Interpretation ID: 9808
General Motors Corporation
Legal Staff
N Center One Building
3031 West Grand Boulevard
P.O. Box 33122
Detroit, MI 48232
Dear Mr. Gannon:
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.
Sincerely,
John Womack Acting Chief Counsel
ref:VSA#114 d:9/16/94