Interpretation ID: aiam4408
Manager
Automotive Lighting
Engineering Control Dept.
Stanley Electric Co.
Ltd.
2-9-13
Nakameguro
Meguro-ku
Tokyo 153
Japan;
Dear Mr. Chikada: This is in reply to your letter of September 18, 1987, with respect t a new headlamp design of very low profile. The height of the headlamp is less than that required by dimension A of Figure 4, of Standard No. 108, and you have asked NHTSA: 'to make the height of the headlamp lower than dimension A...on condition that the additional adaptor will be provided as original equipment'.; You are under the impression that our interpretation to you dated Marc 26, 1987, relating to acceptability of a headlamp lens with a 60 degree angle was an affirmative one conditioned upon the provision of an adaptor as original equipment. In fact, we only advised you that such an adaptor should be provided, not that it was required. With respect to your present letter, dimension A is established by Standard No. 108 and cannot be modified except through rulemaking, whether or not an adaptor is provided.; If you wish to submit a petition for rulemaking to amend dimension A o Figure 4 we shall be pleased to consider it. The agency also intends to publish in the near future a Notice asking comments on various aspects of vehicle headlamp aim and aiming methods which you may wish to consider in relation to your new headlamp design.; Sincerely, Erika Z. Jones, Chief Counsel