ID: nht73-5.23

DATE: 09/20/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Auto Safety Research Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 27, 1973, which requests information on the requirements of Standard 206, Door Locks and Door Retention Components, and suggests that door locking mechanisms should prevent operation of the inside and outside handles latch release controls) of both front and rear doors.

The standard presently requires that engagement of the front-door locking mechanism on passenger cars, multi-purpose passenger vehicles, and trucks render the outside door handle (latch release control) inoperative. On passenger cars and multipurpose passenger vehicles, engagement of the rear-door locking mechanism must render both inside and outside handles inoperative. Your suggestion that inside front door handles also be rendered inoperative was proposed in 1967 as an initial standard, but it was determined at that time that ease of escape in the event of accident made one-step operation of the door more desirable. It was concluded that the vehicle operator would have sufficient control over children in the front seat to permit such override operation.

We are still interested in the best arrangement of locking mechanisms and override at the various seating positions. At the moment, available accident data does not justify further rulemaking. Your comments will be fully considered in the event we decide to take further action.

AUTO SAFETY RESEARCH CENTER

June 27, 1973

U.S. Department of Transportation

Dear Sir;

We were under the impression that, since about 1968, an automobile door, once locked, could not be opened from either the outside or inside, unless it was subsequently unlocked, and that there were Federal regulations to this effect. However, at least on some 1973 cars, the doors can be opened from the inside, even while locked, and a number of people have come to us both surprised and concerned that children and others can open a supposedly locked door.

Please advise us if there is indeed a Federal regulation concerning door lock operation. If there is no regulation to the effect that the door handles, both inside and outside, are rendered inoperative when the door is locked, then may we suggest that, from a safety standpoint, such a regulation should be adopted as soon as possible.

Sincerely,

Delbert A. Russell, Jr. Director

ID: 1982-2.39

DATE: 08/16/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mazda (North America), Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. David N. Cumming Mazda (North America), Inc. 23777 Greenfield Road, Suite 462 Southfield, Michigan 48075

Dear Mr. Cumming

This responds to your recent letter requesting clarification concerning the positioning of vehicles for testing under Safety Standards Nos. 212, 219 and 301. Specifically, you are concerned with a vehicle which is capable of height adjustment by manufacturer design, i.e., a 4-wheel drive vehicle which has one height position for normal highway driving and another for off-road driving.

The safety standards to which you refer do not specify a height adjustment because almost all vehicles have a single, set height. In fact, we have checked the agency's past interpretations for all three standards and determined that this question has never arisen. After careful consideration, it is the agency's position that such a vehicle capable of variable height adjustment would have to comply with the vehicle adjusted to any position that is possible. This is true because the vehicle could be driven on the highway, for example, even if it were adjusted to the off-road position. Consequently, it is important that the vehicle comply with the standards in all positions. To save on testing costs, you should be able to determine the worst case position, particularly with regard to Standard No. 301, and test only in that position. Your responsibility under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, et seq.) is to exercise due care to determine that your vehicles are in compliance with all applicable safety standards.

I hope this has been fully responsive to your inquiry. Please contact Hugh Oates of my staff if you have any further questions.

Sincerely,

Frank Berndt Chief Counsel

June 11, 1982

Mr. Frank A. Berndt, Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D. C. 20590

RE: Test Condition - Safety Standard Compliance Tests On Vehicles Capable Of Vehicle Height Adjustment

Dear Mr. Berndt:

We would like a clarification regarding the position for testing vehicles which are capable of vehicle height adjustment by manufacturer design (for example, a 4-wheel drive vehicle which has one height position for normal highway driving and another for off-road driving).

To determine compliance with Motor Vehicle Safety Standards such as 212, 219, and 301, what height position would NHTSA specify for testing the vehicle.

For example:

(1) highway driving position (2) off-highway position (3) design position, if different than (1) and (2), etc.

Also, please verify whether the manufacturer is responsible for compliance at height positions other than the specified test position.

Your response prior to July 30, 1982 would be greatly appreciated.

Thank you.

Sincerely,

David N. Cumming Engineer

DNC/mjs

ID: 77-2.29

TYPE: INTERPRETATION-NHTSA

DATE: 05/05/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: D. G. Moore - Dry Launch

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 7, 1977, asking for a clarification of S4.3.1.1.1 of Standard No. 108. Your initial question of December 27, 1976, was not clear to us hence the reason my answer of March 4, 1977, caused you some confusion.

The diagram in your letter of April 7 clearly depicts the exemption provided by S4.3.1.1.1 for the specific reasons therein, that when a clearance lamp indicating overall width is not located on the rear of a vehicle it need not be visible at 45 degrees inboard. As the only required points of photometric measurement of a clearance lamp so located are to the rear and at 45 degrees outboard, the lamp need not be visible at any point in the 45 degree arc depicted in your letter.

SINCERELY,

DRY LAUNCH

April 7, 1977

Frank Berndt Acting Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Admin.

Refering to your letter of March 4, 1977, #N40-30 (ZTV) the last two paragraphs dealt with my question - if it were permissible to eliminate photometric requirements in the "shaded" area provided for in the November 1975 amendment (S4.3.1.1.1). I'm afraid your answer was not clear to me and I can't say if you said it was permissible or not. Would you please clarify.

Dennis G. Moore

Does this area have photometric requirements when applied to the O.E.M. level?

(Graphics omitted)

ID: aiam3153

Dear Mr. Milby: This responds to your October 3, 1979, letter asking the Nationa Highway Traffic Safety Administration to permit the production of a limited number of school buses that do not comply with Standard No. 222, *School Bus Passenger Seating and Crash Protection*. The buses would be designed to transport severly handicapped students.; As you know, Standard No. 222 permits side-facing seats for handicappe students. However, the standard does not permit other variations of seating for the transportation of the handicapped. The agency's notice of July 12, 1976 (41 FR 28506) specifically limited its action with respect to handicapped student transportation to the provision of side-facing seats.; In your letter, you state that you intend to have forward and rearwar facing seats surrounded by a cubicle to restrain children that are severely handicapped. Since only side-facing seats are acceptable as a variation from the standard's required seating, the standard cannot be interpreted in such manner that would permit the type of seats that you propose to install in your bus. Further, according to our regulation governing exemptions from the safety standards, it would appear that you would not qualify under any of the criteria that have been established. Therefore, it would not be useful to seek an exemption or waiver from the standards.; The agency has been confronted with the special problems for th handicapped many times and in a variety of vehicles. The NHTSA realizes the special needs of these individuals and further understands that these needs require the agency to be flexible in the enforcement of standards applicable to vehicles used by the handicapped. As a result the agency has stated in the past, that it will overlook some noncompliances in vehicles that are serving the special needs of the handicapped. The agency concludes that compliance with Standard No. 222 will not be enforced in certain circumstances for buses designed to transport the handicapped.; The above exemption from enforcement of compliance with Standard No 222 is limited. The seating in such special buses must be distinctly different from that of typical school buses. For example, your placement of the seats in cubicles would provide such a distinction from normal school bus seats. The mere increase of seat spacing with the use of the traditional school seats, on the other hand, would not qualify for freedom from compliance with the standard. With respect to your bus, the agency concludes that all other passenger seats beyond these constructed in the cubicles must comply with the standard. The agency further notes that the use of this type of bus is appropriate only for the most extreme cases of handicapped transportation and is not necessary for the transportation of all handicapped.; Although it would not be required by regulation, manufacturers shoul label these unique buses for the handicapped in some manner that will identify them as appropriate only for the transportation of handicapped students and not as a regular school bus. Such a label would be important in alerting both the Federal and State government officials to the fact that this is not a regular school bus and thus might be subject to different considerations with respect to the enforcement of compliance with safety standards. You should also check with State officials to ensure that they will permit the use of such buses.; Sincerely, Frank Berndt, Chief Counsel

ID: nht76-2.10

DATE: 09/02/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

COPYEE: TRUCK BODY AND EQUIP. ASSOC.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Blue Bird Body Company's July 20, 1976, question whether the NHTSA's redefinition of "school bus" (40 FR 60033, December 31, 1975) includes buses designed for intercity transportation utilized in charter operation to transport school children to and from school or related events, and what constitutes "interstate commerce" as that term is used in the redefinition. A second July 20, 1976, letter from Blue Bird Body requests reconsideration of two NHTSA interpretations of Standard No. 221, School Bus Body Joint Strength, that were issued in an April 26, 1976, letter.

The redefinition of school bus (effective April 1, 1977) states:

"School bus" means a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.

The definition is not intended to include intercity type buses on regular common-carrier routes, although they may be used in some circumstances to transport school students to and from school or related events. This bus type has never been considered a school bus under existing motor vehicle safety standards or Pupil Transportation Standard No. 17 (43 CFR 1204). In light of the major standard-setting activity undertaken by Congress for school buses under the Motor Vehicle and Schoolbus Safety Amendments of 1974 (the Act) (15 UVS.C. @ 1392(i), it is unlikely that such a board change of regulatory direction would be contemplated by Congress without explicit discussion in the legislative history. The boundaries of coverage of the redefinition are explicitly left by the statute to agency determination, and the agency did not include the intercity buses you describe in the redefinition.

The meaning "interstate commerce" in the redefinition is the same as for that term in @ 108(a)(1)(A) of the Act, which states that no person shall "manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import" non-complying vehicles. While the legislative history of the Act does not directly address the meaning of the term, the House of Representatives Committee Report stated:

. . . The purpose of this section is to prohibit the manufacture, sale, or importation into this country of vehicles . . . that fail to meet the Federal safety standards . . . (H.R. Rep. No. 1776, 89th Cong., 2d Sess 22 (1966))

The agency adopts the existing construction of the term set forth in Katzenback v. McClurg, 379 U.S. 294 (1974). To answer your specific question, however, it should be clarified that only the classification of the bus as a school bus is determined by the ambit of "interstate commerce" in those infrequent cases where a sale does not occur. Blue Bird Body's responsibilities to conform to the standards arise directly from its manufacturing activities under @ 108(a)(1)(A). For example, a bus built in Georgia must conform to the school bus standards if it is sold to a Georgia school for use in transportation of school students, even if it never leaves the State.

Your second July 20 letter requests reconsideration of the NHTSA's April 26, 1976, decision that the area of contact between headlining panels and the "header" over the windows qualifies as a body joint subject to the requirements of the standard. You assert that the area of contact is not such a joint because it is covered by a molding and therefore does not "enclose occupant space" and cannot be considered a "surface component".

"Body panel joint" is defined in the standard to mean, with several exceptions, the area of contact or close proximity between the edges of a body panel and another body component. Whether or not the joint itself is covered is not relevant to its status. The separate definition of "body panel" does refer to the surface of the exterior or interior of the bus and to use of the panel in enclosing the bus occupant space. Thus, it is the body panel and not the joint which must form part of the exterior or interior surface of the bus. In the case you describe, the head-lining panel does enclose the bus occupant space and constitutes a part of the interior surface of the bus. Thus it does form a "body panel joint" at the point of contact with the header (a separate body component).

You also suggest that the requirements do not apply to a joint where the edges of the body panel join a body component at a point other than at the edge of the body component. Your interpretation is incorrect. In the case you describe, the floor panel's edges form a right angle that is attached to a central portion of the tag panel at some distance from its edges. The definition of "body panel joint" refers to contact between the edges of the body panel and another body component, without regard to the proximity of the edges of the body component.

You also request confirmation that a statement on rubrails in our April 26 letter is fulfilled by ensuring that, in testing a complex joint to which rubrails are fastened, the rubrails are modified so that they are not held by the gripping fixture of the tensile strength test machine. Your interpretation is correct.

In a related matter, the NHTSA would like to advise you of failure in our April 26, 1976, letter to respond fully to Blue Bird Body Company's February 13, 1976, letter. You asked if the cove molding that is attached at the border of the bus body floor against the sidewall of the bus body would qualify as a surface component whose edges form a joint subject to the standard's requirements. From your description of the cove molding and its use at the edge of the floor, the agency considers that it does not have a function in enclosing the occupant space and is therefore not considered a body component for purposes of the requirements. A copy of your illustration of this component is attached for the benefit of interested persons.

Finally, I would like to acknowledge receipt of your July 28, 1976, letter to the Administrator, asking that the new definition of "school bus" become effective on April 1, 1977, instead of October 27, 1976. Your request has been granted by a recent notice of rulemaking.

YOURS TRULY,

BLUE BIRD BODY COMPANY

July 28, 1976

John Snow, Administrator National Highway Traffic Safety Administration

The Motor Vehicle and School Bus Safety Amendments of 1974, Public Law 93-492, precipitated a number of Federal Motor Vehicle Safety Standards as well as an amended definition of a school bus (Section 201). We have noted that Public Law 94-346 has changed the effective dates of the new standards from October 26, 1976 to April 1, 1977, but apparently the school bus definition remains effective October 26, 1976. We believe that this must be an oversight and probably wouldn't achieve the uniformity of a consistent change that you would desire. We do feel that this difference in dates will cause confusion and hardship. Therefore, we request that the new school bus definition also be changed to be effective April 1, 1977.

Thanks for your consideration in this matter.

W. G. Milby Staff Engineer

C: BYRON CROMPTON; TBEA

BLUE BIRD BODY COMPANY

July 20, 1976

Thomas W. Herlihy National Highway Traffic Safety Administration

The purpose of this letter is to clarify certain questions pertaining to definition of a school bus which becomes effective October 27, 1976.

First, we would like to know exactly what constitutes "Interstate Commerce" as it is used in the school bus definition. The question has been raised: do the new school bus standards only apply to buses which cross state lines while transporting students?

Another question relates to the scope of the exception clause which states that a school bus . . . "does not include a bus designed and sold for operation as a common carrier in urban transportation." Are we correct in assuming that this exception does not extend to Greyhound or Trailways type buses which are chartered for the purpose of ". . . .carrying students to and from school . . . related events. . . ."?

Thank you for your early reply to these important questions.

W. G. Milby Staff Engineer

BLUE BIRD BODY COMPANY July 20, 1976

Thomas W. Herlihy National Highway Traffic Safety Administration

REFERENCE: 1. Letter W. G. Milby to R. B. Dyson, dated 2-13-76

2. Letter Frank Berndt to W. G. Milby, dated 4-26-76; N40-30

The purpose of this letter is to question several of the interpretations NHTSA has given us in reference 2 regarding FMVSS 221.

Item 4, page 2 of reference 1 pertains to the area where the header and headlining come in contact. As explained in reference 1, this area of contact is completely covered and, therefore, isolated from the bus occupant space by the wire molding. In reference 2 NHTSA said "the terms which establish the applicability of the requirements of the standard to a particular section of a school bus body are defined in S4 of the standard. Read together they establish the following test. If the edge of the surface component (made of homogeneous material) in a bus that encloses the bus' occupant space comes into contact or close proximity with another body component the requirements of S5 apply. . .".

In our opinion the area of contact between the header and headlining does not meet this criteria for two reasons:

1. Because it is completely enclosed by the wire molding, it cannot be construed to be "a surface component".

2. Also because it is covered by the wire molding it does not "enclose the bus occupant space".

Therefore, we would ask NHTSA to reconsider its interpretation given to us in reference 2 and rule that the area of contact between the header and headlining is not a joint which must meet the requirements of S5.

Item 15, page 5 of reference 1 pertains to the area of contact between the tag panel and the floor. In our opinion this does not meet the criteria required for a joint because the area of contact between the tag panel and the floor is several inches from the edge of the tag panel. This fact was overlooked in the preparation of reference 1. Hence in reference 2 NHTSA ruled that this would be a joint subject to the requirements of S5. Since the area of contact is several inches from the tag panel, we are proceeding on this not being a joint. I am including it in this letter merely to document the reason for our not considering it to be a joint after having received the interpretation given in reference 2 which was based on incomplete information.

In reference 2 NHTSA ruled that rubrails ". . . are not themselves considered to have a function in enclosing the occupant space and, therefore, are not considered body components for purposes of the requirements. For purposes of testing the complex joints to which they are fastened, they should be modified as necessary to prevent them from affecting testing of the underlying joint." In the many hundreds of joint tests we have run in preparation for compliance with FMVSS 221 we have come to the conclusion that it's virtually impossible to modify the rubrail in such a way that it does not have any effect on the underlying joint. We also feel that it is unrealistic to attempt to modify the rubrail so that it has no effect on the underlying joint. This is because that in order for the underlying joint to fail on a vehicle the rubrail must also fail. Therefore, in our testing of joints which include a rubrail we have modified them in such a way that the gripping fixture of the tensile testing machine only grips the panel portion of this specimen and in no way contacts the rubrail. In this way the tensile load is imparted wholly to the panel specimen. However, we cannot guarantee that the rubrail section has no effect on the underlying joint. We are confident that our testing method is more severe than any kind of loading that could even be imparted in an accident. Further we are confident that our testing method meets the full spirit of FMVSS 221. I include this discussion again simply to document our testing methodology and to indicate that we do not feel it is possible or reasonable to construct and test a sample joint in which the rubrail has no effect on the underlying joint.

Thank you for your consideration of the header to headlining and we look forward to your early reply.

W. G. Milby Staff Engineer

(Graphics omitted)

TOLERANCE ON ALL DIMENSIONS IS, PLUS (Illegible Word) OR MINUS (Illegible Word) UNLESS OTHERWISE SPECIFIED

INACTIVATES NOS.

REPLACED BY NOS.

RELEASED

BLUE BIRD BODY CO. FORT VALLEY, GEORGIA, U.S.A.

(Illegible Word)

COVE MOLDING TO FLOOR

(Illegible Words)

SIZE:

ID: 000490.drn

Susanne Krg, Account Manager
Lemfrder Corporation
Schaltungssysteme GmbH
Technical Center
15811 Centennial Drive
Northville, MI48167

Dear Ms. Krg:

This responds to your August 30, 2002, request for an interpretation of Federal Motor Vehicle Safety Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect. In a letter of August 1, 2002, we responded to your earlier questions whether a motor vehicle that includes several proposed shift-by-wire shift patterns would meet Standard No. 102. In your August 30, 2002, letter you provide diagrams with more details of several other shift patterns that we did not address earlier because not enough detail was provided.

Lemfrder did not ask for confidential treatment of any information in its letter. In a September 26, 2002, telephone conversation between yourself and Dorothy Nakama of my staff, you confirmed that after consulting with Lemfrder engineers in Germany, Lemfrder does not request confidential treatment for any information in the letter.

Please note that unlike the case in Europe and Japan, the National Highway Traffic Safety Administration (NHTSA) does not "approve" motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet applicable standards. The following presents our opinion of Lemfrders proposed design, based on the information in your letter to us.




The Proposed Design Described in Lemfrders August 30, 2002, Letter

I will assume for purposes of this letter that NHTSAs August 1, 2002, description of Lemfrders general design applies to the proposed shift patterns depicted in your new letter. NHTSA noted that in Lemfrders design, the shifting would be done by means of a joy stick, which, after being shifted, would return to a default position designated as the "X" position. NHTSA further noted that the joy stick may be moved straight up, straight down, and to the right

and left (i.e., imagining the face of a clock, to the 12 oclock, 6 oclock, 3 oclock, and 9 oclock positions) only. Diagonal movements such as to the one oclock or two oclock positions would not be permitted. Most of the shift patterns have two neutral positions. In all of the shift patterns depicted, before the joy stick may go into "drive" or "reverse," it must first be moved to "neutral." Thus, for example, to go into reverse, one moves the joy stick straight up (to go to neutral) and then to the left (to reverse).

With your new letter, you provided diagrams of nine more proposed configurations of shift-by-wire shift patterns. In five of the proposed configurations, it will be possible to shift from the "X" position manually to a higher or lower drive. For each of these five configurations, your proposed design depicts an "+" and "-" sign that "reflect the possibility to shift manually up or down by tipping towards the plus or minus, while the car is in D." None of the proposed configurations includes a "park" position. We assume that the shift patterns are intended to be used in motor vehicles with automatic transmissions.




Shifting from "Neutral" to "Drive" or "Reverse"

Requirements for shift patterns are specified at paragraph S3.1.1 of Standard No. 102, which states in part:

A neutral position shall be located between forward drive and reverse drive positions . . . . If the transmission shift lever sequence includes a park position, it shall be located at the end, adjacent to the reverse drive position.

All of your nine additional proposed shift patterns meet the requirement that "a neutral position shall be located between forward drive and reverse drive positions." As stated in NHTSAs August 1, 2002, letter since nothing in S3.1.1 specifies that only one neutral position is to be provided, your patterns that would include two neutral positions are not prohibited by S3.1.1.

Since none of your proposed shift patterns includes a "park" position, we will not discuss the S3.1.1 provision specifying that if the transmission shift lever sequence includes a "park" position, it "shall be located at the end, adjacent to the reverse drive position."




Standard No. 102s Identification of Shift Lever Position Requirements

In our letter of August 1, 2002, we noted that unlike traditional transmission shift levers that stay in the gear position selected by the driver, the joy stick in your design defaults to the "X" position after the gear is selected. As a result, a visual display other than the joystick must inform the driver of the current gear selection. The August 1, 2002, explanation of Standard No. 102s identification requirements would apply to the nine shift pattern configurations that you have presented in your letter to us.

I hope this information is helpful. If you have any questions, please contact Ms. Nakama at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:102
1/13/03

ID: aiam1772

Dear Ms. Black: This is in response to your letter of December 19, 1974, requestin interpretations of two test conditions contained in Standard No. 301-75, *Fuel System Integrity*.; Your first question relates to the static rollover test condition an asks whether it was the NHTSA's intention that the vehicle be rotated to three positions only for spillage measurement. (Paragraph S7.4 specifically refers only to increments of 90 degrees, 180 degrees, and 270 degrees.) The static rollover test is intended to test the amount of fuel spillage a vehicle experiences at each 90 degree increment in a full 360 degree rotation. The standard presumes that the test begin with the vehicle in an upright position. It is from this upright position that the vehicle begins its movement to the remaining three 90 degree increments.; Your second question asks for an interpretation of the section relatin to the operation of the vehicle's fuel pump during testing. Paragraph S7.1.3 of the standard requires that a electrically driven fuel pump be in operation during the barrier crash tests if it normally operates with the activation of the vehicle's electrical system. If pump operation requires the operation of the vehicle's engine, ten (sic) the pump should not be running during the barrier crash tests. If the fuel pump installed in your barrier is capable of independent operation as described in SF.1.3 it should be operating during the barrier crash tests even if it cuts off fuel at the moment of impact. Under the existing requirements, whether a pump out of fuel at impact would not be relevant to whether it must be operating at impact. Of course, over cutoff feature would be considered as pard of the bump's normal operation.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: nht92-2.10

DATE: November 23, 1992

FROM: T. Kouchi -- Director & General Manager, Automotive Equipment, Development & Administration Department, Stanley Electric Co., Ltd.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12/30/92 from Paul J. Rice to T. Kouchi (A40; Std. 108)

TEXT:

We are investigating the development of automotive tail & stop lamps using light emitting diodes (LEDs) as light sources.

We have already asked you about Center High-Mounted Stop Lamp (CHMSL) using LEDs and have received your letter of January 9, 1986, in which you answered that such type of CHMSL would be acceptable when it complies with the photometric requirements and provides replaceability of light sources (S4.1.41(e)) specified in FMVSS No. 108.

From your answer, we consider that LEDs can be used in tail & stop lamps.

Now we would like to ask you additional questions as follows:

(1) Is it possible for us to group LED tail & stop lamps into three categories in terms of the number of lighted sections to determine applicable photometric requirements, as specified in paragraph 4.1.5.1 of SAE J1389 JUN83?

(2) Where the above view is acceptable, could we consider the number of lighted section as "one" in case of a lamp which contains three LED arrays arranged as shown in the attached drawing, if the circumferenc of three projected luminous areas does not exceed 150mm both in horizontal and vertical dimensions?

(3) Where the number of lighted section is determined as "one" in the above, can we locate "the geometric center of the illuminated area" at the point marked in the attached drawing, according to paragraph 2.6 of SAE J1389 JUN83?

We would be very pleased if you kindly inform us of your points of view for the above(1)-(3).

(Drawing omitted.)

ID: 19699.ztv

Mr. Tadashi Suzuki
Manager
Automotive Equipment
Legal & Homologation Sect.
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153-8636
Japan

Re: Motorcycle Headlamp Arrangement

Dear Mr. Suzuki:

This is in reply to your letter of March 10, 1999, pointing out an inconsistency between our letter to you of February 22, 1999, and preamble language to a 1996 amendment of Federal Motor Vehicle Safety Standard No. 108.

The issue is the measurement of photometrics in two-lamp motorcycle headlamp systems: whether the photometric performance of Figure 32 is applied to each headlamp, or to the combined output of both headlamps. Our first interpretation on this subject was provided to M. Iwase of Koito Manufacturing Co., who asked us about the measurement of photometrics in a two-lamp motorcycle headlamp system. We informed Mr. Iwase on November 29, 1985, that:

The fact that the combined maximum value of your system exceeds 75,000 candlepower [for upper beam] is permissible as long as the individual lamps themselves do not exceed 75,000 candlepower.

We confirmed this interpretation in the preamble of the 1996 amendment to Standard No. 108 adopting a new photometric standard for motorcycle headlamps (61 FR 45359). There we said that:

When a motorcycle is equipped with a two-lamp headlamp system, there is no summing of test point values in determining compliance. Each headlamp for use on a motorcycle must comply with specified photometrics for a single lamp, and not as a system of two headlamps.

Thus, the maximum values apply to a single headlamp, and not the system of two headlamps as [Koito and Suzuki] appear to believe" (at 45360).

However, our letter of February 22 informed you that "a [motorcycle headlamp] system of the type described in subparagraph (b) of S7.9.6.2 [a two-lamp system] is not intended to have twice the light output of systems described in S7.9.6.2(a) or S7.9.6.2(c)," which you interpret as contrary to our previous interpretations. You ask that we seek public comment if it is our intent to adopt "one photometric performance for each motorcycle."

We appreciate your calling this matter to our attention. We agree that our interpretation is incorrect and withdraw that portion of our letter of February 22 that is inconsistent with prior interpretations. A conflict appears to arise in the context of a motorcycle headlamp system permitted by S7.9.6.2(b), a two-lamp system in which each lamp contains an upper beam light source, or each lamp contains a lower beam light source. This system could produce total beam photometrics of twice the light output of a single beam system (S7.9.6.2(a)or S7.9.6.2(c)). The edges of luminous lens areas of headlamps meeting S7.9.6.2(b) must be no more than 8 inches apart when they are mounted horizontally, and our remarks in our letter of February 22 reflected our concern that this may be an insufficient distance to prevent glare arising from two beams, especially from the lower beam when other drivers are in close proximity. If you intend to produce a two-headlamp system with two full-intensity upper or lower beams, please keep in mind our safety concerns about glare.

We intend to study this question in the coming months as part of a petition from the Japanese Automotive Parts Industry Association, and would appreciate any data you may have on this subject.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.9/29/99

ID: 19843.ztv

Mr. Masao Muraoka
Deputy General Manager
Technical Administration ept.
Koito Mfg. Co., Ltd.
Shizuoka Works
500, Kitawaki
Shimizu-Shi, Shizuoka-ken
Japan

Re: Motorcycle Headlamp Photometry

Dear Mr. Muraoka:

This is in reply to your letter of April 6, 1999, pointing out an inconsistency between our letter to Stanley Electric Co. of February 22, 1999, and preamble language to a 1996 amendment of Federal Motor Vehicle Safety Standard No. 108.

The issue is the measurement of photometrics in two-lamp motorcycle headlamp systems: whether the photometric performance of Figure 32 is applied to each headlamp, or to the combined maxima of both headlamps. Our first interpretation on this subject was provided to M. Iwase of your company, who asked us about the measurement of photometrics in a two-lamp motorcycle headlamp system. We informed Mr. Iwase on November 29, 1985, that:

The fact that the combined maximum value of your system exceeds 75,000 candlepower [for upper beam] is permissible as long as the individual lamps themselves do not exceed 75,000 candlepower.

We confirmed this interpretation in the preamble of the 1996 amendment to Standard No. 108 adopting a new photometric standard for motorcycle headlamps (61 FR 45359). There we said that:

When a motorcycle is equipped with a two-lamp headlamp system, there is no summing of test point values in determining compliance. Each headlamp for use on a motorcycle must comply with specified photometrics for a single lamp, and not as a system of two headlamps.

Thus, the maximum values apply to a single headlamp, and not the system of two headlamps as [Koito and Suzuki] appear to believe" (at 45360).

However, our letter of February 22 informed Stanley Electric that "a [motorcycle headlamp] system of the type described in subparagraph (b) of S7.9.6.2 [a two-lamp system] is not intended to have twice the light output of systems described in S7.9.6.2(a) or S7.9.6.2(c)," which you interpret as contrary to our previous interpretations. You ask that we seek public comment if it is our intent to adopt "one photometric performance for each motorcycle."

We appreciate your calling this matter to our attention. We agree that our interpretation is incorrect and withdraw that portion of our letter of February 22 that is inconsistent with prior interpretations. A conflict appears to arise in the context of a motorcycle headlamp system permitted by S7.9.6.2(b), a two-lamp system in which each lamp contains an upper beam light source, or each lamp contains a lower beam light source. This system could produce total beam photometrics of twice the light output of a single beam system (S7.9.6.2(a)or S7.9.6.2(c)). The edges of luminous lens areas of headlamps meeting S7.9.6.2(b) must be no more than 8 inches apart when they are mounted horizontally, and our remarks in our letter of February 22 reflected our concern that this may be an insufficient distance to prevent glare arising from two beams, especially from the lower beam when other drivers are in close proximity. If you intend to produce a two-headlamp system with two full-intensity upper or lower beams, please keep in mind our safety concerns about glare.

We intend to study this question in the coming months as part of a petition from the Japanese Automotive Parts Industry Association, and would appreciate any data you may have on this subject.

Sincerely,
Frank Seales, Jr.
Chief Counsel
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d.9/29/99