ID: nht74-1.31

DATE: 02/26/74

FROM: CERSAS FOR E.T. DRIVER, NHTSA

TO: Mack Trucks, Inc.

COPYEE: J. LEYSATH; MR. VINSON

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 4, 1974, concerning the location requirements of front identification lamps on certain solid-waste disposal vehicles.

You describe the vehicles in question as "short BBC low cab-ever-engine type vehicles -- equipped with a large volume body and a hydraulically operated front leader mechanism. This unit lifts containers of waste up and over the front of the cab and empties the waste into the top of the body. To prevent damage to the front of the vehicle and lamps, a protective guard is installed on the front centerline of the vehicle." You further state that "This guard could obstruct the center identification lamp."

You ask whether or not all three of the front identification lamps may be offset from the front centerline of the vehicle to ensure compliance with the visibility requirements of FMVSS No. 108. In accordance with paragraph S4.3.1. Table II of FMVSS No. 106 specifies that the front identification lamps be located "as close as practicable to the top of the vehicle, at the same height, as close as practicable to the vertical centerline." For the vehicles which you have described, it would appear that location of the front identification lamps either left or right of the vertical centerline would meet this requirement.

Sincerely,

ATTACH.

February 4, 1974

E.T. Driver -- National Highway Traffic Safety Administration, Office of Operating Systems

Dear Mr. Driver:

Subject: Request for Interpretation MVSS 108

Section S4.1.1 table I states that three identification lamps are required for vehicles of 80 or more inches overall width.

Section S4.3.1 table II requires that "three amber identification lamps be located on the front as close as practicable to the top of the vehicle, at the same height, and as close as practicable to the vertical centerline".

In addition, Section S4.3.1.1 requires that each lamp be located so that it meets the visibility requirements of applicable SAE Standards and that no part of the vehicle shall prevent the device from meeting the photometric output at any test point specified in any applicable SAE Standard.

Section S4.3.1.1 also states that if motor vehicle equipment prevents compliance, an auxiliary lamp or device meeting the requirement shall be provided.

The solid waste disposal industry use short BBC low cab-over-engine type vehicles (see Attachments 1 & 2) equipped with a large volume body and a hydraulically operated front loader mechanism. This unit lifts containers of waste up and over the front of the cab and empties the waste into the top of the body. To prevent damage to the front of the vehicle and lamps, a protective guard is installed on the front centerline of the vehicle. This guard could obstruct the center identification lamp. (See Attachment 3 through 6)

One of our customers has requested that we supply four identification lamps on the forward side of our MB series vehicle cab near the top so that he can mount a protective guard on the centerline of the cab and still meet the visibility and photometric requirements.

As we discussed during my visit of January 31st, use of four lamps will not be acceptable to the National Highway Traffic Safety Administration as it would defeat the identification function of these lamps for vehicles over 80" in width.

However, it was proposed that all three identification lamps could be moved to one side of the centerline, thereby permitting compliance with the visibility and photometric requirements when the units are in the installed position. This appears to us to be an effective solution to this problem and we, therefore, request your issuance of an interpretation for an installation of this type.

Very truly yours, MACK TRUCKS, INC.; A. M. Fischer -- Asst. to Exec. V.P.- Engineering & Product

Enclosure Omitted.

ID: nht74-1.32

DATE: 05/16/74

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Lt. Commander Robert H. Weldman, Jr.

COPYEE: LARSON; RANADER

TITLE: FMVSS INTERPRETATION

TEXT: This response to your letter of April 17, 1974, to the Department of Transportation requesting information on standards for (Illegible Word) Lighting systems. We have me record of your (Illegible Words)

In answer to your specific questions --

1. "Are there any federal or state regulations which specify sealed beam headlamps?"

Yes, this requirement has been effective either by Federal or State standards for more than three decades.

2. "Are both acceptable?"

A replacable bulb type headlamp is not acceptable.

3. "Is amber a permissible headlight (Illegible Word)

No, headlight must white light.

4. "Is white mandatory for backup lights?"

Yes, white is mandatory.

Sincerely,

ATTACH.

APRIL 17, 1974

U.S. Department of Transportation,

Attn: Federal Standards for Automobiles.

Dear Sirs,

I wrote you on 12 February 1974 to ask for information on Federal and state standards for automobile lighting systems. I have received no reply, so herewith a repeat of my request: are there any federal or state regulations which specify sealed beam headlamps, or are bulbs acceptable? Is amber a permissible headlight color? Is white mandatory for backup lights?

I will appreciate any information you can give me.

Sincerely,

Robert H. Weidman, Jr. -- LCDR USN,

Box 33 B753, FPO NEW YORK 09540

ID: nht74-1.33

DATE: 02/20/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Spartan Design Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 21, 1974 asking for our comments on your defect notification letter.

In describing the defect (your third paragraph) as required by Section 577.4(c), you should state specifically that the placement of the lamps fails to conform to Federal Motor Vehicle Safety Standard No. 103, and indicate, in general terms, what is the appropriate location. In addition, section 577.4(c) requires the inclusion of precautions the purchaser can take. We believe one precaution that should be included where a lighting problem is concerned is to recommend that night driving be limited as much as possible.

When we have received a corrected copy, we will close our files in this matter.

Sincerely,

ATTACH.

January 21, 1974

Lawrence R. Schneider -- Chief Counsel, U.S. Department of Transportation, National Highway Traffic Safety Adm.

Ref: #N40-30, (ZTV) CIR618

Dear Mr. Schneider:

Enclosed is a copy of the rewritter letter as you requested. (Illegible Word) read the letter and see if it meets with your approval and let us know so that we may then mail it to all our Converta-Trailer owners.

We are sorry to have caused you any inconvenience and if there is any further information you need please let us know.

Sincerely, SPARTAN DESIGN INC.;

Robert W. Borgert -- Vice President

enclosure

Spartan Design Inc.

Dear Converta-Trailer Owner:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

Spartan Design Inc. has determined that a defect which relates to Motor Vehicle Safety exists in Converta-Trailers manufactured between January 1, 1969 and December 8, 1971. According to our records, you are the owner of a 1971 Converta-Trailer bearing the vehicle serial number on the enclosed reply form which has this defect.

(Illegible Word) defect involves the combination rear lamps which are improperly located. Due to the poor visibility of these lamps, a rear end crash can occur.

To prevent the possibility of a rear end crash to your trailer, please contact Spartan Design Inc., who will remove the lights from back of fenders and reinstall them to the far rear of trailer frame, at no charge to you.

The actual time necessary to perform the labor required to install the rear lamps is approximately 2 hours. It is suggested that you make an appointment in advance so work can be scheduled in an orderly manner.

In the event you no longer own your trailer, or these modifications have been performed already, please complete and mail the enclosed form post-paid, in addressed reply envelope so that we may update our records.

We are sorry to cause you this inconvenience; however, we have taken this action in the interest of your safety and continued satisfaction with our product. Your prompt cooperation will be (Illegible Word).

Your truly, SPARTAN DESIGN INC.

ID: nht74-1.34

DATE: 01/10/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Trailmobile Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of October 25, and December 14, 1973. I regret that your earlier letter did not arrive.

You stated that your customer wishes to mount rear identification lamps at the same height from the ground as the rear turn signal, stop, tail and clearance lamps, and that, because of the shallowness of the rear header area it is not "practicable" to mount them there.

Although it may not be "practicable" to mount the Grote #272 lamp, specified by your customer, in the header area, there may be other conforming lamps that it would be "practicable" to mount in that location in a three-lamp identification array. If such lamps are available, then Standard No. 108 takes priority over contractual specifications, especially since the clearance lamps will be mounted at a point other than "as close as practicable to the top of the vehicle".

Yours truly,

ATTACH.

TRAILMOBILE TECHNICAL CENTER

December 14, 1973

Lawrence Schneider, Chief Counsel -- Dept. of Transportation

Dear Mr. Schneider:

Please find enclosed a copy of a letter dated October 25, 1973 in which I requested a ruling on the lowering of the identification lamps on the rear of a trailer under certain conditions of shallow header depth.

Today I talked with Mr. T. Vinson of your office and was advised that the letter must have been lost as he had not seen the request and further advised that I resubmit a copy of the original request.

Sincerely,

Evan Hammond -- Manager - Central Engineering

Encl.

cc: R. J. Deller; J. E. Cook; E. E. Lungren - Chicago

October 25, 1975

Lawrence Schneider, Chief Counsel -- Department of Transportation Dear Mr. Schneider:

Please find enclosed a sketch of a trailer rear end lighting arrangement, on which we are requesting a ruling with respect to conformance to M.V.S.S. no. 108.

In this particular case the customer is specifying a higher than normal rear door opening to facilitate easier loading and unloading of palatized cargo. Accomplishment of this end necessitates that the rear frame header be 2-5/8" deep. At the same time, the customer is specifying a Grote #272 lamp for the rear identification lamp function. It is not possible to mount these lamps on the shallow header in any "practicable" manner to (Illegible Word) the overall height of the trailer. We respectfully request that we may be allowed to mount the lamps to a lower level (same level as the turn signal, stop, tail and rear clearance lamps), this being "as close as practicable to the top of the vehicle" in this case.

We believe that the proposed installation is not in conflict with the intent of the safety standard as it will provide an easier and more reliable installation with simpler maintenance and at the same time, the rear lamp configuration is identical to thousands of platform trailers and container chassis safety in operation today on our highways.

A prompt reply to this request will be greatly appreciated.

Sincerely,

Evan Hammond -- Manager - Central Engineering

Encl. to all

cc: R. J. Deller; J. E. Cook; E. E. Lungren - Chicago

(Graphics omitted)

PROPOSED TRAILER REAR END LAMP CONFIGURATION WITH "SHALLOW HEADER" REAR FRAME

ID: nht74-1.35

DATE: 06/06/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Committee on Transportation, Florida House of Representatives

COPYEE: W. R. EASON; NHTSA REGIONAL ADMINISTRATOR -- ATLANTA

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 7, to Dr. James R. Gregory, Administrator, National Highway Traffic Safety Administration, concerning the activation of headlamps during periods of reduced visibility, and the automatic illumination of vehicle headlights when the windshield wipers are activated.

The National Committee on Uniform Traffic Laws and Ordinances is the custodian of the Uniform Vehicle Code. Any revision of @ 12-201 relating to operation of headlights in line with the Florida law could be duly considered by its Subcommittee on Vehicles and Highways. Perhaps you may wish to submit a proposal to revise this section of the UVC to Mr. Edward F. Kearney, Executive Director, National Committee on Uniform Traffic Laws and Ordinances, 1776 Massachusetts Avenue, M.W., Washington, D.C. 20036. If you choose to do so, this would be a timely action since the various Subcommittees of the National Committee will be meeting in the next few months to consider pending proposals to revise various chapters of the UVC.

With respect to automatic illumination of headlights with the windshield wipers, the NHTSA has conducted, and will continue to conduct, considerable research on improved headlighting. This research will include evaluations of means and features which will enhance the safety of driving during inclement weather, at which time the driver would normally use his windshield wipers. The simultaneous activation of headlights and windshield wipers would ensure that the headlights are in use during adverse weather conditions. This feature would, however, result in unnecessary use of the headlights under fair weather conditions; for example, when the driver is operating his windshield washer or when the windshield wiper is used while the vehicle is parked. Illuminated headlights under fair weather conditions will also decrease the conspicuousness of the front turn signal lamps which are normally located near the headlights. These and other factors must be carefully considered in determining the true merits of a feature which would provide for automatic illumination of the headlamps when the windshield wipers are activated. Based on the information available to date, we are not in a position to justify proposing a Federal requirement for such a feature.

Furthermore, since paragraph S4.5 of Federal Motor Vehicle Safety Standard No. 108 establishes special wiring requirements (including simultaneous activation of taillamps, parking lamps, license plate lamps, and side marker lamps, with the headlamps), we would view differing State wiring requirements as preempted by Section 103(d) of the National Traffic and Motor Vehicle Safety Act, and hence invalid.

An alternative approach to ensuring the use of headlights during adverse weather would be the strict enforcement of State regulations requiring the use of headlights curing periods of reduced visibility, normally less than 500 feet.

This approach might be more cost-effective, since the cost of the automatic feature would be precluded.

Thank you for bringing your Bill HB 3135 to my attention. If I can be of any further assistance, please do not hesitate to contact me.

Sincerely,

NHTSA CONTROL NO. 1496

ATTACH.

FLORIDA HOUSE OF REPRESENTATIVES

COMMITTEE ON TRANSPORTATION

May 7, 1974

James B. Gregory, Administrator -- National Highway Traffic Safety Administration

Re: Uniform Vehicle Code (Rev. 1971) Chapter 12-201 "When lighted lamps are required"

Dear Mr. Gregory:

I call your attention to the above cited requirement of the U.V.C. compared to Florida's law, Chapter 316.217, Florida Statutes. I will agree that Florida requires lamps to be lighted one hour per day longer than the U.V.C. does as well as Florida enumerates the conditions during which time lamps shall be lighted and the U.V.C. does not. We can therefore agree that Florida's law is more stringent in its requirements than your recommendations in the U.V.C.

As you can see from my efforts to change our law, HB 3135 and a timely letter to the editor in the Miami Herald, copies enclosed, we are having our problems in educating the people about and enforcing the provision of the law which requires head lamps to be lighted when it is raining. Rain is not a safety hazard peculiar only to Florida. Perhaps the distinguished drafters of the Code should speak more specifically to this problem, require all states to conform to this law and even require the automobile manufacturers to install the mechanism referred to in Section 2 of my bill which when the windshield wipers are activated, the head lamps will automatically be activated without any additional action required of the operator.

I fully realize just how impractical it is for only one state to have such a requirement placed on the manufacturers of automobiles. However, this is my way of impressing you with the gravity of the situation and that it is within your power to reduce this specific safety hazard by requiring the manufacturers install the aforesaid mechanism. The cost to install such an item will be very nominal, less than $ 2.00, yet the benefits can be very large indeed in the saving of lives and the reduction of property damage.

Sincerely, Vernon C. Holloway -- CHAIRMAN

Enclosures

cc: NHTSA Regional Administrator, Atlanta; Miami Herald, Miami

(Regular Session 1974)

By Representative Holloway

A bill to be entitled

An act relating to the operation of head lamps and windshield wipers during unfavorable atmospheric conditions; arending section 316.217(1), F. S., requiring head lamps and windshield wipers be operated under certain conditions; amending section 501.125, F. S., adding subsection (3) thereto and renumbering (3) as (4); requiring certain automobiles have specific equipment attached before they are sold and licensed in the state; providing an effective date.

Be It Enacted by the Legislature of the State of Florida:

Section 1. Subsection (1) of section 316.217, F. S., is amended to read:

316.217 When lighted lamps are required. --

(1) Every vehicle upon a highway within this state at any time from sunset to sunrise, during fog, smoke, or rain, or atmospheric conditions, are such that there is inadequate light, shall display lighted lamps and illuminating devices as hereinafter respectively required for different classes of vehicles, subject to exceptions with respect to parked vehicles. Stop lights, turn signals and other signaling devices shall be lighted as prescribed for the use of such devices. Whenever conditions are present which require the use of windshield wipers, headlamps shall be activated.

Section 2. Section 501.125, F. S., is amended by adding a new subsection (3) thereto and renumbering (3) as (4) to read:

501.125 Warranty on sale and manufacture of automobiles; energy absorption system, windshield wipers and head lamps. --

(3) Every private passenger automobile manufactured on and after September 1, 1975, and sold and licensed in the state shall be sold subject to the manufacturer's warranty that it is equipped with a mechanism which when the windshield wipers are activated, the head lamps are automatically activated without any additional required action on the part of the operator.

(4) The warranty provisions of this section shall not be applicable with respect to any private passenger automobile as to which the manufacturer files a written certification under oath with the department of highway safety and motor vehicles, on a form to be prescribed by that department, that the particular make and model described therein complies with the applicable standards of this section.

Section 3. This act shall take effect October 1, 1977.

LEGISLATIVE SUMMARY

Requires automobile headlight operation when there is inadequate light, at any time from sunset to sunrise, during fog, smoke or rain. Requires windshield wiper use whenever conditions necessitate. Requires every private passenger automobile manufactured on and after September 1, 1975 and sold and licensed in the state to be warrantied by the manufacturer that it is equipped with a mechanism which automatically activates the head lamps when the windshield wipers are activated.

The Miami Herald

Monday, April 22, 1974

Enforce 'Lights On in Rain' Law

To The Editor:

Is there any law less frequently enforced than the law requiring headlights on during a rainstorm?

I realize that it requires the police officer to get out of his car in the rain, but if nobody is going to enforce it then get the law off the books -- or enforce it.

BOB RESNIZK

ID: nht74-1.36

DATE: 09/09/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Societe de Signalisations Automobiles

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 17, 1974, concerning NHTSA's proposal to apply a manufacturer's identification code to motor vehicle lights.

Motor vehicle lights, including those imported in the United States, subject to MVSS No. 108, Lamps, reflective devices, and associated equipment, would be required to be marked with a manufacturer's identification code under the NHTSA proposal. Just as all motor vehicle lights must meet the performance requirements of Standard 108, if the proposal is adopted as a final rule they would be required to meet the manufacturer's identification code requirement as well.

Thank you for advising us of your views in this matter. We will take them into account in formulating further action.

Yours truly,

ATTACH.

July 17, 1974

Dear Sirs,

Further to the publication of your project in the Federal Register of the 5.6.74 modifying the mode of assigning an identification code we have to inform you that for the little trafic lights still existing nearly everywhere in the world, it will be very difficult to find an aera authorising all the markings.

Unfortunalty, we see no solution to suggest to you but we want to point out the difficulties there will be to account for all of the markings.

Yours faithfully

The Secretary General -- R. VIBART

ID: nht74-1.37

DATE: 06/20/74

FROM: AUTHOR UNAVAILABLE; Lawerence R. Schneider; NHTSA

TO: Western Scooter Distributor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 14, 1974, advising that the State of Virginia refuses to register the Ciao Moped "because there is no high beam."

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, through its incorporation of SAE Standard J584, Motorcycle and Motor Driven Cycle Headlamps, allows motorcycles of 5 horsepower or less to be equipped with either one single beam or one multiple beam headlamp. Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 prohibits a State from having requirements that differ from Federal ones where the same aspect of vehicle performance is concerned. Therefore, a State law or regulation under which a motor driven cycle is barred solely because it is equipped with a single beam headlamp would be preempted and void, by Federal law.

Sincerely,

ATTACH.

June 14, 1974

Chief Counsel -- National Highway Traffic Safety Administration

Dear Sir:

Our firm imports Piaggio motor vehicle products for distribution through the United States. We are currently importing the Vespa Motorscooters and the Ciao Mopeds.

We have recently encountered problems on registration in the State of Virginia concerning the Ciao Moped. The only area in question concerns the headlight. The State of Virginia has refused to register these vehicles because there is no high beam.

It is our interpretation of Standard 108 that "motor driven cycles" do not require a high beam on their headlights.

We request clarification on this matter.

Very truly yours,

R. H. Remensperger -- President, WESTERN SCOOTER DISTRIBUTORS

ID: nht74-1.38

DATE: 01/03/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 20, 1973, concerning the placement of rear identification lamps on the header of Fruehauf trailers.

I enclose a copy of a recent exchange of correspondence between Fruehauf and this agency on this question which I believe is in point. It is our view that if a lamp is available which may be installed in a narrow header area, the upper location is "practicable" even though the lamps may not be the one specified by the vehicle's purchaser.

Yours truly,

ATTACH.

December 20, 1973

Larry Schneider -- Chief Counsel, National Highway Traffic Safety Administration

Subject: Placement of Rear Identification Lights

Dear Mr. Schneider:

We have a customer at the present time who finds it impractical to mount the three rear red identification light at the high level.

Due to the special high door construction on the dry van, the upper door header does not lend itself to the installation of the standard lights that are now used on his equipment.

These trailers are being manufactured by Fruehauf Corporation, and the present quantity is 400 trailers.

In consideration of the large number of containers that are now on the highways with no upper lights and the hardship involved in endeavoring to place improvised lights at this level, we are requesting an opinion from your office as a guide for our future action.

Thank you very much for your consideration.

Yours very truly,

TRUCK-LITE COMPANY; H. A. Sage, Director -- Research Development

Enclosure

CC: R. V. Tarr; J. J. Vicario

ID: nht74-1.39

DATE: 02/25/74

FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA

TO: Ford

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 24, 1974, asking for an interpretation as to whether a rear lamp assembly design that Ford demonstrated to NHTSA representatives conforms to the location requirements of Standard No. 108. The assembly consists of three units which, from outboard to inboard, as a rear lighting assembly, comprise the tail lamp/stop lamp, backup lamp, and turn signal lamp.

Standard No. 108 specifies that stop lamps, tail lamps, and turn signal lamps be "as far apart as practicable." The standard does not specify a minimum separation distance of lamps, a maximum permissible location inboard, or location of one system relative to another. The determination of practicability in lamp spacing is to be made by the vehicle manufacturer, and the agency has generally afforded manufacturers some latitude in this interpretation.

Therefore, the configuration you have described and demonstrated would not violate Standard No. 108. It should be noted, however, that it would be in conflict with the requirements for rear turn signals and stop lamps as proposed in Docket 69-19, Notice 3.

Sincerely,

ATTACH.

January 24, 1974

James B. Gregory -- Administrator, National Highway Traffic Safety Administration

Dear Dr. Gregory:

On January 14 Ford demonstrated a rear lamp design that it plans to use on one of its 1975 models. The purpose of the demonstration was to display the design and make sure there were no misunderstandings as to the lamp's conformance with the location requirements of Motor Vehicle Safety Standard No. 108. Ford pointed out that the various functions of the lamp were "as far apart as practicable" for the rear end design of the vehicle and for the separation of signal functions by space and color in which both the NHTSA and Ford are interested.

For the record the lamp assembly may be described as follows: Red White Amber Left side shown (Approximately to scale)

* The outboard pod has a red lens and wraps around the quarter panel, thus serving as a rear side market, taillamp and stop lamp and as side and rear reflex reflectors.

* The center pod has a white lens and serves as the backup lamp.

* The inboard pod has an amber lens and serves as the turn signal lamp.

While it is our impression that NHTSA technical personnel who examined this lamp design agreed that it fully meets the location requirements of Standard No. 108, we should appreciate formal confirmation that the Administration concurs in our interpretation.

Respectfully submitted,

J. C. Eckhold -- Director, Automotive Safety Office, FORD MOTOR COMPANY

ID: nht74-1.4

DATE: 10/03/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Guy Malleret

TITLE: FMVSS INTERPRETATION

TEXT:

N40-30 (ZTV) OCT 3 1974

Mr. Guy Malleret Director General Officine Alfieri Maserati S.p.A. Modena Italy

Dear Mr. Malleret:

This is in reply to your letter of September 13, 1974 expressing support for the petition by Citroen for rulemaking to amend Standard No. 105-75.

We have responded to Citroen by letter of September 19, 1973 asking for additional technical information and available accident statistics. Since certain models of Maserati vehicles are equipped with the Citroen full power braking system and NHTSA's ultimate decision will affect you. I enclose a copy of our letter with the thought that you may wish to provide us with Maserati's answer to these questions.

Yours truly,

Richard B. Dyson Acting Chief Counsel

Enclosure