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Numerous Tesla owners say they've been trapped inside their EVs after they lost power.
(www.businessinsider.in)
this post was submitted on 20 Aug 2023
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I believe you can write them. Based on this, it does appear to mandate that you have to have a release on the inside. bUT it doesn’t say it has to be manual and it doesn’t necessarily say it has to be operable at all times.
That said, at the least, it would seem BMW would be in violation of the spirit of the law at least, and probably the letter too.
Teslas less so since they have an manual override but it being hidden and not well labeled is it’s own issue.
https://www.nhtsa.gov/interpretations/08-000497-16-jan-09-rewrite