NHTSA Complaint #11705957 — 2022 TOYOTA TUNDRA

I am submitting this complaint regarding Toyota’s decision to exclude hybrid vehicles from an active safety recall affecting non-hybrid Toyota Tundra models equipped with the same twin-turbo V6 engine architecture. Toyota has stated that hybrid vehicles are excluded because they retain motive power through the electric drive system in the event of an internal combustion engine failure. This rationale does not address real-world safety risk and does not reflect the mechanical realities of towing or highway operation. The hybrid version of the Toyota Tundra uses the same base V35A-derived engine architecture, block casting, bearing design, and oiling system as the recalled non-hybrid vehicles. Toyota has not demonstrated that hybrid engines were manufactured differently or are immune to the defect that prompted the recall. In towing conditions, an internal combustion engine failure creates an immediate safety hazard even if limited electric propulsion remains available. Electric-only operation provides severely reduced power, limited speed, and restricted torque, making highway merging, grade climbing, or maintaining safe traffic flow unsafe while towing. Retaining minimal electric motion does not equate to maintaining safe propulsion under load. Additionally, a catastrophic engine failure may introduce metal debris, oil pressure loss, or thermal imbalance that can compromise shared drivetrain and hybrid coupling components. The presence of an electric motor does not mitigate the underlying defect risk or the secondary damage potential. Toyota’s distinction between hybrid and non-hybrid vehicles appears to be regulatory and financial rather than engineering-based. The same defect risk exists regardless of the hybrid system. I request that NHTSA evaluate whether Toyota’s exclusion of hybrid vehicles is based on actual engineering differences or solely on regulatory interpretation.