Interpretation ID: nht88-1.87

TYPE: INTERPRETATION-NHTSA

DATE: 04/06/88

FROM: DENNIS G. MOORE -- PRESIDENT SIERRA PRODUCTS

TO: ERIKA Z. JONES -- CHIEF COUNSEL U.S. DEPARTMENT OF TRANSPORTATION NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/19/88 TO DENNIS G. MOORE, FROM ERIKA Z JONES, REDBOOK A32 (2), STANDARD 108

TEXT: Dear Ms. Jones:

Pursuant to a request, via a telephone conversation with Taylor Vinson of your office and Daryl Thomas of our company relative to the "Canadian Problem", these are the events chronologically:

1) My letter to the NHTSA, dated December 27,1986, asking for a clarification on the law pertaining to the combination of tail light with a clearance light.

The March 4, 1977 reply of acting Chief Counsel Frank Berndt, and his June 18, 1979 reply to the Trailer Manufacturer Association.

2) The 25 letter correspondence between our company and the Transport of Canada, Ottawa.

I have also included a letter I sent to the Canadian Consulate General in Los Angeles dated October 9, 1981, regarding my attempt to try and get our Barrier to Trade Agreement enforced.

Finally, I've included a copy of The Canada Gazette dated August 14, 1987 pertaining to "Optically Combined Lamps" for your reference.

I hope this gives you enough information on this issue to settle it as this puts us in a precarious and "expensive" position as the Canadians are not permitting our lights into Canada because of their new law.

I have several other matters I will be sending you letters about in the next few months, some of which are very old petitions and requests for law interpretations that apparently have been "lost" in the NHTSA System.

Very truly yours,