Interpretation ID: nht88-2.58

TYPE: INTERPRETATION-NHTSA

DATE: 06/28/88

FROM: KARL H. MAYER -- DR ING H. C F PORSCHE AG RULES AND REGULATIONS PORSCHE

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: REQUEST FOR INTERPRETATION/CLARIFICATION FMVSS 101 AND FMVSS 102

ATTACHMT: ATTACHED TO LETTER DATED 04/03/89 FROM ERIKA Z. JONES -- NHTSA TO KARL H. MAYER, REDBOOK A33 (4), STANDARD 101, STANDARD 102; LETTER DATED 06/28/88 FROM KARL H. MAYER TO ERIKA Z. JONES -- NHTSA, REQUEST FOR CONFIDENTIAL TREATMENT; LETTER DATED 08/25/88 FROM DEAN HANSELL TO KATHLEEN DEMETER -- NHTSA, RE PORSCHE'S JUNE 28 REQUEST FOR REGULATORY INTERPRETATION FMVSS 101 AND 102

TEXT:

Dear Ms. Jones,

In connection with the development of a new vehicle transmission we would like to request your opinion concerning regulatory questions raised by this transmission and its related gear shift mechanism, taking into account Federal Motor Vehicle Safety Stan dards 101 and 102.

We understand that the National Highway Traffic Safety Administration ("NHTSA") does not grant approvals of motor vehicles or motor vehicle equipment. We also realize that, under the National Traffic Motor Vehicles Safety Act, it is the responsibility o f the manufacturer to assure that its vehicles and equipment comply with the applicable standards.

Nevertheless, in our opinion it can at times be helpful and desirable for both the NHTSA and a motor vehicle manufacturer if a candid dialogue can be brought about regarding new technological developments and related regulatory questions. It is the inten t of this letter to create such a dialogue, as needed, in connection with the questions we are presenting.

I. Descriptions of the transmission, its functions and the operation of the gear shift lever

The above mentioned motor vehicle transmission is characterized by two functions -- i.e., a manuel gear shift and an automatic gear shift -- combined in a single unit. The transmission will thus let the driver decide at any time if he wishes to shift manually or transfer that task to the automatic portion of the transmission.

A motor vehicle equipped with such a unit does not have a clutch pedal. Regardless of which of the dual functions is chosen, its operation depends entirely on the position selected for the gear shift lever.

As is customary, the gear shift lever is located in the middle console, where it can be moved along either of two slots which are located essentially parallel to the longitudinal axis of the vehicle. The movement between the two slots corresponds to the change-over from the automatic to the manual function or vice versa. Movement of the lever between the slots can be accomplished while driving the vehicle forward or also while the vehicle is standing still, entirely at the option of the driver.

To accomplish the change from one slot (or function) to the other one, the driver only needs to move the shift lever to the other side across a tranverse connecting slot. As attached drawing 1 shows, this change can only be made from the "D" position on the automatic side to the "M" (manual shift) function on the other side, or vice versa.

When the slot exchange takes place from the automatic to the manual function, at first there is no actual gear shift change; i.e., the vehicle remains in the gear it was in on the automatic side. Only after a further "shift order" is given by the dri ver (by tapping on the shift lever) is the desired gear shift change achieved; i.e., either by shifting up (+) or by shifting down (-). (Shifting on the manual side has a "rocker" characteristic similar to that found with a computer video control, which always returns the gear shift lever to the "M" position after being tapped).

When changing from the manual to the automatic function, at first the gear selected on the automatic side is "taken along" from the one selected by the driver in the manual mode. However, immediately thereafter the automatic speed adaption of the aut omatic function takes over. This adaption, as usual, depends upon the load factor and the engine revolutions as well as the vehicular speed, and corresponds to the conventional functioning of existing automatic transmission units.

II. Questions resulting from the new transmission and Standards 101 and 102

1. We are of the opinion that th s new type of transmission with a dual function is basically permissible under the FMVSS, provided certain requirements are met as per FMVSS 101 and 102. We would like to know whether the NHTSA agrees with this inter pretation of the regulations.

The requirements we have taken into consideration in reaching our conclusion are, among others:

The shift lever can be reached by the driver. FMVSS 101. S5.1. hand operated controls, item (j) of the list.

The shift pattern manufactured as per drawing 1, is continually visible to the driver on the middle console during daylight, FMVSS 101, S5.1 displays, item (c) of the list.

The shift pattern, as per drawing 2, shown in the speedometer, is continually visible to the driver and provided with illumination, which is in accordance with the requirement contained in FMVSS 101, S5.3.1.

If a gauge is listed in column 1 of Table 2, and accompanied by the word "yes" in column 5, then the gauge and its identification required by S5.2.3 shall be illuminated whenever the ignition switch and/or the headlamps are activated. Controls, gauge s, and their identifications need not be illuminated when the headlamps are being flashed.

The above mentioned illumination of the shift pattern is adjustable, in accordance with FMVSS 101, S5.3.3.

In the automatic mode the gear position can be set selectively to P, R, N, D, 3, 2, or 1, clearly readable on the guide display plate of the gear shift on the middle console, as well as clearly marked for the driver by illuminating the corresponding a rrows (arrow) on the shift display in the speedometer.

The engine can only be started if the shift lever is in the P or N position as per FMVSS 102. S3.1.3.

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4. The display shown in drawing 3 differs from the mode depicted in drawing 2 only by including the letter "M" on the manual side. The corresponding arrow would be illuminated during use of the manual mode. Additionally the arrow of the selected sh ift position would light up.

Please advise us if the display mode shown in drawing 3 is permissible.

Note: The speedometer depicted in drawings 2 and 3 will have a scale reading in MPH in the version manufactured for the USA instead of a scale in KM.

We are prepared to provide you with any further information that you would need to consider this inquiry, whether by telephone or in writing, or, if you would prefer, in a face-to-face meeting. We have developed a working model of the dual function shif t lever which we are prepared to demonstrate for you, if that would be helpful to you in evaluating these questions.

Your early favorable consideration of these requests would be greatly appreciated so that we can move this technology toward production as soon as possible.

A confidential treatment of this inquiry in accordance with 49 CFR Part 512 ist requested. (See enclosed declaration.)

Very truly yours,

Enclosure

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