Overview
Title
FCA US LLC; Receipt of Petition for Decision of Inconsequential Noncompliance
Agencies
ELI5 AI
FCA US noticed that some of their Alfa Romeo Stelvio cars have a little problem with the backup camera that makes the car look wider than it really is, and they are asking if this tiny mistake is okay and doesn't need fixing. The big car safety group, NHTSA, is thinking about it and wants people to tell them what they think.
Summary AI
FCA US LLC (formerly Chrysler Group LLC) has identified that certain 2018-2022 Alfa Romeo Stelvio models do not fully meet the Rear Visibility safety standards set by the Federal Motor Vehicle Safety Standard No. 111. The issue lies in the rearview camera displays, which mistakenly show the vehicle as wider than it truly is, partially obstructing the view of test objects. FCA US argues this discrepancy is minor and unlikely to jeopardize safety, and thus petitioned to avoid notifying customers or fixing the issue. The National Highway Traffic Safety Administration (NHTSA) is reviewing this petition and seeking public comment.
Abstract
FCA US LLC f/k/a Chrysler Group LLC (collectively referred to as "FCA US") has determined that certain model year (MY) 2018-2022 Alfa Romeo Stelvio motor vehicles do not fully comply with Federal Motor Vehicle Safety Standard (FMVSS) No. 111, Rear Visibility. FCA US filed a noncompliance report dated September 21, 2021. FCA US subsequently petitioned NHTSA on October 14, 2021, for a decision that the subject noncompliance is inconsequential as it relates to motor vehicle safety. This notice announces receipt of FCA US' petition and amended petition.
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Sources
AnalysisAI
Summary of the Document
The document discusses a petition filed by FCA US LLC, previously known as Chrysler Group LLC, regarding certain Alfa Romeo Stelvio models from 2018 to 2022. This petition is about a compliance issue with the Federal Motor Vehicle Safety Standard (FMVSS) No. 111, which deals with rear visibility. The problem identified is with the rearview camera displays that incorrectly show the vehicle as wider than it is, thereby partly obscuring the view of certain test objects. FCA US asserts that this issue is negligible and poses no significant safety risk, hence requesting exemption from notifying customers or correcting the noncompliance. The National Highway Traffic Safety Administration (NHTSA) is considering this petition and has invited public comments on the matter.
Significant Issues and Concerns
Ambiguity in Technical Details
The document contains technical language, such as "dynamic gridlines" and "test objects," which may not be easily understood by the general public. This could lead to confusion about the exact nature of the noncompliance. Providing detailed explanations or illustrations could make these terms clearer to non-experts.
Regulatory References Without Lay Explanation
Although the document mentions specific regulations, such as 49 U.S.C. 30118 and 30120, it doesn't explain them in simpler terms. This could hinder understanding among those unfamiliar with regulatory language, thereby limiting effective public engagement.
Potential Costs and Consequences
The document does not discuss the potential financial implications for FCA US or the consequences for stakeholders if the petition is denied. It leaves stakeholders unsure about the possible outcomes and duties related to addressing the noncompliance after the agency's decision.
Restriction on Comments
The notice states that comments should not exceed 15 pages, which could restrict comprehensive feedback from stakeholders. More space might allow for a deeper analysis and a broader range of opinions from the public and industry experts.
Impact on the Public and Stakeholders
Broad Public Impact
For the general public, especially consumers driving these vehicles, understanding the safety implications is crucial. While the company claims the issue is inconsequential, the public might still have concerns about the reliability of these vehicle safety features.
Impact on Specific Stakeholders
If FCA US's petition is granted, dealers and distributors may benefit from not having to incur costs related to recall notifications or repairs. However, if denied, they will have to adhere to prohibitive sales measures and undertake necessary rectifications, affecting their operations and finances.
Overall, this document showcases an intersection between regulatory compliance, public safety, and corporate responsibility. The considerations and decision-making process highlight the importance of transparency and comprehensibility in public safety regulations and company practices.
Issues
• The phrase 'dynamic gridlines partially cover the lower inside edges of the front test object when the steering wheel is straight' may be ambiguous for those not familiar with FMVSS No. 111 standards, potentially causing confusion.
• The document may benefit from a clearer explanation of the terms 'test object' and how 'dynamic gridlines' work, as these are technical details crucial for understanding the noncompliance.
• While the document mentions specific regulations and code references (49 U.S.C. 30118 and 30120), it lacks a layperson explanation that could enhance understanding for the general public.
• The document does not provide any information on potential costs related to the noncompliance or the consequences if the petition is denied, which might be relevant for stakeholders.
• The description of the overlap with test object E being smaller than the size of a seated Riley Low Birth Weight Infant may be unclear without visual aids or additional context.
• The document states, 'comments must be no greater than 15 pages in length,' which might seem restrictive and could limit comprehensive feedback from stakeholders.