Interpretation ID: nht94-4.31

TYPE: INTERPRETATION-NHTSA

DATE: September 16, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Gerald J. Gannon -- General Motors Corporation, Legal Staff

TITLE: NONE

ATTACHMT: Attached to letter dated 3-22-94 from Gerald Gannon to John Womack

TEXT: This responds to your letter asking whether NHTSA 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.