
owners. The air bag on-off switches are
installed only in vehicles in which the
risk of harm needs to be minimized on
a case-by-case basis.
Estimated Annual Burden: 7,500
hours.
Estimated Number of Respondents:
15,000.
Comments are invited on: Whether
the proposed collection of information
is necessary for the proper performance
of the functions of the Department,
including whether the information will
have practical utility; the accuracy of
the Department’s estimate of the burden
of the proposed information collection;
ways to enhance the quality, utility and
clarity of the information to be
collected; and ways to minimize the
burden of the collection of information
on respondents, including the use of
automated collection techniques or
other forms of information technology.
Issued on: November 21, 2006.
Kevin Mahoney,
Director, Corporate Customer Services.
[FR Doc. E6–20106 Filed 11–27–06; 8:45 am]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety
Administration
[Docket No. NHTSA–2006–25545, Notice 2]
YES! Sportscars; Response to
Application for a Temporary
Exemption From the Advanced Air Bag
Requirements of FMVSS No. 208
National Highway Traffic
Safety Administration (NHTSA),
Department of Transportation (DOT).
AGENCY:
Grant of application for
temporary exemption from certain
provisions of Federal Motor Vehicle
Safety Standard No. 208, Occupant
Crash Protection.
ACTION:
SUMMARY: This notice grants the YES!
Sportscars application for temporary
exemption from certain advanced air
bag requirements of Federal Motor
Vehicle Safety Standard (FMVSS) No.
208, Occupant Crash Protection. This
exemption applies to the YES! Roadster
3.2 and 3.2 Turbo (hereinafter
collectively referred to as ‘‘the YES!
Roadster’’). In accordance with 49 CFR
part 555, the basis for the grant is that
compliance would cause substantial
economic hardship to a manufacturer
that has tried in good faith to comply
with the standard, and the exemption
would have a negligible impact on
motor vehicle safety.
The exemption for the YES! Roadster
is effective September 1, 2006 and will
remain in effect until August 31, 2009.
In accordance with the requirements
of 49 U.S.C. 30113(b)(2), we published
a notice of receipt of the application 1 in
the Federal Register and asked for
public comments.2 We received no
comments on the application.
The exemption from the
specified provisions of FMVSS No. 208
for the YES! Roadster is effective from
September 1, 2006 until August 31,
2009.
DATES:
Mr.
Ed Glancy or Mr. Eric Stas in the Office
of the Chief Counsel at the National
Highway Traffic Safety Administration
(NCC–112), 400 Seventh Street, SW.,
Room 5219, Washington, DC 20590
(Telephone: (202) 366–2992; Fax: (202)
366–3820).
FOR FURTHER INFORMATION CONTACT:
SUPPLEMENTARY INFORMATION:
1 To view the application, go to: https://
dms.dot.gov/search/searchFormSimple.cfm and
enter Docket No. NHTSA–2006–25545.
2 See 71 FR 50980 (August 28, 2006) (Docket No.
NHTSA–2006–25545–1).
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I. Advanced Air Bag Requirements and
Small Volume Manufacturers
In 2000, NHTSA upgraded the
requirements for air bags in passenger
cars and light trucks, requiring what are
commonly known as ‘‘advanced air
bags.’’ 3 The upgrade was designed to
meet the goals of improving protection
for occupants of all sizes, belted and
unbelted, in moderate-to-high-speed
crashes, and of minimizing the risks
posed by air bags to infants, children,
and other occupants, especially in lowspeed crashes.
The advanced air bag requirements
were a culmination of a comprehensive
plan that the agency announced in 1996
to address the adverse effects of air bags.
This plan also included an extensive
consumer education program to
encourage the placement of children in
rear seats. The new requirements were
phased in beginning with the 2004
model year.
Small volume manufacturers (i.e.,
original vehicle manufacturers
producing or assembling fewer than
5,000 vehicles annually for sale in the
United States) were not subject to the
advanced air bag requirements until
September 1, 2006, but their efforts to
bring their respective vehicles into
compliance with these requirements
began several years ago. However,
because the new requirements were
challenging, major air bag suppliers
concentrated their efforts on working
with large volume manufacturers, and
thus, until recently, small volume
manufacturers had limited access to
advanced air bag technology. Because of
the nature of the requirements for
protecting out-of-position occupants,
‘‘off-the-shelf’’ systems could not be
readily adopted. Further complicating
matters, because small volume
manufacturers build so few vehicles, the
costs of developing custom advanced air
bag systems compared to potential
profits discouraged some air bag
suppliers from working with small
volume manufacturers.
The agency has carefully tracked
occupant fatalities resulting from air bag
deployment. Our data indicate that the
agency’s efforts in the area of consumer
education and manufacturers’ providing
depowered air bags were successful in
reducing air bag fatalities even before
advanced air bag requirements were
implemented.
As always, we are concerned about
the potential safety implication of any
temporary exemptions granted by this
agency. In the present case, we are
addressing a petition for a temporary
3 See 65 FR 30680 (May 12, 2000) (Docket No.
NHTSA–2000–7013).
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exemption from the advanced air bag
requirements submitted by a
manufacturer of low volume, exotic
sports cars.
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II. Overview of Petition for Economic
Hardship Exemption
In accordance with 49 U.S.C. 30113
and the procedures in 49 CFR part 555,
YES! Sportscars has petitioned the
agency for a temporary exemption from
certain advanced air bag requirements of
FMVSS No. 208. The basis for the
application is that compliance would
cause substantial economic hardship 4
to a manufacturer that has tried in good
faith to comply with the standard. The
agency closely examines and considers
the information provided by
manufacturers in support of these
factors, and, in addition, pursuant to 49
U.S.C. 30113(b)(3)(A), determines
whether exemption is in the public
interest and consistent with the Safety
Act.5
A manufacturer is eligible to apply for
a hardship exemption if its total motor
vehicle production in its most recent
year of production did not exceed
10,000 vehicles, as determined by the
NHTSA Administrator (49 U.S.C.
30113). In determining whether a
manufacturer of a vehicle meets that
criterion, NHTSA considers whether a
second vehicle manufacturer also might
be deemed the manufacturer of that
vehicle. The statutory provisions
governing motor vehicle safety (49
U.S.C. Chapter 301) do not include any
provision indicating that a manufacturer
might have substantial responsibility as
manufacturer of a vehicle simply
because it owns or controls a second
manufacturer that assembled that
vehicle. However, the agency considers
the statutory definition of
‘‘manufacturer’’ (49 U.S.C. 30102) to be
sufficiently broad to include sponsors,
depending on the circumstances. Thus,
NHTSA has stated that a manufacturer
may be deemed to be a sponsor and thus
a manufacturer of a vehicle assembled
by a second manufacturer if the first
manufacturer had a substantial role in
the development and manufacturing
process of that vehicle.
Finally, while 49 U.S.C. 30113(b)
states that exemptions from a Safety Act
4 When considering financial matters involving
companies based in the European Union (EU), it is
important to recognize that EU and U.S. accounting
principles have certain differences in their
treatment of revenue, expenses, and profits. Public
statements by EU manufacturers relating to
financial results should be understood in this
context. This agency analyzes claims of financial
hardship carefully and in accordance with U.S.
accounting principles.
5 The Safety Act is codified as Title 49, United
States Code, Chapter 301.
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standard are to be granted on a
‘‘temporary basis,’’ 6 the statute also
expressly provides for renewal of an
exemption on reapplication.
Manufacturers are nevertheless
cautioned that the agency’s decision to
grant an initial petition in no way
predetermines that the agency will
repeatedly grant renewal petitions,
thereby imparting semi-permanent
exemption from a safety standard.
Exempted manufacturers seeking
renewal must bear in mind that the
agency is directed to consider financial
hardship as but one factor, along with
the manufacturer’s on-going good faith
efforts to comply with the regulation,
the public interest, consistency with the
Safety Act, generally, as well as other
such matters provided in the statute.
III. YES! Sportscars
Background. YES! Sportscars is a
division of Funke & Will
Aktiengesellschaft (AG), a German
corporation formed in 2000. Funke &
Will AG is a specialized engineering
firm which offers engineering services
to the automobile industry on small
volume projects. Although the parent
company’s two founders together own
85 percent of the corporation’s shares,
the German state of Saxony does have
a 15-percent ownership stake.7
YES! Sportscars, a separate vehicle
manufacturing part of the company,
began production in 2001 of highperformance sports cars based on an
aluminum spaceframe. This application
concerns the YES! Roadster (currently
the company’s only model) which is
expected to retail for $59,000. To date,
the primary markets for the YES!
Roadster have been Europe and the
Middle East, with the following
numbers of vehicles being produced
over the past five years: 12 vehicles in
2001; 37 vehicles in 2002; 42 vehicles
in 2003; 48 vehicles in 2004, and 54
vehicles in 2005. None of those vehicles
has been sold in the U.S. market.
According to the petition, the
company had originally planned to
prospectively produce vehicles for the
European, Mid-East, and Far-East
markets, but it has been determined to
be a matter of financial necessity for
YES! Sportscars to enter the U.S.
market, particularly given the limited
but global market for these high-end
sports cars. The company anticipates
6 49
U.S.C 30113(b)(1).
to the petitioner, the German state
government took an ownership interest in the firm
in exchange for subsidies for capital investment in
facilities and equipment. According to YES!
Sportscars, these subsidies cannot be used for
operational expenditures and research and
development funding.
7 According
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that approximately 65 percent of its
total sales will be to the U.S. market.
As discussed in further detail below,
the petitioner argued that it tried in
good faith, but could not bring the
vehicle into compliance with the
advanced air bag requirements, and
would incur substantial economic
hardship if it cannot sell vehicles in the
U.S. after September 1, 2006.
Eligibility. As discussed in the
petition, YES! Sportscars is a division of
Funke & Will AG, a German corporation
formed in 2000. The entire organization
currently employs 49 people. No other
vehicle manufacturer has an ownership
interest in either YES! Sportscars or
Funke & Will AG, and the reverse is
likewise true. Stated another way, YES!
Sportscars is an independent
automobile manufacturer which does
not have any common control or is
otherwise affiliated with any other
vehicle manufacturer.
The company is a small volume
manufacturer whose total production
has ranged from 12 to 54 vehicles per
year over the period from 2001 to 2005.
According to its current forecasts, YES!
Sportscars anticipates that
approximately 250 vehicles would be
imported into the U.S. during the threeyear period for its requested exemption,
if such request were granted.
Requested exemption. YES!
Sportscars stated that it intends to
certify the YES! Roadster as complying
with the rigid barrier belted test
requirement using the 50th percentile
adult male test dummy set forth in
S14.5.1 of FMVSS No. 208. The
petitioner stated that it previously
determined the YES! Roadster’s
compliance with rigid barrier unbelted
test requirements using the 50th
percentile adult male test dummy
through the S13 sled test using a generic
pulse rather than a full vehicle test.
YES! Sportscars stated that it, therefore,
cannot at present say with certainty that
the YES! Roadster will comply with the
unbelted test requirement under
S14.5.2, which is a 20–25 mph rigid
barrier test.
As for the YES! Roadster’s compliance
with the other advanced air bag
requirements, YES! Sportscars stated
that it does not know whether the YES!
Roadster will be compliant because to
date it has not had the financial ability
to conduct the necessary testing.
As such, YES! Sportscars is requesting
an exemption for the YES! Roadster
from the rigid barrier unbelted test
requirement with the 50th percentile
adult male test dummy (S14.5.2), the
rigid barrier test requirement using the
5th percentile adult female test dummy
(belted and unbelted, S15), the offset
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deformable barrier test requirement
using the 5th percentile adult female
test dummy (S17), the requirements to
provide protection for infants and
children (S19, S21, and S23) and the
requirement using an out-of-position 5th
percentile adult female test dummy at
the driver position (S25).
YES! Sportscars stated its intention to
produce a second generation of the YES!
Roadster by September 1, 2009, which
would be certified as complying with all
applicable U.S. standards, including the
advanced air bag requirements.
Accordingly, the company is requesting
an exemption from the above-specified
requirements of FMVSS No. 208 for the
period from September 1, 2006 to
August 31, 2009.
Economic hardship. Publicly
available information and also the
financial documents submitted to
NHTSA by the petitioner indicate that
the YES! Roadster project will result in
financial losses unless YES! Sportscars
obtains a temporary exemption.
Over the period 2001–2005, the YES!
Sportscars division of Funke & Will AG
has experienced net operational losses
totaling $618,000 (484,000 euros at an
exchange rate of 1 euro = $1.277).8 As
of the time of the application, YES!
Sportscars has invested over $3.0
million on the design, development, and
homologation of the YES! Roadster
project in order to have the vehicle meet
U.S. standards—not including the
advanced air bag requirements which
are the subject of the present petition for
temporary exemption. The company has
stated that it cannot hope to attain
profitability if it incurs additional
research and development expenses at
this time.
YES! Sportscars stated that costs
associated with advanced air bag
engineering and development
(including research and development,
testing, tooling, and test vehicles) have
been estimated to be $1.7 million
(including internal costs). In its petition,
YES! Sportscars reasoned that sales in
the U.S. market must commence in
order to finance this work and that nonU.S. sales alone cannot generate
sufficient income for this purpose. In
essence, YES! Sportscars argued that the
exemption is necessary to allow the
company to ‘‘bridge the gap’’ until fully
compliant vehicles can be funded,
developed, tooled, and introduced for
the U.S. market.
8 According to the YES! petition, the engineering
portion of Funke & Will AG has made a modest
profit in the past few years, but in total, such profits
would only amount to 45 percent of the funding
needed to finance the requisite advanced air bag
work.
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If the exemption is denied, YES!
Sportscars projects a net loss of $1.1
million over the period from 2006–2008
(assuming a delayed start of U.S. sales
until 2008). However, if the petition is
granted, the company anticipates a
profit of nearly $1.4 million during that
same period. The petitioner argued that
a denial of this petition could preclude
financing of the project for USAcompliant vehicles, a development
which would have a highly adverse
impact on the company.
Good faith efforts to comply. As stated
above, YES! Sportscars initially planned
to produce vehicles for the European,
Mid-East, and Far-East markets, but
once it was determined in 2005 that
entry into the U.S. market was a
necessary part of its business plan, the
company invested over $3.0 million on
research and development and tooling
for its U.S. YES! Roadster program
(including adoption of a U.S.-certified
engine and drive train). In that time, the
company was able to bring the vehicle
into compliance with all applicable
NHTSA regulations, except for the
advanced air bag provisions of FMVSS
No. 208.
In light of limited resources, the
petitioner stated that it was necessary to
first develop the vehicle with a standard
U.S. air bag system. The company has
spent over $630,000 to reengineer the
YES! Roadster to include a standard air
bag system, which it stated will then be
‘‘expanded’’ into an advanced air bag
system.
According to its petition, even though
advanced air bags are beyond its current
capabilities, YES! Sportscars is
nonetheless planning for the
introduction of these devices. The
company stated that Siemens Restraint
Systems will spearhead this effort, and
current plans estimate a cost of $1.1
million (excluding internal costs) and a
minimum lead time of 24 months for the
advanced air bag project. YES!
Sportscars stated that the following
engineering efforts are needed to
upgrade the YES! Roadster’s standard
air bag system to an advanced air bag
system: (1) Interior redesign work to the
dashboard, steering column, and
electronic systems; (2) sourcing and
organization of supplier and engineering
personnel and resources for
development work (including sensor
calibration); (3) construction of
prototypes, and (4) testing.
In addition, YES! Sportscars stated
that finding suppliers willing to work
with a manufacturer with very low
production volumes has proven
extremely difficult, and as a result, the
company must wait for technology to
‘‘trickle down’’ from larger
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manufacturers and suppliers. YES!
Sportscars further stated that small
volume manufacturers simply do not
have the internal resources to do full
U.S. homologation projects without
reliance on outside suppliers of
advanced engineering technologies.
In short, YES! Sportscars argued that,
despite good faith efforts, limited
resources prevent it from bringing the
vehicle into compliance with all
applicable requirements, and it is
beyond the company’s current
capabilities to bring the vehicle into full
compliance until such time as
additional resources become available
as a result of U.S. sales. With funding
from the sale of the current generation
of YES! Roadsters, the company expects
that additional development efforts
could start in 2007, thereby allowing
introduction of a fully compliant
vehicle in September 2009.
YES! Sportscars argues that an
exemption would be in the public
interest. The petitioner put forth several
arguments in favor of a finding that the
requested exemption is consistent with
the public interest and would not have
a significant adverse impact on safety.
Specifically, YES! Sportscars argued
that the vehicle would be equipped with
a fully-compliant standard U.S. air bag
system (i.e., one meeting all
requirements of FMVSS No. 208 prior to
implementation of S14). Furthermore,
the company emphasized that the YES!
Roadster will comply with all other
applicable FMVSSs.
The company asserted that granting
the exemption will benefit U.S.
employment, companies, and citizens,
because YES! Roadsters will be sold and
serviced through a network of U.S.
dealers. YES! Sportscars also argued
that denial of the exemption request
would have an adverse impact on
consumer choice, suggesting that there
is domestic demand for a performance
vehicle in the YES! Roadster’s price
range. The company also argued that an
exemption is unlikely to have a
significant safety impact because these
vehicles are not expected to be used
extensively by their owners, due to their
‘‘second vehicle’’ nature and
‘‘minimalist design.’’ The company also
reasoned that given the nature of the
vehicle, it is less likely to be used to
transport young children than most
other vehicles.
As an additional basis for showing
that its requested exemption would be
in the public interest, YES! Sportscars
stated that the YES! Roadster has an
extremely strong and protective chassis,
which is composed of aluminum tubes
and composite structure parts.
According to YES! Sportscars, the
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vehicle design is such that occupants
are effectively placed in a ‘‘protective
‘cell’ ’’ with the chassis structure built
around them.
Agency Decision on YES! Sportscars
Petition. We are granting the YES!
Sportscars petition to be exempted from
portions of the advanced air bag
regulation required by S14.2
(specifically S14.5.2, S15, S17, S19, S21,
S23, and S25). The exemption does not
extend to the provision requiring a
belted 50th percentile male barrier
impact test (S14.5.1(a)). In addition to
certifying compliance with S14.5.1(a),
YES! Sportscars must continue to certify
to the unbelted 50th percentile barrier
impact test in force prior to September
1, 2006 (S5.1.2(a)). We note that the
unbelted sled test in S13 is an
acceptable option for that requirement.
The agency’s rationale for this decision
is as follows.
The advanced air bag requirements
present a unique challenge because they
would require YES! Sportscars to
undertake a major redesign of its
vehicles, in order to overcome the
engineering limitations of the YES!
Roadster. Specifically, YES! Sportscars
would be required to undertake
significant interior redesign in order to
upgrade the vehicle’s standard air bag
system to an advanced air bag system.
While the petitioner was aware of the
new requirements for some time, its
business plans did not initially involve
sales in the U.S. However, YES!
Sportscars subsequently determined
that it would be necessary to introduce
the YES! Roadster into the U.S., thereby
raising the problem of compliance with
the advanced air bag requirements.
Once the determination was made to
seek entry into the U.S. market, YES!
Sportscars undertook significant
homologation efforts in order to meet
applicable U.S. requirements, but
compliance with the advanced air bag
provisions of FMVSS No. 208 were
beyond the company’s capabilities at
the present time. YES! Sportscars plans
to utilize proceeds from sales of the
current generation of YES! Roadsters to
finance the development of a fully
compliant successor vehicle.
YES! Sportscars explained the main
engineering challenges precluding
incorporation of advanced air bag into
the YES! Roadster at this time, as
follows. The company must undertake
redesign work to the vehicle’s
dashboard, steering column, and
electronic systems. Furthermore, the
petitioner stated that it would need
additional time to work with an
advanced air bag supplier, because very
low volume manufacturers have had to
wait for technology to ‘‘trickle down’’
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from larger manufacturers and
suppliers. YES! Sportscars has made
clear that such a prospect would pose a
unique challenge to the company, due
to the high cost of development and its
extremely small sales volumes.
Based upon the information provided
by the petitioner, we understand that
YES! Sportscars made good faith efforts
to bring the YES! Roadster into
compliance with the applicable
requirements until such time as it
became apparent that there was no
practicable way to do so. As a small
specialty manufacturer, the company
had a difficult time in gaining access to
advanced air bag systems and
components (which presumably reflects
restraint system suppliers’ initial focus
on meeting the needs of large volume
manufacturers), so alternative means of
compliance were not available as a
practical matter. Small manufacturers
such as YES! Sportscars are dependent
upon air bag suppliers for the
engineering expertise and technology
transfer necessary for compliance with
FMVSS No. 208. This further reduced
the lead time available for development.
Furthermore, because YES! Sportscars
is an independent automobile
manufacturer, there was no possibility
of technology transfer from a larger
parent company that also manufactures
motor vehicles. Consequently, no viable
alternatives remain. The petitioner is
unable to redesign its vehicle in time to
meet the new advanced air bag
requirements that became effective on
September 1, 2006.
After review of the income statements
provided by the petitioner, the agency
notes that the company has faced
ongoing financial difficulties,
experiencing net operating losses of
about $618,000 (484,000 euros) over the
past five years (2001–2005). The
company was not profitable in any year
during that period. If the petitioner’s
request for a temporary exemption is
denied, the company will be precluded
from selling any vehicles in the U.S.
market at this time. The resulting loss of
sales would cause substantial economic
hardship within the meaning of the
statute, potentially amounting to the
difference between a profit of nearly
$1.4 million (if an exemption is granted)
and a loss of $1.1 million (if an
exemption is denied) over the period
from 2006–2008. Ultimately, denial of
the exemption request could preclude
development of a U.S.-compliant
vehicle and jeopardize the continued
existence of YES! Sportscars.
According to YES! Sportscars, absent
the exemption, the company anticipates
being unable to enter the U.S. market
during the period from 2006–2008.
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However, YES! Sportscars’ problems
would be compounded without its
requested temporary exemption,
because it needs the revenue from sales
of the YES! Roadster over the next two
years to finance development of a fully
compliant vehicle for delivery to the
U.S. market. Granting the exemption
will allow YES! Sportscars to earn the
resources necessary to bridge the gap in
terms of development of a successor
vehicle for the current YES! Roadster
that meets all U.S. requirements.
While some of the information
submitted by YES! Sportscars has been
granted confidential treatment and is
not detailed in this document, the
petitioner made a comprehensive
showing of its good faith efforts to
comply with the requirements of S14.2
of FMVSS No. 208, and detailed
engineering and financial information
demonstrating that failure to obtain the
exemption would cause substantial
economic hardship. Specifically, the
petitioner provided the following:
1. Chronological analysis of YES
Sportscars’ efforts to comply, showing
the relationship to the rulemaking
history of the advanced air bag
requirements.
2. Itemized costs of each component
that would have to be modified in order
to achieve compliance.
3. Discussion of alternative means of
compliance and reasons for rejecting
these alternatives.
4. A detailed OEM price-volume
quotation from an advanced air bag
supplier, including detailed costs for the
necessary components for each stage of
the development program.
5. Explanations as to why components
from newer, compliant vehicle lines
could not be borrowed.
6. Corporate income statements and
balance sheets for the period from 2000–
2005, and projected profits for the
period from 2006–2008 (analyzing
alternative scenarios in which the
petition is granted and denied).
While noting that reduction of sales
revenue resulting from a denial of the
company’s requested temporary
exemption would have a negative
impact on YES! Sportscars’ financial
circumstances, we also sought to
evaluate a denial’s affect on U.S.
employment, in light of the company’s
statement that it anticipates selling the
YES! Roadster through a network of U.S.
dealers. Traditionally, the agency has
concluded that the public interest is
served in affording continued
employment to the petitioner’s U.S.
work force. As a corollary, the agency
also may consider prospective
employment gains as part of its analysis
of what is in the public interest.
E:\FR\FM\28NON1.SGM
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68892
Federal Register / Vol. 71, No. 228 / Tuesday, November 28, 2006 / Notices
However, YES! Sportscars provided no
information on prospective U.S. dealers,
projected sales per outlet, or
employment. Thus, it is difficult to
assess the likely employment impacts
associated with granting the petition, as
any such conclusions would be largely
speculative.
We believe that this exemption will
have negligible impact on motor vehicle
safety because of the limited number of
vehicles affected (approximately 250
imported for the duration of the
exemption). Furthermore, as discussed
in previous decisions on temporary
exemption applications, the agency
believes that the public interest is
served by affording consumers a wider
variety of motor vehicle choices.
We note that, as explained below,
prospective purchasers will be notified
that the vehicle is exempted from the
specified advanced air bag requirements
of Standard No. 208. Under § 555.9(b),
a manufacturer of an exempted
passenger car must affix securely to the
windshield or side window of each
exempted vehicle a label containing a
statement that the vehicle conforms to
all applicable Federal motor vehicle
safety standards in effect on the date of
manufacture ‘‘except for Standard Nos.
[listing the standards by number and
title for which an exemption has been
granted] exempted pursuant to NHTSA
Exemption No.l.’’ This label notifies
prospective purchasers about the
exemption and its subject. Under
§ 555.9(c), this information must also be
included on the vehicle’s certification
label.
The text of § 555.9 does not expressly
indicate how the required statement on
the two labels should read in situations
where an exemption covers part but not
all of a Federal motor vehicle safety
standard. In this case, we believe that a
statement that the vehicle has been
exempted from Standard No. 208
generally, without an indication that the
exemption is limited to the specified
advanced air bag provisions, could be
misleading. A consumer might
incorrectly believe that the vehicle has
been exempted from all of Standard No.
208’s requirements. Moreover, we
believe that the addition of a reference
to such provisions by number without
an indication of its subject matter would
be of little use to consumers, since they
would not know the subject of those
specific provisions. For these reasons,
we believe the two labels should read in
relevant part, ‘‘except for S14.5.2, S15,
S17, S19, S21, S23, and S25 (Advanced
Air Bag Requirements) of Standard No.
208, Occupant Crash Protection,
exempted pursuant to * * *.’’ We note
that the phrase ‘‘Advanced Air Bag
VerDate Aug<31>2005
15:42 Nov 27, 2006
Jkt 211001
Requirements’’ is an abbreviated form of
the title of S14 of Standard No. 208. We
believe it is reasonable to interpret
§ 555.9 as requiring this language.
In sum, the agency concludes that
YES! Sportscars has demonstrated good
faith effort to bring the YES! Roadster
into compliance with the advanced air
bag requirements of FMVSS No. 208,
and has also demonstrated the requisite
financial hardship. Further, we find the
exemption to be in the public interest.
In consideration of the foregoing, we
conclude that compliance with the
advanced air bag requirements of
FMVSS No. 208, Occupant Crash
Protection, would cause substantial
economic hardship to a manufacturer
that has tried in good faith to comply
with the standard. We further conclude
that granting of an exemption would be
in the public interest and consistent
with the objectives of traffic safety.
In accordance with 49 U.S.C.
30113(b)(3)(B)(i), the YES! Roadster is
granted NHTSA Temporary Exemption
No. EX 06–9, from S14.5.2, S15, S17,
S19, S21, S23, and S25 of 49 CFR
571.208. The exemption is effective
from September 1, 2006 to August 31,
2009.
Issued on: November 21, 2006.
Nicole R. Nason,
Administrator.
[FR Doc. E6–20091 Filed 11–27–06; 8:45 am]
BILLING CODE 4910–59–P
DEPARTMENT OF TRANSPORTATION
Surface Transportation Board
[STB Finance Docket No. 34911 (Sub-No.
1)]
Montana Rail Link, Inc.—Trackage
Rights Exemption—BNSF Railway
Company
AGENCY:
Surface Transportation Board,
to expire on or about December 31,
2010, in accordance with the agreement
of the parties, subject to the employee
protective conditions set forth in Oregon
Short Line R. Co.—Abandonment—
Goshen, 360 I.C.C. 91 (1979).
DATES: The exemption will be effective
on December 28, 2006. Petitions to stay
must be filed by December 8, 2006.
Petitions to reopen must be filed by
December 18, 2006.
ADDRESSES: An original and 10 copies of
all pleadings, referring to STB Finance
Docket No. 34911 (Sub-No. 1) must be
filed with the Surface Transportation
Board, 1925 K Street, NW., Washington,
DC 20423–0001. In addition, a copy of
all pleadings must be served on
petitioner’s representative: Troy Garris,
1300 19th Street, NW., Fifth Floor,
Washington, DC 20036.
FOR FURTHER INFORMATION CONTACT:
Joseph H. Dettmar, (202) 565–1609.
[Assistance for the hearing impaired is
available through the Federal
Information Relay Service (FIRS) at
1–800–877–8339.]
SUPPLEMENTARY INFORMATION:
Additional information is contained in
the Board’s decision. To purchase a
copy of the full decision, write, e-mail,
or call: ASAP Document Solutions, 9332
Annapolis Rd., Suite 103, Lanham, MD
20706; e-mail: asapdc@verizon.net;
telephone: (202) 306–4004. [Assistance
for the hearing impaired is available
through FIRS at 1–800–877–8339.]
Board decisions and notices are
available on our Web site at https://
www.stb.dot.gov.
Decided: November 17, 2006.
By the Board, Chairman Nottingham, Vice
Chairman Mulvey, and Commissioner
Buttrey.
Vernon A. Williams,
Secretary.
[FR Doc. E6–19977 Filed 11–27–06; 8:45 am]
BILLING CODE 4915–01–P
DOT.
ACTION:
Petition for Partial Revocation.
The Board, under 49 U.S.C.
10502, exempts the trackage rights
described in Montana Rail Link, Inc.—
Trackage Rights Exemption—BNSF
Railway Company, STB Finance Docket
No. 34911 (STB served Oct. 13, 2006)
(MRL Trackage Rights) 1 to permit them
SUMMARY:
1 On
September 25, 2006, Montana Rail Link, Inc.
(MRL) concurrently filed a notice of exemption
under the Board’s class exemption procedures at 49
CFR 1180.2(d)(7). The notice covered the agreement
by BNSF Railway Company (BNSF) to grant
overhead trackage rights to MRL over BNSF’s rail
lines extending from approximately milepost 51.07
at or near Garrison, MT, to approximately milepost
21.5, a location south of Warm Springs, MT, a
distance of approximately 29.57 miles. See MRL
PO 00000
Frm 00099
Fmt 4703
Sfmt 4703
DEPARTMENT OF THE TREASURY
Office of the Comptroller of the
Currency
Agency Information Collection
Activities: Submission for OMB
Review; Comment Request
Office of the Comptroller of the
Currency (OCC), Treasury.
ACTION: Notice and request for comment.
AGENCY:
SUMMARY: The OCC, as part of its
continuing effort to reduce paperwork
Trackage Rights. The trackage rights operations
under the exemption were scheduled to be
consummated on or after October 2, 2006.
E:\FR\FM\28NON1.SGM
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Agencies
[Federal Register Volume 71, Number 228 (Tuesday, November 28, 2006)]
[Notices]
[Pages 68888-68892]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-20091]
-----------------------------------------------------------------------
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2006-25545, Notice 2]
YES! Sportscars; Response to Application for a Temporary
Exemption From the Advanced Air Bag Requirements of FMVSS No. 208
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Grant of application for temporary exemption from certain
provisions of Federal Motor Vehicle Safety Standard No. 208, Occupant
Crash Protection.
-----------------------------------------------------------------------
SUMMARY: This notice grants the YES! Sportscars application for
temporary exemption from certain advanced air bag requirements of
Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash
Protection. This exemption applies to the YES! Roadster 3.2 and 3.2
Turbo (hereinafter collectively referred to as ``the YES! Roadster'').
In accordance with 49 CFR part 555, the basis for the grant is that
compliance would cause substantial economic hardship to a manufacturer
that has tried in good faith to comply with the standard, and the
exemption would have a negligible impact on motor vehicle safety.
The exemption for the YES! Roadster is effective September 1, 2006
and will remain in effect until August 31, 2009.
In accordance with the requirements of 49 U.S.C. 30113(b)(2), we
published a notice of receipt of the application \1\ in the Federal
Register and asked for public comments.\2\ We received no comments on
the application.
---------------------------------------------------------------------------
\1\ To view the application, go to: https://dms.dot.gov/search/
searchFormSimple.cfm and enter Docket No. NHTSA-2006-25545.
\2\ See 71 FR 50980 (August 28, 2006) (Docket No. NHTSA-2006-
25545-1).
DATES: The exemption from the specified provisions of FMVSS No. 208 for
the YES! Roadster is effective from September 1, 2006 until August 31,
---------------------------------------------------------------------------
2009.
FOR FURTHER INFORMATION CONTACT: Mr. Ed Glancy or Mr. Eric Stas in the
Office of the Chief Counsel at the National Highway Traffic Safety
Administration (NCC-112), 400 Seventh Street, SW., Room 5219,
Washington, DC 20590 (Telephone: (202) 366-2992; Fax: (202) 366-3820).
SUPPLEMENTARY INFORMATION:
I. Advanced Air Bag Requirements and Small Volume Manufacturers
In 2000, NHTSA upgraded the requirements for air bags in passenger
cars and light trucks, requiring what are commonly known as ``advanced
air bags.'' \3\ The upgrade was designed to meet the goals of improving
protection for occupants of all sizes, belted and unbelted, in
moderate-to-high-speed crashes, and of minimizing the risks posed by
air bags to infants, children, and other occupants, especially in low-
speed crashes.
---------------------------------------------------------------------------
\3\ See 65 FR 30680 (May 12, 2000) (Docket No. NHTSA-2000-7013).
---------------------------------------------------------------------------
The advanced air bag requirements were a culmination of a
comprehensive plan that the agency announced in 1996 to address the
adverse effects of air bags. This plan also included an extensive
consumer education program to encourage the placement of children in
rear seats. The new requirements were phased in beginning with the 2004
model year.
Small volume manufacturers (i.e., original vehicle manufacturers
producing or assembling fewer than 5,000 vehicles annually for sale in
the United States) were not subject to the advanced air bag
requirements until September 1, 2006, but their efforts to bring their
respective vehicles into compliance with these requirements began
several years ago. However, because the new requirements were
challenging, major air bag suppliers concentrated their efforts on
working with large volume manufacturers, and thus, until recently,
small volume manufacturers had limited access to advanced air bag
technology. Because of the nature of the requirements for protecting
out-of-position occupants, ``off-the-shelf'' systems could not be
readily adopted. Further complicating matters, because small volume
manufacturers build so few vehicles, the costs of developing custom
advanced air bag systems compared to potential profits discouraged some
air bag suppliers from working with small volume manufacturers.
The agency has carefully tracked occupant fatalities resulting from
air bag deployment. Our data indicate that the agency's efforts in the
area of consumer education and manufacturers' providing depowered air
bags were successful in reducing air bag fatalities even before
advanced air bag requirements were implemented.
As always, we are concerned about the potential safety implication
of any temporary exemptions granted by this agency. In the present
case, we are addressing a petition for a temporary
[[Page 68889]]
exemption from the advanced air bag requirements submitted by a
manufacturer of low volume, exotic sports cars.
II. Overview of Petition for Economic Hardship Exemption
In accordance with 49 U.S.C. 30113 and the procedures in 49 CFR
part 555, YES! Sportscars has petitioned the agency for a temporary
exemption from certain advanced air bag requirements of FMVSS No. 208.
The basis for the application is that compliance would cause
substantial economic hardship \4\ to a manufacturer that has tried in
good faith to comply with the standard. The agency closely examines and
considers the information provided by manufacturers in support of these
factors, and, in addition, pursuant to 49 U.S.C. 30113(b)(3)(A),
determines whether exemption is in the public interest and consistent
with the Safety Act.\5\
---------------------------------------------------------------------------
\4\ When considering financial matters involving companies based
in the European Union (EU), it is important to recognize that EU and
U.S. accounting principles have certain differences in their
treatment of revenue, expenses, and profits. Public statements by EU
manufacturers relating to financial results should be understood in
this context. This agency analyzes claims of financial hardship
carefully and in accordance with U.S. accounting principles.
\5\ The Safety Act is codified as Title 49, United States Code,
Chapter 301.
---------------------------------------------------------------------------
A manufacturer is eligible to apply for a hardship exemption if its
total motor vehicle production in its most recent year of production
did not exceed 10,000 vehicles, as determined by the NHTSA
Administrator (49 U.S.C. 30113). In determining whether a manufacturer
of a vehicle meets that criterion, NHTSA considers whether a second
vehicle manufacturer also might be deemed the manufacturer of that
vehicle. The statutory provisions governing motor vehicle safety (49
U.S.C. Chapter 301) do not include any provision indicating that a
manufacturer might have substantial responsibility as manufacturer of a
vehicle simply because it owns or controls a second manufacturer that
assembled that vehicle. However, the agency considers the statutory
definition of ``manufacturer'' (49 U.S.C. 30102) to be sufficiently
broad to include sponsors, depending on the circumstances. Thus, NHTSA
has stated that a manufacturer may be deemed to be a sponsor and thus a
manufacturer of a vehicle assembled by a second manufacturer if the
first manufacturer had a substantial role in the development and
manufacturing process of that vehicle.
Finally, while 49 U.S.C. 30113(b) states that exemptions from a
Safety Act standard are to be granted on a ``temporary basis,'' \6\ the
statute also expressly provides for renewal of an exemption on
reapplication. Manufacturers are nevertheless cautioned that the
agency's decision to grant an initial petition in no way predetermines
that the agency will repeatedly grant renewal petitions, thereby
imparting semi-permanent exemption from a safety standard. Exempted
manufacturers seeking renewal must bear in mind that the agency is
directed to consider financial hardship as but one factor, along with
the manufacturer's on-going good faith efforts to comply with the
regulation, the public interest, consistency with the Safety Act,
generally, as well as other such matters provided in the statute.
---------------------------------------------------------------------------
\6\ 49 U.S.C 30113(b)(1).
---------------------------------------------------------------------------
III. YES! Sportscars
Background. YES! Sportscars is a division of Funke & Will
Aktiengesellschaft (AG), a German corporation formed in 2000. Funke &
Will AG is a specialized engineering firm which offers engineering
services to the automobile industry on small volume projects. Although
the parent company's two founders together own 85 percent of the
corporation's shares, the German state of Saxony does have a 15-percent
ownership stake.\7\
---------------------------------------------------------------------------
\7\ According to the petitioner, the German state government
took an ownership interest in the firm in exchange for subsidies for
capital investment in facilities and equipment. According to YES!
Sportscars, these subsidies cannot be used for operational
expenditures and research and development funding.
---------------------------------------------------------------------------
YES! Sportscars, a separate vehicle manufacturing part of the
company, began production in 2001 of high-performance sports cars based
on an aluminum spaceframe. This application concerns the YES! Roadster
(currently the company's only model) which is expected to retail for
$59,000. To date, the primary markets for the YES! Roadster have been
Europe and the Middle East, with the following numbers of vehicles
being produced over the past five years: 12 vehicles in 2001; 37
vehicles in 2002; 42 vehicles in 2003; 48 vehicles in 2004, and 54
vehicles in 2005. None of those vehicles has been sold in the U.S.
market.
According to the petition, the company had originally planned to
prospectively produce vehicles for the European, Mid-East, and Far-East
markets, but it has been determined to be a matter of financial
necessity for YES! Sportscars to enter the U.S. market, particularly
given the limited but global market for these high-end sports cars. The
company anticipates that approximately 65 percent of its total sales
will be to the U.S. market.
As discussed in further detail below, the petitioner argued that it
tried in good faith, but could not bring the vehicle into compliance
with the advanced air bag requirements, and would incur substantial
economic hardship if it cannot sell vehicles in the U.S. after
September 1, 2006.
Eligibility. As discussed in the petition, YES! Sportscars is a
division of Funke & Will AG, a German corporation formed in 2000. The
entire organization currently employs 49 people. No other vehicle
manufacturer has an ownership interest in either YES! Sportscars or
Funke & Will AG, and the reverse is likewise true. Stated another way,
YES! Sportscars is an independent automobile manufacturer which does
not have any common control or is otherwise affiliated with any other
vehicle manufacturer.
The company is a small volume manufacturer whose total production
has ranged from 12 to 54 vehicles per year over the period from 2001 to
2005. According to its current forecasts, YES! Sportscars anticipates
that approximately 250 vehicles would be imported into the U.S. during
the three-year period for its requested exemption, if such request were
granted.
Requested exemption. YES! Sportscars stated that it intends to
certify the YES! Roadster as complying with the rigid barrier belted
test requirement using the 50th percentile adult male test dummy set
forth in S14.5.1 of FMVSS No. 208. The petitioner stated that it
previously determined the YES! Roadster's compliance with rigid barrier
unbelted test requirements using the 50th percentile adult male test
dummy through the S13 sled test using a generic pulse rather than a
full vehicle test. YES! Sportscars stated that it, therefore, cannot at
present say with certainty that the YES! Roadster will comply with the
unbelted test requirement under S14.5.2, which is a 20-25 mph rigid
barrier test.
As for the YES! Roadster's compliance with the other advanced air
bag requirements, YES! Sportscars stated that it does not know whether
the YES! Roadster will be compliant because to date it has not had the
financial ability to conduct the necessary testing.
As such, YES! Sportscars is requesting an exemption for the YES!
Roadster from the rigid barrier unbelted test requirement with the 50th
percentile adult male test dummy (S14.5.2), the rigid barrier test
requirement using the 5th percentile adult female test dummy (belted
and unbelted, S15), the offset
[[Page 68890]]
deformable barrier test requirement using the 5th percentile adult
female test dummy (S17), the requirements to provide protection for
infants and children (S19, S21, and S23) and the requirement using an
out-of-position 5th percentile adult female test dummy at the driver
position (S25).
YES! Sportscars stated its intention to produce a second generation
of the YES! Roadster by September 1, 2009, which would be certified as
complying with all applicable U.S. standards, including the advanced
air bag requirements. Accordingly, the company is requesting an
exemption from the above-specified requirements of FMVSS No. 208 for
the period from September 1, 2006 to August 31, 2009.
Economic hardship. Publicly available information and also the
financial documents submitted to NHTSA by the petitioner indicate that
the YES! Roadster project will result in financial losses unless YES!
Sportscars obtains a temporary exemption.
Over the period 2001-2005, the YES! Sportscars division of Funke &
Will AG has experienced net operational losses totaling $618,000
(484,000 euros at an exchange rate of 1 euro = $1.277).\8\ As of the
time of the application, YES! Sportscars has invested over $3.0 million
on the design, development, and homologation of the YES! Roadster
project in order to have the vehicle meet U.S. standards--not including
the advanced air bag requirements which are the subject of the present
petition for temporary exemption. The company has stated that it cannot
hope to attain profitability if it incurs additional research and
development expenses at this time.
---------------------------------------------------------------------------
\8\ According to the YES! petition, the engineering portion of
Funke & Will AG has made a modest profit in the past few years, but
in total, such profits would only amount to 45 percent of the
funding needed to finance the requisite advanced air bag work.
---------------------------------------------------------------------------
YES! Sportscars stated that costs associated with advanced air bag
engineering and development (including research and development,
testing, tooling, and test vehicles) have been estimated to be $1.7
million (including internal costs). In its petition, YES! Sportscars
reasoned that sales in the U.S. market must commence in order to
finance this work and that non-U.S. sales alone cannot generate
sufficient income for this purpose. In essence, YES! Sportscars argued
that the exemption is necessary to allow the company to ``bridge the
gap'' until fully compliant vehicles can be funded, developed, tooled,
and introduced for the U.S. market.
If the exemption is denied, YES! Sportscars projects a net loss of
$1.1 million over the period from 2006-2008 (assuming a delayed start
of U.S. sales until 2008). However, if the petition is granted, the
company anticipates a profit of nearly $1.4 million during that same
period. The petitioner argued that a denial of this petition could
preclude financing of the project for USA-compliant vehicles, a
development which would have a highly adverse impact on the company.
Good faith efforts to comply. As stated above, YES! Sportscars
initially planned to produce vehicles for the European, Mid-East, and
Far-East markets, but once it was determined in 2005 that entry into
the U.S. market was a necessary part of its business plan, the company
invested over $3.0 million on research and development and tooling for
its U.S. YES! Roadster program (including adoption of a U.S.-certified
engine and drive train). In that time, the company was able to bring
the vehicle into compliance with all applicable NHTSA regulations,
except for the advanced air bag provisions of FMVSS No. 208.
In light of limited resources, the petitioner stated that it was
necessary to first develop the vehicle with a standard U.S. air bag
system. The company has spent over $630,000 to reengineer the YES!
Roadster to include a standard air bag system, which it stated will
then be ``expanded'' into an advanced air bag system.
According to its petition, even though advanced air bags are beyond
its current capabilities, YES! Sportscars is nonetheless planning for
the introduction of these devices. The company stated that Siemens
Restraint Systems will spearhead this effort, and current plans
estimate a cost of $1.1 million (excluding internal costs) and a
minimum lead time of 24 months for the advanced air bag project. YES!
Sportscars stated that the following engineering efforts are needed to
upgrade the YES! Roadster's standard air bag system to an advanced air
bag system: (1) Interior redesign work to the dashboard, steering
column, and electronic systems; (2) sourcing and organization of
supplier and engineering personnel and resources for development work
(including sensor calibration); (3) construction of prototypes, and (4)
testing.
In addition, YES! Sportscars stated that finding suppliers willing
to work with a manufacturer with very low production volumes has proven
extremely difficult, and as a result, the company must wait for
technology to ``trickle down'' from larger manufacturers and suppliers.
YES! Sportscars further stated that small volume manufacturers simply
do not have the internal resources to do full U.S. homologation
projects without reliance on outside suppliers of advanced engineering
technologies.
In short, YES! Sportscars argued that, despite good faith efforts,
limited resources prevent it from bringing the vehicle into compliance
with all applicable requirements, and it is beyond the company's
current capabilities to bring the vehicle into full compliance until
such time as additional resources become available as a result of U.S.
sales. With funding from the sale of the current generation of YES!
Roadsters, the company expects that additional development efforts
could start in 2007, thereby allowing introduction of a fully compliant
vehicle in September 2009.
YES! Sportscars argues that an exemption would be in the public
interest. The petitioner put forth several arguments in favor of a
finding that the requested exemption is consistent with the public
interest and would not have a significant adverse impact on safety.
Specifically, YES! Sportscars argued that the vehicle would be equipped
with a fully-compliant standard U.S. air bag system (i.e., one meeting
all requirements of FMVSS No. 208 prior to implementation of S14).
Furthermore, the company emphasized that the YES! Roadster will comply
with all other applicable FMVSSs.
The company asserted that granting the exemption will benefit U.S.
employment, companies, and citizens, because YES! Roadsters will be
sold and serviced through a network of U.S. dealers. YES! Sportscars
also argued that denial of the exemption request would have an adverse
impact on consumer choice, suggesting that there is domestic demand for
a performance vehicle in the YES! Roadster's price range. The company
also argued that an exemption is unlikely to have a significant safety
impact because these vehicles are not expected to be used extensively
by their owners, due to their ``second vehicle'' nature and
``minimalist design.'' The company also reasoned that given the nature
of the vehicle, it is less likely to be used to transport young
children than most other vehicles.
As an additional basis for showing that its requested exemption
would be in the public interest, YES! Sportscars stated that the YES!
Roadster has an extremely strong and protective chassis, which is
composed of aluminum tubes and composite structure parts. According to
YES! Sportscars, the
[[Page 68891]]
vehicle design is such that occupants are effectively placed in a
``protective `cell' '' with the chassis structure built around them.
Agency Decision on YES! Sportscars Petition. We are granting the
YES! Sportscars petition to be exempted from portions of the advanced
air bag regulation required by S14.2 (specifically S14.5.2, S15, S17,
S19, S21, S23, and S25). The exemption does not extend to the provision
requiring a belted 50th percentile male barrier impact test
(S14.5.1(a)). In addition to certifying compliance with S14.5.1(a),
YES! Sportscars must continue to certify to the unbelted 50th
percentile barrier impact test in force prior to September 1, 2006
(S5.1.2(a)). We note that the unbelted sled test in S13 is an
acceptable option for that requirement. The agency's rationale for this
decision is as follows.
The advanced air bag requirements present a unique challenge
because they would require YES! Sportscars to undertake a major
redesign of its vehicles, in order to overcome the engineering
limitations of the YES! Roadster. Specifically, YES! Sportscars would
be required to undertake significant interior redesign in order to
upgrade the vehicle's standard air bag system to an advanced air bag
system. While the petitioner was aware of the new requirements for some
time, its business plans did not initially involve sales in the U.S.
However, YES! Sportscars subsequently determined that it would be
necessary to introduce the YES! Roadster into the U.S., thereby raising
the problem of compliance with the advanced air bag requirements. Once
the determination was made to seek entry into the U.S. market, YES!
Sportscars undertook significant homologation efforts in order to meet
applicable U.S. requirements, but compliance with the advanced air bag
provisions of FMVSS No. 208 were beyond the company's capabilities at
the present time. YES! Sportscars plans to utilize proceeds from sales
of the current generation of YES! Roadsters to finance the development
of a fully compliant successor vehicle.
YES! Sportscars explained the main engineering challenges
precluding incorporation of advanced air bag into the YES! Roadster at
this time, as follows. The company must undertake redesign work to the
vehicle's dashboard, steering column, and electronic systems.
Furthermore, the petitioner stated that it would need additional time
to work with an advanced air bag supplier, because very low volume
manufacturers have had to wait for technology to ``trickle down'' from
larger manufacturers and suppliers. YES! Sportscars has made clear that
such a prospect would pose a unique challenge to the company, due to
the high cost of development and its extremely small sales volumes.
Based upon the information provided by the petitioner, we
understand that YES! Sportscars made good faith efforts to bring the
YES! Roadster into compliance with the applicable requirements until
such time as it became apparent that there was no practicable way to do
so. As a small specialty manufacturer, the company had a difficult time
in gaining access to advanced air bag systems and components (which
presumably reflects restraint system suppliers' initial focus on
meeting the needs of large volume manufacturers), so alternative means
of compliance were not available as a practical matter. Small
manufacturers such as YES! Sportscars are dependent upon air bag
suppliers for the engineering expertise and technology transfer
necessary for compliance with FMVSS No. 208. This further reduced the
lead time available for development.
Furthermore, because YES! Sportscars is an independent automobile
manufacturer, there was no possibility of technology transfer from a
larger parent company that also manufactures motor vehicles.
Consequently, no viable alternatives remain. The petitioner is unable
to redesign its vehicle in time to meet the new advanced air bag
requirements that became effective on September 1, 2006.
After review of the income statements provided by the petitioner,
the agency notes that the company has faced ongoing financial
difficulties, experiencing net operating losses of about $618,000
(484,000 euros) over the past five years (2001-2005). The company was
not profitable in any year during that period. If the petitioner's
request for a temporary exemption is denied, the company will be
precluded from selling any vehicles in the U.S. market at this time.
The resulting loss of sales would cause substantial economic hardship
within the meaning of the statute, potentially amounting to the
difference between a profit of nearly $1.4 million (if an exemption is
granted) and a loss of $1.1 million (if an exemption is denied) over
the period from 2006-2008. Ultimately, denial of the exemption request
could preclude development of a U.S.-compliant vehicle and jeopardize
the continued existence of YES! Sportscars.
According to YES! Sportscars, absent the exemption, the company
anticipates being unable to enter the U.S. market during the period
from 2006-2008. However, YES! Sportscars' problems would be compounded
without its requested temporary exemption, because it needs the revenue
from sales of the YES! Roadster over the next two years to finance
development of a fully compliant vehicle for delivery to the U.S.
market. Granting the exemption will allow YES! Sportscars to earn the
resources necessary to bridge the gap in terms of development of a
successor vehicle for the current YES! Roadster that meets all U.S.
requirements.
While some of the information submitted by YES! Sportscars has been
granted confidential treatment and is not detailed in this document,
the petitioner made a comprehensive showing of its good faith efforts
to comply with the requirements of S14.2 of FMVSS No. 208, and detailed
engineering and financial information demonstrating that failure to
obtain the exemption would cause substantial economic hardship.
Specifically, the petitioner provided the following:
1. Chronological analysis of YES Sportscars' efforts to comply,
showing the relationship to the rulemaking history of the advanced air
bag requirements.
2. Itemized costs of each component that would have to be modified
in order to achieve compliance.
3. Discussion of alternative means of compliance and reasons for
rejecting these alternatives.
4. A detailed OEM price-volume quotation from an advanced air bag
supplier, including detailed costs for the necessary components for
each stage of the development program.
5. Explanations as to why components from newer, compliant vehicle
lines could not be borrowed.
6. Corporate income statements and balance sheets for the period
from 2000-2005, and projected profits for the period from 2006-2008
(analyzing alternative scenarios in which the petition is granted and
denied).
While noting that reduction of sales revenue resulting from a
denial of the company's requested temporary exemption would have a
negative impact on YES! Sportscars' financial circumstances, we also
sought to evaluate a denial's affect on U.S. employment, in light of
the company's statement that it anticipates selling the YES! Roadster
through a network of U.S. dealers. Traditionally, the agency has
concluded that the public interest is served in affording continued
employment to the petitioner's U.S. work force. As a corollary, the
agency also may consider prospective employment gains as part of its
analysis of what is in the public interest.
[[Page 68892]]
However, YES! Sportscars provided no information on prospective U.S.
dealers, projected sales per outlet, or employment. Thus, it is
difficult to assess the likely employment impacts associated with
granting the petition, as any such conclusions would be largely
speculative.
We believe that this exemption will have negligible impact on motor
vehicle safety because of the limited number of vehicles affected
(approximately 250 imported for the duration of the exemption).
Furthermore, as discussed in previous decisions on temporary exemption
applications, the agency believes that the public interest is served by
affording consumers a wider variety of motor vehicle choices.
We note that, as explained below, prospective purchasers will be
notified that the vehicle is exempted from the specified advanced air
bag requirements of Standard No. 208. Under Sec. 555.9(b), a
manufacturer of an exempted passenger car must affix securely to the
windshield or side window of each exempted vehicle a label containing a
statement that the vehicle conforms to all applicable Federal motor
vehicle safety standards in effect on the date of manufacture ``except
for Standard Nos. [listing the standards by number and title for which
an exemption has been granted] exempted pursuant to NHTSA Exemption
No.--.'' This label notifies prospective purchasers about the exemption
and its subject. Under Sec. 555.9(c), this information must also be
included on the vehicle's certification label.
The text of Sec. 555.9 does not expressly indicate how the
required statement on the two labels should read in situations where an
exemption covers part but not all of a Federal motor vehicle safety
standard. In this case, we believe that a statement that the vehicle
has been exempted from Standard No. 208 generally, without an
indication that the exemption is limited to the specified advanced air
bag provisions, could be misleading. A consumer might incorrectly
believe that the vehicle has been exempted from all of Standard No.
208's requirements. Moreover, we believe that the addition of a
reference to such provisions by number without an indication of its
subject matter would be of little use to consumers, since they would
not know the subject of those specific provisions. For these reasons,
we believe the two labels should read in relevant part, ``except for
S14.5.2, S15, S17, S19, S21, S23, and S25 (Advanced Air Bag
Requirements) of Standard No. 208, Occupant Crash Protection, exempted
pursuant to * * *.'' We note that the phrase ``Advanced Air Bag
Requirements'' is an abbreviated form of the title of S14 of Standard
No. 208. We believe it is reasonable to interpret Sec. 555.9 as
requiring this language.
In sum, the agency concludes that YES! Sportscars has demonstrated
good faith effort to bring the YES! Roadster into compliance with the
advanced air bag requirements of FMVSS No. 208, and has also
demonstrated the requisite financial hardship. Further, we find the
exemption to be in the public interest.
In consideration of the foregoing, we conclude that compliance with
the advanced air bag requirements of FMVSS No. 208, Occupant Crash
Protection, would cause substantial economic hardship to a manufacturer
that has tried in good faith to comply with the standard. We further
conclude that granting of an exemption would be in the public interest
and consistent with the objectives of traffic safety.
In accordance with 49 U.S.C. 30113(b)(3)(B)(i), the YES! Roadster
is granted NHTSA Temporary Exemption No. EX 06-9, from S14.5.2, S15,
S17, S19, S21, S23, and S25 of 49 CFR 571.208. The exemption is
effective from September 1, 2006 to August 31, 2009.
Issued on: November 21, 2006.
Nicole R. Nason,
Administrator.
[FR Doc. E6-20091 Filed 11-27-06; 8:45 am]
BILLING CODE 4910-59-P