In my last smart fortwo passion blog, the comments strayed away from the topic at hand (as is the point of the internet) and onto the shift pattern of the US model versus that of the European one. The statement from Bumby was "We didn't get the Euro shifter because the PRND layout is required by US law." EPBrown found an exception to this quickly "We're swimming in cars that use semi-auto gearboxes that use the N/R/+/- shifter. It's on every SMG-equipped BMW." That got me to thinking and then to researching exactly what is required by the NHTSA. And let me tell you now, it's not easy. The NHTSA only lists a "quick reference" guide to searching the Federal Motor Vehicle Safety Standards. In order to access the full text, one needs to go to http://www.gpoaccess.gov/ and search for "49 CFR 571." Obvious, right? Whatever, here it is:
FMVSS Rule 102 beings "Sec.571.102 Standard No. 102; Transmission shift position sequence, starter interlock, and transmission braking effect. S1. Purpose and scope. This standard specifies the requirements for the transmission shift position sequence, a starter interlock, and for a braking effect of automatic transmissions, to reduce the likelihood of shifting errors, to prevent starter engagement by the driver when the transmission is in any drive position, and to provide supplemental braking at speeds below 40 kilometers per hour (25 miles per hour). " That sounds about what I was looking for.
The section that pertains to our question is S3.1.1: (S3.1, of course, being titled Automatic Transmissions.) "Location of transmission shift positions on passenger cars. A neutral position shall be located between forward drive and reverse drive positions." And S3.1.1.1: "Transmission shift levers. If a steering-column mounted transmission shift lever is used, movement from neutral position to forward drive position shall be clockwise. If the transmission shift lever sequence includes a park position, it shall be located at the end, adjacent to the reverse drive position."
Oh, but that only appears to deal with column-mounted shifters, not the nub of a shift lever the 2008 X5 uses,
let's try "S3.1.4 Identification of shift positions and of shift position sequence. S3.1.4.1 Except as specified in S3.1.4.3, if the transmission shift position sequence includes a park position, identification of shift positions, including the positions in relation to each other and the position selected, shall be displayed in view of the driver whenever any of the following conditions exist: (a) The ignition is in a position where the transmission can be shifted; or (b) the transmission is not in park." That would mean that the BMW's park button is legally acceptable, but still stupid.
But what about the R8 and BMWs with SMG? Well, S3.1.4.2 handles that:
"Except as specified in S3.1.4.3, if the transmission shift position sequence does not include a park position, identification of shift positions, including the positions in relation to each other and the position selected, shall be displayed in view of the driver whenever the ignition is in a position in which the engine is capable of operation."
The rest of FMVSS 102 isn't nearly as exciting, but that seems to have settled the debate pretty thoroughly: PRND is not required, but N must be between D and R and, if applicable, Park must be labeled (as it is in the X5), and if there is no park (like the R8 and the 2008 M3 with DCT), gear position must be labeled and visible to the driver.
Here are quick links to FMVSS 102 and to the entirety of the Code of Federal Regulations Title 49: Transportation.
Mike Magrath, Vehicle Testing Assistant and unqualified legal researcher
Smart and X5 photos by Kurt Niebuhr, R8 photo by Bryan Moody

firstwagon says:
01:54 PM, 01/24/09
It's amazing that someone actually took the trouble (and money) to make up all those rules.
Seems to me it would much simpler to just have one rule...
All drivers are required to read the owners manual before driving a car they have not operated before.
pengwin says:
03:03 PM, 01/24/09
what do those slots in front of the gear lever do?
epbrown says:
03:47 PM, 01/24/09
The ones on the Smart? Those are to hold coins, believe it or not. Yep, you can only hold 4 coins - ideally 4 quarters. And if you've got a convertible, you're down to two.
But thanks for clearing up the debate, Mr. Magrath. It looks like if the car doesn't have a park position, it's pretty much a free-for-all as long as you can see what gear you're in. An on the Smart, I seem to remember reading in the manual that Park really isn't Park like on a automatic trans and you should really use the parking brake.
This is all over-thinking anyway - most likely the first guess was right, and Marketing figured the US market is too dumb to work the other shifter. Over-thinking is another thing the internet's good for, though. That, and guys insisting they would never sleep with Jessica Alba, even if she begged, because her 2nd toe is longer than her big toe.
estreka says:
05:39 PM, 01/24/09
I'm impressed, Mike. I know that couldn't have been a "quick read" by any stretch of the imagination.
Regs are so difficult sometimes.
ddoouugg says:
06:23 PM, 01/24/09
That research must have taken a while.
carfreak8394 says:
08:57 PM, 01/24/09
Thanks, Mike, for your research. Very informative. And this is completely unrelated, but I thought you guys might like this. It's a pretty cool technology.
http://www.volvocars.com/us/campaigns/Misc/Pages/XC60LaunchUS.aspx
Edmunds, when are you going to get a Volvo, by the way? I think the XC60 would be a good one to get for the fleet.
pengwin says:
09:08 AM, 01/25/09
only volvo worth buying right now is the S80.
cwc1 says:
01:00 PM, 01/25/09
"It's amazing that someone actually took the trouble (and money) to make up all those rules."
Our tax dollars and bureaucrats at work, doing what they do best - exerting more control over individuals' lives, and taking away liberty and personal responsibility.
carlisimo says:
04:09 PM, 01/25/09
The money spend on writing those rules is less than the amount that would've been spent on lawsuits after transmission-related accidents ("I thought it was in Reverse...").
Those accidents still happen, but less frequently. Thanks to the existing regulation, the manufacturer has something they can point to and say, "See, we did our part... you can't sue us for that driver's mistake."
I work with buildings instead of cars, but it's not too different. The only alternative to standards is dealing with every single case on its own, and that's worse.
07mx5 says:
06:28 PM, 01/25/09
"Our tax dollars and bureaucrats at work, doing what they do best - exerting more control over individuals' lives, and taking away liberty and personal responsibility. "
if only more people exercised personal responsibility...
altimadude00 says:
06:58 PM, 01/25/09
If the Smart's shifter was wrapped in white leather, it would look like a baseball.
zoomzoomn says:
05:11 AM, 01/26/09
You know, I remember the day when you could climb in just about anything and just drive it. And I'm not that old! It's getting ridiculous to me when you almost literally have to read the owner's manual just to be able to start the car and drive off. And that doesn't even account for using the radio, climate system and all of the other normal stuff! What ever happened to simple is better?
dougtheeng says:
06:41 AM, 01/26/09
The Smart has key positioning like a Saab eh? I've always wondered if I would love or hate that key position...or neither.
epbrown says:
07:56 AM, 01/26/09
zoomzoomn wrote: "You know, I remember the day when you could climb in just about anything and just drive it."
That attitude is sort of what started the discussion in the previous blog entry. The Smart's gearbox comes in for a lot of criticism, and I think it's unjust. The Fortwo uses a sequential manual gearbox like BMW's SMG, Ferrari's F1, and so on. Everyone HATES auto-mode in those gearboxes, and if Edmunds long-term E46 M3 had an SMG no one would use auto-mode all the time.
Because of the attitude you expressed - a common American viewpoint, I think - Smart chose to package their manual like a vanilla automatic transmission with the PRND layout. Sure, that helps people accept the car in the new market, but you end up with customers and reviewers upset when the car doesn't drive like it's got a TH400. The standard layout sets expectations that the car simply can't meet, and using the N/R/+/- layout typical for this type of gearbox would 1) change expectations of how the Smart should shift and drive, and 2) get more people driving in the much better "manual" mode, because no one expects to like auto-mode on sequential gearboxes to work as well as a real automatic.
If you browse the European Smart forums, you don't get a 1/10th the complaints about the 451's transmission compared to the US forums because everyone drives the car like a manual. It's the only way I've driven mine, because I knew what such gearboxes are like going in.
I'll concede that this could have hurt sales - the Smart has a funky urban young image in Europe, but in the US it's inordinately popular with retirees.
firstwagon says:
08:21 AM, 01/27/09
"You know, I remember the day when you could climb in just about anything and just drive it. And I'm not that old! It's getting ridiculous to me when you almost literally have to read the owner's manual just to be able to start the car and drive off. And that doesn't even account for using the radio, climate system and all of the other normal stuff! What ever happened to simple is better? "
I got a ride home the other day in a 2004 Buick Century you would just love. It was the most straight forward simple to use car I have seen in long time.
Comfortable, reliable and guaranteed not to require one bit of thought or effort on your part.
bob_wheeler says:
01:02 AM, 12/ 8/09
Good job Mike. Are there similar issues in Europe?