Interpretation ID: nht90-2.15

TYPE: INTERPRETATION-NHTSA

DATE: 04/12/90

FROM: BARRY FELRICE ASSOCIATE ADMINISTRATOR FOR RULEMAKING

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL NHTSA

TITLE: ACTION: PORSCHE'S MODIFIED ANTITHEFT EXEMPTION

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM BARRY FELRICE -- NHTSA TO MIKE LOVE -- PORSCHE, A 35 PART 543; LETTER DATED 03/30/90 FROM MIKE LOVE -- PORSCHE TO JERRY CURRY -- NHTSA ADMINISTRATOR ON 49 CFR PART 543 EXEMPTION

TEXT: On April 4, 1990, Porsche Cars North America, Inc. (Porsche) submitted a request for approval of a modification to the existing antitheft device for the exempted MY 1990 Porsche 911 and 928 carlines.

Rulemaking has reviewed the changes submitted by Porsche, and finds that the system activation process as described by Porsche would not undermine the device and that it would qualify for de minimis treatment. Porsche has changed the antitheft system by allowing it to additionally monitor the glove box for opening. This means that if the glove box is opened while the system is armed, the alarm will be activated. Previously, the antitheft system would only monitor the vehicle's doors, hood, hatc, igni tion switch, and removal of its radio.

The system's alarm control unit will now be integrated with the central locking and interior light control units to save space and to simplify the vehicle's electrical system. Porsche's antitheft system will also now have the capability to accept other inputs such as motion sensors, and improved diagnostic capability to enhance serviceability.

The new system will continue to be armed by locking either the driver or passenger door with the ignition key. The same points of entry will continue to be monitored by the system and the disabling and alarm features will remain the same. The new syste m will also continue to be as protected and tamper resistant as the current system.

As stated above, Rulemaking does not believe that these changes are significant enough to warrant submission of a full modification petition by Porsche and, therefore, would qualify for de minimis treatment. Accordingly, Rulemaking requests a letter gra nting the change to the antitheft system be forwarded to Porsche, pursuant to Part 543.9(j).

Attachment Letter from Porsche Cars North America, Inc.