Interpretation ID: 3007yy
U.S. Factory Representative
Peugeot
U.S. Technical Research Company
1099 Wall Street West
Lyndhurst, NJ 07071
Dear Mr. Lucki:
This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You asked whether a planned gear position display for automatic transmission vehicles would meet the standard's requirement that full gear position information be provided in a single location. As discussed below, the answer to that question is yes.
By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles and equipment meet applicable standards. The following represents our opinion based on the facts provided in your letter.
As you are aware, on March 26, l99l, this agency published in the Federal Register a final rule amending Standard No. l02. Among the amendments is a new S3.l.4.4 that requires, for all automatic transmission vehicles, that full gear position information, i.e., identification of shift level positions, including the position of the gears in relation to each other, and the gear position selected, be displayed "in view of the driver in a single location."
According to a drawing enclosed with your letter, your planned gear position display would be located on the instrument panel, between the speedometer and tachometer. The current gear position, either P, R, N, D, 3, 2, or l, would be shown in a square, by means of electronic display. The position of the gears in relation to each other, i.e., P R N D 3 2 1, would be marked adjacent to the electronic display. You state that the gear positions in relation to each other will be illuminated when the headlamps are activated.
It is our opinion that your planned design would meet S3.l.4.4's requirement that full gear position information be displayed in a single location. The gear position selected would be shown in the square electronic display. The position of the gears in relation to each other would be marked adjacent to the electronic display. Because the marking of the position of the gears in relation to each other would be adjacent to the electronic display, it is our opinion that all of the information would be considered to be provided in a single location.
I note that this same issue was addressed in the preamble to the March l99l final rule, in connection with a comment submitted by Chrysler. The agency stated the following:
If Chrysler wishes to provide a display of current gear position information on the instrument panel, it is free to do so. Under the amendment, it can either provide full gear position information at that location, e.g., include a "P R N D L" label adjacent to the display, or it can provide a display of current gear position information only on the instrument panel and include a display of full gear position information elsewhere, e.g., on the floor console. 56 FR l2470, March 26, l99l.
Your proposed design is consistent with the first of the two options discussed in that paragraph.
I hope this responds satisfactorily to your concerns. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
ref:102 d:5/29/9l