ID: 21883.ztv

Mr. Arman Asinmaz
611 Golden Harbour Drive
Boca Raton, FL 33432





Dear Mr. Asinmaz:





This is in reply to your e-mail of July 1, 2000, in which you ask "what color lights are permitted inside the headlight." We are unsure whether you are asking about the color of the headlamp beam or whether headlamps may incorporate a colored light source for a function other than headlighting, but we shall answer both questions.

The color of light from headlamps is specified by Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. A state may not prohibit or allow any color for a headlamp other than that specified by Standard No. 108. The Federal standard requires that the light emitted by headlamps be white and comply with SAE Standard J578c, Color Specification for Electric Signal Lighting Devices, February 1977. The SAE standard defines colors in terms of spectral coordinates, and the coordinates of white are such that near the boundaries the color white may be perceived as having a bluish cast. This bluish cast is especially noticeable in the light emitted by high intensity discharge headlamps.

Standard No. 108 also allows turn signal lamps and front side marker lamps to be incorporated "inside the headlight," to use your phrase, that is, to be in the same housing as headlighting sources. The color of light from these lamps is required to be amber. The amber light can be produced by an amber bulb emitted through a clear lens. Thus, amber is a color permitted "inside the headlight " (amber light can also be produced by the combination of a clear bulb and amber lens).

If you have further questions, you may e-mail Taylor Vinson of this Office as you did before

(tvinson@nhtsa.dot.gov).





Sincerely,

Frank Seales, Jr.
Chief Counsel

ref.108
d.8/11/00

ID: 77-3.33

TYPE: INTERPRETATION-NHTSA

DATE: 07/22/77

FROM: AUTHOR UNAVAILABLE; Joan Claybrook; NHTSA

TO: Hon. C. L. Ray - Governor of Washington; DIXY LEE RAY -- GOVERNOR OF WASHINGTON

TITLE: FMVSS INTERPRETATION

TEXT: The purpose of this letter is to express this agency's views on legislation recently enacted by the State of Washington, which appears to be preempted by Federal regulation of the same subject matter.

Specifically we understand that R.C.W. @ 46.37.320 was amended in May 1977 to require that motor vehicle "lighting devices"

". . . shall correlate with, and, so far as practicable, conform to the then current standards and specifications of the society of automotive engineers applicable to such equipment and to the headlamp standards established by the United Nations agreement concerning the adoption of approval and reciprocal recognition of approval for motor vehicle equipment and parts done at Geneva on March 20, 1958, as amended and adopted by the Canadian standards association (CSA standard D106.2): Provided, that the sale, installation, and use of any headlamp meeting the standards of either the society of automotive engineers or the United Nations agreement, as amended, shall be lawful in this state."

Under 15 U.S.C. 1392(d):

"Whenever a Federal motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard." [Emphasis added.]

Pursuant to 15 U.S.C. 1392(a) [Section 103(a) of the National Traffic and Motor Vehicle Safety Act of 1966] Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment (49 CFR 571.108), has been established, effective January 1, 1972, as the Federal standard for lighting devices both as original and replacement equipment on motor vehicles.

Although Standard No. 108 incorporates by reference many lighting standards of the Society of Automotive Engineers (SAE) it contains numerous qualifications of, and variations from, the SAE specifications. Even when Federal requirements and SAE specifications are identical, amendments by the SAE, which occur frequently, do not amend the corresponding Federal requirements. In short, that portion of the amendment to RCW @ 46.37.320 requiring compliance to SAE specifications does not establish requirements that are identical to those of Standard No. 108 and, in our opinion, are preempted by 15 U.S.C. 1392(d) and of no legal effect.

In addition, the United Nations Agreement, as amended by the Canadian Standards Association, permits the use of motor vehicle headlamps that are not of sealed beam construction and whose candlepower output may exceed 75,000. Further, it does not require that the headlamps be mechanically aimable. Standard No. 108, on the other hand, requires that headlamps on passenger vehicles be of sealed beam construction, imposes a limit of 75,000 candlepower on all but one type of headlamp, and specifies that all headlamps be mechanically aimable. Thus, the United Nations Agreement, as amended by the Canadian Standards Association, does not specify requirements for headlamps that are identical to those of Standard No. 108. This means that this part of the amendment to R.C.W. @ 46.37.320 is, in our opinion, also preempted by 15 U.S.C. 1392(d), and of no legal effect.

As a consequence, it is our conclusion that any person in Washington manufacturing for sale, selling, offering for sale, introducing or delivering for introduction in interstate commerce, or importing into the United States through the State of Washington any lighting equipment that does not conform to Standard No. 108, in reliance upon R.C.W. @ 46.37.320, could be subject to civil penalties for apparent violations of 15 U.S.C. 1397(a)(1)(A) in an amount up to $ 800,000 (15 1399(a)). There is no preemption, however, of your State's right to specify requirements for lighting equipment not currently included in Standard No. 108 (e.g. foglamps).

Section 1392(d) and the Act's preemptive effect have been invariably upheld. (See e.g. Chrysler Corp. v. Malloy, 294 F. Supp. 524 (U.S.D.C. Vt. 1968), Chrysler Corp. v. Tofany, 419 F.2d 499 (C.C.A. 2 1969)). We would also observe that the interpretation by an administering agency of its own statutes and regulations, has been viewed by courts as "of controlling weight." (Thorpe v. Housing Authority of Durham, 393 U.S. 268 (1969) quoted with approval in Chrysler Corp. v. Tofany, supra, at 512.)

We would appreciate the views of the State of Washington on this subject. Questions on it may be referred to the Chief Counsel of this agency, Joseph J. Levin, Jr.

ID: 02388.ztv

Ms. Collette Walsh
345 University Avenue
Belleville
Ontario K8N 5T7
Canada

Dear Ms. Walsh:

This is in reply to your fax of November 12, 2002, with respect to your fax requests of September 4 and 5, 2002, for interpretations of Federal Motor Vehicle Safety Standard No. 108. Im sorry to say that we have no record of receiving your earlier faxes.

The interpretation you requested on September 4 concerns the headlamp lens marking requirement of the standard for a Type H headlighting system, specifically S7.3.9(c). Paragraph (c) requires that "The face of letters, numbers, or other symbols molded on the surface of the lens shall not be raised more than 0.020 in. (0.5 mm) . . . ." It also requires that "The marking shall be molded in the lens and shall be not less than in. (6.35 mm) in size."

You asked whether "the lens marking (pattern) [must be] in the mold at the time of manufacture" and whether "an acceptable alternative [would be] . . . to laser etch the lens after the molding process." You explained that the marking would be indelible and not raised more than 0.020 in.

We have no information on the durability of laser etching on a headlamp lens but note that a laser etching would not be "molded into the lens" as specified in S7.3.9(c). Therefore, we do not regard your alternative as one that would comply with the standard.

The interpretation you requested on September 5 again involves lens marking. You asked whether it is acceptable to place the information required to be on a lens "on the top of the housing of a tail lamp or headlamp assembly" You added that "the marking would be clearly visible only if the trunk lid or engine compartment lid was open." This would not be acceptable. The information required to be on a lens must be placed on the lens.

If you have further questions, you may call Taylor Vinson of this Office at 202-366-5263.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
12/10/02

ID: 16613.ztv

Mr. Yanichi Yoshimoto
Deputy General Manager
Technical Administration Dep't.
Koito Manufacturing Co., Ltd.
Shizuoka Works
500,Kitawaki
Shmimzu-Shi, Shizuoka-ken
Japan

Dear Mr. Yoshimoto:

This is in reply to your letter of November 28, 1997, to the Associate Administrator for Safety Performance Standards, asking for an interpretation of the humidity test requirements of Federal Motor Vehicle Safety Standard No. 108. For your future reference, requests for interpretation should be addressed to the Chief Counsel.

After a humidity test, paragraph S7.4(h)(6) of Standard No. 108 requires the inside of a headlamp to "show no evidence of delamination or moisture, fogging or condensation visible without magnification." You ask whether moisture is nevertheless permissible if it is located in an area of the interior where it cannot affect the photometric performance of the headlamp.

The requirement is absolute: no moisture that is visible without magnification is permitted on the interior of a headlamp after the humidity test, whether or not it is located in an area related to the photometric performance of the headlamp. Thus, moisture is not permissible in the situation shown in your Case 1 (moisture on the lens area of the turn signal lamp portion of a single compartment lamp) or your Case 2 (moisture in a location outside the photometric effective area of the headlamp).

Sincerely,
John Womack
Acting Chief Counsel
d.1/8/98
ref:108

ID: nht90-2.72

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 3, 1990

FROM: MARGRET SCHMOCK -- ROBERT BOSCH GMBH

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-25-90 TO MARGARET SCHMOCK FROM STEPHEN P. WOOD; (A35; VSA 103(d)) TEXT:

Could you please be so kind and answer me some questions about the FVMSS 108 and the CAC Title 13, Article 9.

The amended FMVSS 108 says: S7.7.3 When a headlamp system is tested in a laboratory, the range of its vertical aim shall not be less than +/- 4 degrees ... S7.7.4 When a headlamp system is tested in a laboratory, the range of its horizontal aim shall not be less than +/- 2.5 degrees ... CAC says: The range of adjustment from the specified aim the lamp shall be at least +/- 4 degrees in both the vertical and horizontal directions. So my questions are: Does this mean that our headlamps still must have an adjustment range of +/- 4 degrees in horizontal direction, although the FMVSS 108 has been changed? Is it possible that the CAC meanwhile has been amended according to the FMVSS 108? Is it true that the CAC doesn't differ between auxiliary lamps and headlamps (in opposite to the FMVSS 108 that is only valid for headlamps)? Thanking you very much in advance for your actions.

ID: aiam2633

Dear Mr. McLaine: This is in reply to your letter of June 28, 1977, to Mr. Vinson of thi office, asking for our comments on the flashing of ambulance headlamps for signaling purposes. You enclosed a copy of a Bulletin dated June 27, 1977, that New Jersey recently sent to its Inspection Stations advising rejection of ambulances equipped with headlamp flashing devices.; Paragraph S4.6(b) of Federal Motor Vehicle Safety Standard No. 10 *Lamps, Reflective Devices, and Associated Equipment,* requires that lamps other than turn signals, hazard warning signals, and school bus warning signals be steady-burning in use, 'except that means may be provided to [automatically] flash headlamps . . . for signaling purposes.' The purpose of the exception was to allow continued use of automatic flashing devices in jurisdictions where it was permitted when the standard was adopted, for without the exception manufacture and sale of vehicles so equipped would have violated the National Traffic and Motor Vehicle Safety Act. The exception provided by S4.6(b) has a preemptive effect only in that a State cannot forbid the sale and registration of a vehicle equipped with a flashing device, but there is no restriction on a State's authority to forbid the use of such mechanisms when it deems it in the interests of traffic safety to do so.; Thus, we have no objection to New Jersey's Bulletin of June 27, 1977. Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: 86-3.18

TYPE: INTERPRETATION-NHTSA

DATE: 05/08/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M. Iwase

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. M. Iwase Manager, Technical Administration Department Koito Manufacturing Co., Ltd. Shizuoka Works 500, Kitawaki Shimizu-shi, Shizuoka-ken Japan

Dear Mr. Iwase:

This is in reply to your letter of March 28, 1986, asking about the permissibility under Motor Vehicle Safety Standard No. 108 of two different designs of supplementary parking lamp systems.

In your first design, the vehicle headlamps on each side are bracketed by two parking lamps, the one closest to the vehicle edge termed "obligatory" and the inner one "supplementary." Both are designed to comply with Standard No. 108. Paragraph S4.1.3 of Standard No. 108 permits the installation of supplementary lighting equipment as long as it does not impair the effectiveness of the lighting equipment that Standard No. 108 requires. From the information you have provided us, it would not appear that the supplementary parking lamps designed to meet Standard No. 108 would impair the effectiveness of the headlamps, turn signal lamps, or "obligatory" parking lamps.

In your second design, the "obligatory" parking lamps remain outboard of the vehicle's headlamps but a single supplementary parking lamp is installed on the centerline of the vehicle. This lamp will also be designed to comply with the parking lamp requirements of Standard No. 108. From your drawing, it appears that this lamp extends from the centerline almost to each headlamp. This supplementary lamp is also subject to the same restrictions of S4.1.3. Although the design is unusual, the low photometric output associated with parking lamps should insure that this lamp does not impair the effectiveness of Standard No. 108's required lighting equipment.

I hope that this answers your questions.

Sincerely, Original Signed By

Erika Z. Jones Chief Counsel

Air-Mail (1/2)

Ms. Erika Z. Jones Date: Mar. 28, 1986 Chief Counsel Ref No.86.03.28.01 National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Re: Supplementary Parking Lamp

Dear Sir:

Many thanks for your kind consideration which you have extended to us.

We would hereby ask for your kind advice to the subject matter.

In S4.1.1 and Attached Table III of FMVSS No. 108, passenger cars of less than 80 inches overall width are required to be equipped with at least one(1) parking lamp on each side of the vertical centerline.

According to this prescription, a supplementary parking lamp is being equipped on passenger cars in addition to an obligatory parking lamp which is specified in the FMVSS No. 108.

We would hereby ask you to provide us with your kind advice as to whether such a supplementary parking lamp as shown in Case-A or Case-B could be accepted or not under the FMVSS No. 108.

"INSERT FORMULA"

Supplementary Parking Lamp Headlamp obligatory Parking Lamp specified in FMVSS No. 108

Note: 1. A supplementary parking lamp will be installed on each side of the vertical centerline and located adjacent and inner to headlamps.

2. This supplementary parking lamp will be designed to comply with the requirements of performance specified in FMVSS No. 108.

Atten.: Ms. Erika Z. Jones Date : Mar. 28, 1986

Case-B:

Supplementary Parking Lamp Headlamp obligatory parking Lamp specified in FMVSS No. 108

Note: 1. A supplementary parking lamp will be installed on the centerline of vehicle.

2. This supplementary parking lamp will be designed to comply with the requirements of performance specified in FMVSS No. 108.

Upon your kind review to this matter, your kind and prompt reply would be greatly appreciated.

Yours very truly,

M. Iwase, Manager Technical Administration Dept. KOITO MANUFACTURING CO., LTD. Shizuoka Works

ID: nht90-3.24

TYPE: Interpretation-NHTSA

DATE: July 19, 1990

FROM: Guy Dorleans -- Manager, Regulatory Affairs Department Division Eclairage-France

TO: P. J. Rice -- Chief Counsel, NHTSA

TITLE: Ref: gd 862 M90

ATTACHMT: Attached to drawing (graphics omitted); Also attached to letter dated 9-12-90 from P.J. Rice to M.G. Dorleans (A36; Std. 108)

TEXT:

Valeo Lighting, manufacturer of car headlamps, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108," Lamps, Reflective Devices and Associated Equipment ."

In its edition of May 9th 1989, the Federal Register Vol. 54 N 88 allows the use of lamps with moving reflectors. This possibility is an important step in the direction of world harmonization, since this concept is widely used in Europe and in Japan. V aleo lighting is determined to use this possibility as soon as possible, and in this purpose has studied the:

"Aiming concept for headlamps. Solution 3." The attached documents explain how our engineers have solved the problems of providing the aiming feature on each lamp, and summarize the instructions which will be written in the maintenance book of each car. These instructions will emphasize on the nov elty in using SAE J602 headlamp external aimers.

We would greatly appreciate if you would kindly treat all the drawings as confidential, because they involve our own idea for development of on-vehicle aiming which has something related to a patent application.

We would ask you to provide us with your confirmation of our interpretation of the Standard 108 in this matter. We are ready to demonstrate NHTSA a working prototype if you deem it necessary.

Upon your kind review to this matter, your promptly reply would be greatly appreciated.

Enclosure

July 19th, 1990

Aiming concept for headlamps. Solution 3. 1) Description of the headlamp.

The lens has 3 aiming pads on which can be attached a mechanical aiming device as per SAE J602 Oct 80. The housing contains a movable reflector, a horizontal aiming feature and a vertical aiming feature. These parts and the fixed point are designed so that there is no possibility to modify

the horizontal aim when aiming vertically, and vice versa.

The vertical aiming feature consists in two combined coaxial screw and nut, hereafter referred to as AV and BV:

AV is used on the assembly lines of the lamp manufacturer and also on the assembly lines of the car manufacturer. While the aiming plane is placed in its designed position, the low beam is photometrically aimed and the fiducial mark of BV is set to zero . The rotation of AV achieves this initial aim, while BV can not move. Then the cap is inserted. This cap can not be removed using simple tools. The repair shops and the dealers have the necessary equipment to remove the cap. AV is also the aiming f eature which must be used to repair the vehicle after accident damage.

BH is the aiming nut which must be used during normal reaim operations

The horizontal aiming feature is so designed that when a torque is applied to BV, AV rotates with the same angle. In other terms, the friction torque between BV and AV is far bigger than the friction torque between AV and the housing.

The horizontal aiming feature, consisting of a screw AH and a nut BH, uses basically the same principle as its vertical counterpart.

Both vertical and horizontal reaim features are permanently attached to the headlamp.

2) Vertical reaim.

A commonly available mechanical aimer must be used. This kind of aimer has been used in the US since the early '50s, and are available in each repair shop or dealers. Among them, the Hopkins B4A is a good example of easy-to-use external aimer, with aer odynamic headlamps capability thanks to its articulated vacuum cup and universal extender.

The ground surface must be substentially flat. The car must fulfill the requirements of SAE J 599 May '81.

2 1) Set to zero the fiducial mark on BV

2 2) Attach calibration fixtures to the aimers, place aimers at the centerline of each wheel on one side of the vehicle. Level each unit by adjusting screw on each calibration fixture.

2 3) Transfer the reading indicated on the horizontal dial to the floor level dial on each aimer. Set the "vertical" dial of each aimer at zero.

2 4) Remove calibration fixture

2 5) Check that universal extenders are set to the values engraved on the lens, and attach each mechanical aimer to its designated lamp. Check the sight openings face each other.

2 6) Rotate the "vertical" dial of each aimer intil the bubble is centered

in the vial. Tranfer to BV the value the "vertical" dials indicate for each side of the car.

3) Horizontal reaim.

3 1) The horizontal dials and the BH nuts must be set to zero.

3 2) Rotate each "horizontal" dials until the the split image of each aimer are aligned.

3 3) Respective of the side, transfer the readings of the aimers to the BH nuts.

4) After accident damage.

This procedure is not part of the normal maintenance of the car. It involves tools which are normally owned by dealers or repair shops. The floor must be rigid, flat and horizontal The special tools allow to remove the cap, thus giving access to the A H and AV screws. The BH and BV nuts being securely maintained in zero position, the operator:

4 1) Checks the angles of the aiming plane 4 2) Uses a screen at 7.6 m, or a fractional balance aiming machine, or a pair of string aimers.

Guy Dorleans Valeo Lighting.

Enclosure: 1

(Drawing attached, graphics omitted)

ID: 1982-1.36

TYPE: INTERPRETATION-NHTSA

DATE: 03/30/82

FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL

TO: ARMOND CARDARELLI -- DIRECTOR, SAFETY EQUIPMENT SERVICE AMERICAN ASSOCIATION OF MOTOR VEHICLE ADMINISTRATORS

TITLE: NOA-30

TEXT: Dear Mr. Cardarelli:

The purpose of this letter is to call your attention to a practice of the AAMVA which we believe should be reviewed.

Recently we received copies of Certificate of Equipment Approval Nos. 800643, 800641, 800642, and 800193, rendered "Candle Power Inc." of Rockville, Maryland. In each instance, the Certificate describes the item as a "Motorcycle Headlamp Unit," specifies its use "on Motorcycles" and states that the unit is "in compliance with the United States Federal Motor Vehicle Safety Standard No. 108." It is the implications of AAMVA's certification of compliance that we question.

First of all, we believe that a legal certification of conformance with Federal motor vehicle safety standards can be made only by the manufacturer of the unit. We believe that the role of the independent test laboratories is to provide data indicating compliance upon which a manufacturer can base its certification, but that a single test report cannot alone establish certification. It has been the policy of this agency never to judge conformance on the basis of test results of a single lamp because of the multitude of test points to be met and variables in the manufacturing process and the quality control procedures of the individual manufacturers. Indeed, the agency has said that test failures will not lead to a noncompliance determination if they are "random" or "occasional." We therefore believe it is inappropriate for the AAMVA Certificate to state that a lamp conforms to Standard No. 108 when that statement is made on the basis of a single test report submitted by the manufacturer and when it is intended to cover production for five years after the issuance of the Certificate. On the other hand, it would not be inappropriate for the Certificate to state that the test report showed the unit in compliance with appropriate SAE requirements.

P2

With respect to Candlepower's headlamps, they are unsealed units which we believe to be intended primarily for use on passenger cars but which may also meet the requirements of J584 for motorcycle use. In our litigation presently pending against importers of these headlamps, we are taking the position that the manufacturer, with knowledge of the capacity for dual use of these headlamps, must certify conformance (in the words of 15 U.S.C. 1413) "with all applicable safety standards" which means standards applicable to both passenger car and motorcycle headlamps. We do not approve of a split certification whereby a headlamp capable of two end uses is certified only for one. We therefore view the AAMVA statement of compliance with Standard No. 108 inappropriate from this standpoint as well. On the other hand, it would not be inappropriate for the Certificate to state that the unit complies with SAE J584.

We request that AAMVA review its practice with regard to statements of Federal conformity on its approval certificates and that you provide us with its view.

Sincerely,

ID: nht88-3.42

TYPE: INTERPRETATION-NHTSA

DATE: 09/12/88

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: GEORGE ZIOLO -- DOT PAPERWORK PROCESSOR

TITLE: NONE

ATTACHMT: LETTER DATED 04/20/88 TO ERIKA Z. JONES FROM GEORGE ZIOLO RE HEADLAMP COMBINATIONS-REQUEST FOR CLARIFICATION, FMVSS 108; OCC - 1932;

TEXT: Dear Mr. Ziolo:

This is in reply to your letter of April 20, 1988, asking about the acceptability under Safety Standard No. 108 of modifying imported vehicles so that they are equipped with two Type 2D1 and two Type 1C1 headlamps. You have been informed by the agency's Office of Vehicle Safety Compliance that this is impermissible "because they are 'nonconforming' 'headlight systems'." You disagree because you believe that the minimum requirements of the Standard are satisfied by the Type 2D1 lamps, and that "S4.4 app ears to permit such a combination."

Paragraph S4.4 is not applicable to the situation you present as it refers to combinations of lamps serving different functions; in your discussion, the lamps serve the identical function of headlighting. Given the fact that the Type 2D1 sealed beam 7" diameter headlamps fulfill the headlighting requirements of the Standard, your question must be viewed as whether a supplement to the headlighting system is permissible under Standard No. 108.

Paragraph S4.1.3 of Standard No. 108 permits the addition of nonrequired lighting equipment provided it does not impair the effectiveness of the equipment that the standard requires. The two Type 1C1 5 3/4" diameter sealed beam lamps in a four lamp head lighting system form the major portion of an upper beam headlighting system. The two Type 2D1 lamps in a two lamp headlighting system form the whole of an upper beam headlighting system. Thus, a vehicle furnished with the systems you posit would be equ ipped with more than one upper beam headlighting system. The Type 2D1 system must be designed to conform to the photometric requirements of SAE Standard J579c DEC79 "Sealed Beam Headlamp Units for Motor Vehicles." The SAE Standard establishes at two tes t points, H-V and 4 D-V, maximum allowable candela of 75,000 and 5,000 respectively for each Type 2D1 headlamp. This means that the maximum allowable candela for headlighting systems at these test points is 150,000 and 10,000 candela. The Type 1C1 head lamps will also be designed to conform to SAE J579c. Corresponding maxima at test points H-V and 4 D-V for Type 1C1 systems are 60,000 and 5,000. Thus, a vehicle equipped

with the lamps you have described could emit a total of 270,000 candela at test point H-V (when only 150,000 is permitted), and 20,000 at 4D-V (when only 10,000 is allowable).

Agency research has shown that candela readings in excess of 150,000 greatly increase the potential for glare with little increase in seeing ability. This glare would be visible both to the driver of an oncoming car, and the driver of the modified vehic le itself through creation of a "veiling" glare. The addition of the Type 1C1 headlamps would therefore impair the effectiveness of the Type 2D1 headlighting system, and is forbidden by S4.1.3.

We appreciate your interest in safety.

Sincerely,