**Docket No. NHTSA-2008-0015**

**RIN 2127-AG51**

**Federal Motor Vehicle Safety Standards;**

**Roof Crush Resistance**

1.  **Weight is irrelevant all manufacturers' feet should be held to the
    fire to produce safe fleets of vehicles.**

Choosing differing standards for roof crush capabilities for different
weight class vehicles makes little sense when the goal of these new
standards is to protect passengers in rollover accidents.

First, vehicles such as "Super-Duty" trucks, large SUVs, and passenger
vans which often have curb weights over 6000 pounds are much more likely
to rollover than are passenger cars. The vehicles are further more
dangerous because they have higher payload and/or passenger capacities
than passenger cars. For example, 15 passenger vans, as this agency
already knows, are particularly rollover prone especially when compared
to normal passenger cars. These vehicles have the added dangers of
carrying large numbers of people and being driven by average or lesser
experienced drivers. If this agency chooses a lesser standard for the
roof strength of these vans, it is only perpetuating a deadly problem
rather than correcting it.

Next, it is important to look at what the overall cost benefit analysis
would be when suggesting the increase in overall safety. While I have
not done an in depth analysis of the tooling, and weight costs, I find
the Explorer example telling. In that example, the overall cost to
improve the roof strength of the Explorer to that of the XC90 would only
cost \$81 per vehicle. Even if that cost were quadrupled, the public
would hardly be affected in terms of actual purchase price. Rarely,
would a new car buyer choose a less safe car in order to save three to
five hundred dollars. Especially when the average cost of the 6000 lb+
category of vehicles exceeds \$30,000. Further, when many of these
vehicles are being purchased by churches and schools, this limited cost
of protecting passengers is hardly unjustified. Ford Motor Company
states that, "cost considerations should never preclude improving the
state of the art in safety." This mantra should be central to the
decision of this agency for the protection of the citizens of this
country.

Finally, vehicle manufacturers such as Ford, Chrysler, and GM who do
business worldwide can hardly balk at the idea of making vehicle roofs
stronger, when they do so for European customers routinely. For example,
the XC90, a vehicle manufactured while Ford owned Volvo and sold
throughout the world, has an impressively strong roof structure in
comparison to the Explorer which is manufactured and marketed here in
the United States.

2.  **The monetary cost implications of the two sided program versus the
    single sided program are *de minimus* when weighed against the lives
    which could be saved.**

The two sided testing program for roof strength, while still
insufficient, is a much better indicator of how a vehicle will perform
when subjected to a rollover situation than a single side test. These
dynamic and fluid events produce enormous forces on various parts of the
vehicle throughout the event. It is very important to consider that many
times the vehicle does not simply impact one side or even one angle of
the roof structure during the rollover event; rather in the most extreme
rollovers it impacts numerous areas of the roof, the body, and the
chassis. This agency's own testing has demonstrated that the roof
strength on the second side is significantly reduced after the first
side test. This strength loss directly correlates to roof crush in
severe rollover events. In fact, in many real world accidents, the
source of roof crush is not the first impact, but rather the latter
impacts after the roof structure has been significantly weakened by the
first.

The cost benefit analysis of this program has already been demonstrated
by the Volvo XC90 versus Explorer example proffered in the request for
comments. When the overall cost per vehicle to move a vehicle from
barely passing the current "resistance to roof crush standards" to
surviving the most rigorous tests in the industry being less than \$100,
it seems a price too low not to bear.

Finally, this agency should consider the effect of the vehicle glazing
on this standard. For example, the agency noted that it stopped testing
several times once the windshield cracked. What happens, though, when
the windshield is expelled during a rollover event? What structural
strength is lost due to this? Often during multiple rollover events, any
and all glazing gives way significantly reducing the roof strength of
the vehicle. This should lead to the logical conclusion that
manufacturers should test these vehicles without windshields or glazing
to provide an analysis of the "worst case scenario" rather than the
best.

3.  **Manufacturers already use different design strategies for
    producing vehicles of differing weights simply due to their
    differing tasks.**

Manufacturers currently utilize different design strategies for the roof
structures of SUVs as compared to passenger cars. Further Ford utilizes
different strategies for its vehicles than do GM and Chrysler. The
necessity for different design strategies is not an undue onus on the
auto manufacturers, but a fact of doing business. For example, a
construction company is not likely to want a passenger car to move heavy
equipment; nor is a soccer mom likely to want a two seat sports car to
transport her children around. Simply put manufacturers build vehicles
with different design strategies now in order to meet federal
regulations and corporate goals. The debate over whether different
design strategies will be required is moot; they will. Further, the cost
consideration should be left to corporate boards to consider when
choosing which platforms to pursue, and what to price them.

Respectfully Submitted,

Jason Robinson