Interpretation ID: nht87-2.35

TYPE: INTERPRETATION-NHTSA

DATE: 07/09/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Ms. Dianne Black

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Dianne Black Engineering Manager, Legislation, Compliance, and Product Development Jaguar Cars, Inc. 600 Willow Tree Road Leonia, NJ 07650

Dear Ms. Black:

Your letter to Barry Felrice concerning Federal Motor Vehicle Safety Standard No. 114 has been referred to me for response. This response is based on your letter, and a telephone conversation of March 17, 1987, between Mr. Edward Stumpkey of Jaguar and M r. Kenneth Rutland of this agency clarifying certain matters raised in your letter. I regret the delay in this response.

Standard 114, Theft Protection, requires that each vehicle subject to must have a key-locking system which must prevent not only normal engine activation, but also either steering or forward self-mobility or both when the key is removed.

You mention a system intended to meet the standard, but indicate that "for security reasons," you are reluctant to supply specific details on that system. Without reference to specific data, you state that your system meets paragraph S4.2(a) of Standard 114, that is, removing the key from the ignition prevents normal engine activation.

You go on to say that the microprocessing systems that control vehicle operations will not function when the driver removes the ignition key. Therefore, you state, you meet one of the conditions in S4.2(b) of the Standard, that is, removing the key must prevent forward self-mobility of the vehicle.

Based on the information you supplied, NHTSA can not agree that your key-locking system meets either requirement of S4.2(b). As I understand your description of Jaguar's system, deactivating the engine is the means by which you assert you prevent vehicle forward self-mobility. If a manufacturer could comply with the S4.2(b) with respect to preventing forward self-mobility by preventing normal engine activation under S4.2(a), S4.2(b) would be redundant. Paragraph S4.2(b) requires an added safeguard with respect to forward self-mobility, such as a transmission lock or other means, to prevent a vehicle from moving under its own power should the engine somehow be activated without inserting the key.

Therefore, preventing normal engine activation under S4.2(a) will not meet the condition in S4.2(b) of preventing vehicle forward self-mobility. If jaguar has some means other than deactivating the engine to prevent forward self-nobility, its system may be acceptable. Otherwise, Jaguar must add some means to meet at least one of the conditions in S4.2(b).

Sincerely,

Erika Z. Jones Chief Counsel

Mr. Barry Felrice National Highway Traffic Safety Administration 400 Seventh Street SW Washington, D. C. 20590

RE: FMVSS 114

Dear Mr. Felrice:

At the NHTSA Industry meeting last Wednesday, I promised to call you the following day to discuss the difficulty we had encountered with FMVSS 114 as it relates to new technology.

I did not call, obviously, because it appeared that I needed same more detail from the engineering development and design staff in England. That detail has now arrived and to allow you the opportunity to look at the problem, I have opted to write. Once y ou have had an opportunity to look over the text, perhaps we can discuss either by telephone or in person.

Our difficulty appears to be with S4.2 and S4.3 of the relevant standard. Summary of S4.2 Each vehicle shall have a key locking system that whenever the key is removed, will prevent:

a) normal activation of the vehicles engine or other main source of native power.

b) either steering or forward self mobility of the vehicle or both.

Summary of S4.3 The prime means of deactivating the vehicles engine or other main source of motive power shall not activate the deterent required by S4.2(b).

For security reasons, I will not go into specific details of the system other than to say that by taking the key out of the ignition, we would meet paragraph (a) of S4.2. In other words, without the ignition key the vehicle cannot be activated. Without t he insertion of the ignition key activated, thus rendering the fueling and ignition maps inactive. This meets one of the condition in paragraph (b) of S4.2, in that with the processors inactive the engine will not run therefore the vehicle cannot move un der it; own forward mobility.

Perhaps we have overinterpreted the standard 114 to require steering column locks but your comment and thoughts would be appreciated. In further discussion, I can provide more detail of the system for you.

Sincerely yours,

Dianne Black Engineering Manager, Legislation, Compliance and Product Development