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The problem with conversions is that most people simply install a ballast and a bulb, not even a good bulb at that.
The only technically legal way to do a conversion would be to install an entire headlamp assembly with ballasts and bulbs that all meet all the FMVSS #108 requirements and any other requirements for lighting equipment.
And that's also the only SMART way to do it too. Using a conversion kit in any headlamp assembly not specifically designed for the HID bulb you use is just unsafe and stupid to do. If anybody wants to know more on that, let me know and I can get you the nitty gritty.
I haven't seen anywhere that DOT/NHTSA has made a ban on HID conversions. That's the whole point of that letter. There is no rule stating that you can't do an HID conversion, however there aren't really any conversions sold that are legal because they violate FMVSS #108 requirements. Perhaps you could point me to where that ban is stated?
They have opened up a forum for public comment (actually did this a long time ago) on whether HIDs and HID conversions should be banned. However that keeps open the possibility of banning HIDs as an option on vehicles. I think it's unlikely they'd do that, but I do think it's likely that they'll make a specific ban on conversions. Most of these conversion kits aren't legal to be sold or imported to the US anyways, hence why APC got fined.
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