Interpretation ID: nht90-1.92

TYPE: INTERPRETATION-NHTSA

DATE: 03/30/90

FROM: MICHAEL LOVE -- MANAGER SAFETY COMPLIANCE PORSCHE

TO: JERRY CURRY -- NHTSA

TITLE: 49 CFR PART 543 EXEMPTION

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM BARRY FELRICE -- NHTSA TO MIKE LOVE -- PORSCHE, A 35 PART 543; LETTER FROM BARRY FELRICE -- NHTSA TO STEPHEN WOOD -- NHTSA ACTING CHIEF COUNSEL ENTITLED PORSCHE'S MODIFIED ANTITHEFT EXEMPTION, LETTER DATED 04/12/90

TEXT: On January 25, 1989, Porsche submitted petitions for exemption from the Vehicle Theft Prevention Standard under 49 CFR Part 543 for its 1990 (MY) 911 and 928 models. NHTSA granted the petitions on May 26, 1989, on condition that any modifications to the alarm systems require Porsche to re-petition the NHTSA unless the modifications could be characterized as de minimus.

Porsche is planning to make the modifications set forth below to the alarm systems of MY 1991 911 and 928 model lines. For the following reasons, the changes described below should be considered de minimus:

1) The alarm control unit will be integrated with the central locking and interior light control units in order to save space and simplify the vehicle electrical system.

2) The system changes will be virtually transparent to the operator. The system will still be armed by locking either door with the key.

3) All of the same points of entry (i.e., door, hood, hatch, etc.) will be monitored by the system and the engine disabling and alarm features are the same. The system will be as protected and tamper resistant as the current system.

4) The new system will also monitor the glove box for opening. If the glove box is opened while the alarm is armed, the alarm will be set off (this is important for convertibles).

5) The system will have improved diagnostic capability in order to enhance serviceability.

6) The system will have the capability to accept other inputs (such as motion sensors) if they are desired in the future.

Based on the above, we believe that the alarm systems as modified contains all of the functions and features on which NHTSA based its decision to grant the exemptions. For that reason, we respectfully request a ruling from you that the planned modificat ions are de minimus and thus, obviating the need for a formal petition.

If you have any questions, please call me at (702) 348-3198.