Mr. Karl-Heinz Ziwica
General Manger, Environmental Engineering
BMW of North America, Inc.
BMW Plaza
Montvale, NJ 07645-1866

Ref: A:FW22197

Dear Mr. Ziwica:

This responds to your request for an interpretation of Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect as it applied to a proposed BMW transmission design with electronic shifting controls.

We have reviewed the arguments presented in your request for an interpretation, and cannot agree with BMW that S3.1.1 Location of transmission shift lever positions on passenger cars, S3.1.3 Starter interlock and S3.1.4 Identification of shift lever positions "are not applicable to automatic transmissions without a shift lever." However, the agency is carefully reviewing BMW's related petition for rulemaking submitted on November 19, 1997, the same date as the request for interpretation. The agency will inform you of its decision on the petition for rulemaking after it has completed its review of your petition.

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

John Womack
Acting Chief Counsel