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I did once think about fitting them but decided it was a pointless exercise for the amount of use it would get. the subframe or lower arms at front or axle at rear are perfectly suitable for flat towing in a break down scenario.
I thought about under subframe,but as i cant get to the car lock down, can't check whether the subframe is lower than the front valance, don't want to rip the front spoiler off when being towed
The Subframe IS lower than the front valance but most assuredly NOT lower than the spoiler.
The process i've seen most repeated is the "strap and loop" required on race cars (and some trackdays) where the strap is secured behind the innermost of the bumper iron bolts and is fed out through the hole the bumper iron passes through. Usually with MUCH bigger washers either side of the front inner panel to distribute the load better in the shell. A 5/16" bolt in a 20 guage steel sheet is not very stong to take the load of pulling a ton of Dolomite out of a ditch! TBH I think this "solution" is more one of conforming to a rule in letter rather than spirit and such a thing would not be very practical in service. ie, if you used it in anger, the car might be a rather different shape afterwards!
To do the whole thing justice it would probably be needful to weld an extension to the subframe forward to just behind the valance/spoiler with a borrowed-from-a-modern LHT fitting and do what the moderns do, cut a hole to access it with a separate screw in eyelet and blank the hole when it's not broken down! Seems like a lot of extra work for very little reward to me, but what do I know?
Steve