ID: 86-6.22

TYPE: INTERPRETATION-NHTSA

DATE: 12/24/86

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: HIROSHI MORIYOSHI -- EXECUTIVE VICE-PRESIDENT AND GENERAL MANAGER MAZDA (NORTH AMERICA), INC.

TITLE: NONE

ATTACHMT: LETTER DATED 04/09/86, TO ERIKA Z JONES FROM HIROSHI MORIYOSHI RE REQUEST FOR INTERPRETATION FMVS 101 CONTROLS AND DISPLAYS AND FMVSS 102 TRANSMISSION SHIFT LEVER SEQUENCE STARTER INTERLOCK AND TRANSMISSION BRAKING EFFECT; OCC - 0476

TEXT: Dear Mr. Moriyoshi:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standards No. 101, Controls and Displays, and No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You asked about the identification and visibility requirements of these standards for the gear position indicator of an automatic transmission. As part of a design you are considering producing, a gear position indicator, using light-emitting diodes (LED's), would be located within the instrument panel. Your letter states that this system would conform with all applicable requirements when the ignition switch is in the on and start position, but would not be visible when the ignition switch was in the accessory or off positions. Your letter states further that, in addition to this LED display, the steering-column-mounted gear shift selector would be provided with embossed position indicators conforming to Standard No. 102, except that the identifiers would only be visible from the inboard side of the steering column and thereby require the driver to lean forward and to the right for visual confirmation of the automatic gear position. The issues raised by your letter with respect to whether the design you are considering would comply with Standards No. 101 and No. 102 are addressed below.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.

I will begin by identifying the requirements of Standards No. 101 and No. 102 that are relevant to your request. Section S3.2 of Standard No. 102 states that the "(i)dentification of shift lever positions of automatic transmissions and of the shift lever pattern of manual transmissions . . . shall be permanently displayed in view of the driver." (Emphasis added.)

Standard No. 101 specifies requirements for the location, identification and illumination of automatic gear position displays. Section S5.1 requires that gear position displays must be visible to the driver under the conditions of section S6. Section S6 provides that the driver is restrained by the crash protection equipment installed in accordance with Standard No. 208, Occupant Crash Protection, adjusted in accordance with the manufacturer's instructions. Section S5.3.1 and Table 2 of the standard together require that automatic gear position displays be illuminated whenever the ignition switch and/or the headlamps are activated. The entry in Table 2 concerning the automatic gear position display references Standard No. 102.

I will now address these requirements in relation to the design you are considering. As discussed below, it is our opinion that your proposed design would not meet Standard No. 102's requirement that the identification of shift lever positions of automatic transmissions must be permanently displayed in view of the driver.

While your design would include two automatic gear position displays, neither display would provide identification of shift lever positions of automatic transmissions in view of the driver when the ignition switch is in the accessory or off position. As noted by your letter, NHTSA has interpreted the words "permanently displayed" to require a display which can be seen regardless of the operating mode of the engine. The display on the instrument panel would not be visible when the ignition switch is in the accessory or off positions. The other display, located on the steering column, would not be visible to the driver regardless of the position of the ignition switch.

NHTSA has previously addressed Standard No. 102's requirement that certain identification be "in view of the driver" in connection with a request for interpretation concerning the identification of the shift lever pattern of manual transmissions. The agency concluded that the pattern "is deemed to be 'displayed in view of the driver' if part of it may be seen from the driver's normal eye position and a reasonable amount of movement of the driver allows him to gain full view of the pattern." (Letter to Daimler-Benz of North America, February 27, 1967)

As noted above, your letter states that the display on the steering column would "only be visible from the side of the steering column and thereby require the driver to lean forward and to the right for visual confirmation of the automatic gear position." This suggests that little, if any, of the display may be seen from the driver's normal eye position

and that a significant amount of movement of the driver would be required to see the full display. This is further confirmed by a statement in your letter indicating that the driver would need to lean forward, utilizing the flexibility provided by an emergency locking retractor, in order to see the display, and then return to the normal driving position. (Emphasis added) It therefore appears that the display is not "in view of the driver."

While your letter suggests that the degree of visibility provided by the display might be appropriate for situations where the vehicle is not activated, Standard No. 102's requirement that the display be within the "view of the driver" does not distinguish between whether the engine is on or off. We also note that a driver used to viewing the gear position indicator on the instrument panel might not be aware that another display, which would not be visible from a normal driving position, even exists.

Since neither display would provide identification of shift lever positions of automatic transmissions in view of the driver when the ignition switch is in the accessory or off position, it is unnecessary to address the issue raised by your letter concerning whether multiple and complementary indicators can be used to meet the requirements of Standards No. 101 and No. 102 for gear position displays, where no single indicator meets the requirements.

Sincerely,

ID: 22652.ztv

AIR MAIL





Mr. Richard King
Manager/Director
Wheel Lighting Devices, Ltd.
Downs Road South Brydone R.D. 4
Gore, New Zealand


FAX: 64 3 2066786




Dear Mr. King:

John A. Hill has asked that we send our reply to you responding to his e-mails of January 4 and February 2, 2001, in which he asked for an interpretation of U.S. Federal laws as they relate to "HubLites." His e-mails have been supplemented by yours of March 5, 2001, to Taylor Vinson of this Office.

Mr. Hill explained that HubLites are "novelty lighting equipment," installed on the hubs of heavy trucks and trailers. It is equipment offered in the aftermarket and will "be retrofitted by truck owners themselves." In his opinion, HubLites do not interfere with any of the lighting equipment required under Federal Motor Vehicle Safety Standard No. 108. You have informed us that HubLites are steady-burning and "orange/amber" in color.

The installation of aftermarket lighting equipment under the laws of the United States is governed by 49 U.S.C. 30122, Making safety devices and elements inoperative. Essentially, this section prohibits manufacturers, distributors, dealers, and motor vehicle repair businesses from modifications that create a noncompliance with any Federal motor vehicle safety standard. However, Section 30122 does not include owners in the list of persons prohibited from making modifications. Mr. Hill has informed us that HubLites will be installed by truck owners. Thus, the prohibition would not appear to apply. However, the use of HubLites is subject to the laws of the individual states in which they are used, and we are unable to advise you on these.

We differ with Mr. Hill's unsupported conclusion that HubLites would not interfere with any of the lighting equipment required by Standard No. 108. The fact that a vehicle owner may legally modify his or her vehicle in a manner that would cause it to no longer comply with a Federal safety standard does not mean that it is wise to do so; in fact, it lowers the safety level of the vehicle. I would call your attention to a similar product which was the subject of an opinion letter from this Office of March 15, 1989, to Byung M. Soh. In that instance, the product was a self-lighting hub cap which included a motion-activated LED light whose intensity varied according to the speed of the vehicle. We stated our belief that "effectiveness [of some required lamps] may be impaired if the device created . . . confusion with the signal sent by another lamp," and that the hubcap light might cause "motorists to confuse its signal with the signal emitted by headlamps, stoplights, brakelights, taillights, side marker lamps, and other lighting devices." In our opinion, "such confusion is possible since your product is located on the wheels at approximately the same level as some of the lights required by Standard No. 108. This impairment of effectiveness would be especially likely if the hub cap lights were the same color (red, amber, or white) as the lights required by Standard No. 108." The previous two sentences apply equally as well to the factors of color and location of HubLites; they would not be permissible under Standard No. 108 as original equipment. Although a truck or trailer owner may install HubLites without violating Section 30122, this should not be interpreted or advertised as indicating U.S. "approval" of HubLites. We have no authority to "approve" or "disapprove" vehicles or equipment; we only advise as to the relationship of these products to the laws that we administer.

Mr. Hill asked if other Federal safety laws might apply. Trucks and trailers used in interstate commerce within the United States are subject to the regulations of the Federal Motor Carrier Safety Administration (FMCSA) of the Department of Transportation. We have asked the FMCSA whether HubLites would be prohibited by any of its regulations, and it has informed us that HubLites would not be allowable. Section 393.3 (49 CFR 393.3) of the FMCSA's safety regulations prohibit interstate motor carriers from using additional equipment and accessories if the use of such devices is inconsistent with that agency's regulations, or if the use of such devices decreases the safety of operation of the vehicles on which they are used. With respect to vehicles that it regulates, FMCSA concurs with the impairment conclusions that we have reached. Because 49 CFR 393.11 requires interstate motor carriers to maintain their vehicles to meet the requirements of Standard No. 108, and HubLites would not be permissible under Standard No. 108, HubLites may not be used on trucks and trailers used in interstate commerce and regulated by the FMCSA.

Mr. Hill also asked if there are any other Federal rules that the manufacturer of HubLites should be aware of in order to sell motor vehicle equipment in the United States, such as the need to have a registered agent (the product would be imported from New Zealand). HubLites are motor vehicle equipment. This means that Wheel Lighting Devices, Ltd. must designate an agent for service of process, as set forth in 49 C.F.R. 551.45, Service of process on foreign manufacturers and importers.

Additionally, you should be aware that as a manufacturer of motor vehicle equipment, you will be subject to the requirements of 49 U.S.C. 30118-30121 concerning the recall and remedy of motor vehicle equipment with defects related to motor vehicle safety. If either you or we determine that HubLites contain a defect related to motor vehicle safety, you as the manufacturer would be required to notify purchasers of the defect, and either repair HubLites so that the defect is removed, or provide a non-defective replacement. In either case, your company must bear the full expense of the remedy and cannot charge the owner for the remedy if the product was first purchased less than ten years before the notification campaign.

If you have any questions, you may email Taylor Vinson at tvinson@nhtsa.dot.gov.

Sincerely,

John Womack
Acting Chief Counsel
ref:108
d.4/12/01

ID: 86-1.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/10/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Timothy Pawl, P.E. -- President, Pawl Inventioneering Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Timothy Pawl P.E. President Pawl Inventioneering Corporation P.O. Box 5425 West Bloomfield, Michigan 48033

This is in response to your letter of November 29 ,1985, to the former Chief Counsel of this agency Jeffrey R. Miller, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

Your letter is vague as to the precise function of your "safety related" lighting device, and whether you wish to offer it as original equipment or equipment intended for installation after the sale of a vehicle to its first purchaser for purposes other than resale. If the latter, then its legality is determinable solely under the laws of each State in which it will be used.

If you intend it as original equipment, on a vehicle at the time of its initial sale, then its legality would be determinable under Standard No. 108. As a general rule, section S4.1.3 prohibits the installation of any device that would impair the effectiveness of lighting equipment required by the standard. You have informed us that your device, which consists of "amber LED's" in the "rear package tray," is inoperative during application of the service brakes; thus, it does not appear that it would impair the effectiveness of the center high-mounted stop lamp.

You have also stated that it is located "in relative proximity" to the center stop lamp but is not combined with it, and you have asked if this meets the intent of S4.4.1 regarding equipment combinations. This section forbids the combination of the center stop lamp with any other lamp or reflective device. Since your device is physically separate from the center lamp, S4.4.1 would not appear to prohibit your device.

You have also stated that when viewed from the rear, "the pattern of illuminated LED's may change, possibly giving the illusion of flashing," and you ask for a definition of "flashing" as described in section S4.6(c). This section has been renumbered S4.5.11, and subsection (c) permits an exception to the general rule that lamps in use must be steady-burning, permitting headlamps and side marker lamps to "flash" for signalling purposes. The definition of flash is that contained in S3, a cycle of activation and deactivation by automatic means, and this definition does not specify frequency or other characteristics. To us, the important question is whether your device complies with section S4.5.11(e) which requires all lamps (other than those specifically excepted) to be steady-burning in use. A lamp that changes patterns may not flash, but it cannot be viewed as steady-burning either.

Finally, you state that "section S4.3 states that no function other than red reflex reflectors shall be combined with CHMSL or rear turn signal lamps" and ask whether amber or any other color "may be used in proximity" since it is not used in combination. We believe you must be referring to section S4.4.1 which states that "no clearance lamp may be combined optically with any taillamp or identification lamp, and no high-mounted stop lamp shall be combined with any other lamp or reflective device." As we do not know the intended functions of your LED device, I can offer only general comments. Although red is the required color for all rear lighting devices except backup and license plate lamps, amber is permitted as an optional color for rear turn signals: furthermore, amber is generally accepted as indicating the need for caution. Thus, amber is not a lens color whose presence on rear lighting devices would per se impair effectiveness. The use of other colors for lighting devices on the rear of vehicles could lead to confusion, and be viewed as impairing the effectiveness of required lighting equipment.

Sincerely,

Erika Z. Jones

Chief Counsel

November 29, 1985

Jeffrey R. Miller Chief Council U.S. Department of Transportation 400 7th Street S.W. Washington,D.C. 20590

RE: Request for Interpretation of FMVSS 108

Dear Mr. Miller;

We have under development a new device of a safety related nature for automobiles. Before proceeding further on the development, we are hereby requesting an interpretation of Federal Motor Vehicle Safety Standard 108. Our device mounts in the rear package tray area of the automobile. We are therefore concerned about the specific sections pertaining to the operation and restrictions thereof for the Center High Mounted Stoplamp (CHMSL).

As a means of definition of the areas of concern, I will list the specific operating characteristic of our device and then the section from the Standard for which we device an interpretation.

1. Our device has amber colored LED's, during the application of the service brakes, these LED's are disabled ,allowing a vehicle following to observe only the CHMSL. Hence, although in relative proximity (near the target area of the CHMSL) it is not combined with the CHMSL. Does this operation meet the intent of S4.4.1 concerning equipment combinations.

2. When a vehicle containing our device is viewed from the rear by a following vehicle, the pattern of illuminated LED'a may change, possibly giving the illusion or flashing. We therefore need a definition of flashing as described in section S4.6(c), frequency, length of time between periods of "steady-burning" operation, etc.

3. As previously mentioned the device contains amber LED's, section S4.3 states that no function other than red reflex reflectors shall be combined with CHMSL or rear turn signal lamps.... since it is not used in combination per our question (1) may amber be used in proximity. If not amber, are there any other colors that may be acceptable.

We would appreciate your attention to this matter and await your response. If necessary we may be reached by phone at (313) 682-2007.

Sincerely,

E. Timothy Pawl, P.E. President

ID: 77-5.3

TYPE: INTERPRETATION-NHTSA

DATE: 12/12/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: COBEC Brazilian Trading & Warehousing Corp. of the U.S.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of September 20, 1977, to Mr. Armstrong of this agency regarding the Puma kit car import program. Although your letter is not clear, you appear to be seeking an interpretation as to the applicability of our regulations to the Puma and its proper classification for import into the United States.

FACTS

Our opinion is based upon the factual representations made in your letter, in the advertising brochure issued by Puma Kit Cars, Inc., and an article "Brazilian Puma" by Thos. L. Bryant which appeared in the October 1977 issue of Road & Track (pp. 112-13). As we understand it, Pumas are shipped to the United States both as complete vehicles and in kit form. The completed vehicles are imported and sold by a Kansas firm. The kit vehicles on the other hand are imported by COBEC and sold to Puma Kit Cars, Inc. for further sale to individual purchasers.

The manufacturing operations that occur to the Puma kit car before it is exported are reported by Road & Track as:

"For normal production, Puma [Brazil] buys the [new VW] floorplan assemblies from the factory and removes 10 in. from its length . . . . All cables and fluid lines are removed and replaced with shorter versions. The modified chassis is then fed into the assembly line and if the final unit is to be sold locally, a finished car emerges from the other end. For those slated for export to the U.S. a few steps are left out. These consist of the installation of the front and rear ends and the engine. Aside from these omissions the completed cars are identical."

The completeness of the initial manufacturing process is highlighted in the Puma Kit Car Inc., brochure:

The Puma kit car is complete in every sense of the word: body, special floor pan, wiring, gas tank, rear torsion, steering wheel, tinted safety glass, roll up windows and plush upholstery. All you require in addition to the Puma kit is a VW ball joint front end, swing axle transmission, VW or Porsche engine, wheels, tires, and a battery."

The missing components are available from Puma Kit Car according to the brochure:

"In addition to the basic Puma Kit, complete factory engines, front end assemblies including disc brakes and brand new transaxle assemblies are available. You can assemble a new Puma car from off the shelf factory parts." CLASSIFICATION OF THE PUMA KIT CAR FOR IMPORTATION

COBEC commercial invoices of July 1977 show that Puma kit cars have been identified as "Replacement Body GTE for Volkswagen 1966" and "Replacement Chassis for Volkswagen 1966." The merchandise appears invariably identified as replacement equipment for 1966 Volkswagens.

As the Federal motor vehicle safety standards did not apply to passenger cars and equipment until January 1, 1968, it appears that COBEC is attempting to argue that the merchandise is not subject to Federal regulation under the National Traffic and Motor Vehicle Safety Act. But generally Federal standards covering replacement equipment apply as of the date the equipment is manufactured. Therefore, any item of motor vehicle equipment supplied in the Puma kit that is covered by a Federal motor vehicle safety standard (e.g. headlamps, glazing) must comply with it.

RESPONSIBILITY OF COBEC AS IMPORTER OF THE PUMA KIT CARS

If an equipment item does not comply, Pumas must be entered pursuant to 19 CFR 12.80(b)(2)(iii) as nonconforming motor vehicle equipment that will be brought into compliance before being offered for sale, and COBEC is responsible for submission of compliance documentation under 19 CFR 12.80(b)(2)(iii).

I hope that this is responsive to your request.

SINCERELY,

September 20, 1977.

Francis Armstrong, Director Office of Standards Enforcement Motor Vehicle Programs NHTSA, U.S. Department of Transportation

RE: PUMA KIT CAR IMPORT PROGRAM

With reference to the above-mentioned program we would like to express our opinion that these kits are in every way incomplete cars and, therefore, we so classified them on your Special Customs Invoice.

As per your request and for your own evaluation we enclose pictures as well as the following pertinent technical data about our kit car.

1. Our kit car consists of:

- fiber glass body shell,

- metal floor pan,

- AS1 safety glass (U.S. approved windshield),

- AS2 tempered glass, side and rear windows, - full set of dash control instruments,

- one set of seal beam headlights, (General Electric), U.S. made,

- one set of tale lights (U.S. approved).

2. Optional items:

- Seats and safety steering wheel.

3. Our vehicles do not include the following items:

- wheels,

- tires,

- front and rear axle,

- differential,

- transmission,

- motor,

- suspension components,

- steering components,

- break components,

- gas system,

- heating system.

These kits are intended to the sale to "DO IT YOURSELF MECHANIC" who in turn might have an old Volkswagen. By using components of the vehicle and the kit car it is possible to assemble. Within a time frame of 80 hrs., a small personal 2 (two) passenger car.

Please note that all of the service is accomplished by the owner himself. We feel that this explanation is sufficient for all your requirements, however, in case you need any additional information please do not hesitate to contact us.

Thank you for your prompt attention to this matter, since as of this moment we have ceased all current shipments into the U.S. until your final decision has been reached.

COBEC BRAZILIAN TRADING & WAREHOUSING CORP. OF THE U.S.

Egon Poisl Assistant Treasurer

(Graphics omitted) (Graphics omitted)

ID: nht87-2.47

TYPE: INTERPRETATION-NHTSA

DATE: 07/13/87

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: Mr. Yueh-An Chen

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Yueh-An Chen Division Head Planning Division Yue Loong Motor Engineering Center P.O. Box 510 Taoyuan, Taiwan Republic of China

Dear Mr. Chen:

This is in reply to your letter of June 5, 1987, asking whether certain rear lighting arrangements are acceptable under Federal Motor Vehicle Safety Standard No. 108.

You have submitted a diagram showing four lamps on either side of the vertical centerline of the rear of the car. The most inboard lamps, denoted "R", are the backup lamp system. Yue Loong contemplates four different functions for the remaining three sys tems of lamps, "A", "B", "C", and "D", "E", "F" (inboard to outboard) and asks about acceptability.

1. In the first system, ABC or DEF will serve the respective turn signal functions. All lamps would serve as hazard warning signal lamps and stop lamps. Standard No. 108 generally does not prohibit lamp clusters from performing multiple functions. This s ystem is permissible as long as ABC and DEF meet all Standard No. 108's requirements for turn, hazard warning, and stop signals when tested in those modes. Your diagram, however, does not indicate which, if any, of these lamps provide the taillamp functi on that Standard No. 108 also requires for the rear of motor vehicles. Therefore, lamps ABC and DEF would have to meet the taillamp requirements as well.

2. The second system differs from the first in that the hazard warning system would not operate through all six lamps of the turn signal system, but only through the two most outboard lamps. This system is permissible, as Standard No. 108 does nor mandat e use of all turn signal lamps for the hazard warning signal mode, requiring only "at least one" on each side of the vehicle, front and rear.

3. The third system differs from the second in that the two most outboard lamps would no longer be part of the stop lamp system. We view this arrangement as permissible. Standard No. 108 requires that stop lamps, turn signal lamps, and taillamps be locat ed "as far apart as practicable". In a literal sense this would appear to require stacking the lamps vertically at the outboard edges of the vehicle, but NHTSA has not adopted a design-restrictive interpretation of this requirement. The determination of practicability is initially that of the manufacturer, but it is subject to review and comment by this agency in instances where such a determination appears clearly erroneous. Where the turn signal system (or part of it) is located at the outboard edges of the vehicle, and the stop lamps and taillamps are adjacent to it, or to each other, we view the "practicability" requirement as met.

4. The fourth system differs from the third in that the stop lamp system would be either that of the systems discussed in items 2 and 3 above, and operating according to Section 3 of your letter. Either system would be acceptable, subject to the operatio nal restriction with turn signal lamps that I shall discuss in my response to Section 3.

Next, you have presented four kinds of flashing arrangements for the turn signal lamps. You ask (a) which could meet Standard No. 108, and (b) which could meet Standard No. 108 assuming a flash cycle of 1-4 seconds. With respect to (a), all four would ap pear to be acceptable. The standard allows multiple turn signal lamps either to flash simultaneously, or sequentially in the direction of the turn. With respect to (b), Standard No. 108 specifies that a turn signal flasher provide not less than 60 and no t more than 120 cycles per minute. This translates to not less than 1 and not more than 2 cycles per second. This requirement would have to be met by all lamps in arrangement i.e. where all lamps operate simultaneously. When operating sequentially, each lamp individually would be subject to the restrictions with the result that the inclusive cycle for a three lamp system would be not less than 3 seconds and not more than 6 seconds. Therefore, arrangements (a), (b), and (c) would meet this requirement as suming a flash cycle of 4 seconds, but arrangement (d) would not, being restricted to a cycle of 2 seconds maximum.

In your third question, or Section 3 as you term it, you have combined the conditions of your first two questions and attached a table of "detailed operating states" of the rear lamps, which incorporates three attached figures, with the question whether it would comply with Standard No. 108. Two of the Operating States illustrated denote the stop lamp "on" and, individually, the right or left turn signal as "on". Standard No. 108 does not allow simultaneous activation of the stop lamp and turn signal la mp when the stop signal is optically combined with the turn signal, In that event, the circuit must be such that the stop signal cannot be turned on in the turn signal which is flashing (paragraph 4.2, SAE Standard J586c Stop Lamps, August 1970, incorpor ated by reference in Standard No. 108). Our other comment concerns "Fig. a", "Fig. b", and "Fig. c" depicting flash cycles of the turn signal lamp;. As we noted earlier, the individual lamps are subject to the cycle minima and maxima of 1 to 2 cycles per second, and none of the rates depicted in the three Figures appears to meet the minimum requirement of 1 second. Otherwise, the "Operating State" table appears acceptable.

I hope that this answers your questions.

Sincerely,

Erika Z. Jones Chief Counsel

June 5, 1987

Ms. Erika Z. Jones Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh St., S.W. Washington, D.C. 20590

Dear Mr. Jones,

On Jan. 23, 1986 we consulted NHTSA about the problems of headlamps systems, and received your reply letter of May. 8, 1986. The information was very useful to us, thank you again for your kind assistance.

Now, we still have some questions about the turn signal lamps and other rear lamps, will you please kindly give us your suggestions as soon as possible?

The feature of rear lamps of the vehicle is shown as fig. 1. In the following conditions, which could meet the requirements of the FMVSS No. 108 and other related U.S.A. regulations?

1. As shown in Fig. 1, "R", is the backup lamp, and the lighting function of the other lamps "A", "B", "C", "D", "E", "F" are shown as Table 1. In the four cases, which could meet the requirements of U.S.A. regulations?

2. As shown in Fig. 2, there are four kinds of flashing arrangements for the turn signal lamps "ABC" (LH) & "DEF" (RH). a. Which could meet the requirements of U.S.A. regulations? b. If the period of flashing (t) 1 cycle = 1 - 4 sec. which could meet the requirements of U.S.A. regulations?

3. Combining the conditions of section 1, 2, we set a detailed operating state of the rear lamps as shown in Table 2. Could it meet the requirements of U.S.A. regulations?

Your kind assistance and earlier reply will be highly appreciated.

Sincerely yours,

Yueh-An Chen Division Head Planning Division SEE HARD COPY FOR GRAPHIC INFORMATION

ID: 571.108 -- Parking Lamp Activation -- Mazda 1-- 17-0655.docx_sig (003)

Mr. David Robertson

Environmental and Safety Engineering

Mazda North America Operations

1025 Connecticut Ave NW, Suite 910

Washington, DC 20036

Dear Mr. Robertson,

This responds to your letter requesting an interpretation of the “steady burning” requirement for parking lamps under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment. You ask how the steady burning requirement for parking lamps applies to an optically combined LED parking/turn signal lamp while the turn signal is activated.1

You describe in your letter an optically combined LED parking/turn signal lamp which contains two discrete LED light sources: one that is amber and one that is white. When the LED lamp operates as a parking lamp only, the amber LED is off and the white LED is steady burning.  However, you ask about the permissibility of two alternative ways in which these LEDs could possibly operate once the turning signal is activated. Under the first alternative (“Alternative A”), the amber and white LEDs flash in an alternating pattern. To an observer of Alternative A, the lamp would alternate its color between amber and white for the duration of the turn signal’s activation, then would return to steady-white. Under the second alternative (“Alternative B”), the white LED turns off for the duration of the turn signal’s activation. To an observer of Alternative B, the LED lamp would alternate between amber and “off” for the duration of the turn signal’s activation, then would return to steady-white. This interpretation assumes that your lamp’s LEDs do not fluctuate in intensity while activated.

As explained below, our answer is it would be permissible for an optically combined parking/turn signal lamp to alternate its parking lamp and turn signal lamp LEDs while the turn signal is activated (which is the case under Alternative A), but it would not be permissible for the lamp to completely deactivate the parking lamp LED while the turn signal is activated (Alternative B).

1 We note that, while you originally requested confidential treatment of portions of your interpretation request, you withdrew that request in a subsequent communication with Daniel Koblenz of my staff, so your entire interpretation request is now publicly releasable.

In addition, as explained at the end of this letter, our interpretation about the permissibility of Alternative A applies only to lamps that use LEDs, and not to vehicles using traditional incandescent lamps.

Requirements for optically combined lamps

FMVSS No. 108 governs signal lamp performance. Under S4 of the standard, “optically combined” is defined, in relevant part, as: “a lamp having… two or more separate light sources that operate in different ways, and has its optically functional lens area wholly or partially common to two or more lamp functions.” Because your lamp meets this definition, we consider it to be an “optically combined” lamp.2 Under S6.3 of the standard, optically combined lamps are only permissible “if the requirements for each lamp, reflective device, and item of associated equipment are met.”

The specific requirements that apply to turn signal lamps are found in S7.1, and the requirements that apply to parking lamps are found in S7.8. We assume for purposes of our analysis that your lamp would meet these general requirements for both its turn signal and parking lamp functions.3

According to FMVSS No. 108, parking lamps must be activated with a vehicle’s headlamps, and they must be “steady burning” at all times.4 In past interpretations, we have understood the “steady burning” requirement for vehicle lighting to be met if the lamps is “is perceived as being steady-burning” by an observer even if, as a technical matter, the lamp is not steady burning.5

Discussion

Because your parking lamp’s LEDs are not, technically, steady burning in either of the alternatives you describe, the key question is whether the parking lamp in the alternatives would appear to be “steady burning” to an observer while the turn signal is activated.

In our view, Alternative A is permissible, while Alternative B is not.  This is because only Alternative A would give an observer the perception that the parking lamp is steady burning throughout the operation of the turn signal. Under Alternative A, an observer would see the turn signal alternate between two states: amber and white.  From the observer’s standpoint, at no point is the lamp completely off; whenever the amber LED is on, the white LED is off, whenever the amber LED is off, the white LED is on. Because there is no gap in LED illumination, an observer would perceive that the white LED is on for the entire time that the turn signal is activated, and that the white light it produces is combined with the amber LED’s light while the

2 S4.

3 Please note that there are luminosity requirements for optically combined turn signal and parking lamps that are different than the luminosity requirements for turn signal lamps and parking lamps that are not optically combined. These requirements are set out in S7.1.1.12.

4 Table I-a.

5 See letter to Kiminori Hyodo (Nov. 5, 2005), available at https://isearch.nhtsa.gov/files/Koito.2followup.html.

amber LED flashes. Because the white LED would appear to be illuminated at all times, the lamp in Alternative A would meet the “steady burning” requirement for parking lamps.6 (Please note that, because FMVSS No. 108 requires that the parking lamp be steady burning, if the lamp’s amber LED becomes inactive or is otherwise unable to meet the performance requirements for turn signals, the white LED must remain steady burning at all times, including when the turn signal is activated.)

Conversely, under Alternative B, when the amber LED is off, the lamp produces no light whatsoever. Thus, an observer would perceive that the lamp deactivates for the duration of the turn signal’s activation, which, as noted earlier would violate the “steady burning” requirement for parking lamps.

Applicability

Please note that this interpretation applies only to optically combined parking and turn signal lamps that use LEDs. This is because, unlike traditional incandescent lamps, LEDs are capable of turning on and shutting off almost instantaneously. Traditional incandescent lamps take some time to power up and shut off, which means that if an optically combined incandescent lamp were to flash according to Alternative A, there would be observable gaps in illumination while the lamp is powering up. Because an observer would be able to perceive these gaps, an observer would not perceive the lamp to be steady-burning. Therefore, Alternative A would not be permissible for an incandescent lamp.

If you have any questions, please contact Daniel Koblenz of my staff at (202) 366-2992.

Sincerely,

JONATHAN CHARLES MORRISON

Digitally signed by JONATHAN CHARLES MORRISON

Date: 2020.06.11 14:16:32

-04'00'

Jonathan C. Morrison Chief Counsel

Dated: 6/11/20

Ref: FMVSS No. 108

6 It is NHTSA’s understanding that, due to the photometric differences between LEDs and incandescent light sources, if the white LED were to stay illuminated while the amber LED flashed, the combined light of the two LEDs would appear to be pink in color, rather than amber.

ID: aiam3532

Dear Mr. Ziwica: This responds to your letter asking several questions about the use o informational readout displays in relation to FMVSS 101-80 *Controls and Displays*, 105 *Hydraulic Brake Systems* and 208 *Occupant Crash Protection*.; Each of your questions assumes the use of informational readou displays as telltales. The light intensity requirements of Standard No. 101- 80 currently prevent informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section requires that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.; The agency has recently issued a notice of proposed rulemaking (NPRM that would permit informational readout displays to be used as telltales. We have enclosed a copy of that notice.; I would like to point out the following statement in the NPRM: >>>Various amendments may be necessary to Standard No. 101-80, as wel as to several other safety standards which include requirements for warning indicators, to permit fuller use of informational readout displays. The amendments proposed by this notice are a first step in that direction.<<<; We would welcome any comments that you might have on this matter t assist us in future rulemaking. You may also wish to consider submitting a petition for rulemaking on any changes that you believe should be made.; The following discussion explains the effect that the proposal woul have on your questions.; *Question 1* Your first question asks whether the words 'Fasten Seat Belts' may b used in an informational readout display instead of the seat belt warning symbol under FMVSS 101-80 and 208.the answer would be yes under the proposal. The NPRM states:; >>>Sections S4.5.3.3(b) and S7.3 of S571.208 would be amended to permi the words 'Fasten Belts' or Fasten Seat Belts' as an alternative to the seat belt warning symbol in informational readout displays.<<<; *Question 2* Your second question concerns the possibility of allowing cancellatio of telltales by voluntary action on the part of the driver. The question asks whether it is permissible to provide a push button that enables drivers to cancel telltales. The answer to this question, which is not dealt with in the NPRM, is no.; While the question is asked separately for the seat belt telltale an telltales not required by any safety standard in the first place, the answer is not dependent of that distinction. Section S5.3.3 of Standard No. 101-80 requires that the light intensity of each telltale shall not be variable and shall be such that, when activated the telltale and its identification are visible to the driver under all daytime and nighttime conditions. We interpret this section to mean that a telltale cannot be cancellable. If it were cancellable, the telltale would not meet requirements that it not be variable and that it be visible to the drive under all daytime and nighttime conditions.; We note that the activation requirements for the seat belt telltal depend on whether it is for a manual belt or automatic belt. For a manual belt, section S7.3 of Standard No. 208 states that the seat belt assembly provided at the driver's seating position must be equipped with a warning system that activates for a period of not less than 4 seconds and not more than 8 seconds a continuous or flashing light. Thus, while a manufacturer has the discretion to provide an activation time of between 4 and 8 seconds, the telltale still may not be cancellable.; Section S4.5.3.3 requires a different type of warning system fo automatic belts. While the audible signal must be activated for a period of not less than 4 seconds and not more than 8 seconds, the visual warning light must be activated for as long as the belt is not fastened.; *Question 3* Your third question asks whether it is permissible to use a information readout display to meet the visual brake warning system requirements of Standard NO. 105. The answer would be yes under the proposal.; Section S5.3.5 of Standard No. 105 states: >>>Each indicator lamp shall have a lens labeled in letters not les than 1/8-inch high, which shall be legible to the driver in daylight when lighted. The lens and letters shall have contrasting colors, one of which is red....<<<; It is our interpretation that the illuminated pattern of letters an glazing of an information readout display would constitute a 'lens labeled in letters.' This interpretation leaves unanswered other questions about whether a particular informational readout display would meet other requirements of Standard No. 105, such as the color requirement of section S5.3.5.; *Question 4* Your fourth question asks whether an informational readout displa specifying specific brake problems constitutes separate indicator lamps under the language of Standard NO. 105, if a brake warning lamp is present which separately fulfills the requirements of S5.3.5 of Standard No. 105. The answer is no.; Section S3 of Standard No. 105 specifies various performanc requirements for brake system indicators lamps. Under section S3.5, a manufacturer may meet the requirements either by a single common indicator or by separate indicator lamps.; It is our interpretation that if a manufacturer separately meets th requirements of section S3 by a single common indicator lamp, additional indicator lamps that are added voluntarily by the manufacturer are not subject to Standard No. 105's requirements.; *Question 5* Your fifth question asks about the requirements for an informationa readout display which is a telltale. The NPRM proposes the following language:; >>>S5.3.3.2 Telltales and gauges incorporated into informationa readout display--<<<; >>>(a) Shall have not less than two levels of light intensity, a highe one for day and a lower one for nighttime conditions.<<<; >>>(b) In the case of telltales and gauges not equipped with a variabl light intensity control, shall have a light intensity at the higher level provided under paragraph (a) of this section whenever the headlamps are not illuminated.<<<; >>>(c) In the case of telltales and gauges equipped with a variabl light intensity control, shall be visible to the driver under all daytime and nighttime conditions when the illumination level is set to its lowest level.<<<; The agency does find the system that you are considering developin very interesting. If you do submit a petition for rulemaking, there is one issue that we would appreciate your addressing. Our initial reaction to the idea of permitting drivers to cancel telltales is one of concern, since drivers might either cancel a telltale inadvertently or simply forget that they have done so. An informational readout display which flashed its warnings in sequence might answer those concerns. We would appreciate your addressing the safety consequences of those and any other alternatives that your might be considering.; Sincerely, Frank Berndt, Chief Counsel

ID: nht92-9.46

DATE: January 21, 1992

FROM: William H. Spain -- Touch Wood

TO: Taylor Vinson -- Legal Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/27/92 from Paul J. Rice to William H. Spain (A39; Std. 108)

TEXT:

We have developed a lighting device for heavy duty trucks which may or may not fall under the purview of NHTSA statues.

We have very briefly discussed this with your Mr. Britell and Mr. Cavey, who suggested that we submit the information to you.

I am attaching a description of the device and as a separate item the way we feel the statues may or may not apply to it. Please be patient and understanding as I am not a lawyer.

I want to be clear in that we are not seeking an endorsement or even an opinion as such. We do not want to put you in the position of having to make a ruling. All we ask is your initial first impression as to whether or not we might have a problem. We have spent quite a bit of time and money on this device and are to the point of manufacture. If we have a problem then we need to stop now and back away from it. We do not intend to get into an argument over it, we will let it die first. We do however think it is a needed device that is totally in harmony with the stated purpose of 571.108 and that the device will save lives.

Realizing how very busy you must be as well as needing an indication at your earliest convenience, I have tried to keep the attached as brief as possible.

Your assistance is very much appreciated and we will be looking forward to hearing from you.

AUXILIARY LIGHTING DEVICE

As you are aware on trucks both the left and right turn signal circuits are separate from the tail lamp circuit. This device uses both the left and right turn signal circuit to act as either emergency/auxiliary tail lamps or as fog lamps. When in use neither of these new functions will interfere with normal operation of the turn signals. Each function shall be described separately.

These two new functions are controlled by a normal toggle switch mounted on the vehicle dash. In the toggle switches normal position, it is off.

It is not an uncommon occurrence for a tractor/trailer to lose its tail lamps due to a circuit or wiring malfunction. A obvious contributing factor is the constant switching of trailers between trucks. When this occurs the driver's only choice on the road is to switch on his hazard flashers which is not their intended purpose and is disconcerting to other motorists. It also defeats his normal turn signal circuits.

If our toggle switch is flipped upward to a position marked (on a nameplate) "EMERG T/LMPS", then two things happen. Firstly the center of the toggle switches lever, or paddle is illuminated and glows red. This is to remind the driver that he has something on that is not normal and to remind him to turn it off when it is no longer needed. Secondly a reduced voltage is fed through both right and left rear turn signal circuits to cause both turn signal lamps to illuminate at a reduced brilliance equal to that of a normal tail lamp. If either turn signal is activated then the full voltage is fed to that particular (left or right) lamp and the lamp flashes at its normal turn signal brilliance. To an observer the net effect is the same as normal turn signal operation (which it is).

In the event of a failure of the normal tail lamps this device provides a means of normal illumination on the vehicle's trailer and allows the driver to proceed in a safe manner to a location to have the failed, regular tail lamps repaired.

Another problem with all vehicles is reduced visibility in fog. In heavy fog the only present choice is for a motorist or trucker to activate their hazard flashers for increased rear visibility. Again this practice is disconcerting and defeats the use of normal turn signals. The European countries allow and on some trucks require a rear special fog lamp of increased brilliance for use in fog.

If our switch is flipped downward to a position marked R/FOG again two things happen. First the center of the switch will illumine red. Second a higher voltage is fed through both rear turn signal circuits to cause them to burn at approximately their full brilliance. If however either turn signal is activated then that particular (right or left) side reverts to normal turn signal operation. Therefore normal turn signal operation is not defeated.

The circuitry of our device is so configured that it automatically adjusts for the particular number of turn signal lamps on a particular truck/trailer.

STATUTES

First it shoUld be noted and considered that this device is totally in harmony with the stated purpose of 571.108.

There are obviously two directions to take in considering application of 571.108 to this device. It is very likely that 571.108 does not apply to this device. This is an auxiliary device. It does not affect those items which are required by 571.108 and auxiliary devices of this nature are not addressed by 571.108.

This device in its emergency tail lamp mode would be used only upon failure of the vehicle's regular lighting system. Its effect would be no different from the driver calling a wrecker which after hooking up would place the wrecker's own emergency tail lamps upon the rear of the towed vehicle. Obviously the wrecker's portable emergency/auxiliary tail lamps do not have to comply with 571.108 although they become the towed vehicle's tail lamps. Just as obviously they are needed on the rear of the towed vehicle on a temporary basis.

This device in its rear fog lamp mode would be two auxiliary lamps on the rear which do not interfere with normal operation of either the vehicle's normal tail lamps or turn signals. For that matter all new Jaguar automobiles imported into the U.S. come with two rear fog lamps as standard.

If however the position were to be taken that this device does fall under 571.108 then it becomes more complicated. S5.1.1.11 refers to minimum candlepower for turn signal LAMPS. This does not apply as it is common practice for manufacturers to utilize a common LAMP for both tail lamp and turn signal function. Although they do this by utilizing a dual filament bulb and dual circuits, there is no section of 571.108 requiring that this particular method be used. The net effect of our device would be identical to that of a dual filament bulb/separate circuit.

As our device does not impair the operation of any lamps required by 571.108 then we are in compliance with S5.1.3.

Whereas the normal location of rear turn signal lamps on any vehicle is assumed to be in compliance with 571.108 then these exact same lamps would also be in compliance when illuminated by our device (S5.3.1.1).

it is possible that we may have to configure our circuit in such a manner that when our switch is in the up position for emergency tail lamps it wold be on whenever the vehicle's headlamps were on. (S5.5.3).

Reference S5.5.10 (a) and when the turn signal lamps are used in conjunction with our device they are wired to flash. The lamps do not however become turn signal lamps until such time as the turn signal function is selected (by the operator). Prior to that time, the circuit, filaments, lamps, etc. can be used for other purposes as they are not turn signals until activated for that function and purpose. An example of this is the use of the turn signal circuit, filaments and lamps as stop lamps on many cars. The circuit, filaments and lamps are used in stop lamp mode until they are activated as turn signals at which time the stop lamp mode is interrupted on the appropriate side and they become turn signal lamps.

ID: Wallach.3

ID: nht79-2.16

DATE: 11/02/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Hisakazu Murakami Technical Representative - Safety Engineering Office of North America Nissan Motor Co., Ltd. 1919 Pennsylvania Ave., N.W., Suite 707 P.O. Box 57105 WashinSton, D.C. 20037

Dear Mr. Murakami:

This is in response to your letter of September 14, 1979, in which you asked about the applicability of the variable intensity illumination requirements of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays, to various components in your company's automobiles. You listed and identified these parts in Figure 1 of your letter which will refer to in answering your questions.

The variable intensity illumination requirements of section 5.3.3 of Safety Standard 101-80 are applicable to (1) "con- trols, gauges, and their identification, and to (2) any illumination that is provided in the passenger compartment when and only when the headlights are activated." As noted in section 5 of Safety Standard 101-80, the location identification, and illumination requirements are applicable only to passenger cars and other vehicles equipped with any control listed in section 5.1 or in column 1 of Table 1. The term "gauqe" is defined in Section 4 as a "display that is listed in section 5.1 or in Table 2 and is not a telltale."

Applying these criteria to the list of automobile components in your letter, I have concluded that none of the listed components, except the ordinary clock and the automatic gear position illumination lamp, are subject to the requirements of section 5.3.3 of Safety Standard 101-80. Since this result resolves the issues raised in Questions Q2.1 - Q2.5 of your letter, I have not addressed them in this response.

The components identified in your diagram by letters a - h (the room lamp, spot lamp, luggage room lamp, personal lamp, radio, foot lamp step lamp, and the luggage room lamp for hatchback vehicles) are not subject to the requirements of section 5.3.3. This is because they are not controls listed in section 5.1 or in column 1 of Table 1 of Safety Standard 101-80 and because they do not illuminate the passenger compartment when and only when the headlights are activated.

Similarly the glove box lamp and the console box lamp (items i and j) are not subject to section 5.3.3. They are not controls listed in Safety Standard 101-80 and they are not activated when and only when the headlights are activated since their activation requires both opening the box lids and switching on the headlights.

The ignition key illumination lamp (item k), which is not a control listed in Safety Standard 101-80, is activated when the light control switch is turned to the "small lights only" position (this activates the clearance clamps, identification lamps, and other exterior lamps other than the headlights.) When the switch is turned to the position that activates both, the small lights and the headlights, the key illumination lamp is deactivated. Consequently, the lamp is not activated when and only when the headlights are activated and is, therefore, not subject to the variable intensity illumination requirements.

You noted in conversation with Ms. Debra Weinner of my office that your company uses two types of clocks (item 1 in your letter) in its automobiles. One is an ordinary clock whose face is illuminated when and only when the headlights are activated. The requirements of section 5.3.5 would apply to the illumination of this type of clock.

The other clock used in your company's automobiles is a digital clock with a flourescent readout which shines with greater intensity during the day and with a lower intensity at night when the headlights are activated. Since this clock is not a control or a display listed in Safety Standard 101-80 and its illumination is not activated when and only when the headlamps are activated, the requirements of section 5.3.3 for continuously variable illumination are not applicable. Section 5.3.3 also provides that light intensity for informational readout systems shall have at least two values. The term "informational readout systems" which is not defined in Safety Standard 101-80 refers to the term "informational readout display," which is defined as "a display using light-emitting diodes, liquid crystals, or other electro illuminating devices where one or more than one type of information or message may be displayed." The term "display" includes only those displays listed in section 5.1 or in column 1 of Table 2 of the standard and these listings do not include a digital clock. Therefore, the digital clock would not be subject to the light intensity requirements for informational readout systems.

The automatic gear position illumination lamp (item m in your letter) is subject to the variable intensity illumination requirements of section 5.3.3. Although it is not a control (see preamble to Safety Standard 101-80, 43 FR 27541, June 26, 1978) this lamp is activated when and only when the headlights are activated.

In Question 2 of your letter, you asked for the definition of the terms "continuously variable" and "variable." The term "continuously variable" is defined in section 5.3.3(a) and (b) of Safety Standard 101-80. It is followed by a description of the two light intensities which must be provided for informational readout systems. The term "variable" appears in the next sentence in section 5.3.3 which states that:

"The intensity of any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable in a manner that complies with this paragraph.

The underlined words in the quoted sentence refer to the definition of "continuously variable" except in the case of informational readout displays where the words refer to illumination of two intensities.

If you have any further questions, I will be happy to answer them.

Sincerely,

Frank Berndt Chief Counsel

September 14, 1979

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

Dear Mr. Berndt:

Re FMVSS 101-80 - Controls and Displays I would like to take this opportunity to ask for your interpretation with regard to FMVSS No. 101-80 - Controls and Displays.

I would appreciate it if you could please answer the questions that I have attached.

Thank you for your usual fine cooperation.* CR Very truly yours,

NISSAN MOTOR CO., LTD.

Hisakazu Murakami Technical Representative Safety

HM:kb

Attachments Q-1 Generally speaking, would it be necessary for each one of items (a) to (m) in Figure-1 to meet the requirements of S 5.3.3?

Q-2 Assuming that your answer to Q-1 is "yes",

Q-2.1 Please explain the reason for your answer being "yes"

Q-2.2 Would the light intensity of (a) to (e), as shown in Figure-1, and having individual "On-Off" Manual Switches be considered variable?

Q-2.3 Would the light intensity of (f) Foot Lamp, (g) Step Lamp and (h) Luggage Room lamp, which light automatically only when doors are open, and not when they are closed, be considered variable?

Q-2.4 Would the light ingensity of (i) Glove Box Lamp and (j) Console Box Lamp, which are placed in their boxes and light only when the headlights are activated and their lids are open, be considered variable?

Q-2.5 Would the light intensity of (k) Ignition Key Illumination Lamp, which is placed near ignition key cylinder and lights only when clearance lamps, identification lamps and side marker lamps, etc. (other than headlights) are lit, be considered variable?

Q-2.6 Would the clock (1) with the flourescent display be considered to be the informational readout system?

Q-2.7 Assuming that your answers to Q-2.2 -Q-2.5 are "no", please explain the definition of the word "variable" and "not continuously variable".

Q-2.8 Would the light intensity of (m) Automatic Gear Position Illumination Lamp, which is placed on the floor-console box, be required to be variable, or continuously variable?

**INSERT** (a) Room (Dome) Lamp

(b) Spot Lamp (like one in airplane)

(c) Luggage Room for wagon vehicle -

(d) Personal Lamp for rear seat passengers

(e) Radio

(f) Foot Lamp

(g) Step Lamp

(h) Luggage Room Lamp for hatchback vehicle

(i) Glove Box Lamp

(j) Console Box Lamp

(k) Ignition Key Illumination Lamp (l) Clock

(l) Clock

(m) Automatic Gear Position Illumination Lamp -

FIGURE - 1