Interpretation ID: aiam4342
Engineering Manager
Legislation
Compliance
and Product Development
Jaguar Cars
Inc.
600 Willow Tree Road
Leonia
NJ 07650;
Dear Ms. Black: Your letter to Barry Felrice concerning Federal Motor Vehicle Safet Standard No. 114 has been referred to me for response. This response is based on your letter, and a telephone conversation of March 17, 1987, between Mr. Edward Stumpkey of Jaguar and Mr. Kenneth Rutland of this agency clarifying certain matters raised in your letter. I regret the delay in this response.; Standard 114, *Theft Protection, requires that each vehicle subject t it must have a key-locking system which must prevent not only normal engine activation, but also either steering or forward self-mobility or both when the key is removed.; You mention a system intended to meet the standard, but indicate tha 'for security reasons,' you are reluctant to supply specific details on that system. Without reference to specific data, you state that your system meets paragraph S4.2(a) of Standard 114, that is, removing the key from the ignition prevents normal engine activation.; You go on to say that the microprocessing systems that control vehicl operations will not function when the driver removes the ignition key. Therefore, you state, you meet one of the conditions in S4.2(b) of the Standard, that is , removing the key must prevent forward self-mobility of the vehicle.; Based on the information you supplied, NHTSA can not agree that you key- locking system meets either requirement of S4.2(b). As I understand your description of Jaguar's system, deactivating the engine is the means by which you assert you prevent vehicle forward self-mobility. If a manufacturer could comply with the S4.2(b) with respect of preventing forward self-mobility by preventing normal engine activation under S4.2(a), S4.2(b) would be redundant. Paragraph S4.2(b) requires an added safeguard with respect to forward self-mobility, such as a transmission lock or other means, to prevent a vehicle from moving under its own power should the engine somehow be activated without inserting the key.; Therefore, preventing normal engine activation under S4.2(a) will no meet the condition in S4.2(b) of preventing vehicle forward self-mobility. If Jaguar has some means other than deactivating the engine to prevent forward self-mobility, its system may be acceptable. Otherwise, Jaguar must add some means to meet at least one of the conditions in S4.2(b).; Sincerely, Erika Z. Jones, Chief Counsel