Interpretation ID: nht87-3.10

TYPE: INTERPRETATION-NHTSA

DATE: 10/07/87

FROM: ANDREW E. WOOLNER -- GENERAL MANAGER AUSTIN ROVER

TO: ERIKA JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: INTERPRETATION OF FMVSS NO. 101, CONTROLS AND DISPLAYS, SECTION S 5.3.5.

ATTACHMT: ATTACHED TO LETTER DATED 11/23/88, FROM ERIKA Z. JONES -- NHTSA, TO ANDREW E. WOLLNER -- AUSTIN ROVER, REDBOOK A33, STANDARD 101; BROCHURE FROM AUSTIN ROVER, UNDATED (RE CONTROLS AND DISPLAYS)

TEXT: Austin Rover Ltd. (ARG), the mamufacturer of the Sterling passenger car seeks an interpretation of FMVSS NO 101, Controls and Displays as of September, 1989.

1. All Sterling 825 vehicles have a fuel gauge and a speedodometer/odometer located in the instrument panel immediately in front of the driver as illustrated in Fig. 1.

2. The Sterling SL has in addition to the above-mentioned displays, a trip computer fitted in the center console (Fig. 2). This trip computer is able, among other functions to display supplemental information in relation to fuel consumption, (instan taneous and average), fuel used, average speed, trip distance and distance to arrival. The attachment shows the method of operation and the functions.

ARG interprets the illumination requirements of standard 101 as applicable to the trip computer display as being:

a. The illumination requirement not mandatory.

b. The illumination provided at the choice of the manufacturer is subject to the requirements of section S 5.3.5. and not section S 5.3.3.

The reasons for our interpretation are as follows:

a. The fuel section of the trip computer does not show the fuel level in the fuel tank.

b. The distance and speed functions cannot be considered as "speedodometer" because it does not indicate actual vehicle speed at any instant. Also there is no need to illuminate an odometer even if the distance function could be so considered.

Would you please confirm that ARG's interpretation for 1 and 2 above are correct. That is, that such displays contained in our trip computer which offer "supplemental information" to other gauges and displays that are clearly regulated by FMVSS NO. 101 will categorically fall under S 5.3.5 requirements for illumination.

Sincerely,

Enc.