Mr. Bryan Couch
Systems Zone Leader
Motor Coach Industries
Door 10
475 Clarence Avenue
Winnipeg, Manitoba R3T IT5

Dear Mr. Couch:

This responds to your FAX of August 8, 1995, asking for our comments on a "preliminary drawing showing our proposed location for the front marker lamp and supplementary front marker lamp." The front marker lamp will meet all photometry requirements of Federal Motor Vehicle Safety Standard No. 108 and, in your opinion, will be placed as far forward as practicable on the vehicle. The supplementary lamp will not meet the 45 degree rearward photometry requirement.

We have only a couple of comments. The first is that initially the determination of practicability of the location of the front side marker lamps is that of the vehicle manufacturer who certifies compliance with Standard No. 108, and NHTSA will not question that determination unless it appears clearly erroneous. In this instance, we see no reason to question your opinion.

Our second comment is that a supplementary side marker lamp need not meet any of the requirements for side marker lamps; it must not, however, as provided in paragraph S5.1.3 of Standard No. 108, impair the effectiveness of any lighting equipment installed to meet the requirements of Standard No. 108. Given the small size and candela output of side marker lamps, we do not believe that your supplementary side marker lamp would have this effect.

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


John Womack Acting Chief Counsel ref:108 d:8/28/95