Interpretation ID: nht70-2.47

DATE: 10/19/70

FROM: L. R. Schneider, NHTSA

TO: American Honda Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Douglas W. Toms has asked me to reply to your letter of 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.

Douglas W. Toms Director National Highway Safety Bureau

We would appreciate receiving an interpretation to clarify the meaning of Paragraph S3.1.2 of Federal Motor Vehicle Safety Standard 102.

It is our understanding that a transmission gear ratio other than the highest ratio is not required to be available at all speeds below 25 miles per hour. For example, in the case of a vehicle equipped with a three speed automatic transmission, if second gear became available only when selected at speeds below 15 miles per hour, the vehicle would conform to the requirements of Paragraph S3.1.2 provided that within the speed range when second gear was available, the vehicle deceleration was greater than if the highest gear ratio were engaged.

We believe that rewording Paragraph S3.1.2 of M.V.S.S. 102 as follows would clarify this matter:

"S3.1.2 Transmission Braking Effect. In vehicles having more than one forward transmission gear ratio, one forward drive position shall provide a greater degree of vehicle deceleration than the highest speed transmission ratio when tested below 25 miles per hour and within the speed range at which the lower gear ratio is available."

We would greatly appreciate an early reply.

C. L. Hale Staff Engineer