Interpretation ID: nht90-3.51

TYPE: Interpretation-NHTSA

DATE: August 8, 1990

FROM: Robert Erhardt -- Senior Project Engineer, Advance Transformer Co.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-13-90 from P.J. Rice to R. Erhardt (A36; VSA Sec. 10(a)(2))

TEXT:

As you may know, we at Philips are working on the development of high intensity discharge (HID) lighting systems for use as motor vehicle headlamps. These systems promise dramatic improvements in forward illumination while using less energy in a lower p rofile (allowing more aerodynamic vehicle design).

We are now at the point in our development where we have engineering samples available that we wish to test on road vehicles and would like to be advised of the laws concerning such an undertaking. It is our intention to equip 110 private and/or company vehicles for everyday use. The test would continue indefinitely (for lifetime/reliability evaluation) and could begin as early as August 27, 1990.

If a waiver or official authorization for this type of test is necessary, please consider this a request for same.

Given the competitive nature of the market that this product is being developed for, we are interested in beginning our test as soon as possible. A response by August 27 would be greatly appreciated.

If you have any questions concerning our program please contact either our Director, Mark Fellows, or myself at Advance Transformer (708) 390-5000.