ID: 10462-2

Mr. John E. Getz
Director, Mobile Products Engineering
Ellis & Watts
4400 Glen Willow Lake Lane
Batavia, Ohio 45103

Dear Mr. Getz:

This responds to your letter asking whether certain operations that your company performs on used trailers result in the trailers being considered "newly manufactured" for purposes of the Federal motor vehicle safety standards. You stated that you sometimes change the finishing and equipment of a used trailer for a new application. As an example, you stated that you recently took a 10- year old trailer, stripped the inside, and refinished it as a mobile marketing facility. You also stated that in some cases you may cut a hole in the side and install a door for a specific application. In a telephone conversation with Dorothy Nakama of my staff, you indicated that you have also changed trailers by adding heating or air conditioning units, or making the trailer usable as an auditorium.

In your letter, you asked whether the trailers would be considered "newly manufactured" if the running gear, VIN and the basic trailer structure do not change, but the ownership does change. You asked this question in light of the fact that change of ownership is relevant under 49 CFR part 571.7(f) in determining whether a trailer manufactured from new and used components is considered newly manufactured. As discussed below, it is our opinion that the operations you describe do not result in the trailers being considered newly manufactured.

By way of background information, the National Highway Traffic Safety Administration issues safety standards for new motor vehicles and new motor vehicle equipment. The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles or equipment meet all applicable standards. The following represents our opinion based on the facts provided in your letter.

Section 49 CFR part 571.7(f) reads as follows:

Combining new and used components in trailer manufacture. When new materials are used in the assembly of a trailer, the trailer will be considered newly manufactured for

purposes of [the safety standards], unless, at a minimum, the running gear assembly (axle(s), wheels, braking and suspension) is not new, and was taken from an existing trailer--

(1) Whose identity is continued in the reassembled vehicle with respect to the Vehicle Identification Number; and

(2) That is owned or leased by the user of the reassembled vehicle.

This section only applies when new and used materials are used in the "assembly" of a trailer. It is our opinion that the operations that you describe, i.e., where the running gear, VIN and the basic trailer structure do not change, do not constitute trailer assembly. Therefore, this section, including its provision concerning transfer of ownership, does not apply. We consider your operations to be in the nature of repair or refurbishment of a used trailer, which does not result in the trailer being considered newly manufactured.

I hope this information is helpful. If there are any questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

Philip R. Recht Chief Counsel

ref:571 d:3/2/95

ID: 04-006678drn

Mr. Robert Strassburger
Vice President Safety and Harmonization
Alliance of Automobile Manufacturers
1401 Eye Street, NW, Suite 900
Washington, DC20005

Dear Mr. Strassburger:

This responds to your request of August 26, 2004 that we extend the date at which the National Highway Traffic Safety Administration will begin enforcing a May 6, 2003 interpretation letter, addressed to Jaguar Cars, on the meaning of "daylight opening" in Federal Motor Vehicle Safety Standard (FMVSS) No. 104, Windshield wiping and washing systems. As explained below, we have decided to grant your request.

In our letter to you of March 31, 2004, in which we denied your request for reconsideration of the May 6, 2003, interpretation, we acknowledged that there has been some confusion in industry regarding the proper interpretation of the term "daylight opening". We stated that we would begin enforcing FMVSS No. 104 consistent with our May 6, 2003 interpretation letter beginning with motor vehicles manufactured on September 1, 2005.

In your letter of August 26, 2004, you stated that "substantial work" will be needed on some vehicle models to meet the May 6, 2003 interpretation letter. You stated that some wiper systems may have to be redesigned to increase the wiped area and that windshield redesign may be required. You indicated "substantial costs can be avoided" if, for those models that need reworking, the wiper system and windshield redesigns can be accomplished at the same time as scheduled platform changes. You asked that the agency provide manufacturers until September 1, 2007, to permit an orderly transition to designs that comply with the interpretation.

Two vehicle manufacturers subsequently submitted additional information in support of your organizations request. They focused on the work that will be needed for some vehicle models to meet FMVSS No. 104s requirement that windshield wiping systems wipe at least 94% of "Area B".

One manufacturer indicated that, taking account of the agencys May 6, 2003 interpretation letter, seven of its vehicles will not meet the 94% requirement. The other manufacturer indicated that five of its vehicles will be below 94% (but at or above 93.2%) for the wiped Area B. That manufacturer stated that it is not easy to increase the 93.2% area because the wiped areas have already been optimized to maximize the wiped surfaces. Even the small increases required to bring the wiped Area B to meet 94% cannot be done with simple changes in the wiper system. The manufacturer stated that some vehicles will require a complete redesign of the wiper geometry, including changes to the sheet metal stampings. Such changes are normally only done when a complete redesign of a model is scheduled because changes to the stamping tools are always expensive.

After carefully considering your request and the additional information provided by the two manufacturers, and to minimize the costs of compliance, we agree to provide the requested additional time. While we believe the original date of September 1, 2005 was sufficient to enable manufacturers to make simple changes in wiper systems, we are persuaded that more significant design changes will be needed for a number of vehicles. Therefore, we will begin enforcing FMVSS No. 104 consistent with our May 6, 2003 interpretation letter beginning with motor vehicles manufactured on September 1, 2007.

If you have any further questions, please contact Ms. Dorothy Nakama at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:104
d.1/7/05

ID: 05-002791drn

Cesar H. Cozzi Gainza, Esq.
Ministerio de Relaciones Exteriores
Comercio Internatcional y Culto
Direccion General de Asuntos Jurisdicos
Esmeralda 1212. 4 piso (1007)
Buenos Aires, Argentina

RE: "Miranda Guillermo Jorge y otros c/Centro Naval y otros s/daos y perjuicios" (expte. No. 13.445/02)

Dear Seor Gainza:

This responds to your request for our legal opinion concerning any United States "safety standard or legal, ruling or administrative provisions in force to compel the manufacturers and/or importers of automobiles with manual transmission to include a mechanism to block the ignition and thus avoid accidents".It is our understanding that that there is civil lawsuit before your court resulting from a car crash which is described as follows:

In Olivos, Province of Buenos Aires, on January first, two thousand, when the automobile of the Plaintiff, occupied by a minor child and a dog fell into the River Plate.The Plaintiff states that the cause of the casualty was due to the fact that the vehicle has no ignition blocking system, activated when the vehicles are in a gear, because the automobile which was involved in the accident was activated when the minor child started the ignition while the vehicle was in gear.The Defendant states that it is not compulsory to provide vehicles with said systems, and the lack thereof implies no design error.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue the Federal Motor Vehicle Safety Standards (FMVSSs), which apply to new motor vehicles and new items of motor vehicle equipment manufactured for sale, sold, offered for sale, introduced or delivered for introduction in interstate commerce or imported into, the United States of America.(See Title 49 of the United States Code Section 30112.)NHTSA does not provide approvals of motor vehicles or motor vehicle equipment.Instead, manufacturers are required to certify that their vehicles and equipment meet applicable standards.

There is nothing in the FMVSSs that require new motor vehicles with manual transmissions to have an "ignition blocking system, activated when the vehicles are in a gear".The FMVSS most relevant to your case is FMVSS No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect, which specifies requirements for the transmission shift lever sequence, a starter interlock, and for a braking effect of automatic transmissions, to reduce the likelihood of shifting errors, starter engagement with vehicle in drive position, and to provide supplemental braking at speeds below 40 kilometers per hour. FMVSS No. 102 applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. A copy of FMVSS No. 102 is enclosed for your information.

FMVSS No. 102 has only the following requirement for motor vehicles with manual transmissions:

S3.2 Manual transmissions.Identification of the shift lever pattern of manual transmissions, except three forward speed manual transmissions having the standard "H" pattern, shall be displayed in view of the driver at all times when a driver is present in the drivers seating position.

As you can see, S3.2 does not require new motor vehicles with manual transmissions to have an "ignition blocking system, activated when the vehicles are in a gear."

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Enclosure

Sincerely,

Jacqueline Glassman
Chief Counsel
Enclosure

ref:102#VSA
d.6/23/05

ID: 10931

Mr. Jim Burgess
Engineering Manager
Independent Mobility Systems, Inc.
4100 West Piedras St.
Farmington, NM 87401

Dear Mr. Burgess:

This responds to your letter of May 18, 1995 to this office and your telephone conversations with Walter Myers of my staff on June 14 and 27, 1995, concerning an exclusion in Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door retention components. The standard excludes from its requirements doors equipped with wheelchair lifts and either a visual or audible alarm system.

You state that your company converts minivans into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp to the right rear side sliding door area, with an audible and/or visual alarm. The issue you raise is whether FMVSS No. 206's exclusion of wheelchair-equipped doors also excludes a ramp-equipped door. The answer is no.

FMVSS No. 206 requires that side doors leading directly into a compartment containing one or more seating positions must conform to the standard. However, paragraph S4 of the standard states:

[S]ide doors equipped with wheelchair lifts and which are linked to an alarm system consisting of either a flashing visual signal located in the driver's compartment or an alarm audible to the driver which is activated when the door is open, need not conform to this standard.

FMVSS No. 206 was amended to add the wheelchair lift exception by final rule dated March 27, 1985 (50 FR 12029, copy enclosed). The agency's rationale was that when not in use, wheelchair lifts are stowed in a vertical position parallel to and in close proximity to the interior surface of the vehicle door, thus providing a barrier to occupant ejection if the door opened while the vehicle was in motion or in the event of a crash. The alarm requirement was intended to alert the driver to a door that was open on a vehicle that was in motion.

While the information you provided us showed that your wheelchair ramp is also stowed in a vertical position parallel to and in close proximity to the door and that you install audible and/or visual alarms for the driver, wheelchair lifts and wheelchair ramps are distinctly different components. Although they serve the same purpose and are similarly configured when in the stowed position, this agency cannot by interpretation say that "lift" includes "ramp." In order to amend the standard to exclude wheelchair ramps as well as lifts, rulemaking action would be required. You may petition this agency to do rulemaking, under 49 CFR Part 552 (copy enclosed). This agency will entertain your petition and decide whether a rulemaking proceeding is appropriate.

I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosures (2) 1985 final rule Part 552

ref:206 d:8/4/95

ID: 07-002929drn-2

ID: 1984-2.40

TYPE: INTERPRETATION-NHTSA

DATE: 07/31/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Automobile Importers of America,Inc

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Bruce Henderson Automobile Importers of America, Inc. 1735 Jefferson Davis Highway, Suite 1002 Arlington, Virginia 1002 Dear Mr. Henderson:

This is in reply to your letter to Mr. Vinson of this office, in which you asked for an interpretation of Motor Vehicle Safety Standard No. 108. Specifically, you would like to know whether a supplementary turn signal unit may be added to each front fender near the wheel well of a vehicle already equipped with a turn signal system meeting Standard No. 108. You also asked whether there were any restrictions on the mounting height of such a lamp.

Standard No. 108 allows lighting equipment additional to that required by the standard provided that it does not impair the effectiveness of the lighting equipment that the standard requires (paragraph S4.1.3). The supplementary turn signal unit that you describe would appear to enhance the effectiveness of the required turn signals rather than detract from them. There is no requirement that equipment, added at the option of the manufacturer, meet the specific requirements of the standard applicable to identical or similar items of equipment; i.e., the supplementary unit is not legally required to have the same flash rate as the primary turn signals, nor is it subject to the same mounting height restrictions. Obviously, if these specifications are met, supplementary equipment is less likely to impair the effectiveness of the required equipment within the meaning of S4.1.3.

As you are no doubt aware, some manufacturers are wiring their front side marker lamps to flash with the turn signals. This type of supplementary system is acceptable to us.

I hope that this answers your questions.

Sincerely,

Frank Berndt Chief Counsel

July 17, 1984

Mr. Taylor Vincent Office of Chief Counsel - NOA-30 National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, DC 20590

Dear Mr. Vincent:

We would like to request all interpretation of the application of Federal Motor Vehicle Safety Standards (in particular, FMVSS 108) in the following case:

A passenger car complies fully with the requirements for turn signals in FMVSS 108. Is it permissable to add a "turn signal repeater lamp" to each front fender near the wheel well? This repeater lamp would indicate to a vehicle in an adjacent lane an intention to change lanes. The vehicle would continue to to meet requirements in FMVSS 108 for rate of flash, bulb burnout indications, etc.

If the use of such turn signal repeaters in addition to the "four-corner" signal lamps is permissible, is there any restriction on the mounting height - maximum or minimum?

Thank you for your attention and assistance in this matter.

Sincerely, Bruce Henderson BH:bd

ID: nht87-1.69

TYPE: INTERPRETATION-NHTSA

DATE: 04/22/87

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakemeguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of March 13, 1987, with respect to the mounting height of driving lamps and front fog lamps. Noting that these lamps are not equipment required by Federal Motor Vehicle Safety Standard No. 108, you have asked whether they need to be mounted within the range of height which the standard prescribes for headlamps, or may they be mounted, for example, at a height lower than 22 inches such as in the front bumper.

Any lamp that is not required by Standard No. 108 may be added to a motor vehicle and located wherever it appears suitable, provided that the lamp at its location does not impair the effectiveness of lighting equipment required by the standard. Headlamps , parking lamps, and turn signal lamps are the lighting equipment required by Standard No. 108 on the front of a passenger car, and any other four-wheeled vehicle of less than 80 inches overall width. Although Standard No. 108 imposes a minimum mounting height of 22 inches on headlamps, it allows parking lamps and turn signal lamps to be mounted as low as 15 inches above the road surface, which means that they could be mounted in the front bumper, or otherwise close to the mounting location of fog lamps and driving lamps. Therefore, compliance with paragraph S4.1.3 of Standard No. 108 would require a manufacturer of a vehicle equipped with fog and driving lamps to ensure that they do not impair the effectiveness of the headlamps, turn signal lamps, and parking lamps.

Because fog lamps and driving lamps are not covered by Standard No. 108, the individual States may have their own restrictions on the mounting height of these lamps. We regret that we are unable to advise you on these laws. However, the American Associat ion of Motor Vehicle Administrator (AAMVA), 1201 Connecticut Ave., N.W., Washington, D.C., may be able to advise you.

Sincerely,

Erika Z. Jones Chief Counsel

Ms. Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones,

Re : Mounting height of auxiliary driving lamps and front fog lamps

We have a question on mounting height of driving lamps and front fog lamps.

Do they need to be mounted within the range of height which is required for headlamps in FMVSS No. 108?

Although they help the function of headlamps, they are not required lighting equipments in FMVSS No. 108.

So we understand that they can be mounted in the lower position than 22 inches, the lower required height of headlamps; for example, into the front bumper, the height of which is less than 22 inches.

We would like to have your confirmation on this matter. We are looking forward to your reply.

Yours sincerely,

Stanley Electric Co, Ltd.

T. Chikada Manager, Automotive Lighting Engineering Control Dept.

ID: nht90-4.38

TYPE: Interpretation-NHTSA

DATE: October 9, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: William D. Rogers -- President, SportsCar America, Inc.

TITLE: None

ATTACHMT: Attached to report entitled NHTSA Office of Vehicle Safety Compliance Reports Accepted During September 90 for Test Program 90

TEXT:

We have received the (unsigned) petition of SportsCar America, Inc., for a temporary exemption from Motor Vehicle Safety Standard No. 208, on grounds of substantial economic hardship, and are returning all copies to you for the reasons stated below.

SportsCar America wishes to undertake the importation and sale of passenger cars produced in Brazil. Pursuant to an "Exclusive Distribution Agreement" ("the Agreement") with Alfa Metais Veiculos Ltda. of Brazil, which you enclosed, it has imported a pro totype vehicle for study, with reference to its status of conformance with the U.S. vehicle safety and emission standards.

The proper petitioner for this exemption is Alfa Metais Veiculos Ltda., identified in the Agreement that you attached as the "Manufacturer." Under Section 1 of the Agreement, SportsCar America is to return the prototype to the Manufacturer with "those mo difications necessary in order to meet the emission and safety standards necessary for the importation" of the cars, and the Manufacturer will then use it as a model for the production of vehicles for sale in the United States. Under 49 CPR Part 567, th e Manufacturer must also attach its certification of compliance to the completed vehicle before its shipment to the United States. Part 555 restricts petitions for temporary exemptions to Manufacturers of motor vehicles.

Although you identify SportsCar America as the "distribution agent", we have no record that the Manufacturer has filed the designation of agent pursuant to 49 CPR 551.45 that is required of Manufacturers offering their products for importation and sale i n the United States. Presumably Alfa Metais would wish to appoint SportsCar America as its agent. Once it has done so, SportsCar America may submit the petition on behalf of the Manufacturer. The production and financial data (in dollars, please) must be those of the Manufacturer. However, we regard as relevant to conformance arguments the efforts that SportsCar America intends to make during the time a possible exemption is in effect, as outlined in your petition.

Noting your requests for confidential treatment of information, we are returning all copies of your petition, with our comments. Generally, the agency does not like to accord confidential treatment to all financial data submitted. At a minimum, it woul d like to include in its notice asking comments from the public a dollar amount of the cumulative net profit or loss experienced by the Manufacturer in the three years preceding the filing of the petition. Similarly, it would like to publish a dollar fi gure in discussing the effects of a denial of the petition on

the petitioner. The purpose of this is our policy that if the public is to make an informed comment on the issue of whether compliance would cause a Manufacturer substantial economic hardship, the public should have access to much the same data as is av ailable to the agency in its determination.

If you would like clarification of any of these matters, Taylor Vinson of this Office (202-366-5263) will be happy to provide them.

ID: nht89-2.23

TYPE: INTERPRETATION-NHTSA

DATE: 06/29/89

FROM: SAMUEL K. SKINNER -- DOT

TO: ERNEST F. HOLLINGS -- CHAIRMAN, COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION UNITED STATES SENATE

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/24/89 EST; FROM JEFFREY R. MILLER -- NHTSA TO MICHAEL E. KASINER -- NATIONAL TRUCK EQUIPMENT ASSOCIATION; REDBOOK A34, STANDARD 204; LETTER DATED 08/01/89 FROM MICHAEL E. KASTNER -- NATIONAL TRUCK EQUIPMENT ASSOCIATI ON; TO SAMUEL K. SKINNER -- DOT, OCC 3809; LETTER DATED 08/26/87 FROM ERIKA Z. JONES -- NHTSA TO TAK FUJITANI

TEXT: Dear Mr. Chairman:

Thank you for your letter, co-signed by other members of the Senate Commerce Committee, concerning the issuance of certain safety standards for light trucks and vans ("LTV's"), including sport utility vehicles. I share your interest in ensuring that occ upants of these vehicles are well protected. As I stated in my confirmation hearing, I place a high priority on the safety of all our transportation systems including motor vehicles used for personal travel. I wish to assure you that the Department is moving expeditiously to improve vehicle safety, including rulemaking for additional LTV safety standards.

The Department has carefully reviewed those passenger-car safety standards which do not currently apply to LTV's, as evidenced by our reports to Congress in May 1987 and April 1988. As noted in those reports, we are committed to prompt rulemaking action s and decisions. Specifically, the Department's National Highway Traffic Safety Administration (NHTSA) has already issued Notices of Proposed Rulemaking (NPRM) to require both head restraints and rear-seat lap/should belts in LTV's, and an Advance Notice of Proposed Rulemaking to require side-impact protection in LTV's. In addition, NHTSA is currently preparing an NPRM to establish a minimum roof-crush resisance standard for LTV's.

In each of these four areas -- head restraints, side-impact protection, roof-crush resistance, and rear-seat lap/shoulder belts -- I expect to begin discussions within the Administration during the next 90 days on our recommendations for the next rulemak ing actions to be taken. These discussions will also address an NPRM to require automatic occupant protection for LTV's. I will advise you of the conclusion of these discussions.

NHTSA is also analyzing the research on how to enhance brake light performance on these vehicles, and expects to make a decision on requiring additional stop lamps by the end of the summer. Lastly, NHTSA has already granted a petition for rulemaking to d evelop a rollover protection standard and has a comprehensive data collection and research program under way to provide the basis for an effective regulation. Most of that research should be completed by year's end, and I assure you that we will not tol erate delays in the research schedule.

We note that the Department has initiated these and other vehicle safety rulemaking proceedings under the National Traffic and Motor Vehicle Safety Act, which provides a solid, effective, legal framework for these activities. Therefore, we do not believe that specific legislative mandates and timetables for LTV rulemaking projects are necessary or appropriate.

In closing, I appreciate your concern for improving the safety of vehicles and highway travel. Please be assured that this Department will continue to take whatever actions are needed to assure further progress in highway safety.

Sincerely,

ID: nht88-3.42

TYPE: INTERPRETATION-NHTSA

DATE: 09/12/88

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: GEORGE ZIOLO -- DOT PAPERWORK PROCESSOR

TITLE: NONE

ATTACHMT: LETTER DATED 04/20/88 TO ERIKA Z. JONES FROM GEORGE ZIOLO RE HEADLAMP COMBINATIONS-REQUEST FOR CLARIFICATION, FMVSS 108; OCC - 1932;

TEXT: Dear Mr. Ziolo:

This is in reply to your letter of April 20, 1988, asking about the acceptability under Safety Standard No. 108 of modifying imported vehicles so that they are equipped with two Type 2D1 and two Type 1C1 headlamps. You have been informed by the agency's Office of Vehicle Safety Compliance that this is impermissible "because they are 'nonconforming' 'headlight systems'." You disagree because you believe that the minimum requirements of the Standard are satisfied by the Type 2D1 lamps, and that "S4.4 app ears to permit such a combination."

Paragraph S4.4 is not applicable to the situation you present as it refers to combinations of lamps serving different functions; in your discussion, the lamps serve the identical function of headlighting. Given the fact that the Type 2D1 sealed beam 7" diameter headlamps fulfill the headlighting requirements of the Standard, your question must be viewed as whether a supplement to the headlighting system is permissible under Standard No. 108.

Paragraph S4.1.3 of Standard No. 108 permits the addition of nonrequired lighting equipment provided it does not impair the effectiveness of the equipment that the standard requires. The two Type 1C1 5 3/4" diameter sealed beam lamps in a four lamp head lighting system form the major portion of an upper beam headlighting system. The two Type 2D1 lamps in a two lamp headlighting system form the whole of an upper beam headlighting system. Thus, a vehicle furnished with the systems you posit would be equ ipped with more than one upper beam headlighting system. The Type 2D1 system must be designed to conform to the photometric requirements of SAE Standard J579c DEC79 "Sealed Beam Headlamp Units for Motor Vehicles." The SAE Standard establishes at two tes t points, H-V and 4 D-V, maximum allowable candela of 75,000 and 5,000 respectively for each Type 2D1 headlamp. This means that the maximum allowable candela for headlighting systems at these test points is 150,000 and 10,000 candela. The Type 1C1 head lamps will also be designed to conform to SAE J579c. Corresponding maxima at test points H-V and 4 D-V for Type 1C1 systems are 60,000 and 5,000. Thus, a vehicle equipped

with the lamps you have described could emit a total of 270,000 candela at test point H-V (when only 150,000 is permitted), and 20,000 at 4D-V (when only 10,000 is allowable).

Agency research has shown that candela readings in excess of 150,000 greatly increase the potential for glare with little increase in seeing ability. This glare would be visible both to the driver of an oncoming car, and the driver of the modified vehic le itself through creation of a "veiling" glare. The addition of the Type 1C1 headlamps would therefore impair the effectiveness of the Type 2D1 headlighting system, and is forbidden by S4.1.3.

We appreciate your interest in safety.

Sincerely,