ID: nht88-3.34

TYPE: INTERPRETATION-NHTSA

DATE: 09/07/88

FROM: LEONARD M. PERKINS -- L AND M COMPANY

TO: ROBERT BURNLEY -- SECRETARY OF TRANSPORTATION DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 02/06/89 EST, FROM ERIKA Z. JONES -- NHTSA TO LEONARD M. PERKINS, REDBOOK A33, STANDARD 108

TEXT: Dear Sir:

We have an automobile safety device worthy of your consideration.

According to a recent survey we read, the rear window brakelight has reduced rear end collisions by about 25% nationwide. We have travelled bumper to bumper freeway traffic for many years and found directional signals on most new cars very difficult to see, due to our line of vision being concentrated on the cars in front, on each side and the closeness of all cars at speeds of 50-60 miles per hour. Also, the placement of these signals now are where the car design people think they blend in best, m ainly in the bumper area.

Our design patent has moved these signals up where they can be seen readily as the rear window brake light (see enclosed copies of patent application). Our suggestion for color of these directional side lights would be yellow, an eye catching color f or split second sightings. We feel that the turn signals joined with the rear window brake light should have a dramatic effect on rear and side collisions.

Having spent much time driving Los Angeles and Phoenix freeways, we feel this would not only cut down accidents, but save millions of dollars in property damage each year.

We have been told by informed sources that this conception is at present illegal. Your comments and help would be greatly appreciated.

Yours truly,

(FIGURES 1 - 5 OMITTED)

ID: nht70-1.1

DATE: 04/30/70

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: David Sugarman, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of April 16 I enclose copies of Federal Motor Vehicle Safety Standards Nos. 107 (Reflecting Surfaces) and 108 (Lamps, Reflective Devices, and Associated Equipment). Copies of the ASTM and SAE standards cross-referenced in the Federal standards are available from the American Society for Testing and Materials and the Society of Automotive Engineers. You may find particularly helpful SAE Handbook Supplement 19, "SAF Technical Reports Referenced in Federal Motor Vehicle Safety Standards".

The answer to your first question is that Standard No. 108 requires passenger cars manufactured on or after January 1, 1970, to be equipped with a total of 4 side marker lamps and 4 side marker reflectors, one marker and one reflector, amber in color, on each side of the vehicle "as far forward as practicable", and one marker and one reflector, red in color, on each side of the vehicle, "as far to the rear as practicable" Between January 1, 1969 and January 1, 1970 the option of reflectors or markers, or a combination of the two, was permitted. Prior to January 1, 1969 the Federal lighting standard did not apply to passenger cars. I will note in passing that the rear marker lamps on the Monteverd; displayed at the recent New York show were number and must be changed to red before these vehicles are sold. There are no requirements as to size and shape of lamps and reflectors, but the SAE standards applicable to them and incorporated by reference in Standard No. 108 do set forth certain photometric requirements which must be met.

In answer to your second question, Table III of Standard No. 108 requires tail lamps to be red, but permits stop lamps and rear turn signals to be either red or amber. A proposal has been issued however (35 F.R. 106) that stop lamps be red only on passenger cars manufactured on or after January 1, 1971.

You have asked in your third question whether headlamps may be placed in the grill. The answer to this is yes, provided that this location meets the lateral spacing and height above road surface requirements of Table IV of Standard No. 108. Also, headlamps must not be covered by a grille or plastic shield when in use.

Standard No. 107 does not specify a particular color for the horn ring and hub of the steering assembly but it does specify a maximum permissible value for specular glass.

Finally, other than Standard Nos. 205 (Glazing Materials) and 212 (Windshield Mounting) which all passenger cars must meet, there is no "specific safety requirement as to the windshield" for convertibles, and there is no "requirement as to a roll bar".

Sincerely,

Enclosures April 16, 1970

U.S. Department of Transportation Federal Highway Administration

Re: F.H.W.A. Temporary Exemption

No. 69-9 issued to Automobile

Monteverdi Ltd.

September 9, 1969 expiring

August 1, 1971

Gentlemen:

I represent Automobile Monteverdi Ltd. of Switzerland. In furtherance of my letter of April 9, 1970 requesting certain information as to the above, will you inform me as to the following:

1-a)Is there a safety standard requirement with regard to lights on the side of the automobile (front and/or back); if so, is it a requirement for a light or may it be a reflector?

b) Whether it is a requirement for a light or a reflector, is there a requirement as to its size or shape?

2. With regard to rear lights, brake, safety stop and blinker; is there a specific requirement as to the color of such lights, may they be red or orange etc?

3. With regard to headlights, may the manufacturer place headlights in the grill on a two seater model and a convertible model?

4. With regard to the steering wheel is there a specific requirement that the cross bar of a steering wheel be a particular color e.g. black or grey? I know that it may not be chromed.

5. With regard to a convertible model, is there a specific safety requirement as to the windshield, and is there any requirement as to a roll bar?

I would appreciate hearing from you.

Very truly yours,

David Sugarman

ID: 86-3.47

TYPE: INTERPRETATION-NHTSA

DATE: 06/12/86

FROM: JAMES J. DABROWSKI -- REGULATIONS/STATISTICS COORDINATOR JAGUAR

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMIN.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/15/86 TO, JAMES J. DABROWSKI, FROM ERIKA Z. JONES, REDBOOK A29 (4); SEC 102, 151; RECALL LETTER TO GRAY MARKET VEHICLE OWNERS FROM JAGUAR CARS INC AND RELEASE DATED 06/12/86 EST

TEXT: Dear Ms. Jones:

Attached you will find a copy of our letter to individuals or firms who have been identified as being in possession of or who have imported a Gray Market Jaguar vehicle that may be subject to a manufacturer's recall campaign. Also attached is a standard release form which we will require the owner/importer to sign before we attempt any recall repair.

As we understand, Jaguar Cars has no legal responsibility to notify owners of these vehicles or to repair these vehicles. Therefore, the usual NHTSA recall notification, owner letter, and reporting, etc., requirements are not binding. By way of explanation, however, the fact that we are not bound by these regulations is not the reason for our "abbreviated" owner notification approach.

The convoluted nature of virtually all aspects of this undertaking from sorting out complicated and often poor attempts at compliance modifications, unknown technology and unknown repair times to logistical questions regarding a cooperating dealer and arranging for a pre-repair inspection, etc., dictate a simple letter. It would be impossible under these circumstances to produce an all encompassing owner notification letter. In this instance, it is more efficient to liaise with the customer via phone.

We would like to make you aware of our endeavor. Mr. D. Allen of your office has, via Mr. F. Armstrong, seen our letters and expressed no objection. Would you please be kind enough to review the attached documents and confirm that Jaguar Cars is not bound by normal NHTSA recall procedures.

ATTACHMENT

Yours sincerely,

ID: nht74-4.42

DATE: 01/14/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Trailer Manufacturers Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 26, 1973, asking whether motor vehicle new or used car dealers are prohibited from selling vehicles mounted on regrooved or recapped tires. You indicated in a phone conversation with Michael Peskoe of this office that your concern is with motor vehicles generally, and not passenger cars alone.

New passenger cars are required to be sold with tires meeting the requirements of Motor Vehicle Safety Standard No. 109 (49 CFR 571.109; 571.110). New vehicles other than passenger cars are not presently required by NHTSA regulations to be sold with particular tires, but requirements in this regard have been proposed (36 F.R. 14273; August 3, 1971).

This agency has no requirements regarding the sale of used motor vehicles equipped with recapped or retreaded tires. However, buses subject to Bureau of Motor Carrier Safety regulations are prohibited from operating with recapped, retreaded, or regrooved tires on their front wheels (49 CFR @ 393.75(d)).

Trucks and truck tractors subject to Motor Carrier Safety requirements may not be operated with regrooved tires on the front wheels which have a load carrying capacity equal to or greater than that of 8.25-20 8 ply-rating tires (49 CFR 393.75(e)). For more information regarding the applicability of these requirements you should contact, Regulations Division Bureau of Motor Carrier Safety, Federal Highway Administration, United States Department of Transportation, Washington, D. C. 20590.

P2

The sale of regrooved tires is subject to regulations issued by this agency (49 CFR Part 569). The recent opinion issued by the United States Court of Appeals (NAMBO v. Brinegar, D.C. Cir., Case No. 71-1268; July 26, 1973) appears to allow the sale of regrooved tires under these regulations in certain circumstances. We believe the opinion is unclear in this regard, and as a result we have determined to seek additional judicial review to further clarify the matter.

ID: aiam3872

Dear Mr. Shaw: This is in reply to your letter of December 5, 1984, with respect t the permissibility under Federal regulations of a 'Supplemental Eye-Level Rear Stop Light' which provides functions additional to a stop signal.; Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflectiv Devices and Associated Equipment* specifies requirements only for center high-mounted stop lamps as original equipment on passenger cars, and for equipment that replaces original equipment center high mounted stop lamps.; If you offer this device to new car dealers for installation on ne cars before their sale, the dealer bears the responsibility for insuring that the car he sells complies with the center high mounted stop lamp requirements for new motor vehicles. On vehicles manufactured before September 1, 1986, equipped with the center lamp, that lamp may flash with the hazard warning lamp, but it cannot be combined with other lighting functions such as turn signal.; However, the device you wish to offer appears intended as a aftermarket device and not intended as original equipment for passenger cars. If this assumption is correct, there is no Federal standard that applies to it, and its legality must be determined according to the law of each State where it will be in use.; We hope that this information has been helpful. Sincerely, Frank Berndt, Chief Counsel

ID: nht76-1.49

DATE: 12/08/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Kelsey-Hayes Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Kelsey-Hayes' April 21, 1976, question whether motor vehicle rims that are labeled in conformity with the requirements of Standard No. 120, Tire Selection and Rims for Vehicles Other Than Passenger Cars, may be installed on passenger cars.

The requirements of S5.2 of Standard No. 120 for labeling of rims for use on multipurpose passenger vehicles, trucks, buses, trailers, and motorcycles do not affect the use of those rims on passenger cars. This situation would change if Standard No. 110, Tire Selection and Rims, is modified in the future to prohibit one or more of the items required by S5.2, but such an eventuality is considered to be unlikely.

Sincerely,

ATTACH.

KELSEY-HAYES COMPANY

November 9, 1976

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration

RE: Request for Interpretation: FMVSS-120

Dear Mr. Berndt:

We requested an interpretation on this safety standard in April, 1976 and have not yet received a reply. A copy of my April 21 letter is enclosed for reference.

May we hear from you soon on this matter? We have some pressing business decisions to make.

Very truly yours,

John F. McCuen

enclosure

KELSEY-HAYES COMPANY

April 21, 1976

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration RE: Request for Interpretation - FMVSS-120 Non-Passenger Car Rims

Dear Mr. Berndt:

Kelsey-Hayes Company is a domestic manufacturer of motor vehicle equipment including rims for passenger car, truck, and other vehicle applications.

We make some rims that are used for both original equipment passenger cars and original equipment recreational trailers. As we understand the provisions of FMVSS-120, such a rim, when manufactured and sold for use on a trailer, must conform to FMVSS-120. It is not clear, however, whether rims conforming to FMVSS-120 may also be used on new passenger cars.

We envision circumstances under which a rim marked in conformance with FMVSS-120 is inadvertently shipped to a passenger car assembly plant for use on a new passenger car. We seek your interpretation of whether or not a manufacturer of passenger cars may use rims conforming to FMVSS-120. Assuming there is a safety benefit to the marking of rims for use on vehicles other than passenger cars, we assume those benefits are comparable when the same rim is used on a passenger car. This apparent benefit would seem to outweigh the costs associated with segregating identical wheels as a factor of the customers to whom we ship them to.

Accordingly, (Illegible Words) which would enable us to sell (Illegible Words) to FMVSS-120 for original equipment passenger car applications.

Very truly yours,

John F. McCuen

ID: nht81-3.10

DATE: 08/25/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT:

AUG 25 1981 NOA-30

Roger E. Maugh, Director Automotive Safety Office Environmental and Safety Engineering Staff Ford Motor Company The American Road Dearborn Michigan 48121

Dear Mr. Maugh:

This responds to your letter of July 31, 1981, to Hugh Oates of my staff requesting an interpretation concerning Safety Standard No. 210, Seat Belt Assembly Anchorages. You ask whether you are correct in your belief that the requirements of paragraph S4.3.1.1 of the standard apply to the seat belt anchorages used in your planned 1982-model Continental passenger cars rather than the requirements of paragraph S4.3.1.2.

Paragraph S4.3.1 of the Standard specifies location requirements for the seat belt anchorages for Type 1 seat belt assemblies and the pelvic portion of Type 2 seat belt assemblies. Paragraph S4.3.1.1 applies in those installations in which the seat belt does not bear upon the seat frame, and the requirements of paragraph S4.3.1.2 apply in installations in which the seat belt does bear upon the seat frame. On the 1982 Continental passenger cars, the buckle end of the seat belt assembly passes through a "console support structure" which is connected to the bottom of the seat frame. However, you contend that since the console support structure is not a structural component of the seat frame, the seat belt does not bear upon the seat frame and, consequently, that paragraph S4.3.1.1 applies.

Your interpretation of paragraphs S4.3.1.1 and S4.3.1.2 is correct. The phrase "bears upon the seat frame" as used in paragraph S4.3.1.2 refers to seat belt assemblies in which the seat belt presses or rests directly on the main structural frame of the seat. As illustrated in the photographs supplied in your letter, the seat belt in the 1982-model Continental passenger cars does not bear upon the structural seat frame. Rather, the belt rests on the console support frame which is not a necessary structural component of the main seat frame, but is merely attached to the seat frame at the bottom on the inboard side. Since the seat belt is located to the side of the seat frame and does not bear upon the structural seat frame itself, the requirements of paragraph S4.3.1.1 apply to the location of the seat belt anchorages used in the 1982 Continental passenger cars rather than the requirements of Paragraph S4.3.1.2.

We note that the console support frame could easily have been attached to the transmission tunnel rather than to the seat frame. In that case, the seat belt obviously would not bear upon the seat frame. However, with such a design, the frame supporting the belt would not move with the seat, and the driver could have problems reaching the belt and positioning it properly when the seat is in certain positions. The design of the passenger seat and seat belt assembly in the 1982 Continental is very desirable because attachment of the console support frame to the seat makes the seat belt very accessible in all seat positions. The fact that the console was attached to the seat frame for convenience purposes does not mean that the console is part of the seat frame within the meaning of S4.3.1.2.

The original intent of the location requirements of FMVSS 210 was to enhance belt performance with acceptable belt comfort and convenience. The specific requirements that are the subject of this interpretation were intended to ensure that belts would not develop excessive slack if a seat structural member bent or failed during a crash, and to reduce the likelihood that the lap belt would move into the abdominal area during a crash. We trust that Ford has adequately tested the configuration that is proposed here to ensure proper performance in a crash situation.

Please contact this office if you have further questions.

Sincerely,

Frank Berndt Chief Counsel

July 31, 1981

Hugh F. Oates, Jr., Esq. Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S. W. Washington, D. C. 20590

Dear Mr. Oates:

This letter is to request concurrence in Ford Motor Company's view that compliance to section S4.3 "Location" of Motor Vehicle Safety Standard No. 210 properly should be evaluated under subsection S4.3.1.1 for passenger seats of a new design being introduced in 1982 model Continental passenger cars. The applicability of subsection S4.3.1.1, rather than subsection S4.3.1.2, of Standard No. 210 was discussed between Ford personnel and you and Mr. R. Hitchcock of the Administration in Dearborn yesterday. At that time you were shown the new seat design and told why we believe it presents the possibility that a compliance tester might erroneously conclude that it should be evaluated against the criteria of subsection S4.3.1.2. If anchorage locations of these vehicles were to be evaluated under that subsection, rather than subsection S4.3.1.1, the location specifications could not be met.

The potential for misunderstanding arises, we believe, out of the fact that the bottom of the seat frame has connected to its inboard side a console support structure through which the inboard (buckle) end of the seat belt assembly passes. The console support structure is intended to provide a base for a "mini-console" that is to be installed on the inboard side of each half of a split bench seat. It is not a structural member of the seat frame and therefore, in our opinion, the fact that the inboard end of the belt would bear on the structure of the console support should not result in the anchorage locations being evaluated under the criteria of subsection S4.3.1.2 which apply only to installations in which the "...belt bears upon the seat frame...".

As may be seen from sketches provided by the Administration to contractors evaluating compliance to Standard No. 210 (Attachment A), the routing of the seat belts contemplated by the drafters of the standard as "bearing upon the seat frame" involve configurations wholly unlike that in question. Moreover, routing the inboard end of the seat belt assembly through a console support structure that moves with the seat frame has the salutary effect of helping to best position the belt and improving belt accessibility, no matter what position the seat is adjusted to. Ford could obviate all risk of misapplication of subsection S4.3.1.2 to the new seat design by physically modifying the console support so that the inboard end of the seat belt would not bear upon its structure, but only on the trim cover. For the reasons discussed above, we respectfully submit that we should not be required to do so.

Furnished for your reference are Attachment B which depicts the lower seat frame for the 1982 Continental, Attachment C, the console support and its cover, Attachment D, the untrimmed console support attached to the seat frame, and Attachment E, a finished seat assembly.

In order to avoid needless misunderstanding about the compliance of these seat belt assemblies to the anchorage location provisions of Standard No. 210 after production commences in mid-August, I should appreciate receiving the Administration's prompt confirmation of our analysis of the applicability of subsection S4.3.1.1 to the newly designed seat and console assembly, or your expression of any grounds on which the Administration may disagree with that analysis. Sincerely

Roger E. Maugh

Attachments

ID: nht88-2.79

TYPE: INTERPRETATION-NHTSA

DATE: 07/24/88

FROM: STEPHEN BORKOWSKI

TO: ERICA JONES -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATOR

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/10/88 TO STEPHEN BORKOWSKI FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 108

TEXT: This letter is request for the legality of my Bimmer Dimmer Safety Stop Light Concept. It utilizes various devices to govern the intensity of brake light brightness to indicate the degree of braking being applied to a vehicle. The goal of my concept is to lessen the chance of rear end collisions.

My concept was borne by a personal experience of mine in which I was able to avoid crashing into a car in front of me but four cars behind me were not able to escape damage as a result of multiple rear end collisions.

As a driver with 40 years of experience with a good driving record, I pondered over why or what I did wrong that put me into such a situation. My conclusion is that through the years I was lulled into a false sense of security. I realized there were co untless number of times when I was in a line of cars that were slowing down and the brake lights of the car or cars in front of me were lit even though we all were in the process of moving. Also, there are many times when drivers "ride" the brakes in hi gh density traffic. The activated stop light, therefore, does not indicate a drivers intent to actually come to a stop or the degree of his slowing down.

In the military as well as in other organizations, people are trained for emergency situations so that they will react in the correct manner, subconsciously. If drivers can learn to apply their brakes quickly and fully when they see a very bright red br ake light, I believe a false sense of security will not be developed and thus, hopefully, rear end collision can be reduced. I would like to pursue to research and develop my concept to test its validity and effectiveness.

I would appreciate any advice and suggestions that I should have in seeing how I could make it legal.

Sincerely,

ID: nht75-4.25

DATE: 08/12/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Daniel W. Lang

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 15, 1975, in which you inquire as to the applicability of the National Traffic and Motor Vehicle Safety Act and the regulations promulgated thereunder to your client, Star Vision, as a manufacturer and installer of see-through fiberglass replacement tops.

Section 108(a)(2)(A) prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. This means that the installation of the top by Star Vision must not take a vehicle out of compliance with Safety Standard No. 216 or any other applicable safety standard. You should note that the requirements of section 108(a)(2)(A) apply to modifications of vehicles following their sale to a purchaser for purposes other than resale. It appears from the literature accompanying your letter that the tops are not installed on vehicles prior to their first sale. If they are, then Star Vision is subject to the notification, remedy, certification, and recordkeeping requirements of section 108(a)(1).

There is no specific requirement for testing the replacement tops in order to determine compliance with Standard No. 216. However, since the Act prohibits knowingly rendering inoperative any vehicle or part of a vehicle in compliance with an applicable safety standard, Star Vision is under an obligation to test its product if it has reason to believe that installation of the tops will substantially degrade the performance of the vehicle roofs. If the company has no reason to believe that installation will affect the safety characteristics of the vehicle, it is not obligated to conduct compliance tests.

The replacement tops appear to be subject to Safety Standard No. 205, Glazing Materials (49 CFR 571.205). As a result, Star Vision must certify the tops in accordance with section 114 of the Act (15 U.S.C. @ 1403).

If the tops do not comply with Standards Nos. 205 or 216 or any other applicable safety standard, or if they contain a malfunction or defect related to motor vehicle safety, the company will be obligated by sections 151-60 of the Act to notify the purchasers of the kits and to remedy the defect or noncompliance without charge. In addition, section 108(c) of the Act provides that compliance with the Act will not exempt a person from common law liability.

We trust that this information will be of assistance.

SINCERELY,

July 15, 1975

James Gregory National Highway Traffic Safety Administration Attention: Office of Chief Counsel

Re: "Star Vision See Thru Tops"

This office represents Star Vision, a division of Etanter Enterprises, of Los Angeles, California.

Star Vision, as the enclosed literature indicates, sells a see-through fiberglass replacement top for most makes of automobiles, both domestic and foreign. Installation requires the cutting of a hole in the roof of a vehicle. The top may be purchased in a kit for home installation or installed by a Star Vision distributor who purchases tops from the company. Star Vision occasionally in the past has installed a top itself.

I would appreciate your consideration in answering the following questions:

1. Does @108 of the 1966 Act or @103 of the 1974 Act control the activities of the company;

2. Does the company have to test its product to determine whether or not it complies with Safety Standard #216;

3. If yes, how, where, and when can a product be tested in a manner acceptable under the law;

4. What responsibilities does the company have as a manufacturer only; as a manufacturer-installer;

5. What responsibility does the company have under the law to a do-it-yourself purchaser of a home installation kit?

The company is most anxious to be adequately informed about any standards or requirements that might affect their business. A prompt reply will help us greatly.

Daniel W. Lang Additional notes and hints to aid the installation of the STAR VISION rooftop kit.

Some cars come equipped with a beam across the roof under the headliner. Make sure that when you lay out the panel that you leave enough clearance about 1 1/2". If the panel supplied for your car should clear all beams or bars. If for any reason it does not, do not proceed with the installation, measure the space that is available, ship us back the panel that you have with the size that you need and we will ship you the proper size.

BEFORE cutting or laying out the area to be cut, carefully feel around the headliner for any obstructions. Be careful that your car does not have a double roof, such as some late model GM cars. (Illegible word) Be sure to leave room near the windshield, some cars such as some Toyotas will have about 3" of extra support so stay back from that as you will not make a clean installation.

Stay back from the sun visors but as far as possible to the front of the car. The Star Vision roof kit is most beneficial as far forward as possible than over or behind the drivers head.

We have installed our STAR VISION rooftop kit in almost every kind of car. If you have any problems with your particular car do not hesitate to contact us, we will research the problem free of charge and forward you the help that you seek.

BE SURE TO READ ALL THE INSTRUCTIONS CAREFULLY. PROCEED WITH CARE, PATIENCE AND PRIDE.

STAR VISION

TRANSPARENT ROOF TOP KITS

Your STAR VISION Transparent rooftop kit will add years of enjoyment to your driving pleasure. The installations is simple, the following instructions will help you achieve professional results.

Lay the piece of transparent panel flat on the roof of your car. DO NOT remove the protective paper until last. Place the material as for forward as possible with out interfering' with the windshield mouldings and framework. (usually about 4 to 6 inches.) Measure the distance on both sides to ensure an even fit. Now measure the distance from the edges left and right to ensure that the panel is centralized. Use some masking tape to prevent the panel from moving once the exact position has been arrived at.

Use a crayon pencil to trace out the outline of the panel. The line should be 3/8 inch away from the panel to leave room for the moulding. Drill four (4) 5/16" holes thru the roof of your car at each corner of the panel. Drill thru the headliner. Now get in the car and note the four holes. Using a single edge razor blade cut out the headliner using the holes as reference points. (NOTE some cars such as Porsche 914 and Fiat X 1/9 do not have a headliner)

NOTE: If your car has thin metal bars suspended across to hold up the headliner, cut them in the middle and remove them completely. On older cars the headliner may be brittle and subject to tearing, use extreme caution in those cases. Before going to them next step check out the total travel of your jigsaw blade, make sure that when you start to cut out the panel, that the blade will not tear into the remaining headliner. You can shorten the blade by merely breaking of the tip about one inch. Use a soft cloth on the side of the jigsaw foot that is going over the part of the roof that will remain so that it will not scratch the surface.

Using a Jig saw with a 32 tooth per inch blade cut out the outlined panel. When completed use masking tape to adhere headliner to the roof so when the molding is applied the headliner will neatly tuck away. Adhere only about 1/4 inch to the headliner and adhere the rest to the roof see illustration.

When installing the molding always use the wooden tools supplied to "Lip" over the rubber. Should your hand slip, these tools will not scratch the plexiglass or paint. Also use the blunt end of the tool to pry apart the locking slot to insert the "lock" use a weak soap solution to aid installation.

Now you are ready to install the panel. First install the rubber molding as in illustration #2. Note that the molding has two different sides to accommodate different roof thicknesses. Any side can be used for the panel. Install the molding with the "lock" side up. After the panel is in place install the "lock" to ensure leak proofing. Note that your supplied with a few extra inches of molding. Trim excess to fit, but leave extra inch. Compress this extra inch, this will expand and make a leakproof seal. If for any reason your top leaks, use the tool supplied to lift up the molding and apply any commercial windshield sealer under the molding. Wipe away any excess. Use non abrasive cleaners only!

(Graphics omitted)

Eatanter Products presents another quality product, completely new in style, and guaranteed to enhance the appearance of your car.

Our transparent 'STAR VISION' roof top kit adds a whole new feeling of freedom and comfort to your driving pleasure, experience all the skies and sights under any weather condition.

To complement the appearance of your automobile, we are offering several tints to suit your personal car.

NEW!

STAR VISION

TRANSPARENT ROOF TOP KITS

VOLVO

Ford

FIAT

CHEVROLET

Mazda

VW

LOW COST FUN!

EAST DO IT YOURSELF

your car or ?.....?

12" x 24" $ 43.95 15" x 30" size $ 64.95 15" x 40" size $ 74.95

SHIPPING NOT INCLUDED.

We accept BANKAMERICARD.

Easy Do-it yourself!!!

Complete illustrated instructions in every kit. Also HELPFUL hints & TOOLS.

Enjoy all the skies and sights under all weather conditions with our new 'STAR VISION' rooftop kit. Our 'STAR VISION' rooftop kit is a low cost practical method to add prestige and value to your automobile. Our 'STAR VISION' is a full time accessory unlike the $ 450 to $ 800 'moonroofs' and sunroofs that can only be used under ideal weather conditions. Our roofkit is in use ALL THE TIME.

On the coldest nights or downpour rainfalls, when other sunroofs and tops are unusable, our rooftop kit is in use. Our kit is a permanent installation. There are no parts to wear out, no pulleys to crank, only pure enjoyment of great views and a whole new world of new sights, previously unattainable. Our STAR VISION rooftop kit is available in SMOKE, BLUE, GREEN, AMBER and clear. The kits are designed for easy installation and come complete with a set of thorough instructions. The only tools that are not supplied are a sabre saw, and a hand-drill. Average installation time is two hours.

ID: aiam2614

Dear Mr. Long: Your letter of May 9, 1977, to the Federal Trade Commission, on behal of Mr. Edward L. Armstrong, Sr., Baltimore, Maryland, expressing his concern that new passenger car manufacturers will discontinue supplying spare tires, has been referred to this office of the National Highway Traffic Safety Administration, Department of Transportation, for additional consideration and reply.; We believe that Mr. Armstrong's concern deals with the recentl approved 'temporary use' spare tire that will be manufactured and used with some of the new 1978 model automobiles. the use of a temporary use spare tire is not a new concept. These tires have been used with compact sport cars, such as Firebird and Camaro, since 1967. The further development of these spare tires has been fostered by the desire if the U.S. automobile manufacturers to produce small, lightweight cars in furtherance of the national energy conservation program. I am sure that you have noticed the new 1977 models by some domestic automobile manufacturers are, in fact, smaller. Of course, the development of these smaller, lightweight, energy-efficient automobiles has resulted in a substantial reduction in usable car trunk space, and therefore, providing a second reason to develop a spare tire which takes less storage space than a conventional tire.; Since this spare tire is designed for use in the nation's highways, i must conform to the minimum performance requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 109, *New Pneumatic Tires - Passenger Cars*, for strength, endurance and high speed performance, For your information, we have enclosed a copy of this standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;