Interpretation ID: nht88-1.91

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 8, 1988

FROM: M. IWASE -- MANAGER, TECHNICAL ADMINISTRATION DEPT., KOITO MFG. CO., LTD. TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: Headlamp Aimability (Docket No. 85-15; Notice 5)

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO M. IWASE FROM STEPHEN P. WOOD; (A35; STD. 108). ALSO ATTACHED TO LETTER DATED 10-18-89 TO ERIKA Z. JONES FROM M. IWASE AND LETTER 9-12-88 TO M. IWASE FROM ERIKA Z. JONES. TEXT:

We would ask you to provide us with your confirmation of interpretation of proposed rulemaking; Headlamp Aimability as cited in Docket No. 85-15; Notice 5 of Federal Register dated Dec. 29, 1987.

We are now in the stage of studying and developing a new technology of on-vehicle aiming (Vehicle Headlamp Aiming Device) in conformity with the said NHTSA proposal so that we can adopt it into our headlamps as soon as possible in case that the proposal is put into effect as a rule.

Upon our careful review to this proposal and also through our talk with Mr. Richard Van Iderstine / Rulemaking Office of NHTSA, our ideas for headlamp aiming configuration as shown in the attached sheet are fully consistent with NHTSA's intention for hea dlamp aimability proposed therein, we believe.

Please refer to the attached sheet in which our specific questions are shown.

We would greatly appreciate it if you would kindly treat Structure-2 of attached as "Confidential" because it involves our own idea for development of on-vehicle aiming which has something related with our patent application intended hereafter.

Upon your kind review to this matter, your prompt reply would be greatly appreciated.

Attachment

Question:

Whether the following structure of on-vehicle aiming could be accepted in case that the proposed requirements of S7.7.5.2 "On-Vehicle aiming" would be regulated in the FMVSS No. 108 as they are.

Structure-2: Built-in Reflector System [GRAPHICS OMITTED]1) Lens and Housing are bonded together.

2) Built-in reflector is mounted with aiming mechanism onto Housing.

3) Aiming is made by adjusting faced direction of built-in reflector.

4) Spirit level is mounted on built-in reflector and can be seen through lens for the vertical aiming.

5) Headlamp assembly can comply with the applicable requirements of FMVSS No. 108.