Interpretation ID: nht93-1.14

DATE: January 21, 1993

FROM: Michael Love -- Manager, Compliance, Porsche

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re: Request For Interpretation

ATTACHMT: Attached To Letter Dated 5/17/94 From John Womack To Michael Love (A42; Std. 102; Std. 101)

TEXT: Dear Mr. Rice:

On June 28, 1988 Porsche submitted a request for interpretation regarding FMVSS 101 and 102 as they applied to a new transmission design. NHTSA responded to that request in a letter dated April 3, 1989. Since that time, Porsche has introduced that transmission as the "Tiptronic (R)" on two models. Porsche is currently considering changes to the method of shifting of this transmission and has several questions regarding the applicability of FMVSS 101 and 102 to those changes.

The current design of the shift lever console and transmission position display in the speedometer is as shown in Figure 1. Porsche is considering three options for changes.

1) As shown in Figure 2, eliminate the 3, 2, and 1 positions on the automatic (left) side of the shift gate.

2a) As shown in Figure 3, eliminate the 3, 2, and 1 positions on the automatic side of the shift gate; the gear shift lever can be moved from D to M to select automatic or manual shifting respectively; in the manual mode, gear selection would be accomplished not by the shift lever but by shift rocker switch(es) on the steering wheel.

2b) As shown in Figure 4, eliminate the 3, 2, and 1 positions on the automatic side of the shift gate and eliminate the separate manual side of the shift gate. Once in the D position, the shift lever can be pulled backward to change from automatic to manual gear selection by means of a switch activated in the same manner as the switches in the manual mode of the current Tiptronic. Pulling the lever backwards a second time would change back from manual to automatic gear selection. Once in the manual mode, gear selection would be accomplished not by the shift lever but by shift rocker switch(es) on the steering wheel.

2

In all three options, the speedometer display of transmission position would remain as shown in Figure 1. This display would be the same for all options. The shift lever position selected would be indicated by lighting an arrow ((or)) next to the appropriate symbol, as is done on the current display.

As shown in Figure 1, Porsche currently has gear selection positions 3, 2 and 1 in line with PRND positions. For options 1, 2a and 2b, Porsche believes that it is not necessary to have the shift lever positions 3, 2 and 1, or to necessarily display these positions if selected automatically in the D position, as long as they are displayed when selected manually by use of the shift lever (in option 1) or shift rocker switch(es) (in options 2a and 2b). Does NHTSA concur?

Porsche believes that under options 2a and 2b, both the shift lever and the shift rocker switch(es) would be considered as "shift levers" during the period when they are capable of changing the transmission position. The "shift lever position" would then be defined as the transmission position, or mode of operation, that was selected by manipulation of any combination of "shift levers". It follows then that identification of "shift lever position" would entail identifying the distinct transmission operating modes, in relation to each other and the specific mode selected.

Based on this understanding, we believe that the display as shown in Figure 1, if lighted during the conditions of 571.102 @ 3.1.4.3(a) and (b), fulfills the requirements of @ 3.1.4.4. Does NHTSA concur with this interpretation?

For options 2a and 2b, Porsche believes it is not necessary to illuminate the shift rocker switches, just as it is not necessary to illuminate the shift lever, under provisions of FMVSS 101, as long as the display in the speedometer showing transmission position is illuminated. Does NHTSA concur?

Sincerely,