ID: nht87-2.15

TYPE: INTERPRETATION-NHTSA

DATE: 06/18/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Joe Rutman -- Travelite Division

TITLE: FMVSS INTERPRETATION

ATTACHMT: 5/12/86 letter from Erika Z. Jones to Mary Fulton (Std. 108); 1/12/87 letter from Erika Z. Jones to Fred E. Maynard

TEXT:

Mr. Joe Rutman Travelite Division Pathway, Ltd. BOX 195 Grand Rapids, MI 49508

This is in reply to your letter of February 11, 1987, providing information about the electronic message display known as "Tellite" which has been developed by Pathway Limited.

I enclose copies of two recent agency interpretations on electronic message displays similar to yours. You will see that under Federal law such displays may not be used as original equipment, or as replacement equipment on passenger cars that carried cen ter highmounted stop lamps as original equipment. Whether they are acceptable as aftermarket equipment on other vehicles depends on the laws of the individual States there the display will be sold and operated.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

(See 5/12/86 and 1/12/87 NHTSA letters to Mary Fulton and Fred E. Maynard

Re: Pathway Limited

Dear Ms. Jones:

This is in response to your letter of January 7, 1987, regarding the electronic message display known as "Tellite" which has been developed by Pathway Limited.

Enclosed with this letter, you will find the following:

1. A letter from the Company's engineers, explaining certain material features of the display, and

2. Drawings of the display and the handheld keyboard which is used to activate the display.

It should be pointed out that the display can be read from directly behind the vehicle, but cannot be read from the side. You should also be aware that the handheld keyboard only activates the display, and does not program messages.

I am also enclosing the 16 messages with which it is currently intended that every chip will be programmed.

If you require anything further, please advise.

Sincerely,

PATHWAY LTD. Joe Rutman

February 9, 1987

Mr. Joe Rutman President Travelite Division of Pathway, Ltd. P.O. Box 88111 Grand Rapids, MI 49508

Subject: U.S. DEPARTMENT OF TRANSPORTATION LETTER OF INQUIRY

In regards to the questions raised in the aforementioned letter:

1. light emitted by the brake-light portion of the display will pass through the message portion, as the light sources for both portions originate from the same printed circuit board. Red L.E.D.'s are used for the brake-light and yellow L.E.D.'s are used for the message display.

2. The brake-light circuit overrides the message display by disabling and blanking out any message displayed at the time the brake-light is turned on.

I hope the above answers are satisfactory. If you have any other questions, feel free to call.

FRANK HOCKEBORN, PROPRIETOR

SEE DIAGRAMS...

TELLITE MESSAGES

1. CAUTION. CHANGING LANES LEFT.

2. CAUTION. CHANGING LANES RIGHT.

3. PLEASE DIM YOUR LIGHTS...THANK YOU.

4. PLEASE DON'T FOLLOW SO CLOSE...THANK YOU.

5. I AM OUT OF GASOLINE...PLEASE SEND HELP.

6. DEAD BATTERY...I NEED A JUMPER.

7. I HAVE A FLAT TIRE...PLEASE SEND HELP.

8. MY CAR WILL NOT START...NEED HELP.

9. SORRY.

10. PLEASE SEND A WRECKER...THANK YOU.

11. MY CAR IS STUCK...PLEASE SEND HELP.

12. GO AROUND...I AM WAITING FOR A PARKING PLACE...THANK YOU.

13. THANK YOU.

14. CAUTION...SLOWING TRAFFIC...ROAD REPAIRS? ACCIDENT?

15. ILLNESS...HELP...HELP...HELP.

16. PLEASE CALL POLICE...SEND AN AMBULANCE.

ID: nht87-2.16

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 18, 1987

FROM: MARY F. BARRAS -- SALES ASSISTANT, CONTRACT ADMINISTRATION, M.A.N. TRUCK & BUS

TO: MICHAEL W. VORIS -- BUS PROCUREMENT SUPERVISOR, METRO

TITLE: CONTRACT NO. T/F 19-84 REAR EMERGENCY WINDOW

ATTACHMT: MEMO DATED 2-23-88, TO JAY COSTA, FROM ERIKA Z. JONES, STD 271, REDBOOK A31; MEMO DATED 7-1-87, TO ERIKA Z. JONES, FROM JAY COSTA; MEMO DATED 6-25-87, CONTRACT NO. T/F 19-83 REAR EMERGENCY WINDOW

TEXT: In response to your letter of June 16, 1987 I am providing the following information in regard to converting the rear emergency window to a non-openable type window.

According to FMVSS 217, a total of 4,355 square inches is required for this bus. Please see the attached FMVSS information provided in regard to the computations used to arrive at this figure. Our bus has 19 windows, including the rear window, which totals 536 square inches per window. The bus also has 3 roof hatches which total 506.25 square inches per hatch. Therefore, the computations are listed below: 536 sq. ins. x 19 windows, including rear = 10,184 sq. ins. 506.25 sq. ins. x 3 roof hatches = 1,519 sq. ins. *11,703 sq. ins. * This total can be considered the accountable square inches on the bus in regard to safety requirements set forth by FMVSS 217. Also, 1,742 square inches (40%) of one side of the bus is unobstructed thereby, complying with this standard.

Therefore, the rear emergency window may be changed and the bus will remain within the FMVSS 217 boundries.

May we suggest that Metro directly contact the window manufacturer in regard to any modification to be made to this window so that warranty provisions do not become void. Please feel free to contact Mr. Mike Hurtekant at Excel Industries at (219) 264 -2131 in Elkhart, Indiana. ATTACHMENTS

ID: nht87-2.17

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

AIR MAIL

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

Dear Mr. Chikada:

This is in reply to your letter of March 4, 1987, with reference to aiming adjustment of fog lamps. We understand that Stanley is developing a fog lamp and replaceable bulb headlamp with a common lens and housing. Since the portion of the housing also fu nctions as a reflector, the fog lamp moves simultaneously with the headlamp in aiming adjustment. In your view, it will not impair the effectiveness of the headlamp, and you ask for confirmation that the lamp "is acceptable in the U.S.A."

Federal Motor Vehicle Safety Standard No. 108 contains no requirements for a fog lamp, and would prohibit it only if it impaired the effectiveness of any other lamp mounted on the front of a vehicle that is required by the standard. Assuming that the fog lamp does not impair the effectiveness of the headlamp, its installation would not create a noncompliance with Standard No. 108. However, in the absence of a Federal standard on fog lamps, the individual States may establish their own requirements for f og lamps. We are unable to advise you whether this design would be acceptable in each of the 50 States, and other jurisdictions in which the Federal standards must be met; we can only advise you that it does not appear prohibited by Federal law.

The American Association of Motor Vehicle Administrators (AAMVA), 1201 Connecticut Avenue, N.W., Washington; D.C., 20036 may be able to advise you as to state laws relevant to your design.

Sincerely,

Erika Z. Jones Chief Counsel

March 4, 1987

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 : Aiming adjustment of Front fog lamps

We are now developing a new fog lamp, which has a common lens and housing with a replaceable bulb headlamp. (See attached drawing.)

Since the portion of housing also functions as a reflector, this new fog lamp moves simultaneously with headlamp in aiming adjustment.

This fog lamp is designed to satisfy the requirements of SAE Standard J583. So it will not impair the effectiveness of the headlamp, or rather, it will promote the function of headlamp. We Think this new fog lamp is acceptable in the U.S.A.

Please give your advice whether our understanding is right or not.

Sincerely yours,

Stanley Electric Co., Ltd.

T. Chikada Manager, Automotive Lighting Engineering Control Dept.

SEE ATTACHMENT

ID: nht87-2.18

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Jim Ross

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Jim Moss President, Auto Mark Corp. 3901 Atkinson Drive Suite 220 Louisville, Kentucky 40218

Dear Mr. Moss:

This responds to your letter to Ms. Barbara Kurtz of our Office of Market Incentives. In your letter, you posed several questions about a stencil your company would like to offer to direct importers for marking their vehicle parts in compliance with 49 C FR Part 541, Federal Motor Vehicle Theft Prevention Standard. Before responding to your specific questions, I would like to briefly explain the parts marking requirements of Pact 541 as they apply to direct importers.

Direct importers are required to inscribe an identifying number on the specified parts for each passenger car subject to Part 541 that they import: @541.5(a). The identifying number inscribed on the parts must be the original vehicle identification numbe r assigned to the car by its original manufacturer in the country where the car was assembled or produced: @54l.5(b) (3). The identifying number inscribed on the parts must satisfy the size and style requirements specified for vehicle certification label s: @54l.5(c). Finally, the identifying number inscribed on the parts must comply with the three requirements of @54l.5(d) (2). These requirements are:

1. Removal or alteration of any portion of the number must visibly alter the appearance of the section of the vehicle part on which the identification is marked:

2. The number must be placed on each part in a location that is visible without further disassembly once the part has been removed from the vehicle: and

3. The number must be placed entirely within the target area specified by the original manufacturer for that part.

There are no other requirements for marking direct importers' vehicles. Once the direct importer determines that its vehicle complies with these requirements, it certifies that compliance by affixing a label to the vehicle, as specified in 49 CFR S567.4( k). This certification label must be affixed to the vehicle before it is imported into the United States.

To respond to your specific questions, you stated that you advise direct importers to leave your stencil on each part after etching it. You then posed three questions:

1. Must the initials DOT appear on the stencil?

ANSWER: No. Part 541 does not require that the DOT symbol appear as a part of or in conjunction with inscribed markings on parts.

2. May we leave our name (logo) printed on the stencil? ANSWER: Yes. Using the same principles we have applied in the case of labeling requirements in our safety standards, manufacturers may label information in addition to that which is required by the theft prevention standard, provided that the additional information does not obscure or confuse the meaning of the required information or otherwise defeat its purpose. The purpose of requiring the vehicle identification number to be inscribed on specifi ed parts is to allow law enforcement officials to quickly and conclusively establish whether a vehicle or major part is stolen. We do not believe it is possible that law enforcement officials will be distracted from examining the markings inscribed on th e parts by the presence of a stencil with your company name on it. Therefore, you are free to leave your company name on the stencil.

3. Do you have any suggestions or objections to offer?

ANSWER: Our only concern is that direct imports comply with the requirements of Part 541. Assuming that your stencil is a means for direct importers to comply with those requirements, we have no additional advice to offer.

If you have any further questions or need more information on this subject, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Erika Z. Jones Chief Counsel

ID: nht87-2.19

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Ted Stevens

TITLE: FMVSS INTERPRETATION

TEXT: The Honorable Ted Stevens United States Senate Washington, DC 20510

Dear Senator Stevens:

Thank you for your April 23. 1987 letter on behalf of your constituent, Ms. Nadra L. Angerman of Wrangell, who is concerned that there is no Federal requirement for safety belts on school buses. Your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.

I appreciate this opportunity to respond to Ms. Angerman 's concerns. As explained below, NHTSA does not require large school buses to have safety belts for passengers because we require those buses to provide an alternate form of passenger crash protect ion. Our safety standards are directed at improving the interior of large school buses so that passengers will be provided adequate crash protection even if safety belts are not used.

I Would like to begin with some background information on our school bus regulations. NHTSA is responsible for developing safety standards applicable to all new motor vehicles, including school buses. In 1977, we issued a set of motor vehicle safety stan dards for various aspects of school bus safety. Included in that set is Federal Motor Vehicle Safety Standard No. 222, School Bus passenger Seating and Crash Protection. Standard No. 222 requires large school buses--i.e., those with gross vehicle weight ratings over 10,000 pounds--to provide passenger crash protection through a concept called "compartmentalization." Compartmentalization refers to designing the interior of large buses so that children are protected regardless of whether they have fasten ed a safety belt. The key features include higher hnd stronger seat backs, additional seat padding, and better seat spacing and performance.

Our safety standards require a safety belt for the school bus driver since the driver's position is not compartmentalized. We also require safety belts for passengers in smaller school buses because those buses experience greater crash forces than do lar ger buses.

However, because large school buses already offer substantial protection to passengers, we believe a Federal requirement for safety belts in those vehicles is unnecessary. Large school buses are very safe vehicles not only because they meet Federal schoo l bus safety standards, but also because of their size and weight, the training and experience of their drivers and the extra care that other road users employ in the vicinity of school buses. NHTSA does not prevent States and local jurisdictions that wi sh to order safety belts on their own large school buses from doing so. Such a decision is a matter for the officials of the particular State or local jurisdiction, who are best able to assess their own preferences regarding pupil transportation.

A June 1985 NHTSA publication entitled, Safety Belts in School Buses, discusses many of the issues relating to safety belts in large school buses. I have enclosed a copy of the report for your information.

I hope you have found this information to be helpful. If you or your constituent have any further questions, please do not hesitate to contact me.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

Edward Babbitt, Director Office of Congressional Relations Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Babbitt:

One of my constituents/ Ms. Nadra L. Angerman of Wrangell( Alaska, has recently informed me of her concern about the need for mandatory seat belt installation laws for school buses nation-wide. I've enclosed a copy of her letter on this subject for your reference.

I would greatly appreciate any information you could provide on recent proposals or assessments relating to possible national requirements to install seatbelts in school buses. Thank you for your assistance in addressing my constituent' s concerns. With best wishes,

TED STEVENS

Enclosure

April 13 1987

The Honorable Ted Stevens United States Senate Washington, D.C. 20515

Dear Senator Stevens:

Automobile safety is becoming one of the most common concerns of Americans. Automobiles traveling at excessive speeds, unsafe road conditions, and the risks of drunk drivers almost makes me want to stay off the highways.

With recent bills pertaining to mandatory use of seat belts I can say that use of seat belts is a very good idea for everybody. Senior citizens, adults, teenagers, and small children should all be protected by such devices.

My main concern is that there are no seat belts school buses. School buses serve as a major source of transportation for children ranging from grades K through 12. In event of an accident there is nothing to keep a child in his/her seat. This fact should be looked at more seriously.

Thank you for your time, please keep my concerns with automobile safety and seat belts on school buses a priority in your busy schedule.

Sincerely,

Nadra L. Angerman

ID: nht87-2.2

TYPE: INTERPRETATION-NHTSA

DATE: 06/08/87

FROM: ROSE TALISMAN -- JOAN FABRICS CORP

TO: DOUG COLE -- NATIONAL VAN CONVERSION ASSOC., INC.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A32, STANDARD 302; LETTER DATED 06/29/87 FROM JONATHAN JACKSON TO DOUG COLE; LETTER DATED 06/22/87 FROM ROSE M. TALISMAN TO DOUG COLE; LETTER DATED 06/23/87 FROM DOUG CO LE TO STEVE KRANTZKE

TEXT: Dear Mr. Cole:

In accordance with our understanding from Mr. Irving Brown of C.M.I. Automotive, we are sending to your attention the specifications from both Ford Motor Company and General Motors in Detroit regarding the specific testing procedures required for meeting their codes for fire retardancy.

As you are well aware, we have run correlation studies on our pattern Passport with your recommended testing agency, Commercial Testing Company of Dalton Georgia. The test results have indicated a specific difference in correlation depending on the test method utilized. The method utilized and recommended to us by both Ford Motor Company and General Motors which requires the use of heat resistance support wires as stated on the attached specification are the direct guidelines we utilized in testing al l fabric designated for motorized product from our mill.

We certainly would be happy to discuss the rational and our specific methods for testing based on Detroit's specific requirements. Do not hesitate to call if you have any questions or need additional information.

Ford Laboratory Test Methods;

FLAMMABILITY TEST FOR AUTOMOTIVE INTERIOR MATERIALS

II. Small Parts (contd.)

A surrogate test plaque specimen made with a composition identical to that of the component material(s) shall be produced in the shape of a rectangle 4 inches (100 mm) wide, 14 inches (356 mm) long and the minimum thickness of the component up to 1/2 inch (12.7 mm) maximum, employing the same or equivalent process as used to produce the component part. The thickness of the plaque is that of the material as utilized in the vehicle except where it exceeds 1/2 inch (12.7 mm). In those applications, th e plaque is to be reduced to a uniform thickness of 1/2 inch (12.7 mm) to include the surface material exposed to the occupant compartment air space.

Test Procedure 1. Prior to testing, each specimen is conditioned for 24 hours at a temperature of 73.4 +/- 3.6 degrees F (23.0 +/- 2.0 degrees C) and 50 +/- 5% relative humidity and the test is conducted under those conditions.

2. Material is placed in the specimen holder as indicated below and tested in the direction (transverse or longitudinal) that produces the most adverse results. The specimen is oriented so that the surface closest to the occupant compartment air spa ce faces downward on the test frame.

(a) The standard test specimen (4 x 14 in (100 x 356 mm) x thickness) is inserted between two matching U-shaped frames (specimen holder) so that both sides of the specimen are held by the frames. The temperature of the frame in Figure 4 at the start of each test shall not exceed the conditioned temperature as stated above in Paragraph 1 of Test Procedure.

(b) Where the maximum available width of the specimen is 2 in (50 mm) or less so that the sides of the specimen cannot be held in the two matching U-shaped frames, it is to be supported by the use of 10 mil (0.25 mm) wires spanning the top surface of the bottom U-shaped frame at 1 in (25 mm) intervals, keeping such specimens from bending away from the horizontal at the flaming end, thereby allowing a more uniform and constant burn rate (see Figure 5). The bottom U-shaped frame shall always be positi oned so that the wires are "sandwiched" between the top and bottom frames.

(c) Samples tested with support wires: Flexible specimens, such as genuine leather, supported and unsupported vinyls, textile and backing fabrics, foams, textile padding[Illegible Word] compounds, etc., that frequently soften and bend at the flaming e nd so as to cause a non-uniform, uneven burn rate.

Samples tested without wires: Less flexible materials such as paperboard, carpets, rigid plastics, etc., seldom soften and bend at the flaming end; therefore, do not justify or necessitate support wires.

(d) Adjust ventilation hood door opening to approximately 23 in (580 mm) and regulate ventilation up to 110 CFM (0.052 m<3>/s) maximum air flow to prevent smoke and fumes from entering room.

ID: nht87-2.20

TYPE: INTERPRETATION-NHTSA

DATE: 06/22/87

FROM: ROSE M. TALISMAN -- JOAN AUTOMOTIVE INDUSTRIES TESTING LAB

TO: DOUG COLE -- NATIONAL VAN CONVERSION ASSOCIATION, INC.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A 32, STANDARD 302; LETTER DATED 06/08/87 FROM ROSE TALISMAN TO DOUG COLE; LETTER DATED 06/23/87 FROM DOUG COLE TO STEVE KRANTZKE; LETTER DATED 06/29/87 FROM JONATHAN JA CKSON TO DOUG COLE

TEXT: Dear Doug:

As I stated earlier correspondence Joan Automotive Industries conducts its flammability testing according to Federal Motor Vehicle Safety Standard No. 302. This includes the use of heat resistant support wires as indicated in paragraph S5.1.3, "A specime n that softens and bends at the flaming end so as to cause erratic burning is kept horizontal by supports consisting of thin, heat resistant wires, spanning the width of the U-shaped frame under the specimen at 1-inch intervals."

It is our belief that this method satisfies the requirements of FMVSS 302 testing and is the standard industry procedure for testing automotive bodycloth.

Please keep us informed as to what the Department of Transportation's response is to your inquiry.

ID: nht87-2.21

TYPE: INTERPRETATION-NHTSA

DATE: 06/23/87

FROM: DOUG COLE -- NATIONAL VAN CONVERSION ASSOCIATION INC

TO: STEVE KRANTZKE -- NHTSA/

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A32, STANDARD 302; LETTER DATED 06/29/87 FROM JONATHAN JACKSON TO DOUG COLE; LETTER DATED 06/22/87 FROM ROSE M TALISMAN TO DOUG COLE; LETTER DATED 06/08/87 FROM ROSE TAL ISMAN TO DOUG COLE

TEXT: Hi Steve!

It was a pleasure talking with you and thanks again for a speedy returned call. George Shiflett recommended I contact your office about an issue that has arisen from a Certification program that National Van Conversion Association (NVCA) sponsors. The i ssue surrounds the question of "compliance with FMVSS #302".

A part of NVCA's Certification includes the physical gathering of random samples of fabrics, foams, carpets, and other flammable items that van conversion firms use in vehicles. These samples are then channeled to an accredited testing firm for destruct ive testing to verify compliance with FMVSS #302. NVCA has found many samples, according to the tests performed, not to be in compliance with FMVSS #302. The manufacturers of these samples vehemently oppose NVCA's findings and insist that their samples are indeed in compliance with FMVSS #302.

In an effort to double check NVCA's test procedures, I contacted four major testing laboratories recommended by the American Association of Motor Vehicles Administrators. Half of those contacted suggested that NVCA's test methods were correct and the ot her half disagreed. Each half was quite certain they were right. The issue appears to be about when to use (or not to use) support wires in conjunction with the FMVSS #302 test. NVCA doesn't use any support wires in its test; some fabric manufacturers use support wires in their tests. In many (not all) instances, these support wires are an influence on whether a material passes or fails the FMVSS #302 test. Will you please clarify for us whether to use or not to use the support wires?

I have enclosed copies of test procedures from NVCA's testing lab, a fabric manufacturer, Ford, and Fisher Body Division of GM for your review. Also enclosed is a copy of a letter NVCA will include with its communications with conversion firms (in the c ase of a FMVSS #302 failure, per NVCA's current test methods). If you see anything that we need to alter immediately, please contact me; if not, I realize your interpretations, comments, opinions, rulings, or whatever may take some time to formulate and NVCA will proceed as normal until we hear from you. Your assistance in this matter will be greatly appreciated by many involved. If I can provide any additional data or be of service in any way, please call on me.

ENCLOSURE

ID: nht87-2.22

TYPE: INTERPRETATION-NHTSA

DATE: 06/24/87

FROM: DIETMAR K. HAENCHEN -- VOLKSWAGEN OF AMERICA, INC.

TO: ERIKA Z. JONES -- NHTSA

TITLE: REQUEST FOR INTERPRETATION - FMVSS 205

ATTACHMT: ATTACHED TO LETTER DATED 11/03/88 FROM ERIKA Z JONES TO DIETMAR K HAENCHEN; REDBOOK A32 (2), STANDARD 205

TEXT: Dear Ms. Jones:

The design of passenger cars has changed in recent years to reduce aerodynamic drag and increase fuel efficiency. Volkswagen is planning to improve interior comfort and reduce energy consumption in future car models by introducing selected areas with re duced energy transmission via ceramic dots on the car's glazing. The reduced energy radiation into the interior increases driver's and passenger's comfort and results in increased active safety. We believe that the application of shaded areas on the wi ndows complies with the applicable safety standards. Different methods exist for shading those areas; the glass may be tinted like shade bands applied to windshields, or small ceramic dots can be applied on the glass surface having the same effect on th e reduction of energy transmission. The sections of glass selected for the application of the ceramic paint could, if not for styling aesthetics, be covered with sheet metal in order to avoid questions of interpretation of FMVSS 205. However, the styli ng incentive is compelling and driver visibility with the proposed configuration is better than total blockage with sheet metal, which would clearly be allowable. We are, therefore, seeking the agency's opinion of this concept which we are considering fo r the next new model line. While the agency does not give advance approval of specific product designs, the agency's opinion of whether the configuration proposed herein appears to comply with the applicable Federal Motor Vehicle Safety Standards will a id manufacturers in determining whether the numerous variations of the concept applied to various vehicles will comply with the standards.

Volkswagen has reviewed Standard 205 which in turn refers to ANS z26.1 (1980) which establishes requirements for safety glazing material for use in passenger cars. In Section 4.2 of ANS z26.1, specifications for items 1 and 2 glazing which VW intends to apply to the windshield and side/rear glass respectively refer to footnotes 1 and 3 when specifying Test 2 - Light Transmittance. Those footnotes allow areas of the glazing to have less than 70% light transmittance if the areas are not within the "leve ls required for driving visibility".

The term "levels requisite for driving visibility" has been used by the agency in interpretations and on several occasions has been addressed more precisely such as the interpretation to Mr. G. Nield on 15 February, 1974 as follows: "We (the agency) cons ider the word 'levels' in Standard 205 to mean vertical heights in relation to driver's eyes." To our knowledge the agency has not gone beyond the above interpretation in further defining "levels requisite for driving visibility".

In order to comply with FMVSS 205 Volkswagen deems it appropriate to use engineering judgement, applicable standards and technical recommendations to define these "levels" so that driving visibility is properly maintained with the installation of glazing material having areas within a single sheet of less than 70% light transmittance.

Footnote 1 of ANS z26.1 - 1980, although not expressively stated, refers mainly to shade bands and has been so construed and treated by the industry. The automobile industry so far has determined which areas are "requisite for driving visibility" and ha s marked the shaded areas as required. In these cases the industry determined how far shade bands can extend donward from the upper edge of the window and still be in compliance with FMVSS 205.

SAE J100 (passenger car glazing shade bands) also refers to ANS z26.1 when defining "glazing shade band" as "an area of the vehicle glazing through which light transmission is less than required for use at levels requisite for driving visibility by USAS z26.1". The SAE recommends shade bands above the 95th eyellipse only, but acknowledged at that time that substantial research to establish the driver's field of view did not exist. Volkswagen also believes that these data do not exist currently.

Guidelines for a determination of "levels" which extend upward from the bottom edge of the vehicle glazing are addressed in Directive 77/649 as amended in 81/643 of the European Economic Community (EEC). The directive specifies levels requisite for driv ing visibility in the driver's 180 degrees forward direct field of vision. Section 5.1.3 specifies the boundaries for the driver's forward direct field of vision by a horizontal plane through V[1] (upper boundary) and by three planes at downward angles of 4 degrees through V[2] (lower boundary). The latter describes the minimum field of view for small persons through the lower portion of the glazing.

The EEC in its effort to set angular limits for the driver's forward direct field of vision used anthropometric data of horizontal head and eye movement to arrive at the 180 degrees limit. The SAE in its information report J985 arrives at the same figur e when the angles of "maximum head movement (is) 60 degrees left and 60 degrees right" and "the eyes can turn 30 degrees to the right in one rapid, smooth movement", are combined.

For the rear visibility in the U.S., the "levels requisite for driving visibility" are not specified if a passenger side rearview mirror is used according to FMVSS 111. Technically, the complete rear glazing can be blocked by a vehicle manufacturer if a passenger side rearview mirror is installed as standard equipment. Volkswagen intends to install a passenger side outside mirror as standard equipment in conjunction with the subject shading configuration and also to provide an area in the rear glazing with transmissability of greater than 70%.

With this background, Volkswagen is planning to include either tinted bands or ceramic dots on glazing as described in Attachments I and II. Volkswagen believes that this concept clearly allows light transmittance in excess of 70% in the areas requisite for driving visibility and consequently should adequately satisfy the safety needs for overall driving visibility.

Volkswagen has tested these boundaries according to the specifications of 77/649/EEC and concluded that ceramic dots in the area defined in 5.1.3 very well cover the vertical heights in relation to even small driver's eyes, which are "requisite for drivi ng visibility". In addition we have designated the area adjacent to the right and left hand outside mirrors as requisite for driving visibility.

This proposal has been approved by the German government (KBA) as recommended by the Technical Service Hannover. This approval was based on the fact that it complies with the driver's direct field of view (forward 180 degrees) and that unobstructed outs ide rearview mirrors are used on both sides to supplement the inside rearview mirror for the driver's indirect field of view. This approval is based on compliance with the applicable EEC Directive and therefore will likely be acceptable to all Common Ma rket countries.

Volkswagen requests the agency's opinion of this proposal and an interpretation of whether the markings described in Section 6 of ANS z26.1 would be required to show the limits of the area that is intended to comply with the 70% transmittance requirement . If required, Section 6 states that the glazing "shall be permanently marked at the edge of the sheet to show the limits of the area that is intended to comply with Test No. 2" (70% transmissability). Interpretation is requested of where these markings should be placed for the configurations shown in Attachments I and II if they are required. Since this is under consideration for the next model year, a timely response is requested.

ATTACHMENTS

ATTACHMENT I

Lichtdurchlassigkeit zwischen 75% and 82% LIGHT TRANSMITTANCE BETWEEN 75% AND 82%

Lichtdurchlassigkeit von 30% , 70% LIGHT TRANSMITTANCE FROM 30% TO 70%

Lichtdurchlassigkeit 30% LIGHT TRANSMITTANCE 30%

Lichtdurchlassigkeit zwischen 75% und 77% LIGHT TRANSMITTANCE BETWEEN 75% AND 77%

Lichtdurchlassigkeit von 30% > 70% LIGHT TRANSMITTANCE FROM 30% TO 70%

Lichtdurchlassigkeit zwischen 72% und 75% LIGHT TRANSMITTANCE BETWEEN 72% AND 75%

Warmeschutzverglasung HEAT ABSORBING GLASS

E/KK - AA 87.01.

ATTACHMENT II

Lichtdurchlassigkeit zwischen 75% und 82% LIGHT TRANSMITTANCE BETWEEN 75% AND 82%

Lichtdurchlassigkeit von 30% > 70% LIGHT TRANSMITTANCE FROM 30% TO 70%

Lichtdurchlassigkeit 30% LIGHT TRANSMITTANCE 30%

Lichtdurchlassigkeit zwischen 75% und 77% LIGHT TRANSMITTANCE BETWEEN 75% AND 77%

Lichtdurchlassigkeit von 30% > 70% LIGHT TRANSMITTANCE FROM 30% TO 70%

Lichtdurchlassigkeit zwischen 72% und 75% LIGHT TRANSMITTANCE BETWEEN 72% AND 75%

Warmeschutzverglasung HEAT ABSORBING GLASS

E/KK - AA 87.01.

ID: nht87-2.23

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 25, 1987

FROM: MARY F. BARRAS -- SALES ASSISTANT, CONTRACT ADMINISTRATION, M.A.N. TRUCK & BUS

TO: MICHAEL W. VORIS -- BUS PROCUREMENT SUPERVISOR, METRO

TITLE: CONTRACT NO. T/F 19-83 REAR EMERGENCY WINDOW

ATTACHMT: MEMO DATED 2-23-88, TO JAY COSTA, FROM ERIKA Z. JONES, STD 271, REDBOOK A31; MEMO DATED 6-18-87, CONTRACT NO. T/F 19-84 REAR EMERGENCY WINDOW; MEMO DATED 7-21-87, TO ERIKA Z. JONES, FROM JAY COSTA

TEXT: Further to my letter of June 18, 1987 pertaining to the subject matter, this letter is to serve as clarification in regard to our position, the manufacturer, of the subject contract trolley buses.

* The trolley bus, as manufactured and delivered to Metro Seattle, more than exceeds the standards set forth by FMVSS 217.

* Paragraph S5.2.1 of the information previously submitted, states that at least one (1) rear exit shall be provided unless the bus configuration precludes the installation of an accessible rear exit. The trolley bus design of the subject, contract d oes not preclude the installation of an accessible rear exit; therefore, because of this requirement and our interpretation of FMVSS 217, a rear exit is provided.

Considering the above, M. A. N. Truck & Bus Corporation recommends that the rear window, as delivered to Seattle Metro, should remain as designed.