Mr. Jeffrey D. Shetler
Manager of Government Relations
Kawasaki Motors Corp. U.S.A.
P.O. Box 25252
Santa Ana, CA 92799-5252

Dear Mr. Shetler:

We are responding to your FAX of March 29, 1995, to Taylor Vinson of this Office.

On May 6, 1994, we advised you that a motorcycle headlamp with an upper beam projector on one side of the vertical centerline and a lower beam projector on the other did not comply with Standard No. 108. You now ask whether the headlamp would comply if an exterior housing were installed on the headlamp which "provides the appearance of two headlamps."

This modification in the design does not result in a complying headlamp. Regardless of its exterior appearance, the lamp remains a single headlamp incorporating both an upper and lower beam projector. Since both projectors are within a single headlamp, both projectors must be on the vertical centerline, as specified in Table IV of Standard No. 108.

Even if the upper and lower beam projectors were in separate units, neither in itself would be a complying headlamp, and hence not a two-lamp system that could be mounted symmetrically about the vertical centerline. Standard No. 108 does not permit motorcycles to have a headlamp system with asymmetrical beam location.

If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,

Philip R. Recht Acting Chief Counsel ref:109 d:4/24/95