Susanne Krg, Account Manager
    Lemfrder Corporation
    Schaltungssysteme GmbH
    Technical Center
    15811 Centennial Drive
    Northville, MI48167

    Dear Ms. Krg:

    This responds to your August 30, 2002, request for an interpretation of Federal Motor Vehicle Safety Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect. In a letter of August 1, 2002, we responded to your earlier questions whether a motor vehicle that includes several proposed shift-by-wire shift patterns would meet Standard No. 102. In your August 30, 2002, letter you provide diagrams with more details of several other shift patterns that we did not address earlier because not enough detail was provided.

    Lemfrder did not ask for confidential treatment of any information in its letter. In a September 26, 2002, telephone conversation between yourself and Dorothy Nakama of my staff, you confirmed that after consulting with Lemfrder engineers in Germany, Lemfrder does not request confidential treatment for any information in the letter.

    Please note that unlike the case in Europe and Japan, the National Highway Traffic Safety Administration (NHTSA) does not "approve" motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet applicable standards. The following presents our opinion of Lemfrders proposed design, based on the information in your letter to us.

    The Proposed Design Described in Lemfrders August 30, 2002, Letter

    I will assume for purposes of this letter that NHTSAs August 1, 2002, description of Lemfrders general design applies to the proposed shift patterns depicted in your new letter. NHTSA noted that in Lemfrders design, the shifting would be done by means of a joy stick, which, after being shifted, would return to a default position designated as the "X" position. NHTSA further noted that the joy stick may be moved straight up, straight down, and to the right

    and left (i.e., imagining the face of a clock, to the 12 oclock, 6 oclock, 3 oclock, and 9 oclock positions) only. Diagonal movements such as to the one oclock or two oclock positions would not be permitted. Most of the shift patterns have two neutral positions. In all of the shift patterns depicted, before the joy stick may go into "drive" or "reverse," it must first be moved to "neutral." Thus, for example, to go into reverse, one moves the joy stick straight up (to go to neutral) and then to the left (to reverse).

    With your new letter, you provided diagrams of nine more proposed configurations of shift-by-wire shift patterns. In five of the proposed configurations, it will be possible to shift from the "X" position manually to a higher or lower drive. For each of these five configurations, your proposed design depicts an "+" and "-" sign that "reflect the possibility to shift manually up or down by tipping towards the plus or minus, while the car is in D." None of the proposed configurations includes a "park" position. We assume that the shift patterns are intended to be used in motor vehicles with automatic transmissions.

    Shifting from "Neutral" to "Drive" or "Reverse"

    Requirements for shift patterns are specified at paragraph S3.1.1 of Standard No. 102, which states in part:

    A neutral position shall be located between forward drive and reverse drive positions . . . . If the transmission shift lever sequence includes a park position, it shall be located at the end, adjacent to the reverse drive position.

    All of your nine additional proposed shift patterns meet the requirement that "a neutral position shall be located between forward drive and reverse drive positions." As stated in NHTSAs August 1, 2002, letter since nothing in S3.1.1 specifies that only one neutral position is to be provided, your patterns that would include two neutral positions are not prohibited by S3.1.1.

    Since none of your proposed shift patterns includes a "park" position, we will not discuss the S3.1.1 provision specifying that if the transmission shift lever sequence includes a "park" position, it "shall be located at the end, adjacent to the reverse drive position."

    Standard No. 102s Identification of Shift Lever Position Requirements

    In our letter of August 1, 2002, we noted that unlike traditional transmission shift levers that stay in the gear position selected by the driver, the joy stick in your design defaults to the "X" position after the gear is selected. As a result, a visual display other than the joystick must inform the driver of the current gear selection. The August 1, 2002, explanation of Standard No. 102s identification requirements would apply to the nine shift pattern configurations that you have presented in your letter to us.

    I hope this information is helpful. If you have any questions, please contact Ms. Nakama at (202) 366-2992.


    Jacqueline Glassman
    Chief Counsel