Mr. Thomas V. Kazyaka
Chief Executive Officer
T.V.K. Industries, Inc.
P. O. Box 1161
Gualala, CA 95445
Dear Mr. Kazyaka:
This responds to your letter asking for reconsideration of our October 15, 2003, interpretation letter to you. In that letter, we concluded that manual transmission shift levers need not be backlit or display the gear engaged in order to comply with S3.2 of Federal Motor Vehicle Safety Standard (FMVSS) No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect.
In your new letter, you stated again that manual transmission shift levers may not be visible in a low light environment. After reviewing your letter, we have concluded it does not provide a basis for us to change our opinion.
As we stated earlier, S3.2 of FMVSS No. 102 specifies the following requirements for vehicles with manual transmissions:
Manual transmissions. Identification of the shift lever pattern of manual transmissions, except three forward speed manual transmissions having the standard "H" pattern, shall be displayed in view of the driver at all times when a driver is present in the drivers seating position.
While this paragraph requires identification of the shift lever pattern of manual transmissions, we affirm that it neither requires identification of the gear engaged nor backlighting. We also note that no other FMVSS requires vehicles with only manual transmission shift levers to identify the gear engaged or to have backlighting.