Mr. Dennis G. Moore
President
Sierra Products, Inc.
1113 Greenville Road
Livermore, CA 94550

Dear Mr. Moore:

This responds to your letter of July 31, 1995, with respect to lens area requirements of amber turn signal lenses.

You believe that "by reducing the minimal area of the Amber Turn Signal light lens from 12 square inches to approximately 8 square inches or 6 square inches the U.S. would have more practical rules for U.S. Exports at no expense to Safety. You ask that, "If NHTSA's Legal Council feels this error should be corrected through the Petitioning Process, I ask that this writing be considered a `Petition for Change of FMVSS #108 Request'".

Standard No. 108 contains two relevant regulations, one applicable to vehicles whose overall width is less than 80 inches, and one to those whose overall width is 80 inches or more.

Under paragraph S5.1.1.26(a), the functional lighted lens area of a single turn signal lamp of either red or amber on a vehicle whose overall width is less than 80 inches shall be not less than 50 square centimeters. This is approximately 8 square inches. Therefore, no rulemaking is required to implement your recommendation.

The standard that applies to turn signal lamps on vehicles whose overall width is 80 inches or more is SAE Standard J1395 APR85, incorporated by reference in Standard No. 108. Under its paragraph 5.3.2, the functional lighted lens area of a single turn signal lamp shall be at least 75 square centimeters, or approximately 12 square inches. Therefore, rulemaking is required to implement your recommendation.

We are transmitting your letter to our Office of Safety Performance Standards for consideration as a petition for rulemaking to change the minimum lens area requirement for

turn signal lamps on large vehicles from 75 to 50 square centimeters. On September 4, 1995, I determined that your letter met our procedural requirements for a petition. Accordingly, the Office of Safety Performance Standards will inform you not later than January 1, 1996, whether your petition has been granted.

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

Sincerely,

John Womack Acting Chief Counsel ref:108 d:9/20/95