Am I missing something? I skimmed the document up to page 18 and found some encouraging statements that appear to make this completely a "non issue" for enthusiasts and for cost except for the few remaining mechanical throttle systems which NHSTA expect will convert to ETC soon. What new cars still have mechanical throttles?
Page 8:
"Based on compliance information that NHTSA receives from vehicle manufacturers annually, almost all model year 2012 light vehicles sold in the U.S. will have a BTO system. Based on our experience with these BTO systems, we believe they will comply with this proposed rule without significant modification. Consequently, any manufacturer design, validation, and implementation costs associated with this proposal should be minimal. Furthermore, compliance testing costs are expected to be low since the proposed test procedure is nearly identical to existing brake performance test procedures. Tests could be conducted along with existing brake performance tests."
Also on page 16:
"return after the driver stops pressing on it, BTO will engage as soon as the driver applies the brake pedal (there may be a delay built into the system on the order of one second; in some systems, other pre-conditions have to be met for the BTO to engage, as discussed below)."
Further down page 16:
"Some manufacturers’ implementation of a BTO system may include checking for certain prerequisite conditions prior to actuation. The BTO system may check conditions such as vehicle speed, engine revolutions per minute (RPM), brake pedal travel, and pedal sequence (i.e., whether the brake was pressed first and then the gas pedal, or vice versa) to determine if the driver’s intention is to stop the vehicle. Based on these conditions, the BTO system may determine that the combined brake and gas pedal inputs are actually intentional, and it would not
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necessarily intervene in that case. This may occur, for example, if the vehicle is at very low speed and the driver presses on the brake first and then on the accelerator. This behavior is consistent with intentional driving maneuvers which may be used for such things as trailer positioning or similar situations. We believe there is no particular safety issue in these situations, and in fact this type of “two-footed” driving capability can be desirable and may be in widespread use. Since there is no reason for the BTO to intervene in this case, today’s proposal would not prohibit this kind of BTO design. In fact, our proposal intentionally avoids restricting the specific design aspects of BTO systems so that current BTO systems can be accommodated to the greatest extent possible, because we believe those systems (based on our testing) would address the safety issue at hand."
Is there something "nasty" I missed?
Dick