Mr. Craig Homberg
Aquatech, Inc.
1777 Miller Parkway
Streetsboro, OH 44241

Dear Mr. Homberg:

This responds to your letter of August 2, 1996, to the former Chief Counsel, Samuel Dubbin, asking for suggestions as to where Aquatech might locate the rear identification lamps on a vehicle that it manufactures. These lamps "are obstructed by a vacuum boom." The lamps cannot be mounted on the boom because it "articulates side to side and extends and retracts." You have enclosed a two-dimensional drawing showing the vehicle from the rear.

Table II of Motor Vehicle Safety Standard No. 108 requires rear identification lamps to be "3 lamps as close as practicable to the top of the vehicle, as close as practicable to the vertical centerline, with lamp centers spaced not less than 6 inches or more than 12 inches apart." Table II does not establish either a minimum or maximum mounting height for these lamps.

The agency realizes that, with some vehicle configurations, the highest practicable location may be approximately the same level as stop and taillamps, such as the frame rail, and the agency has accepted this. Some manufacturers have also added equipment to the vehicle at this level to accommodate identification lamps. The two-dimensional drawing you enclosed shows a horizontal structure below the boom and above the rear axle, where it might be possible to add identification lamps. However, the drawing is two-dimensional and it is not possible for us to assess the dimensional relationship between the horizontal structure and the vertical piece that, in the picture, bisects the lower half of the horizontal structure.

If it is not practicable to add identification lamps on the horizontal structure below the boom and above the rear axle, we would be pleased to advise you further if you would send us a photograph or drawing of the rear that shows the dimensional relationships of the equipment already located there. If you have any further questions, you may call Taylor Vinson of this Office (202-366-5263).


John Womack

Acting Chief Counsel