Author: Subaru of America

Don Bearden
Director of Governmental Affairs
Direct Dial: (856) 488-8644
Fax: (856) 488-3255
E-Mail: dbearden@subaru.com										

							February 12, 2001
							Ref. No. GA01-012C

Docket Management
Room PL-401
National Highway Traffic Safety Administration
400 Seventh Street, S.W.
Washington, D.C. 20590

Re:	Docket No. NHTSA-00-8248; RIN 2127-AF36; Federal Motor Vehicle Safety Standards; Fuel System Integrity, Notice of Proposed Rule-Making

Gentlemen:

Subaru of America, Inc. (Subaru), the distributor for Subaru vehicles in the USA, on behalf of Fuji Heavy Industries Ltd. (FHI), the manufacturer of Subaru vehicles, submits the following comments in response to the subject Notice of Proposed Rulemaking (NPRM) on Fuel System Integrity, FMVSS 301.  Subaru reserves the right for further submission of comments specific to detailed rulemaking issues not incorporated within the NPRM.  Such issues would include protocols for testing, methodology and details omitted from the NPRM as practicable for compliance with the Final Rule.

COMMENTS
Subaru supports NHTSA’s intent to upgrade safety by enacting new and more stringent rear impact test procedures including higher speed and changes to the barrier.  However, we are concerned about the very short lead-time for the new rear impact test requirements.  
NHTSA stated in the preamble that the design changes necessary to meet the new requirements were moderate and not requiring retooling.  Subaru believes that major design changes, including retooling, are necessary for rear floor and frame structures of all of our car lines.  In addition, the fuel system routing also will require redesign to meet the requirements of the proposed new regulation.  
NHTSA indicated that “a lead time of about 27 months is reasonably necessary" however, because this rulemaking will require a large-scale body redesign for all our car lines, Subaru strongly requests that phase-in for this rulemaking begin at the earliest from September 1, 2005 with a 3-year full phase-in (100% compliance after September 1, 2007).

We appreciate the opportunity to offer our comments.

Sincerely,

SUBARU OF AMERICA, INC.

Don Bearden, Director
Governmental Affairs

DB:ds