ID: nht69-2.23

DATE: 09/08/69

FROM: AUTHOR UNAVAILABLE; C. D. Ferguson; NHTSA

TO: Caroline Nigro

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 30, 1969, concerning head restraints on your 1969 Pontiac Catalina.

Before Federal Motor Vehicle Safety Standard No. 202, which requires passenger cars manufactured on or after January 1, 1969, to be equipped with head restraints was issued, the issue you raise, that of the possibility of decreased visibility, was carefully considered. It was felt, however, that the possibility of a slight decrease in visibility, which may occur in certain passenger cars, was far cutweighed by the benefits to safety provided by head restraints.

In a study published by the Society of Automotive Engineers, and conducted by members of the Institute of Transportation and Traffic Engineers, U.C.L.A., it was concluded that (1) "Rear-end collisions are one of the most common types of accidents, and can cause crippling injuries even at low speed," and (2) "head restraints are as important to the motorist involved in rear-end collisions as the safety belt is to the motorist involved in front-end impact."

Furthermore, in the recent case of Sterling Products versus Boyd, in which the Federal Highway Administrator's iasuance of the head restraint standard was challenged and upheld, Judge McGovern of the Circuit Court of Appeals for the District of Columbia concludeds;

"In any event, we find substantial support in the record for conclusion that the contribution of head restriants to consumer safety is such as to warrant their inclusion in all newly manufactured motor cars. There can be no question but that the Administrater, on the besis of the submissions made to him, could reasonably determine that the benefits from mandatory head restraints for outweighed any disadvantage from such restraints due to decreased visibility, or other possible adverse effects upon safety."

Federal law does not prohibit you from removing head restraints. However, I strongly urge that you retain these safety devices in your vehicle for your own safety and protection.

ID: 14896-4.pja

Mr. Charles Jandecka
4481 Dover Center Road
North Olmsted, Ohio 44070

Dear Mr. Jandecka:

I apologize for the delay in responding to your letter requesting a reevaluation of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205), as it relates to tinting of windows. Specifically, you expressed concern about the increase in the number of vehicles with dark-tinted windows.

As you know, Standard No. 205 requires vehicle windows that are "requisite for driving visibility" to meet a 70 percent light transmittance requirement. Darker windows are currently allowed in the rear and rear side windows on trucks, buses, and multi-purpose vehicles (MPVs) because the agency has issued an interpretation stating that these windows are not requisite for driving visibility.

You would like the National Highway Traffic Safety Administration (NHTSA) to prohibit dark-tinted windows in light trucks, MPVs, and vans. You disagree with the conclusion of the agency's interpretation that these windows are not requisite for driving visibility. In addition, you argue that sport utility vehicles and vans should not be relieved of the light transmittance requirement by the interpretation because they do not meet the definition of an MPV. An MPV is ". . . constructed either on a truck chassis or with special features for occasional off-road operation." 49 CFR 571.3.

I will first address your argument regarding classification of vehicles. In contending that these vehicles are not MPVs, you argued that sport utility vehicles were not "off-road vehicles," which you found defined in Executive Order No. 11644 and 16 USC 670. We note that these authorities are not relevant to our regulations. But more importantly, this argument fails to recognize the distinction between a "vehicle with features for occasional off-road operation," and a more capable "off-road vehicle." The definition for off-road vehicles, such as the Humvee, is not relevant to whether vans and sport utility vehicles are MPVs.

Sport utility vehicles clearly meet the MPV definition. They have "special features for occasional off-road operation" such as four-wheel drive, large all purpose tires, large suspension excursions, and high ground clearances. The fact that they offer interior amenities and are often not driven off-road by their owners does not nullify these special features. The classifications are based on design, because ultimate use is something the manufacturer generally does not know. The presence of some of these features on vehicles certified as passenger cars also does not nullify their presence on sport utility vehicles.

Some vans and minivans meet the definition of trucks. Most cargo vans are classified as "trucks" under our safety standards. A truck is defined in 49 CFR 571.3 as being ". . . designed primarily for the transportation of property or special purpose equipment." Many full-size vans are designed on a chassis that may be fitted with any number of body types and is designed and used primarily for carrying cargo.

Most passenger vans and minivans are classified as "multipurpose passenger vehicles," because they are considered by their manufacturers to be "constructed on a truck chassis." Some manufacturers may classify them as MPVs because of heavier running gear, front suspensions, and rear leaf springs, for greater load-carrying capacity. In addition, the rear seats are often removable for carrying large cargo rather than passengers, supporting a colloquial definition of "multi-purpose" vehicles.

Generally speaking, designation of the vehicle type is up to the manufacturer. The definitions of trucks and MPVs overlap somewhat. NHTSA's main concern is that all vehicles meet the standards applicable to the type of vehicle as which they are certified. The agency is aware that in recent years changes in the construction of minivans and sport utility vehicles have tended to blur the line between these vehicles and passenger cars. There has been a convergence in the safety standards applicable to these vehicles and the standards applicable to passenger cars. NHTSA has not tried to create a complex distinction between these vehicle types, but has instead allowed the industry to produce innovative designs that meet the demands of the marketplace.

Moreover, the manufacturers have for many years continued classifying vans and minivans as light trucks for the purpose of complying with the Corporate Average Fuel Economy (CAFE) requirements. The vehicle classification requirements in 49 CFR 523.5(a)(5) allow manufacturers to properly classify vans and minivans with removable seats as light trucks for that purpose. It is doubtful the industry could comply with the CAFE standards if NHTSA suddenly restricted classification capabilities. Therefore, given the industry's longstanding reliance on NHTSA's interpretation and regulation in this area, this office cannot make a such a drastic change in the context of an interpretation letter.

Turning now to your question of whether the rear and rear side windows of sport utility vehicles and vans should be considered "requisite for driving visibility," we continue to believe that they should not be. You correctly identified a change in the agency's opinion between the July 16, 1973 interpretation of Richard Dyson and the April 4, 1985 interpretation of Jeffrey Miller, which first announced the conclusion that these windows were not requisite for driving visibility. However, you are incorrect to conclude that either the January 9, 1990 interpretation by Stephen Wood, or any of the subsequent interpretations you cited represent a change in the agency's position on the matter. Mr. Miller's interpretation still represents the agency's position.

The reasoning behind the Miller interpretation is that these vehicles are often sold in configurations without windows or with small windows to the rear of the driver (e.g., a panel van). Even if the windows to the rear of the driver are large enough, these vehicles may frequently carry loads that block the view out of them. Logically, it is impossible to argue that these windows are requisite for driving visibility when they do not even exist on the next van on the lot. In addition, most minivans and sport utility vehicles today, (even those with larger side windows and without a vision-blocking load) have rear side windows that are too high to rely on for lane changes. Vehicle manufacturers provide right-side rear view mirrors on these vehicles which assist in lane changes.

If these windows were requisite for driving visibility, one might expect that vehicle types with darker glass in those locations would be more involved in crashes, but the data do not show this to be true. Some analyses have shown that they are generally less involved in crashes than passenger cars, and that they are even under-involved in lane change crashes. This indicates that the existing window and mirror systems are meeting the minimum needs for driving visibility.

On January 22, 1992, NHTSA proposed, among other things, transmittance requirements for the windows to the rear of the driver in these vehicles. The proposed requirements would permit windows darker than those in passenger cars, but would require these windows to be lighter than the "privacy glass" currently being sold on some minivans and sport utility vehicles. Comments on the proposal were overwhelmingly negative. The law enforcement community was divided on the issue. Final action on this rulemaking is anticipated soon.

I hope this information is helpful. If you have any further questions, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
ref:205
d.3/10/98

ID: nht78-2.27

DATE: 08/16/78

FROM: A. MALLIARIS FOR M. M. FINKELSTEIN -- NHTSA

TO: Department of Radiology and Nuclear Radiology

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 21, 1978, regarding the height of head restraints in U.S. manufactured cars.

Federal Motor Vehicle Safety Standard No. 202, Head Restraints, Passenger Cars, copy enclosed, requires that when the head restraint is adjusted to its fully extended design position, the top of the head restraint shall not be less than 27.5 inches above the seating reference point. The 27.5 inches approximates the distance from the hip point to the occiput of a 95% percentile anthropometric male figure. The seating reference point in turn corresponds to the hip point. Therefore, head restraints would be expected to be adjustable to the normal sitting height of 95 percent of the male population.

On March 10, 1978, the National Highway Traffic Safety Administration (NHTSA) issued a notice of a draft plan for rulemaking, copy enclosed. Plans for rulemaking concerning head restraints are noted on page 11106 under Docket 74-13. To support future rulemaking regading the height of head restraints we would appreciate any data that you may have in your possession regarding cervical spine injuries in rear impact accidents. It may be forwarded to NHTSA, Docket 74-13.

A copy of your letter is being forwarded to the docket as a matter for the public record.

SINCERELY,

Orlando General Hospital

U.S. Department of Transportation National Highway Safety Administration Office of the Rule Making

July 21, 1978

Dear Sir:

It is my opinion that the headrest on U.S. manufactured cars are designed to prevent injury to the cervical spine and the skull. Through personal experience and experience as a Radiologist, I find that the maximum height of these headrests are not high enough to prevent injury to taller people.

I strongly encourage that the headrests installed in U.S. manufactured automobiles be adjustable by the occupant so that people over 6 foot 2 inches tall may have the benefit of safety. At the present time, the maximum height sometimes encourages more traumatic injuries of the cervical spine rather than preventing them in regards toward tall people.

Bodo E. Pyko, D.O. Chairman Department of Radiology and Nuclear Radiology

ID: nht68-3.47

DATE: 07/31/68

FROM: R.M. O'MAHONEY -- NHTSA; SIGNATURE BY MR. SCHMELTZER

TO: E.L. Mobley

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of July 19 to Mr. Vinson of my staff presents your problem regarding two Volkswagens which have been conditionally admitted to the United States pursuant to 19 C.F.R. @ 12.80(b)(2)(iii) and (c). You state "we want to do whatever is necessary to secure an unconditional release of the cars."

As the Acting District Director of Customs informed you in his letter of July 18, @ 12.80(c) requires that the importer submit to the Bureau of Customs:

". . . a statement verified by the importer or(Illegible Word) that the vehicle . . . described in the declaration filed by the importer has been brought into conformity with applicable safety standards, and identifying the manufacturer, contractor, or other person who has brought such vehicle . . . into conformity with such standards and describing the nature and extent of the work performed."

Production of statements for the two Volkswagens containing the information required by @ 12.80(c) should allow a release of the vehicles and a termination of the bond. As Customs further informed you, these statements are forwarded to the Highway Administration for evaluation. This means that, if questions arise about the conformance work, you will be asked to provide us with the name and addresses of the owners of these vehicles.

I enclose a copy of the standards currently applicable to passenger cars. Two of the three items you mentioned are only a small portion of the overall requirements of the standards. With reference to these items you will note that "seat belts" are covered by three Federal standards: No. 208 requiring installation of upper torso and pelvic restraints, No. 209 specifying conformance of assemblies, and No. 210 specifying detailed requirements for anchorage points. The requirements of Paragraph S 3.1 of Standard No. 201 does not per se require a "padded dash"; conversely there is no assurance that the padding of a previously bare dash panel will bring a non-conforming vehicle into conformity. "Back-up lights" is a Federal requirement only for passenger cars manufactured on or after January 1, 1969.

I hope this answers your questions.

ID: GF002147

ID: aiam3938

Dear Mr. Lakas: Thank you for your letter concerning our regulations that affec tinting businesses, such as yours. I hope that the following discussion will clarify our regulations and answer the questions you raised.; Please note that in all the correspondence the agency has had with you your attorney, and others concerning your business, we have never stated that it is illegal to add all tinting to the glazing of a motor vehicle. We have stated, however, that it is illegal to add some types and levels of tinting. Let me explain further the effect our regulations on tinting.; *Federal Law* The National Traffic and Motor Vehicle Safety Act authorizes our agenc to issue Federal Motor Vehicle Safety Standards that apply to new motor vehicles and items of motor vehicle equipment. In 1967, the agency issued Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, which sets performance requirements for glazing materials used in new motor vehicles and glazing materials sold as items of replacement equipment. (A copy of that standard and the American National Standards Institute's code incorporated by reference in our standard has been previously provided to you.); The performance requirements of the standard include ones regulatin the light transmittance and abrasion resistance of glazing. A manufacturer of new vehicles must certify that the glazing in windows requisite for driving visibility, whether clear or tinted, conforms with the light transmittance and other requirements of the standard. Likewise, if a dealer or other person places tinting film on glazing in a new vehicle prior to the sale of the vehicle, that person must certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Thus, for example, the light transmittance through the combination of tinting film and the glazing must be at least 70 percent in the case of glazing used in windows requisite for driving visibility. Similarly, the combination must also meet the abrasion resistance and other requirements of the standard.; In 1974, Congress amended the National Traffic and Motor Vehicle Safet Act to address the problems of persons tampering with safety equipment installed on a motor vehicle after its first sale. The 1974 amendments added section 108(a)(2)(A) to the Act. That section provides, in part that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, 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 . . . .<<<; Thus no manufacturer, distributor, dealer, or motor vehicle repai business may add tinting to the glazing materials of a motor vehicle, if that tinting would render inoperative the glazing's compliance with Standard No. 205. Again, section 108(a)(2)(A) does not prohibit tinting, it merely limits the use of tinting. The agency has consistently attempted to explain our interpretation of section 108(a)(2)(A) in letters to vehicle, glazing, and tinting manufacturers, state governments, and individual tinting shops. You indicated that we need to do a better job of conveying our interpretation to all affected persons. We will look at ways to accomplish that goal.; Section 108(a)(2)(A) does not establish any limitations on a individual vehicle owner's ability to alter his or her own vehicle. Under Federal law, individual vehicle owners can themselves install any tinting they want on their vehicles, regardless of whether that tinting would render inoperative the compliance of the vehicle's glazing with the performance requirements of Standard No. 205. The agency, of course, urges individual owners not to install dark tinting on their vehicles.; *State Law* Although the agency does not have the authority to regulate the action of individual vehicle owners, States do have such authority. The agency is aware that a number of States have adopted laws which address the tinting of motor vehicles. Let me emphasize that State laws which are inconsistent with these Federal requirements are preempted. Any State law or regulation which would permit any person to install tinting material on a new vehicle in violation of Standard No. 205 is preempted under section 103(d) of the Vehicle Safety Act. for example, a State law which specifies a transmittance level less than 70 percent for windows requisite for driving visibility in new vehicles would be preempted. The adoption or retention of such a law would have no effect on the illegality of that installation under Federal law. Further, any State law or regulation that would permit manufacturers, distributors, dealers or motor vehicle repair businesses to install tinting materials on a vehicle after its first sale in violation of section 108(a)(2)(A) of the Vehicle Safety Act is also preempted.; *Requirements for Different Vehicles* You asked for an explanation of why there is a difference between th visibility requirements set for passenger cars and other motor vehicles. The agency has generally applied more stringent safety requirements for passenger cars, the most prevalent type of vehicle on the road, and has subsequently applied the same or similar requirements to other vehicle types.; In the case of the glazing requirements, the agency has considered al the windows in a passenger car requisite for driving visibility. The agency has applied different requirements to other vehicles such as vans, because of traditional differences in their construction and use. Many vans are constructed without any windows to the rear of the driver. In addition, the space behind the driver in vans is frequently used to haul objects which prevent an interior view to the rear of the vehicle. Because of this situation, the agency has required trucks, buses and van-type vehicles to have dual outside mirrors to ensure that the driver will have a view to the rear of the vehicle.; *VESC Guidelines* You also asked about the guidelines adopted by the Vehicle Equipmen Safety Commission (VESC). In 1958, Congress authorized the creation of VESC for the purpose of encouraging State cooperation in the establishment and carrying out of traffic safety programs. VESC, however, had no authority to adopt regulatory standards that would directly affect individuals, manufacturers, dealers, distributors, or motor vehicle repair businesses. Although VESC could recommend guidelines, those guidelines would have to be adopted by the States to have the force of law. VESC ceased operations in January 1984. In 1980, VESC adopted a guideline, designated as VESC-20, on the tinting of glazing on used vehicles. Several of the provisions in VESC-20 conflict with the requirements of Standard No. 205. As discussed above, the adoption of VESC-20 by a State would govern the use of tinting by an individual vehicle owner. However, that State law would not affect the use of tinting by manufacturers, distributors, dealers, and motor vehicle repair businesses, whose conduct would still be affected by our regulations.; You asked about Maryland's adoption of a regulation based, in part, o VESC-20. Since VESC- 20 is merely a guideline, Maryland is free to choose the portions of VESC-20 it wishes to adopt, but those portions conflicting with Standard No. 205 are subject to Federal preemption.; *AAMVA Approval* You asked about the effect of a 'notice of equipment compliance' issue to tinting manufacturers by the American Association of Motor Vehicle Administrators (AAMVA), which apparently is a certification by the AAMVA that the material complies with VESC-20. Our regulations do not require a manufacturer of tinting materials to obtain a notice of equipment compliance from AAMVA. Individual States may have adopted regulations which require tinting manufacturers to obtain such notices.; Whether a manufacturer has an AAMVA notice or its tinting material ha been approved by a State has no effect on our regulations. As explained above, if a manufacturer, dealer, distributor, or motor vehicle repair business install tinting film which would render inoperative the glazing materials compliance with Standard No. 205, there would be a violation of section 108(a)(2)(A) of the Vehicle Safety Act.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel

ID: aiam4490

Dear Mr. Hocken: This is in reply to your letter of December l6, l98 to Mr. Vinson of this office requesting an interpretation of Motor Vehicle Safety Standard No. 108. You have received a 'Service Information Safety Related letter' from Flxible Corporation stating that deceleration warning lights installed on your buses do not comply with Standard No. 108. You have also asked how you may file for 'Special Exception' if your buses are not in compliance. This will confirm that Flxible Corporation, pursuant to applicable Federal regulations, has determined that certain buses produced by it, including the 67 units furnished Phoenix, do not comply with Standard No. 108, and has initiated a notification and remedy campaign (Campaign 87V-089). The basis of this determination was the manufacturer's conclusion that flashing amber deceleration warning lamps could create confusion when activated simultaneously with the red steady burning stop lamps. The company has advised you of the corrective action to be taken, that is, to remove the deceleration flasher. Although the agency encourages owners of campaigned vehicles to remedy noncompliances, the decision whether to do so rests with the vehicle owner. There is no Federal requirement that an owner correct a noncompliance that exists in his vehicle, and no penalty for his failure to do so. Thus, no 'Special Exception' is either needed or available for an owner who wishes to continue operating a vehicle in a noncompliant state. We are interested in your comment that you experienced a 44 percent reduction in accidents in l985, the first full year that the system was installed on all your buses, compared with l984. This report compares favorably with the accident reduction experienced in our test fleets of passenger cars equipped with center highmounted stop lamps, which was the basis for eventual adoption of that requirement. The agency is engaged in research pertaining to the conspicuity of large vehicles, and would find it helpful to have a copy of the data upon which you based your comment. It should be sent to Michael Finkelstein, Associate Administrator for Research and Development, NHTSA, 400 Seventh Street, S.W., Washington, D.C. 20590. We appreciate your interest in safety. Sincerely, Erika Z. Jones Chief Counsel;

ID: aiam0203

>>>Re: Consumer Information--Certification--Distributons (sic)<<< Dear Mr. Eshelman: This is in reply to your letter of December 20, 1969, in which yo responded to our inquiry concerning consumer information on vehicles sold by your company.; You stated that your Golden Eagle cars are 'made from new mode Chevrolets without any mechanical change,' and that the 'consumer information and the warranty book as supplied by General Motors are passed along to the consumer with the vehicle.' You also stated that you place a label next to the GM certification label, quoting language similar to that specified in the Certification Regulations for the distributor who alters a vehicle, 49 CFR S. 367.6. We are enclosing a copy of the Certification Regulations: please note that the abovementioned distributor statement, if it is applicable, requires that month and year of alteration to be stated immediately after the name of the distributor.; The question whether the procedure you have outlined in respect t certification is acceptable depends on whether the alterations that you perform on the Chevrolets are sufficiently minor to place you in the category of 'distributor' rather than 'manufacturer'. In order to make this determination, we need and would like to receive more detailed information on the work that you do on the vehicles.; The question whether the practice you describe, of passing on th General Motors consumer information, is acceptable depends on whether the information, is acceptable depends on whether the information is actually correct for the vehicles as you alter them. The weight of the final vehicle, for example, is an important factor in the vehicle's performance in all three areas of acceleration, braking, and tire reserve load. We should mention that you are fully responsible, subject to the penalties specified in section 109 of the National Traffic and Motor Vehicle Safety Act, for ensuring that the correctness of the consumer information that you provide with your vehicles is not adversely affected by the work that you do on them, whether you are ultimately paced in the category of manufacturer or distributor.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Assistant Chief Counsel fo Regulations;

ID: aiam4920

Dear Mr. Smith: This responds to your letter of October 14, 1991, t Taylor Vinson of this Office, asking for a confirmation of your interpretation of Motor Vehicle Safety Standard No. 108, based upon a meeting with Mr. Vinson on August 15, l990. You are developing a license plate frame that incorporates a 'flashing/steady burning stop lamp', for use on passenger cars and motorcycles, and 'an auxiliary flashing/steady burning stop lamp' for use on vans, minivans, and pickup trucks. You cite a letter of this agency to Bettie Lou Simcox, dated October 24, 1986, as authority for your understanding that Standard No. 108 allows the use of a flashing, steady burning stop lamp. Standard No. 108 covers original motor vehicle lighting equipment, and lighting equipment that is intended to replace the original lighting equipment. It does not cover supplementary or novelty lighting equipment offered in the aftermarket. Mrs. Simcox asked us about the acceptability of an aftermarket stop lamp which, when the brake is applied, pulses before going into a steady burning mode. We informed Mrs. Simcox that her lamp was unacceptable as replacement equipment because Standard No. 108 requires original equipment stop lamps, and lamps designed to replace that equipment, to be steady burning in use, but that it would be permissible under Standard No. 108 as a supplementary stop lamp. For the same reason, your invention would not be prohibited by Standard No. 108 if it is offered in the aftermarket as a supplementary stop lamp, which we understand is your intent. You should be aware that Standard No. 108 specifically requires motor vehicles to be equipped with one or more license plate lamps. We are uncertain of the effect, if any, that the installation of your combination license plate frame/supplementary stop lamp would have upon conformance of a vehicle's license plate lamp(s) with the requirements of Standard No. 108. We therefore remind you of the prohibition in the National Traffic and Motor Vehicle Safety Act that a manufacturer, distributor, dealer or motor vehicle repair business may not render inoperative, in whole or in part, a device such as the license plate lamp that has been installed in accordance with a safety standard such as Standard No. 108. Sincerely, Paul Jackson Rice Chief Counsel;

ID: aiam5179

"Dear Dr. L ckemeyer: As you have requested, we are responding by FA to your letter of April 28, 1993, to Taylor Vinson of this Office. You have asked two questions with respect to the acceptability of a multiple rear turn signal lamp under Federal Motor Vehicle Safety Standard No. 108, and have enclosed a sketch of the lamp. Your first question is: 'Is it allowed to split the turn signal lamp in two parts with the dimensions given in the sketch . . . where the bigger part (4.5 sq. in.) is on the body of the car. The distance does not exceed 22 in.' Your question indicates that the turn signal lamp array of two lamps that is illustrated in the sketch is intended for installation on passenger cars or other vehicles whose overall width is less than 80 inches. Standard No. 108 incorporates by reference the SAE standard applicable to such vehicles, J588 NOV84. Paragraph 5.1.5.2 of SAE J588 NOV84 permits the use of multiple rear turn signal lamps to meet the photometric requirements of Standard No. 108. When multiple lamps are used to meet the photometric requirements of a rear turn signal lamp, paragraph 5.3.3 of SAE J588 NOV84 requires that the functional lighted lens area of each lamp shall be at least 22 sq. cm, provided the combined area is at least 37.5 sq. cm. Your sketch shows that the functional lighted lens area of one lamp is 23 sq. cm, and of the other, 30 sq. cm, with a combined area of 53 sq. cm. Therefore, Standard No. 108 permits you to use the turn signal lamp array shown in your sketch. Your second question is: 'Is it allowed to use the combination of the two lamps to meet the photometric requirements.' Because the distance between the two adjacent light sources in the array does not exceed 560 mm (the sketch indicates that it is less than 550 mm), paragraph 5.1.5.2 of SAE J588 NOV84 requires that the combination of the lamps be used to meet the photometric requirements for the corresponding number of lighted sections, two in this case. Sincerely, John Womack Acting Chief Counsel";