Evo VIII NHTSA Import Petition Announced
Jun 30, 2003, 03:03 PM
#17
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Originally posted by Celm
Senor do u have to nit-pick everything that has to do w/the JDM evos or E.I?Who cares worry about your self.if someone want to waste there $ as you say at E.I,let them!!Who cares,its not going to feed you,its not going to put money in your pocket.you guys arent going to buy evos from E.I,so why worry and make a big fuss about it.Everyone here is a grown up and have free will to do what ever they want to do in there life
Senor do u have to nit-pick everything that has to do w/the JDM evos or E.I?Who cares worry about your self.if someone want to waste there $ as you say at E.I,let them!!Who cares,its not going to feed you,its not going to put money in your pocket.you guys arent going to buy evos from E.I,so why worry and make a big fuss about it.Everyone here is a grown up and have free will to do what ever they want to do in there life
Some folks here might not be up to downloading the 3.5 meg petition and wading through an 87 page file. So I've reported some of its "highlights" which I guess is considered nitpicking in some quarters. Here's another "highlight" - the petition from G&K is dated June 1, 2003 (see page 3). So who should be faulted for any delay? Evolution Imports claims the fault lies completely with the NHTSA.
Elsewhere on page 3 one finds a statement of the basis of the petition. In addition to the already mention Evo 7 service manuals, the petition cites Mitsubishi press releases. There is only one press release (from Jan 2, 2003) in which a comparsion of the US-spec Evo to a non-US version is made and it says (on page 73 of the petition)
Lancer Evolution VIII marks the introduction of the series in the U.S. market where there has been considerable interest in the series for several years. MMC plans to phase Lancer Evolution into its model lineup in other world markets in the near future.
Having commenced shipments of Lancer Evolution VIII to the United States, MMC decided to give the model its world debut at the Los Angeles Show ahead of its unveiling on the Japanese domestic market, scheduled for early 2003.
The U.S. market specification Lancer Evolution VIII derives from the Japanese market Lancer Evolution VII GSR. While sharing major parts and components with the upcoming Japanese market Evolution VIII, the U.S. model has been developed exclusively for the U.S. to meet crashworthiness and emissions requirements, user needs and preferences, and road and traffic conditions in that market. With a price tag of under US$30,000, Lancer Evolution VIII offers unmatched driving pleasure.
Having commenced shipments of Lancer Evolution VIII to the United States, MMC decided to give the model its world debut at the Los Angeles Show ahead of its unveiling on the Japanese domestic market, scheduled for early 2003.
The U.S. market specification Lancer Evolution VIII derives from the Japanese market Lancer Evolution VII GSR. While sharing major parts and components with the upcoming Japanese market Evolution VIII, the U.S. model has been developed exclusively for the U.S. to meet crashworthiness and emissions requirements, user needs and preferences, and road and traffic conditions in that market. With a price tag of under US$30,000, Lancer Evolution VIII offers unmatched driving pleasure.
And anyone can offer their opinions to the NHTSA on this petition during the comment period. I encourage you to be a bit more brilliant than "James" was in his comment on the Smart micro car petition (see http://dms.dot.gov/search/searchResu...berValue=15428), which I believe I mentioned last week.
Here's how you do it. Go to http://dms.dot.gov/submit/. On the next page you'll want to fill in the following information:
Docket Number: NHTSA-2003-15470
Operating Administration: NHTSA
Docket Type: uncheck "Regulatory"
Docket Existence: check "Does Exist"
Document Title: your-name (or Anonymous) - Comments
Confidential: you decide whether you wish to remain anonymous
Submission Method: it is always better to attach a file which you've formatted and proof-read.
Jun 30, 2003, 03:50 PM
#18
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After reading the petition, my questions to G&K:
How do they plan on passing emissions? The only thing I saw concerning emissions was for the evaporative emissions canister (or whatever it's called) for the gas tank and that they would have to add one. What about the engine emissions?
I was under the impression that the US spec Evo required more than just a new bumper to pass the crash tests, i.e. pieces integral to the frame. Is this a bad assumption and if it isn't, how do they plan on rectifying it?
How do they plan on passing emissions? The only thing I saw concerning emissions was for the evaporative emissions canister (or whatever it's called) for the gas tank and that they would have to add one. What about the engine emissions?
I was under the impression that the US spec Evo required more than just a new bumper to pass the crash tests, i.e. pieces integral to the frame. Is this a bad assumption and if it isn't, how do they plan on rectifying it?
Jun 30, 2003, 03:55 PM
#19
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Downloaded and printed all 88 pages. Haven't gotten to do more than skim, but it's pretty neat. Unfortunately some parts are rather light because they seem to be all scanned original docs. There's some stuff in there that is far from necessary, but it's interesting to take a look at the actual paper work.
Jun 30, 2003, 03:58 PM
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Originally posted by RaX
After reading the petition, my questions to G&K:
How do they plan on passing emissions? The only thing I saw concerning emissions was for the evaporative emissions canister (or whatever it's called) for the gas tank and that they would have to add one. What about the engine emissions?
I was under the impression that the US spec Evo required more than just a new bumper to pass the crash tests, i.e. pieces integral to the frame. Is this a bad assumption and if it isn't, how do they plan on rectifying it?
After reading the petition, my questions to G&K:
How do they plan on passing emissions? The only thing I saw concerning emissions was for the evaporative emissions canister (or whatever it's called) for the gas tank and that they would have to add one. What about the engine emissions?
I was under the impression that the US spec Evo required more than just a new bumper to pass the crash tests, i.e. pieces integral to the frame. Is this a bad assumption and if it isn't, how do they plan on rectifying it?
G&K does not have access to a non-US 2003 LHD Evo VIII, since they do not exist. They're just guessing on the bumper issue (and everything else in their petition).
Jun 30, 2003, 04:23 PM
#22
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Originally posted by i_love_spool
Aren't they're already some Evo 6's and 7 in the US and Canada as rally vehicles?
Aren't they're already some Evo 6's and 7 in the US and Canada as rally vehicles?
Jun 30, 2003, 11:55 PM
#24
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Different states have different rules on kitcars. the entire "turnkey" car is not generally sold as one piece (unless it is already titled..aka..a used kitcar). They sell you the "parts" or a "roller" on one invoice, an engine, etc... on another invoice, then some labor on a 3rd invoice (you get the picture).... this prevents them from having to go through the normal crash testing, emissions, etc.......
I had a Westfield Megabusa built by a place called Alamosportscars in Texas who sent me 3-4 invoices. My state requires you to submit all of the invoices to prove you did not steal anything, along with pictures of the completed car.....along with a certified mechanics statement that the car is road legal and passes all common "inspection" rules....then they determine if it is worthy of getting a "VIN" number.
Bill Reilly (of Reilly and Scott) somehow pulled a "kitcar" trick with his Evo V. Not sure how, but he has $ to burn, so that may be a factor. Making an Evo (any version) into a kitcar just would not work here in Pennsylvania, unless you happened to know the person at the state DOT who approves kitcars.
That is my take on it...... How did I do Seņor?.... by the way... why is it Seņor instead of Seņior?
I had a Westfield Megabusa built by a place called Alamosportscars in Texas who sent me 3-4 invoices. My state requires you to submit all of the invoices to prove you did not steal anything, along with pictures of the completed car.....along with a certified mechanics statement that the car is road legal and passes all common "inspection" rules....then they determine if it is worthy of getting a "VIN" number.
Bill Reilly (of Reilly and Scott) somehow pulled a "kitcar" trick with his Evo V. Not sure how, but he has $ to burn, so that may be a factor. Making an Evo (any version) into a kitcar just would not work here in Pennsylvania, unless you happened to know the person at the state DOT who approves kitcars.
That is my take on it...... How did I do Seņor?.... by the way... why is it Seņor instead of Seņior?
Jul 1, 2003, 04:30 AM
#25
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Originally posted by Seņor Info
The "docket" is here. Currently, the only item in that docket is the petition itself. In a day or two, a copy of the Federal Register notice that was published today will be added. And, if any comments are received, then they, too, will be added to that docket.
The "docket" is here. Currently, the only item in that docket is the petition itself. In a day or two, a copy of the Federal Register notice that was published today will be added. And, if any comments are received, then they, too, will be added to that docket.
Originally posted by Seņor Info
Positive comments don't seem to have any effect but negative comments can substantially lengthen the process. An extreme example would be the failed petition for the 2000 Porsche 911 GT3 (its docket is here). Two negative comments were received during the 30-day comment period, one from Porsche Cars North America and one from "Anonymous." After the comment window closed, the petitioner was given an opportunity to respond to those comments. Then the two original comment-submitters were given an opportunity to respond to the petitioner's response. Then the petitioner was given an opportunity to respond to these new responses.
Positive comments don't seem to have any effect but negative comments can substantially lengthen the process. An extreme example would be the failed petition for the 2000 Porsche 911 GT3 (its docket is here). Two negative comments were received during the 30-day comment period, one from Porsche Cars North America and one from "Anonymous." After the comment window closed, the petitioner was given an opportunity to respond to those comments. Then the two original comment-submitters were given an opportunity to respond to the petitioner's response. Then the petitioner was given an opportunity to respond to these new responses.
It seems that the fact that the US representative of Porsche AG commented negatively on the petition is what got the petition denied; I would therefore guess that negative comments from MNA on the petition for the Euro spec Evo VIII would be the worst thing that could happen to this petition. Now, would such a petition approval be a positive or negative thing for MNA?
Furthermore, on http://www3.us.porsche.com/english/usa/home.htm you can see that the Porsche GT3 is for sale in the USA. In the technical specifications, you can see that tank capacity is 89 litres. I agree that that is not the only thing that needed changing to make the GT3 meet all the required standards, but it does sound a posteriori like Porsche NA wanted to keep the car from being sold in the USA by anybody but themselves.
What's Mitsubishi's position on the "Petition for Decision that Nonconforming 2003 Mitsubishi Evolution VIII, Left Hand Drive Passenger Cars Are Eligible for Importation"?
Originally posted by Seņor Info
I would guess that approval of this petition would have little effect on an Evo VII petition.
I would guess that approval of this petition would have little effect on an Evo VII petition.
Originally posted by Seņor Info
If the petitioner couldn't demonstrate that a foreign Evo VIII is substantially similar to the US Evo, then what chance would he have in demonstrating that the Evo VII is subtantially similar to the US Evo?
If the petitioner couldn't demonstrate that a foreign Evo VIII is substantially similar to the US Evo, then what chance would he have in demonstrating that the Evo VII is subtantially similar to the US Evo?
Originally posted by Seņor Info
In any event the comparison is with the RHD Japanese market version and not with an LHD version.
In any event the comparison is with the RHD Japanese market version and not with an LHD version.
Originally posted by Seņor Info
And anyone can offer their opinions to the NHTSA on this petition during the comment period.
Here's how you do it. Go to http://dms.dot.gov/submit/. On the next page you'll want to fill in the following information:
Docket Number: NHTSA-2003-15470
Operating Administration: NHTSA
Docket Type: uncheck "Regulatory"
Docket Existence: check "Does Exist"
Document Title: your-name (or Anonymous) - Comments
Confidential: you decide whether you wish to remain anonymous
Submission Method: it is always better to attach a file which you've formatted and proof-read.
And anyone can offer their opinions to the NHTSA on this petition during the comment period.
Here's how you do it. Go to http://dms.dot.gov/submit/. On the next page you'll want to fill in the following information:
Docket Number: NHTSA-2003-15470
Operating Administration: NHTSA
Docket Type: uncheck "Regulatory"
Docket Existence: check "Does Exist"
Document Title: your-name (or Anonymous) - Comments
Confidential: you decide whether you wish to remain anonymous
Submission Method: it is always better to attach a file which you've formatted and proof-read.
in the "docket" at some point. What do you think about that?
Originally posted by Seņor Info
any non-resident of the US (including US citizens living abroad) may temporarily import a vehicle in conjuction with their visit to the US for up to 1 year, as long as it's properly registered in some foreign country. Such vehicles can be legally operated on public roads.
any non-resident of the US (including US citizens living abroad) may temporarily import a vehicle in conjuction with their visit to the US for up to 1 year, as long as it's properly registered in some foreign country. Such vehicles can be legally operated on public roads.
Jul 1, 2003, 05:53 AM
#26
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Originally posted by Claudius
I would guess LHD and RHD cars are not considered "substantially similar" even if we are talking about the very same car just one being LHD and the other RHD?
I would guess LHD and RHD cars are not considered "substantially similar" even if we are talking about the very same car just one being LHD and the other RHD?
While there is no specific restriction on importing a right-hand drive vehicle, an eligibility number based on a substantially similar U.S.- certified motor vehicle may not apply. Our experience has shown that the safety performance of right-hand drive vehicles is not necessarily the same as that of apparently similar left-hand drive vehicles offered for sale in this country. However, we will consider them "substantially similar" if the manufacturer advises us that the right-hand drive vehicle would perform the same as the certified left-hand drive vehicle in crash tests. If the vehicle is not substantially similar to one sold in the U.S., the RI would have to demonstrate that the vehicle, when modified, would comply with the applicable Federal motor vehicle safety standards, which could involve crash testing several vehicles.
Originally posted by Claudius
What's Mitsubishi's position on the "Petition for Decision that Nonconforming 2003 Mitsubishi Evolution VIII, Left Hand Drive Passenger Cars Are Eligible for Importation"?
What's Mitsubishi's position on the "Petition for Decision that Nonconforming 2003 Mitsubishi Evolution VIII, Left Hand Drive Passenger Cars Are Eligible for Importation"?
Originally posted by Claudius
Furthermore, on http://www3.us.porsche.com/english/usa/home.htm you can see that the Porsche GT3 is for sale in the USA. In the technical specifications, you can see that tank capacity is 89 litres. I agree that that is not the only thing that needed changing to make the GT3 meet all the required standards, but it does sound a posteriori like Porsche NA wanted to keep the car from being sold in the USA by anybody but themselves.
Furthermore, on http://www3.us.porsche.com/english/usa/home.htm you can see that the Porsche GT3 is for sale in the USA. In the technical specifications, you can see that tank capacity is 89 litres. I agree that that is not the only thing that needed changing to make the GT3 meet all the required standards, but it does sound a posteriori like Porsche NA wanted to keep the car from being sold in the USA by anybody but themselves.
Jul 1, 2003, 06:18 AM
#27
Hello,
It seems that you do kno your stuff Seņor Info. Thanks for all the information, but I feel as if you are only hindering the whole process. I would think you would be that one person that would anyonmously put a post that would only slow the process. Its good and all that you are giving us this information, but I just want to make it clear that alot fo us as customers don't want to hinder the process of what EI and G & K are trying to do. Just chill out, you gotta remember you aren't on the money side of it all! Lets just wait and see what happens! Thats all I wanted to say.
Thanks
It seems that you do kno your stuff Seņor Info. Thanks for all the information, but I feel as if you are only hindering the whole process. I would think you would be that one person that would anyonmously put a post that would only slow the process. Its good and all that you are giving us this information, but I just want to make it clear that alot fo us as customers don't want to hinder the process of what EI and G & K are trying to do. Just chill out, you gotta remember you aren't on the money side of it all! Lets just wait and see what happens! Thats all I wanted to say.
Thanks
Jul 1, 2003, 06:45 AM
#28
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Originally posted by Seņor Info
It is interesting to note that the US Evo's fuel tank capacity is given as 14 gallons or 53 liters which is different than all non-US Evo VIIIs and Evo VIIs, where the GSR has a 55 liter tank and the RS has a 50 liter tank. I wonder why Mitsubishi designed an apparantly special fuel tank just for the US Evo?
It is interesting to note that the US Evo's fuel tank capacity is given as 14 gallons or 53 liters which is different than all non-US Evo VIIIs and Evo VIIs, where the GSR has a 55 liter tank and the RS has a 50 liter tank. I wonder why Mitsubishi designed an apparantly special fuel tank just for the US Evo?
The reason for the tank capacity increase was discussed on here previously; members stated that US standards require a road legal motor vehicle to be able to travel a certain distance without needing to refuel. It makes sense to me that such a standard would exist, but I have not seen any such standard (or any link to such a standard
)
Originally posted by Seņor Info
Mitsubishi Motor Sales America (MMSA) has absolutely no incentive to assist this petition (e.g. by advising NHTSA that the right-hand drive Evo VIII would perform the same as the certified left-hand drive US Evo in crash tests) and every incentive to oppose this peitition (by offering negative comments). I would expect MMSA (and its US dealer network) to adopt the view that every grey market 2003 Evo VIII imported if this petition is approved would represent a lost sale of a US Evo.
Mitsubishi Motor Sales America (MMSA) has absolutely no incentive to assist this petition (e.g. by advising NHTSA that the right-hand drive Evo VIII would perform the same as the certified left-hand drive US Evo in crash tests) and every incentive to oppose this peitition (by offering negative comments). I would expect MMSA (and its US dealer network) to adopt the view that every grey market 2003 Evo VIII imported if this petition is approved would represent a lost sale of a US Evo.
What's more, the margin on the Evo is not something that makes it worthwhile in pure sales terms to sell Lancer Evolution cars in the USA. It's Mitsubishi's most performant car that will give them a better image, make their dealers proud of what they sell, and impress the customers, but I dont think it's a "cash cow" to MMSA. I would therefore not regard a few dozen (if at all) Euro or JDM spec Evos imported, legalized and sold in the USA as a "lost sale" for MMSA, but rather as a very exclusive vehicle made by Mitsubishi showing their competitors what sort of cars Mitsubishi is capable of making. It may even help them further improve their image in the younger market segments and sell OZs and Outbacks and all the other "regular" cars they make.
Jul 1, 2003, 06:54 AM
#29
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Regarding the Porsche GT3 petition, I read at the end of the Note of denial that 3 months must elapse before a petition regarding the same vehicle may be submitted; I could not (by searching for "GT3") find anything in the DMS database that would suggest that another petition had been submitted. Did the petitioner just give up on it since 08/01/2001? Or did this coincide with the moment Porsche announced the GT3 in the USA?
Jul 1, 2003, 07:11 AM
#30
Originally posted by Claudius
I wonder if one could reasonably argue that MMSA may also want to help getting the cars into the USA as they represent an ultra small market niche: people who want the JDM version of the Evo 8, a version that would not make economical sense for Mitsubishi to import into the USA.
What's more, the margin on the Evo is not something that makes it worthwhile in pure sales terms to sell Lancer Evolution cars in the USA. It's Mitsubishi's most performant car that will give them a better image, make their dealers proud of what they sell, and impress the customers, but I dont think it's a "cash cow" to MMSA. I would therefore not regard a few dozen (if at all) Euro or JDM spec Evos imported, legalized and sold in the USA as a "lost sale" for MMSA, but rather as a very exclusive vehicle made by Mitsubishi showing their competitors what sort of cars Mitsubishi is capable of making. It may even help them further improve their image in the younger market segments and sell OZs and Outbacks and all the other "regular" cars they make.
I wonder if one could reasonably argue that MMSA may also want to help getting the cars into the USA as they represent an ultra small market niche: people who want the JDM version of the Evo 8, a version that would not make economical sense for Mitsubishi to import into the USA.
What's more, the margin on the Evo is not something that makes it worthwhile in pure sales terms to sell Lancer Evolution cars in the USA. It's Mitsubishi's most performant car that will give them a better image, make their dealers proud of what they sell, and impress the customers, but I dont think it's a "cash cow" to MMSA. I would therefore not regard a few dozen (if at all) Euro or JDM spec Evos imported, legalized and sold in the USA as a "lost sale" for MMSA, but rather as a very exclusive vehicle made by Mitsubishi showing their competitors what sort of cars Mitsubishi is capable of making. It may even help them further improve their image in the younger market segments and sell OZs and Outbacks and all the other "regular" cars they make.