Interpretation ID: nht95-1.31

TYPE: INTERPRETATION-NHTSA

DATE: January 17, 1995

FROM: Randall B. Clark -- A Concerned Citizen

TO: Office of Vehicle Safety Compliance

TITLE: None

ATTACHMT: ATTACHED TO 2/16/95 LETTER FROM PHILIP R. RECHT TO RANDALL B. CLARK (A43; STD. 108; VSA 30122(6)

TEXT: I respectfully request clarification on the following paragraphs S5.1.1.27(a), Table III & Table IV, located in the "Code of Federal Regulations".

I contend the required Motor Vehicle Lighting Equipment requirements are the minimum requirements ONLY and do not state that this is the maximum stop lamps allowed on the back of any automobile.

In other words, my automobile has the normal two stop lamps and has a spoiler with a stop lamp built into it. The car also has a stop lamp mounted inside the back window which is not currently hooked up due to the fact that "Subaru of America" thinks the procedure is against the law. They have cited the above paragraphs & Tables as their authority.

I would appreciate a specific explanation from the "EXPERTS" stating that an automobile with four stop lamps is perfectly legal in the United States.

Thank you for your dedicated efforts on my behalf to clarify the correct point of view on Motor Vehicle Lighting Equipment.

P. S. I have enclosed the specific paragraphs & Tables discussed in my letter.

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