Interpretation ID: 77-2.36

TYPE: INTERPRETATION-NHTSA

DATE: 05/18/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Video Research Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 15, 1977, concerning Federal Motor Vehicle Safety Standard No. 114, Theft Protection, as it relates to a device you wish to market called "Remote Auto-Start."

Standard No. 114, Theft Protection, which applies to passenger cars, requires that when the key is removed, normal activation of the car's engine and either steering or forward self-mobility of the car is prevented (49 CFR 571.114, S4.1(a) and (b)). According to the material which you forwarded, your device results in the following characteristics which differ from what we consider to be normal activation:

1. The engine deactivates when a door is opened.

2. The steering column and gear shift remains locked until the actual key is inserted.

3. The logic circuitry deactivates the engine after 15 minutes.

Consequently, we have determined that your device does not result in a "normal" activation of the car's engine.

Thus, it appears that the characteristics of the "Remote Auto-Start" system are not in conflict with Standard No. 114.

Sincerely,

ATTACH.

VIDEO RESEARCH CORPORATION

March 15, 1977

Frank Berndt -- Acting Chief Counsel, National Highway Safety Administration

Dear Mr. Berndt:

Last week I had the opportunity of talking to Mr. Tilton in regards to interpretating a law which covers various states, as well as federal, concerning cars left unattended with the motors running.

Sometime back, the American Medical Association contacted me in regards to heart patients that have to use a motor vehicle in extremely hot or cold weather. Since it is a stress on the heart when temperatures vary greatly, they felt if possible we could make an item that would heat or cool the vehicle for 15 to 20 minutes before entering same.

We came up with a tentative item called Remote Auto-Start. By reading the enclosed sheets covering this item which was written by our Director of Engineering, you will note that at no time can the vehicle be operated without the ignition key.

We would appreciate it, after you read the enclosed specifications, if you would let us know whether any federal or state laws will affect us.

Looking forward to hearing from you as soon as possible so we can continue with this particular product.

Thank you in advance for your consideration.

Sincerely yours, Martin Fleischman -- Chairman

[Enclosure Omitted]