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Author Topic: Campaign to Initiate NHTSA Investigation into Kappa Passenger Presence Sensor  (Read 42475 times)

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Offline Gentleman Jack

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Offline ChopTop

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I was just checking out Pontiac Solstice under Google view (5/24/16) and the article came up under this pic;
http://www.carcomplaints.com/news/2016/nhtsa-investigate-pontiac-solstice-saturn-sky.shtml

Offline Robotech

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Just an update on this.

http://api.viglink.com/api/click?format=go&jsonp=vglnk_146432239160810&key=57a535e4d9ab08748681572c51f7a4d3&libId=iop7pzrh01000azx000DA1vqa9pbp&loc=http%3A%2F%2Fwww.skyroadster.com%2Fforums%2Ff5%2Fcampaign-initiate-nhtsa-investigation-into-kappa-passenger-presence-sensor-failure-73441%2Findex7.html&v=1&out=http%3A%2F%2Fwww.wsmv.com%2Fstory%2F24037545%2Fdevices-triggering-passenger-air-bags-repeatedly-recalled&ref=http%3A%2F%2Fwww.skyroadster.com%2Fforums%2Ff5%2Fcampaign-initiate-nhtsa-investigation-into-kappa-passenger-presence-sensor-failure-73441%2Findex8.html&title=Campaign%20to%20Initiate%20NHTSA%20Investigation%20into%20Kappa%20Passenger%20Presence%20Sensor%20Failure%20-%20Page%207%20-%20Saturn%20Sky%20Forums%3A%20Saturn%20Sky%20Forum&txt=Devices%20triggering%20passenger%20air%20bags%20repeatedly%20recalled%20-%20WSMV%20Channel%204

That story was aired in 2013. When the petition was accepted by the NHTSA I contacted the reporter to let him know of the update. After asking a few questions he asked if I would be willing to be interviewed on the subject and I agreed. Yesterday I drove to the Channel 4 NBC Newroom in LA to be interviewed via satellite by the Nashville reporter.

After the interview I started talking to the technician taking off my microphone. He asked what the interview was about and I told him, he mentioned his wife had a Solstice so we talked some more and I went into more detail about this. He then took me and introduced me to the Producer of NBC LA's investigative/consumer reporting division suggesting this would make a good story for NBC LA. I talked to the producer for a while and would email him my paper and supporting documentation later that day for his review.

If NBC LA picks up this story, and I'm hoping they do, the odds of this story getting National coverage is pretty good. If the NY station picks it up, I'm sure this goes National.

On the NHTSA front, IEE requested a conference call today between them, the NHTSA and IEE's attorney. The call was to ask the NHTSA for an extension to the June 1st deadline IEE has to respond to the NHTSA's request for further data. Two documents were added to the NHTSA site today from IEE making this request.

GM has not yet responded but they do have until June 27th but I expect them to request an extension as well.

Will share more when it becomes available.

Offline Robotech

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So I heard from Jeremy Finley, the reporter who interviewed me last week. I figured the report would be aired relatively soon.  Well, here is the link:

Drivers continue push for recall over vehicle's known issue - WSMV Channel 4

He also noted in his email to me that GM has opened an internal investigation into the issue.  I don't know if this is in conjunction with the NHTSA request for information but I'm sure the two are related in some way since information from one would satisfy the other. Now we just cross our fingers GM looks beyond their warranty repair system database for clues into the problem.

Offline TomatoSoup

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A face made for radio :)

Way to go!  Though interesting that they only spoke about the Sky and didn't mention the Solstice.

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Offline Critterman

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That was cold TS, very cold.   Man is trying to help all of us and you are picking on him.  You are getting as bad as GJ or SA, shame on you 
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Wait what did I do this time?
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Offline TomatoSoup

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If you needed to ask...
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Offline Robotech

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LOL TS is right, why do you think I stick to the forums usually?  LOL  I kept looking down and it looks like I'm closing my eyes constantly. Needed a coach...of course my boss mentions this AFTER I do the interview. LOL.

I think they focused on the Sky (even though I kept saying "Pontiac Solstice and Saturn Sky" or "Kappas" during the interview) because this story started with an employee at the station having a Sky with a failed sensor mat. In the original story, I think they only talked about the Sky too even though it's both cars. Believe me, I made sure to talk about both cars in my report and in the interview. LOL

Offline Sol Asylum

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I don't think I have made fun of any forum member for at least the last day or two, I think Critter is trying to hijack this thread.
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Offline TomatoSoup

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I kept looking down and it looks like I'm closing my eyes constantly. Needed a coach...of course my boss mentions this AFTER I do the interview. LOL.

Actually, I thought you came over well and looked comfortable in front of the camera.  I was impressed. Good job!
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Offline Robotech

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Thank you TS. I tried. :)

Offline ChrisPrice

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Did NHTSA grant the delays for IEE and GM to reply? Federal law requires NHTSA to close investigations within four months, though this article notes that date is often missed, as there is no penalty for missing the statutory deadline.

NHTSA doesn't seem to have a status page on open defect petitions, but they have published the petition itself here: http://www-odi.nhtsa.dot.gov/acms/cs/jaxrs/download/doc/UCM518399/INOA-DP16001-7401.PDF

NHTSA also, to my surprise, will publish a final report on the petition in the Federal Register... here's an example of a Crossfire defect petition outcome: https://www.federalregister.gov/articles/2015/08/19/2015-20380/denial-of-motor-vehicle-defect-petition-dp15-003 - that one was rejected because while the back windows were more prone to detach, NHTSA concluded it wasn't a major safety concern. Note to motorcyclists: Driving behind a Solstice or Sky is inherently safer than a Crossfire Convertible!

Offline Robotech

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GM did not request a delay but IEE did and it was granted. For updates, check this link:

http://www-odi.nhtsa.dot.gov/owners/SearchResults?prodType=V&searchType=PROD&targetCategory=A&searchCriteria.model=SKY&stats=216053%2C4%2C2%2C173%2C64%2CSKY&makeStats=&jsonBaseURL=%2Fdownloads%2Ffolders%2F&searchCriteria.model_yr=2007&searchCriteria.make=SATURN&searchCriteria.prod_ids=216053

You just need to click on the investigations tab after the page loads.

Today, NHTSA posted IEE's response. Here is my summary of it.

Well hell, that was quick. After my email last night there are 4 new documents on the NHTSA site this morning. These all have to do with the IEE response to the Office of Defect Investigation (ODI) at NHTSA. I'm going over the documents now and trying to make heads or tails of them. 

What I've determined is that the four documents are:

1. Response letter from IEE
2. Attachment to that letter that includes tables showing make/model/years of all cars with IEE productions as OEM equipment.
3. Additional letter from IEE informing ODI of corrections and addional information to the attached tables of document 2.
4. Attachment to second response letter that is an updated version of document 2.

Document one is the most informative.   

http://www-odi.nhtsa.dot.gov/acms/cs/jaxrs/download/doc/UCM534134/INRL-DP16001-64471P.pdf

It describes the two types of systems IEE produced. One is the OCS and the other is BodySense. They both work very differently.  The OCS product is what was used in our cars.  OCS was an entire system of the sensor mat, cable, interconnector, Hot-met (no idea what this is), Electronics, and Software including algorithm and calibration). However, the OC Sensor Mat was also sold separately as a component, not a system.

Both the whole system and the OC mat were sold to Lear. GM, Hyundai and Kia all received the complete OCS system. Continental received just the OC mat and then used it in their own complete OCS system which they then supplied to BMW, Nissan and Suzuki.

The great thing about this response is there are illustrations and break downs of what made each sensor mat different in each car and what groups they belong to. If you have ever wondered about what makes our mat unique, check out this document! As suspected, while our mats are different than the CTS, the basic principles are the same. From this document:

Quote
The OCS development is an interactive process.  The overall seat design, geometry and vehicle environment affect the pressure that an occupant or child seat places on different parts of the seat.  As a result, each OCS must be designed for the unique seating environment within each vehicle model, requiring the occupant classification system manufacturer to utilize different sensor mats, calibrations, and algorithms to properly classify occupants.  The placement of the sensors, and the amount of pressure each sensor will recognize for an occupant, will vary among the different seat designs and car design.

They use three mats as examples, the Cadillac CTS mat, the Buick Regal mat, and the Kappa Mat.  The Cadillac mat had 3D mesh and taped side-wing sensors.  The Regal mat had no 3D Mesh but the Kappa mat does have a 3D mesh.  Both the Regal and Kappa mats have no taped side-wing sensors. However, there is no mention that the overall construction process and general operation of the sensors and their matrix is vastly different from one car to the next, only the layout of the sensors and the calibration and algorithms for each application. No general difference between the designed operation of the mat is noted.

This piece of the document though is VERY interesting:

Quote
The IEE OCS incorporated into MY 2007-2010 Saturn Sky and 2006-2010 Pontiac Solstice vehicles, were designed and developed for these vehicles' unique seating design, geometry vehicle environment, car design and program specifications.  IEE developed the OCS in partnership with General Motors and Lear Corp. ("Lear"), General Motors' seating supplier for the Pontiac Solstice and Saturn Sky vehicles, to meet the distinctive requirements and specifications for that vehicle platform as defined by General Motors. The testing for the final integration, including durability testing, of the system into the seat and airbag system in the vehicle was the responsibility of General Motors, as the vehicle manufacturer, and the responsibility of the seat manufacturer. [Emphasis by the editor]

IEE clearly places the blame of any durability issues of the mat squarely on GM and Lear.

The document then goes on to explain this second document:

http://www-odi.nhtsa.dot.gov/acms/cs/jaxrs/download/doc/UCM534136/INRD-DP16001-64472P.PDF

What this table shows is each manufacturer, the models, the IEE Project number, IEE Part Numbers, Model year and Manufacturer part number of something IEE made. If anyone here wants to help out, I need to know what these GM part numbers are. They are all for the Kappa platform:

25828680
25855978
10345300
25817110

I'm assuming these go from newest number to oldest since 25828680 is listed for the convertibles and then again for the coupe.  I am also assuming that these are the individual part numbers for the mats themselves. The part number I have been using is for the finished seat assembly from Lear and this part number has never changed. Looking at one of the pictures from my document (I believe this was TomatoSoup's mat) I do see part number 25855978 on the mat controller. This would confirm that this was a GM part number for the Sensor Mat itself but since that part was never sold separately from the finished lower seat foam assembly, GM never had it in their database of OEM parts. So this progression of mat part numbers shows that there were SOME changes to the mat over the course of production but what those changes were is still unknown.

This document though includes BMW, Kia, Suzuki, Nissan, Hyundai, GM, Lear, Mobis, and Autoliv-Korea. It looks to be a list of everyone who got IEE parts, the models and model year the parts were meant for. However, it appears that in some instances the data is incomplete (and noted as such) or the model years are perhaps when the production started as there is only one model year listed for certain manufacturers/models.  Look at the document in the link above and you'll see what I mean. 

There are a couple of things we can take away from these documents though:

First is that IEE is the maker of the sensor mats in our cars. While we knew that going into this, there was never any official documentation or reference linking IEE to Lear to the Kappa. We knew IEE sold to Lear for the CTS, we knew Lear made the assemblies for the Kappa, but never an official link between the two. This document is that official link.

Second, IEE included everyone who got these kinds of mats, whether it was only the mat itself or the whole OCS assembly.  Kia, GM, BMW, Mini, and Suzuki are ALL on this list and ALL have had recalls for a failing mat.  Even though IEE is adamant about each mat assembly being different, I feel this works in favor of a recall for the Kappa.  Some of their designs, both complete OCS systems and OC mats alone, have failed and been recalled in other platforms. Because not EVERY platform these mats have been installed in has failed, it means failure rates will need to be evaluated from one make and model to another in order to determine in THAT SPECIFIC application has a failure issue. We've seen that ours does, no question.  So just because our mat is unique to our car doesn't mean that it can't suffer the same failures as other IEE mats have seen.

Third, since durability testing was not IEE's responsibility and falls on GM instead, if GM did not detect a problem with the mat design they would not have forwarded that information to IEE for correction.  Ergo, if GM states that they did inform IEE of necessary updates to the mat, then GM would have had to had known that there was a problem with the mat's failing.  If GM didn't inform IEE of a potential problem, then this falls back on GM's failure to properly detect and rectify the issue (coming from the standpoint that there IS an issue of course). Since in other recalls it has been noted that manufacturers have reported issues and worked with IEE to rectify similar issues, the precedence is set that if NHTSA or GM decide this is an issue, GM needs to work with IEE for a proper solution.

Well, one response received, now we wait to hear from GM.
« Last Edit: July 21, 2016, 04:28:31 PM by Robotech »

Offline Sly Bob

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Good information and interesting to see it all coming together. Here's hoping the final result is a recall or an extended warranty.
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Offline ChrisPrice

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Ironically, this also happened today:

http://gmauthority.com/blog/2016/07/2009-2010-chevrolet-impala-recall-wires-passenger-presence-sensor-module-airbag/

Quote
The defect: the front passenger seat frame may contact and damage the wires of the passenger presence sensor module.

The hazards: if the wires are damaged, the passenger presence sensory system may fail to recognize that the passenger seat is occupied, disabling the air bag.
Damage may also cause the air bag fuse to short resulting in a loss of all air bags and seat belt pretensions. Both conditions increase the risk of injury during a crash.

GM would now be obligated to acknowledge this in their response.

The Impala is not listed in the IEE document. But there are a couple of GM product codes that are unlisted, including a '06-'09 car that could be the Impala.

GM also admitted that the PSS failure could cause driver-side airbag failure - and - brace yourself (pun intended), seat belt tensioners!

Think about that next time you drive a Kappa with a failed PSS!!

To be clear, I'm not sure it's ironic at all. The Kappa defect petition may have triggered GM's new safety review system - and they're getting out-front of Impala since it wasn't under petition.
« Last Edit: July 21, 2016, 11:37:18 PM by ChrisPrice »

Offline Robotech

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Ironically, this also happened today:

http://gmauthority.com/blog/2016/07/2009-2010-chevrolet-impala-recall-wires-passenger-presence-sensor-module-airbag/

GM would now be obligated to acknowledge this in their response.

The Impala is not listed in the IEE document. But there are a couple of GM product codes that are unlisted, including a '06-'09 car that could be the Impala.

GM also admitted that the PSS failure could cause driver-side airbag failure - and - brace yourself (pun intended), seat belt tensioners!

Think about that next time you drive a Kappa with a failed PSS!!

To be clear, I'm not sure it's ironic at all. The Kappa defect petition may have triggered GM's new safety review system - and they're getting out-front of Impala since it wasn't under petition.

Interesting! Though this is definitely a different system...probably a more updated version of the system that I figured was GM's answer to sensor mat problems. The Kappa PPS system does not tie into the seat belt tension system. That wasn't integrated until much later.

Even so, this kind of exposure to the PPS system in the Impala is a good thing and I have a feeling will help press GM closer to issuing a recall for the Kappa.

I can't wait until we see the response from GM. However, I'm not sure it will be included in the GM response since their deadline was June 30 and this wouldn't have been a recall at that point. I do feel though that perhaps the petition for the Kappa, because it included other vehicles, prompted GM and their NHTSA overseers (which they will have for at least another year due to the ignition switch debacle) to examine other vehicles and perhaps exposed this problem with the Impala. 

OR it's a happy coincidence. Maybe...possibly...though I don't believe in coincidences.

Thanks for that post Chris. gives me a bit more hope something positive will come of this.

Offline ChrisPrice

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The '09 to '10 Impala is the W-Body platform, far older than Kappa, I'm not convinced Kappa's seatbelt tensioner is completely uninvolved.

I believe we do have a pretensioner system in our seatbelts. If it is run by the airbag computer, and a PSS module failure fries the airbag fuse, that could lead to the same problem.

Either way, it does confirm the potential for a PSS module failure to cause driver-side airbag failure. That has been a topic of discussion, and this pretty much solves it.

Even if the PSS module doesn't fry the airbag fuse, GM is pointing something out. Once your airbag light is tripped by the PSS... a subsequent fuse-failure on the airbag module would go unnoticed by the driver.

And that, almost certainly, would prevent airbag deployment for the driver in a Kappa.

The Impala did get a safety overhaul in 2009 - which netted it an IIHS Good rating for side impact, so it could be a more-modern-than-Kappa seatbelt system was added.

I'm not sure if there's a statutory penalty for missing the reply time, but since IEE got an extension - GM might have dovetailed on theirs. It's already July 21, so I suspect GM didn't reply by the 30th.

They may have been digesting IEE's reply, I'm not being critical of GM for a delayed reply here.

Edit: Also noticed GM's fix for the Impala is dirt-cheap. Taping a few wires. I suspect Kappa's repair costs (full sensor mat replacement) would exceed the 290,000 recalled vehicles, despite being almost 33% of the fleet size.
« Last Edit: July 22, 2016, 12:38:00 AM by ChrisPrice »

Offline Robotech

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You bring up a lot of good points Chris so I'm going to kind of split up your response to try and address them clearly.

The '09 to '10 Impala is the W-Body platform, far older than Kappa, I'm not convinced Kappa's seatbelt tensioner is completely uninvolved...

The Impala did get a safety overhaul in 2009 - which netted it an IIHS Good rating for side impact, so it could be a more-modern-than-Kappa seatbelt system was added.

Chris, I owned a 1997 Pontiac Grand Prix that was one of the top 25 fastest W-bodies in the country. I'm very familiar with the W-Body.

However, the law requiring vehicles to have a passenger presence sensor was not mandated until the 2006 model year. The 2005 CTS was the first GM vehicle to have such a device and it used the OCS system that the Kappa's received though with a different mat design. If you look at my research that I posted at the beginning of this thread, you'll see a dramatic decline, a near complete evaporation, in PSS mat failures in the CTS after their redesign in 2008.  It is my belief that when the car was redesigned, it received a new Passenger Presence Sensing system and that this system is more robust than the OCS used in the Kappa and earlier CTS hence the massive reduction in complaints.

Quote
I believe we do have a pretensioner system in our seatbelts. If it is run by the airbag computer...that could lead to the same problem.


We do have a pre-tensioner system but it is the older style that is not controlled by the airbag system, just inertia. The type mentioned in this recall is a completely different style of Passenger Presence Systems.

Quote
Either way, it does confirm the potential for a PSS module failure to cause driver-side airbag failure. That has been a topic of discussion, and this pretty much solves it.

Because they are vastly different systems, I wouldn't say it solves it, but I would say that it further calls into question driver side functionality if the Service Air Bag message is displayed in a Kappa's Driver's Information Center (DIC). Like you said, it has been a common topic of discussion and I have seen evidence in the NHTSA complaint system where owners have been told that with this Service Air Bag message being displayed, no air bags will deploy in the case of an accident. So this is something that needs to be definitively addressed by GM in regards to the Kappa specific system.

Quote
Even if the PSS module doesn't fry the airbag fuse, GM is pointing something out. Once your airbag light is tripped by the PSS... a subsequent fuse-failure on the airbag module would go unnoticed by the driver.

And that, almost certainly, would prevent airbag deployment for the driver in a Kappa.

The way we are seeing the PSS mat fail wouldn't cause a short which is what is necessary for a blown fuse. But you are correct that if the PSS mat fails and turns on the Service Air Bag message and then something else happens to the air bag system that would, without question, disable the air bag system like a blow fuse, the driver would never know the condition had become more serious. Regardless, the safety of the passenger is compromised no matter what when the PSS mat fails.

Quote
I'm not sure if there's a statutory penalty for missing the reply time, but since IEE got an extension - GM might have dovetailed on theirs. It's already July 21, so I suspect GM didn't reply by the 30th.

They may have been digesting IEE's reply, I'm not being critical of GM for a delayed reply here.
There is no penalty and this is why often times these investigations drag on.

If GM wanted an extension they would have had to apply for one separate from IEE. I don't believe they did or, if they did, NHTSA is taking their time in posting that request. With the update yesterday I'm assuming that had GM asked for an extension, the NHTSA would have posted that yesterday too since there is no issue of confidentiality when requesting an extension. 

You'll note the dates on IEE's first letter and attachment are before their deadline.  The updated documents came after. The reason we're not seeing them on the NHTSA site quickly is not because the manufacturers are missing their deadlines necessarily, it is most likely because the NHTSA has to go over them, make sure the manufacturer has not asked for certain parts to be published because of confidentiality when it comes to their design, and then the documents have to be redacted (if necessary), scanned and uploaded to their site. NHTSA is a small government organization...I think it is about 500 employees. For them to cover EVERY vehicle in the U.S. is an overwhelming task.  I'm sure GM has responded in time but now we have to wait for the NHTSA to go over the response and get it posted.

I will be staying on top of them and if I don't see the GM response posted by Aug 1 (that's a month after the deadline) I'll contact the NHTSA again.

Offline Robotech

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I just got an email back from my contacts at NHTSA. It was as I thought, GM has replied by they are going over the reply first before uploading it.

Offline ChrisPrice

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Good info. Just to correct the record, I was wrong. There is a $7,500 per day penalty for not replying timely to the NHTSA (unless granted an extension). There's no penalty for NHTSA missing its deadline.

So, I would presume GM responded timely as NHTSA said - $7,500 still counts somewhere.

It is, however, capped at $35 million should a company decide to not respond at all.
« Last Edit: July 22, 2016, 06:39:02 PM by ChrisPrice »

Offline Robotech

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Dang, $7,500 per day isn't chump change. So the 4 month Deadline is NHTSA's deadline, right?

Offline ChrisPrice

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Correct. That deadline has no penalty since NHTSA can't fine itself.

I also noticed on the NHTSA web site an error. The model years listed in the drop-down tag for Solstice was "2006-2010,2014"

Ironically, 2014 was the year Solstice was supposed to go out of production. Sigh.

Offline Robotech

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Correct. That deadline has no penalty since NHTSA can't fine itself.

I also noticed on the NHTSA web site an error. The model years listed in the drop-down tag for Solstice was "2006-2010,2014"

Ironically, 2014 was the year Solstice was supposed to go out of production. Sigh.

Yea, I saw that typo too. LOL All the documentation I read though has the dates right so I wasn't going to say anything to them. LOL

Offline ChrisPrice

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    • ChristopherPrice.net
It has been more than a month since the last status check with NHTSA, and I'm not seeing GM's reply on the NHTSA site.

On one hand, I think it should have been posted by now either way.

But on the other hand, it may be a good thing. It implies that NHTSA and GM are continuing to have private conversations about this.

 

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