Interpretation ID: aiam5445

Mr. Gerald J. Gannon General Motors Corporation Legal Staff N Center One Building 3031 West Grand Boulevard P.O. Box 33122 Detroit, MI 48232; Mr. Gerald J. Gannon General Motors Corporation Legal Staff N Center One Building 3031 West Grand Boulevard P.O. Box 33122 Detroit
MI 48232;

Dear Mr. Gannon: This responds to your letter asking whether NHTS intended, in a recent final rule, 'to require that vehicles with an automatic transmission with a 'park' provision must prevent steering after removal of the key in order to have an ignition key-operated transmission shift override device?' You stated that the final rule might be interpreted to produce that result, but argued, based on the preamble, that a more limited result was intended. You suggested that a clarifying amendment would be appropriate. We apologize for the delay in our response. After reviewing your letter, we have concluded that the issue you raise should be addressed in rulemaking. We anticipate that a notice addressing this issue will be issued shortly. Sincerely, John Womack Acting Chief Counsel;