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Discussion in 'General Car Discussions' started by JDM lover, Nov 30, 2006.

  1. JDM lover

    JDM lover Member

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    Nov 4, 2006
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    cars to the states.

    If a car model has not previously been determined to be eligible for importation (see http://www.nhtsa.dot.gov/cars/rules...t/ELIG0206.html for the current list), then the RI must submit a petition to NHTSA requesting a determination that the car model is eligible. There are two possible routes to eligiblity: the RI demonstrates that the model he wants to import is substantially similar to a USDM model and can be easily modified to conform to FMVSS (Federal Motor Vehicle Safety Standards) and Bumper standards, or the RI can demonstrate with (destructive) tests, that the car model can be modified to conformance. Obviously, the Lancer petition can be expected to invoke the "substantially similar" provision.

    Here's an outline of the NHTSA process:
    1) RI determines what must be changed on the imported car to achieve FMVSS and Bumper compliance. This ususally involves some disassembly and comparison with the USDM version. Access to manufacturer's parts catalogs for both versions are extremely helpful.
    2) RI submits a petition to NHTSA documenting exactly what he'll change to achieve compliance.
    3) NHTSA reviews petition for deficiencies and once they are all resolved, publishes a notice in the Federal Register soliciting comments on the petition. You can search the Federal Register for such notices at http://www.access.gpo.gov/su_docs/aces/aces140.html. I typicaly use the phrase "Notice of Receipt of Petition for Decision That Nonconforming" (the quotation marks are important) and I tick the "Notices" box and, to speed things up since I search regularly, I indicate and "After" date.
    4) Once the Notice is published, NHTSA sets up a "docket" (think file folder) for the petition in which (theoreticly) all documents related to the petition are placed. You can search for NHTSA dockets at http://dms.dot.gov/search/searchFormSimple.cfm.
    5) Normally, the period in which NHTSA will accept comments is limited to 30 days. However, if comments ARE received, then the petitioner is given an opportunity to respond to those comments. And then those who contributed comments are invited to respond to the petitioner's response. And, finally, the petitioner is allowed a final response/rebuttal.
    6) Finally, after a couple of months spent digesting the docket's information, the NHTSA announces a decision, again published in the Federal Register.

    So, let's look at a few NHTSA dockets for insight into the process and its length.

    First, to get it out of the way, is the Nissan Skyline GTR docket, http://dms.dot.gov/search/searchRes...umberValue=5507. This docket is distinctive in many ways. First, note the word "Skyline" is never used. The petition originated from J.K. Motors in Baltimore, not Motorex (since then, Motorex has become an RI). Four cars were crashed as part of the testing, since there was no "substantially similar" USDM Nissan. Some of the interior cabin modifications necessary for compliance were withheld from the public docket as "proprietary" information (how does one comment on that?). In any event, there were no public comments, probably due to the fact that Nissan had no intention of ever importing Skylines to the US and, therefore, felt no need to "protect" its importer/dealer network. I have never noticed any other successful petition that required crash tests.
    Nov 20, 1998 - Rear crash and gas tank rollover tests performed
    Mar 24, 1999 - Petition submitted
    Jan 19, 2000 - Petition approved

    And here's a sad story, the petition for the 1999-2000 Porsche GT3.
    May 8, 2000 - Petition Submitted
    Oct 6, 2000 - Notice Published
    Aug 1, 2001 - Petition Denined
    Notice that this took about 15 months, only to receive a denial.

    As an aside: What happens when a petition is denied? NHTSA rules require that the imported vehicle(s) be either exported or "abandoned" to the U.S. government. Here's a notice that NHTSA sent to its RIs back in 1994 (see http://www.nhtsa.dot.gov/cars/rules...rs/mviinl05.htm):quote:
    Be aware of the risk involved if you proceed to modify a vehicle while its eligibility petition is under consideration. In the event your petition is denied, the vehicle will have to be exported or destroyed under Customs supervision regardless of how much time and effort you may have invested in it. The surety will also be notified of its potential liability under the bond.

    Getting back to the dockets, here are a couple of petitions submitted by G&K, the folks doing the Lancer conversions.

    1997-98 Ferrari 456 GT and GTA
    Feb 14, 2002 - Petition Submitted
    May 3, 2002 - Notice published
    Jun 3, 2002 - Ferrari submits comments
    Jul 1, 2002 - Ferrari responds to G&K's response to Ferrari's comments
    Jul 25, 2002 - G&K Responds to Ferrari's latest response.
    Today - Awaiting NHTSA decision

    2002 Ferrari 360s Manufactured before September 1, 2002
    May 28, 2002 - Petition submitted
    Sep 10, 2002 - Notice published
    Oct 17, 2002 - Ferrari submits comments
    Today - Awaiting G&K's response to Ferrari's comments

    And here's a really wild petition:
    2001 Ferrari 360 cars
    As you can see, people crawled out the woodwork to respond to this petion. NHTSA, in its comments about approving the petition said:quote:
    the granting of the petition. One comment, from an individual identifying himself as ‘‘James A. Linder’’ and stating that he represented
    the ‘‘Original Automobile Manufacturer’s Association’’ of Concord, New Hampshire, which the agency has learned is a fictitious entity, raised general objections concerning the registered importer program and its impact on fabricating manufacturers, but did not directly address the subject of the petition—whether non-U.S. certified 2001 Ferrari 360 passenger cars are eligible for importation. As a consequence, the agency is not responding to this comment in this notice.
    Sadly, this comment has been excised from the docket. This is what happens whem somebody like me makes a post like this in some forum.

    So, how long should all this take?

    Back in 1996, NHTSA warned its RIs in a newsletter:


    Importation of a vehicle that is readily modifiable and substantially similar to U.S. model that is not already on the list of vehicles determined eligible for importation takes time to process and modify. DO NOT tell a prospective customer that they can have their vehicle in 6-8 weeks. A more realistic time frame is 3-5 months before they will have their vehicle to drive on the highway.
    It now appears that the time to delivery has increased. The most recent NHTSA announcement of petition approvals, on Sep 10, 2002, shows that the most recent quickest time from petition announcement to petition approval is approximately 3 months (no comments received). This was recorded for the 1999-2002 Mercedes Benz S-Class petition (see docket http://dms.dot.gov/search/searchRes...mberValue=12316).
  2. Deibidosan

    Deibidosan Active Member

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    Jul 21, 2006
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    this is very interesting. couldnt they just study the crash test information from japan. and save a car from the crash test. those guys are smart, they could figure it out from the information that, im sure, japan very strictly recorded. maybe someday it will be ok to drive your RHD converted cars w/o getting harassed but the hogs. thats just the man tryin to keep people in line. my 2 cents! :)
  3. 97-ferio

    97-ferio Active Member

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    Jul 11, 2006
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  4. JussHatched

    JussHatched Active Member

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    May 12, 2006
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    Interesting information, but this must be pretty old because none of the links work :(
  5. JDM lover

    JDM lover Member

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    Nov 4, 2006
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    yeah its an oldie
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