Interpretation ID: 24384.drn

Susanne Krg, Account Manager
Lemfrder Corporation
Schaltungssysteme GmbH
Technical Center
15811 Centennial Drive
Northville, MI 48167

Dear Ms. Krg:

This responds to your request for an interpretation of Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect. You wish to know whether a motor vehicle that includes several proposed shift-by-wire shift patterns would meet Standard No. 102.

You included with your request ten pages of drawings, each of which is stamped "CONFIDENTIAL." We agree these drawings are entitled to confidential treatment as the disclosure of the depictions contained within them is likely to cause competitive harm. In the future, a request for confidential treatment consistent with Part 512 of the Agencys regulations should be included with any such submissions.

With your letter, you show 16 proposed configurations of shift-by-wire shift patterns (not counting the shift pattern of the BMW 7 Series). We assume that the shift patterns are intended to be used in motor vehicles with automatic transmissions. In a telephone conversation with Ms. Nakama, you explained that the shifting would be done by means of a joy stick, which, after being shifted, would return to a default position designated as the "X" position. You further explained that the joy stick may be moved straight up, straight down, and to the right and left (i.e., imagining the face of a clock, to the 12 oclock, 3 oclock, 6 oclock and 9 oclock positions) only. Diagonal movements such as to the one oclock or two oclock positions would not be permitted. I note that most of the shift patterns have two neutral positions. In all of the shift patterns depicted, before it may go into "drive" or "reverse," the joy stick must first be moved to "neutral." Thus, for example, to go into reverse, one moves the joy stick straight up (to go to neutral) and then to the left (to reverse).

Shifting from "Neutral" to "Drive" or "Reverse"

Requirements for shift patterns are specified at paragraph S3.1.1 of Standard No 102, which states in part:

A neutral position shall be located between forward drive and reverse drive positions . . . If the transmission shift lever sequence includes a park position, it shall be located at the end, adjacent to the reverse drive position.

All of your proposed shift patterns meet the requirement that "a neutral position shall be located between forward drive and reverse drive positions." Since nothing in S3.1.1 specifies that only one neutral position is to be provided, your patterns that would include two neutral positions are not prohibited by S3.1.1.

Shift Patterns with a "Park" Position

The second quoted sentence in S3.1.1 specifies that the "if the transmission shift lever sequence includes a park position, it shall be located at the end, adjacent to the reverse drive position." Two of your shift patterns (Pattern Number Six on the fourth page, Pattern Number Fourteen, on the tenth page) depict the joy stick as going directly from "X," the default position, to "park." If in fact the park position is part of the shift pattern, a vehicle with a joy stick that goes directly from "X" to "park" would not meet S3.1.1. If it is provided as part of the shift lever sequence, the park position must be located at the end, adjacent to the reverse drive position.

The park position requirement in S3.1.1 was addressed by this office in a letter of September 25, 1998, to BMW of North America, Inc. (BMW). In that letter, we stated in part:

Paragraph S3.1.1 explicitly limits the requirement to those park positions included within the Ashift lever sequence.@ It is our interpretation that if park is not selected by the movement of the shift lever, then the park control is not part of the shift lever sequence. In this case, the sentence quoted above does not apply, and the park control does not have to be located at the end, adjacent to reverse.

The park position described in BMWs letter was not in the shift lever sequence. It was selected not by the movement of the shift lever but by pushing on a push-button control mounted on the end of the transmission shift lever. For this reason, we determined that BMW=s vehicle with the park position control (as described in BMWs incoming letter to NHTSA) need not meet the park position requirement in S3.1.1 of Standard No. 102.

Patterns Depicting Functions Other Than Park, Reverse, Neutral and Drive

The fundamental shift patterns (reverse-neutral-drive) of both Pattern Number Nine (page six) and Pattern Number Sixteen (page ten) would meet S3.1.1 of Standard No. 102. However, both Pattern Number Nine and Pattern Number Sixteen each depict at least two additional functions that are not park, reverse, neutral, or drive. Without more specific information about these functions, including what these functions are and how many of them are to be provided, we are unable to provide an opinion whether a motor vehicle with these functions would meet Standard No. 102.

Standard No. 102s Identification of Shift Lever Position Requirements

Unlike traditional transmission shift levers that stay in the gear position selected by the driver, the joy stick in your design defaults to the "X" position after the gear is selected. As a result, a visual display other than the joystick must inform the driver of the current gear selection.

Section 3.1.4 specifies requirements for identification of shift lever positions as follows:

Vehicles with Park Positions- S3.1.4.1 specifies that except when the ignition is in a position that is used only to start the vehicle, if the transmission shift lever sequence includes a park position, identification of shift lever positions, including the positions in relation to each other and the position selected, shall be displayed in view of the driver whenever any of the following conditions exist: (a) the ignition is in a position where the transmission can be shifted; (b) the transmission is not in park.

Vehicles Without Park Positions - S3.1.4.2 specifies that except when the ignition is in a position that is used only to start the vehicle, if the transmission shift lever sequence does not include a park position, identification of shift lever positions, including the positions in relation to each other and the position selected, shall be displayed in view of the driver whenever the ignition is in a position in which the engine is capable of operation.

S3.1.4.4 specifies that the information required in S3.1.4.1 or S3.1.4.2 must be displayed in view of the driver in a single location. At the option of the manufacturer, redundant displays providing some or all of the information may be provided.

I hope this information is helpful. If you have any questions, please contact Ms. Nakama at (202) 366-2992.

ref:102

d.8/1/02