Interpretation ID: aiam0256

Mr. C. L. Hale, Staff Engineer, American Honda Motor Company, Inc., P.O. Box 50, 100 W. Alondra Boulevard, Gardena, CA 90247; Mr. C. L. Hale
Staff Engineer
American Honda Motor Company
Inc.
P.O. Box 50
100 W. Alondra Boulevard
Gardena
CA 90247;

Dear Mr. Hale:#Douglas W. Toms has asked me to reply to your letter o September 8 which requests confirmation 'that a transmission gear ratio other than the highest ratio is not required to be available at all speeds below 25 miles per hour'.#We cannot confirm this interpretation of S3.1.2 of Motor Vehicle Safety Standard No. 102 (Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect). The phrase at vehicle speeds below 25 miles per hour' in that section is inclusive, it means at *all* speeds below 25 miles per hour, and not at *a* speed.#Sincerely, Lawrence R. Schneider, Acting Deputy Chief Counsel;