Interpretation ID: nht94-8.9

DATE: February 17, 1994

FROM: Karl-Heinz Ziwica -- General Manager, Environmental Engineering, BMW of North America, Inc.

TO: Barbara A. Gray, Office of Market Incentives, NHTSA, U.S. Department of Transportation

TITLE: NONE

ATTACHMT: Attached to letter dated 8/9/94 from Barry Felrice to Karl-Heinz Ziwica (Part 543)

TEXT: Dear Ms. Gray:

This letter is to inform the agency that beginning with the 1995 model year, BMW will be utilizing the 7-carline parts marking exemption granted by the NHTSA on October 9, 1986 (51 CFR 3633). As was explained to you by Mr. James C. Patterson of my staff on February 7, 1994, there have been three updates to the anti-theft device previously approved on the 7-carline. Accordingly, BMW requests that the NHTSA determine these updates constitute de minimus changes to the 7-carline's anti-theft device.

The following paragraphs describes the updates:

1. The remote device has become an integral component within the vehicle key and is the actuator for the alarm system. This change is identical to the change that BMW made on the 8-carline anti-theft device, which NHTSA has already determined to be de minimus (NHTSA letter from Mr. Barry Felrice to K.-H. Ziwica dated 10/04/93).

2. The monitoring circuits for radio theft and glove box entry, now, monitor glass breakage to further ensure the security of the entire occupant compartment, rather than, the individual components. All other monitoring (e.g. doors, hood, trunk, etc.) has remained as when the device was previously approved.

3. The anti-theft device's siren has been changed to a 112db siren.

If further information is needed or you have any questions regarding this matter, please contact Mr. Patterson on (201) 573-2041.