ID: aiam2930

Dear Mr. Ratz: This is in reply to your letter of December 8, 1978, asking whether th front and rear clearance lamps on your Model 870 Urban transit coach comply with Federal Motor Vehicle Safety Standard No. 108.; The front clearance lamps on the Model 870 are combined with the tur signal lamps, side marker lamps, and side reflex reflectors. The units are located 'on line with and just outboard of each rectangular headlamp,' with lens center 32 inches above the road surface, at a point that appears to be at the vehicle's overall width. The rear clearance lamps are combined with the stop lamps and rear side marker lamps, their horizontal center lines 64 inches above the road surface, at approximately the vehicle's overall width. Front and rear identification lamps are mounted at the top of the vehicle.; The general rule expressed by Table II of Standard No. 108 is tha clearance lamps must be mounted 'to indicate the overall width of the vehicle ... and as near the top thereof as practicable.' But a partial exception is provided by S4.3.1.4.: When the rear identification lamps are mounted at the extreme height of the vehicle, rear clearance lamps need not meet the requirement of Table II that they be located as close as practicable to the top of the vehicle.'; This means that the mid-body location of the rear clearance lamp i acceptable since the rear identification lamps are at the extreme height of the vehicle. But the exception does not extend to the front clearance lamps. While Standard No. 108 allows the manufacturer to determine what location is 'as close as practicable to the top of the vehicle', there will be instances when the overall width of the vehicle will not be indicated by the highest location. In such instances the best location will be the one that most closely approximates the intent behind the requirement - to indicate the overall width.; Specifically with reference to the Model 870, it appears to us that th close proximity of the combination lamp to the headlamp may result in the effectiveness of the clearance lamp being impaired by the brightness of the headlamp, and that the most practicable location sufficiently indicating the overall width of the vehicle, would be at the outer edges of the body directly below the windshield.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam4827

Dear Mr. Bethurum: Your letter of December 14, 1990, to the 'U.S National Highway Safety Commission' for reply. Our agency, the National Highway Traffic Safety Administration, is the Federal agency responsible for establishing and enforcing the Federal motor vehicle safety standards. Your client, Mr. E.D. Farnsworth, has asked about 'when and how side lights adjacent to the main head lights came to be first used with head lights on automobiles.' You have, in turn, asked to be apprised of the regulations which govern new headlamp designs for automobiles and other motor vehicles. The Federal regulations that apply to motor vehicle headlamps are found in 49 C.F.R. 571.108, Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. The current version of the CFR volume (Parts 400 to 999) containing that standard is updated to October 1, l990. We are uncertain as to what you mean by 'side lights adjacent to the main head lights'. Standard No. 108 requires amber or white parking lamps on the front of passenger cars and other types of motor vehicles whose overall width is less than 80 inches, amber turn signal lamps, and amber front side marker lamps. Other types of lamps that are sometimes found on the front, and on the side at the front, are fog lamps and cornering lamps. They are not required by Standard No. 108, and are permissible as long as they do not impair the effectiveness of the lighting equipment required by the standard. Standard No. 108, which has been in effect for passenger cars since January l, l969 (the mandatory requirement for a side marker lamp replaced the earlier provision giving manufacturers a choice of lamp or reflector effective January 1, l970), has always prescribed lamp location in general terms. Thus, parking lamps and headlamps are to be installed 'at the front' and 'as far apart as practicable' (Table IV of Standard No. 108). Similarly, turn signals are to be located 'at or near the front' and 'as far apart as practicable.' Amber side marker lamps are to be on the side but placed 'as far to the front as practicable.' Because Standard No. 108 does not otherwise specify lamp location, we surmise that the head lamp and adjacent side lamp relationship to which you refer resulted from the choice of the vehicle manufacturer within the overall general parameters of the Federal specifications. If you have further questions, we shall be pleased to answer them. Sincerely, Paul Jackson Rice Chief Counsel;

ID: nht90-3.19

TYPE: Interpretation-NHTSA

DATE: July 13, 1990

FROM: J.P. Ravier -- R&D Director, Valeo; Guy Dorleans -- Regulatory Affairs Manager, Valeo

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

TITLE: Re Ref: 861 M 90

ATTACHMT: Attached to letter dated 12-13-90 to M.J.P. Ravier from Paul Jackson Rice (A36; Std. 108); Also attached to letter dated 7-30-90 to J.P. Ravier from Kathleen DeMeter

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 Equipmen t."

In its issue of May 9th 1989, the Federal Register Vol. 54 No 88 in paragraph S.7.7.5.2. allows the use of a Vehicle Headlamp Aiming Device for 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. Valeo lighting is determined to use this possibility as soon as possible, and in this purpose has studied the:

" Aiming concept for headlamps. Solution 2." 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.

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.

After our demonstration of a working prototype to NHTSA personnel on June 29th, we would ask you to provide us with your confirmation of our interpretation of Standard 108.

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

Enclosure

July 13th, 1990

Aiming concept for Headlamps. Solution 2. 1) Description of the headlamp.

The lamp is composed of a lens with no aiming pads, a housing bolted on the car body and a reflector which moves independently inside the housing. The lens has a clear area which allows to observe a bubble spirit level fixed on the reflector. This cyli nder has its axis parallel to the longitudinal axis of the vehicle.

The horizontal aiming feature consists in two combined coaxial screws and nut, hereafter referred to as AH and BH. The cap which gives access to the AH screw can be removed by using simple tools. The clearly legible outer surface of BH has graduations representing less than .38 degrees and a total amplitude of .76 degrees to the left and .76 degrees to the right.

2) Vertical reaim.

On the assembly lines of the lamp manufacturer, each lamp is individually aimed thanks to photometric means. The car manufacturer, on its assembly lines, also aims each lamp with photometric means. The position of the seating plane of the housing is ch ecked carefully, and each bubble vial is set to zero and then blocked for life in this position by the lamp manufacturer. To reaim vertically:

2 1) Check the car fulfills the specifications of SAE J 599 May '81. 2 2) Measure the longitudinal angular value of the floor slope. Note the figure and its orientation, positive or negative. 2 3) Operate the aiming control until the bubble has slid by an equal number of fiducial marks in the appropriate direction. 2 4) Do the same for both lamps.

3) Horizontal reaim.

On the assembly lines of the car manufacturer, provisions are taken so that the zero position of the BH nut coincides with the specified aim. To reaim horizontally: Rotate the BH nuts until their fiducial mark coincides with the zero of their body counterparts.

4) Vertical reaim after accident dammage.

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 of their premices must be rigid, flat and substantially horizontal.

4 1) Rotate the vertical aiming control until the bubble comes to the zero position. If, after severe dammage, the bubble can not reach the origin of the scale because the stroke of the aiming screw is too small, place shims between the body panel and t he housing.

5) Horizontal reaim after accident dammage.

The remarks of the preceeding paragraph also apply.

5 1) Set to zero the fiducial mark on BH, right hand side. 5 2) Remove the bulb service bonnets, and attach the string aimer to the reflector, as shown on section AA of attached documents. No mispositionning can happen, because the aimer for t he left hand lamp cannot fit into the right hand lamp.

5 3) Unroll the string from its right hand reel and affix it to the opposite string aimer. 5 4) Tightly prevent the BH nut from rotating, remove the cap 5 5) Operate the right hand screw AH until the string comes to the zero of

the fiducial marking on the right hand aimer. 5 6) Symetrizing the instructions, do the same for the left hand lamp, remove aimers, reinstall the bonnets.

It is important to note that this example does not exclude the use of conventionnal means, like the aiming screen or even the more modern fractionnal balance aiming machines. Like for vertical reaim after dammage, shims may be necessary if the stroke of the AH screw does not suffice.

Attachments

Drawing of string aimer left hand unit solution 2. (Graphics omitted.)

Drawing of horizontal aiming feature solution 2. (Graphics omitted.)

ID: 2644o

C.D. Black, Engineering Manager
Legislation, Compliance
Product Development
Jaguar Cars, Inc.
600 Willow Tree Road
Leonia, NJ 07605

Dear Ms. Black:

This is in reply to your letters of June 8 and October l7, 1987, with respect to an electrically-operated headlamp leveling system that Jaguar intends to offer on passenger cars beginning with the l989 model year. Such a device is required by EEC regulations. You have informed us that the system does not allow lamps to be adjusted above the "zero" position, only downward to compensate for rear end loading of the vehicle. There is no provision for automatic return to the "zero" position when the engine is turned off. Further, there will be no indication to the driver from the vehicle instrumentation that re-aim is necessary when the headlamps are adjusted downward. You have concluded, for the six reasons given in your letter of June 8 that "no aspect of FMVSS l08 . . . is contravened by this proposed installation."

The sole restriction that Standard No. l08 imposes upon an item of motor vehicle equipment not covered by the standard but which a manufacturer wishes to add to a vehicle as original equipment is that it not impair the effectiveness of the lighting equipment that the standard requires (S4.l.3). If a manufacturer concludes that the unrequired equipment would not impair the effectiveness of the required lighting equipment, it may certify that the vehicle complies with Standard No. 108. Based on our understanding of your system, it does not appear to impair the effectiveness of the required equipment. However, we urge you to consider the possible consequences if the driver forgets to return the system to the "zero" position from either of the two adjustment positions. These possibilities are a concern because the system does not automatically return to that position, and no warning is provided to the driver that the headlamps are not in their original design position. On the other hand, if properly used, the system could enhance headlighting effectiveness by ensuring that the headlamp provides the same lighting performance under all conditions of vehicle load.

We hope the information is helpful.

Sincerely,

Erika Z. Jones Chief Counsel ref:l08 d:2/11/88

ID: 1984-1.9

TYPE: INTERPRETATION-NHTSA

DATE: 02/02/84

FROM: AUTHOR UNAVAILABLE; Barry Felrice; NHTSA

TO: Yamaha Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Michael J. Schmitt, Counsel Yamaha Motor Corporation, USA 6555 Katella Avenue Cypress, CA 90630

Dear Mr, Schmitt:

This is in response to your letter asking for an interpretation, of the permissibility of using two type 2A1 headlamps mounted symmetrically disposed about the vertical centerline of the motorcycle.

Federal Motor Vehicle Standard (FMVSS) No. 108, "Lamps, Reflective Devices, and Associated Equipment states in S4.1.1.34 that a motorcycle may be equipped with one of the following headlamp systems, one of which is the "A" type neadlamp system described as follows:

Type 1A1 or Type 1A . . . . 1 lamp and either Type 1A1 or Type 2A . . . . 1 lamp

The standard is specified this way because the 2A1 lamp is a lower beam lamp and the 1A1 is an upper beam lamp. While the 2A1 lamp does have an "upper beam", photometrically it provides only "fill-in" light. The 1A1 lamp provides the high output upper beam. It is not possible to achieve safe upper beam light using only the 2A1 lamp, regardless of how many are used. Therefore, your proposed headlighting application would not be permitted by FMVSS No. 108.

Sincerely, Barry Felrice Acting Associate Administrator for Rulemaking

November 21, 1983

Mr. Charles Kaehn Head, Lighting and Visibility Group National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

RE: FMVSS 108

Dear Mr. Kaehn,

Yamaha would like to incorporate a headlamp system featuring two type 2A1 headlamps. The lamps will be symmetrically disposed about the vertical centerline of the motorcycle. Is such a system permissible? We appreciate your assistance and response in this matter.

Sincerely,

Michael J. Schmitt Counsel

MJS/ts

cc: Shin Kubono

ID: 1984-4.9

TYPE: INTERPRETATION-NHTSA

DATE: 12/19/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: American Honda Motor Co., Inc. -- Brian Gill, Manager, Certification Dept.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Brian Gill Manager, Certification Department American Honda Motor Co., Inc. P.O. Box 50 Gardena, California 90247

This is in reply to your letters of October 8 and 26, 1984, with respect to a proposed motorcycle headlighting system. In this design, two bulbs, each with its own reflector, are combined in a single housing. You have informed us that both bulbs are illuminated when the headlamp is on and together provide "the proper photometric output for low and high beams." Further, each reflector is adjustable individually, horizontally and vertically. The lamp has been designed to comply with the requirements of SAE J584.

Your contemplated design is acceptable for motorcycles; SAE J584 refers to a "light source or sources" ( see "At-Focus Tests") . However, a two-bulb design in a single housing would have to be designed to meet J584's requirements for a single headlamp including maximum output of 75,000 cd. Further, Standard No. 108 permits independently aimable reflectors, or aim by moving the entire assembly whichever you prefer. All that is required is that the unit meet SAE J566 Headlamp Mountings, January 1960.

I hope that this answers your questions.

Sincerely, Frank Berndt Chief Counsel

October 26, 1984

Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh Street, S.W. Washington, D. C. 20590

Dear Sir:

This is in regard to the motorcycle headlight system which I described in my letter of October 8th.

Since that time I have met with Mr. Richard Van Iderstine, Safety Standards Engineer in the Office of Vehicle Safety Standards to discuss this headlight. The following information is provided as a result of that discussion:

1. The device in question is a single motorcycle headlight.

2. The headlight complies with SAE J584, April 1984 as specified in Federal Motor Vehicle Safety Stadard (FMVSS) number 108.

We would appreciate your cooperation in reviewing this material and your confirmation that the headlight complies with FMVSS 108 requirements. Please call me at (213) 327-8280, extension 2198 if you have any questions or comments.

Yours truly,

AMERICAN HONDA MOTOR CO. , INC.

Brian Gill Manager Certification Department BG/jb

October 8, 1984

Office of the General Council NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Department of Trasportation 400 Seventh Street, S.W. Washington, D.C. 20591

Dear Sir:

Enclosed are drawings of a headlight system designed for use on certain 1985 model year motorcycles. We would like to confirm that this design complies with the requirements of FMVSS 108.

Both bulbs are illuminated ay time that the headlight is switched on and together provide the proper photometric output for low and high beams. Each reflector is adjustable individually both horizontally and vertically.

Mr. Medlin of the Crash Avoidance Division of NHTSA told me on October 5th that you are currently considering a similar device but with some significant differences, and that I should bring our motorcycle headlight system to your attention as soon as possible.

I will try to contact Mr. Vincent by telephone on October 10th to discuss this matter further.

Yours truly,

AMERICAN HONDA MOTOR., INC.

Brian Gill Manager Certification Department BG:lw Enclosure Insert,two charts

ID: aiam3123

Dear Mr. Finn:#This responds to your letter requesting a interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. Specifically, you asked whether a 'barely discernible' light on the headlamp control, which is activated when the ignition is turned to the 'on' position, complies with the requirements of the standard. Under S5.3.3, 'any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable ....' Since the light in question is not activated when the headlamps are activated, it need not meet the intensity requirements of S5.3.3.#Sincerely, Frank Berndt, Chief Counsel;

ID: aiam3122

Dear Mr. Finn:#This responds to your letter requesting a interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. Specifically, you asked whether a 'barely discernible' light on the headlamp control, which is activated when the ignition is turned to the 'on' position, complies with the requirements of the standard. Under S5.3.3, 'any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable ....' Since the light in question is not activated when the headlamps are activated, it need not meet the intensity requirements of S5.3.3.#Sincerely, Frank Berndt, Chief Counsel;

ID: GF007944

The Honorable Russell D. Feingold
United States Senate
Washington, DC 20510-4904

Dear Senator Feingold:

Thank you for your October 7, 2004, letter on behalf of your constituent regarding bumper and lighting regulations. Specifically, your constituent is concerned about vehicle compatibility and the height of bumpers and lamps on certain vehicles. I appreciate the opportunity to address your constituents concerns.

The National Highway Traffic Safety Administration (NHTSA) issues standards and regulations applicable to new motor vehicles and motor vehicle equipment. NHTSA regulates bumpers on passenger cars (49 Code of Federal Regulations (CFR) Part 581), but not on multipurpose passenger vehicles (sport utility vehicles), because such regulation could significantly reduce their utility. For vehicles subject to our bumper standards, the bumper must be located at the height of not more than 20 inches above ground.

We note that the agency is very concerned with vehicle compatibility in multi-vehicle crashes. Bumper height is one of the factors affecting vehicle compatibility. In June of 2003, NHTSA published a report describing the scope of the safety problem represented by vehicle incompatibility and outlined strategies the agency plans to pursue in improving vehicle compatibility. See http://www-nrd.nhtsa.dot.gov/departments/nrd-11/aggressivity/IPTVehicleCompatibilityReport/. We have enclosed a copy of the report for your information. Currently, NHTSA and its global partners are conducting research to determine the best regulatory approaches in the area of vehicle compatibility. NHTSA is also working with vehicle manufacturers to minimize the effects of vehicle incompatibility and to develop consumer information related to this issue.

With respect to headlamp location, the Federal lighting standard (49 CFR 571.108) requires that the headlamps for all new vehicles be located between 22 inches and 54 inches above the road surface. Subsequent reinstallation of headlamps at a different height by a dealer or a repair business is also prohibited.

We note that the bumper and headlamp height issues raised by your constituent may not be the product of improper installation of those items, but instead may stem from raising or otherwise altering the vehicle suspension system. While this agency does not regulate suspension alterations, some states may do so. Accordingly, we suggest that your constituent contact the Wisconsin Department of Transportation, Office of General Counsel at (608) 266-8810 or ogc.exec@dot.state.wi.us to ascertain Wisconsin regulations pertaining to vehicles suspension systems, bumper height, and lighting.

If you or your constituent have any further questions regarding this issue, you may contact Scott Brenner, Associate Administrator for External Affairs, at (202) 366-2566.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:581#108
d.11/19/04

ID: nht78-2.11

DATE: 07/10/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Hon. Paul Trible - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to the letter (enclosed) you received from your constituent Mr. Randy Churaman of Hampton, Virginia, concerning plexiglass covers for headlights.

The National Highway Traffic Safety Administration (NHTSA) in 1972 proposed rulemaking to allow fixed plastic covers over motor vehicle headlights. However, during the comment period of the proposed rule-making some controversial items that were raised regarding fixed plastic headlight covers initiated concerns with respect to motor vehicle safety. These concerns were that: (1) moisture condenses inside the plastic covers and greatly increases headlight glare to oncoming traffic, (2) the plastic covers get scratched, thus reducing headlight output and increasing headlight glare at the same time, (3) plastic headlight covers have to be removed to mechanically aim headlamps, which becomes quite expensive to the vehicle owner and (4) correct aim of headlights is often made incorrect when installing fixed plastic headlight covers. Finally, the change in air drag by use of plastic headlight covers is extremely small since the air drag is primarily related to the overall frontal area projection of the vehicle.

Because of the foregoing disadvantages, and no major advantage to fixed plastic headlight covers other than styling, Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices and Associated Equipment, prohibits fixed plastic covers over headlamps. Specifically, FMVSS No. 108 references SAE Standard J580a, which states in part . . . "When in use, a headlamp shall not have any styling ornament or other feature, such as a glass cover or grill, in front of the lens." There is, however, no prohibition on the installation of original equipment retractable clear plastic headlamp concealment devices on newly manufactured motor vehicles.

I trust the foregoing is fully responsive to your inquiry.

ENC. CONSTITUENT'S LETTER

EXECUTIVE TOWER, BOX 59 2101 EXECUTIVE DR. HAMPTON, VA 23666

Dear Mr. Trible

I own a Datsun 280 Z sports car which has a very aerodynamic front end except for the cutouts for the headlights (see sketch). In other countries there are clear plexiglass covers available for the headlights, which fit over the cutouts, and complete the aerodynamic lines. In this country these covers are illegal for reasons which are beyond my comprehension since they would reduce the air drag of the car, and therefore give better gas milage. I would like to see the law changed to permit the use of these headlight covers, or know why they are illegal.

Randy Churaman

(Graphics omitted)