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Interpretation ID: 24780.drn

    Mr. Kenneth Reed
    Product Legislation and Compliance
    Jaguar Cars
    555 MacArthur Blvd.
    Mahwah, NJ 07430-2327


    Dear Mr. Reed:

    This responds to your request for an interpretation of "daylight opening" in Federal Motor Vehicle Safety Standard No. 104, Windshield wiping and washing systems. You ask whether the daylight opening should be measured to the edge of complete blackout area, the start of dot fade area, or to some point in between. As explained below, the daylight opening is measured to the edge of complete blackout area on the windshield.

    Daylight opening is defined at S3 of Standard No. 104 as: "the maximum unobstructed opening through the glazing surface, as defined in paragraph 2.3.12 of section E, Ground Vehicle Practice, SAE Aerospace-Automotive Drawing Standards, September 1963."

    Paragraph 2.3.12 of the SAE standard states:

    The term "Daylight Opening" (abbreviated DLO) refers to the maximum unobstructed opening through any glass aperture, including reveal or garnish moldings adjoining the glass, according to a given direction or projection. If not specified the dimension will be the vertical projection.

    I note that SAE Recommended Practice J1100, which you quote, is a later SAE document, and not the one referenced in Standard No. 104. One difference between the definition of "daylight opening" in the older document and the one in J1100 is that the newer one treats "opaque coatings" in the same manner as reveal or garnish moldings.

    Opaque coatings around the edge of the windshield are now used for the function once served by moldings, i.e., covering the glue around the edges of the windshield. Given this changed technology, we believe it is appropriate to treat opaque coatings around the edge of the windshield in the same manner as moldings, in interpreting the term "daylight opening" in Standard No. 104. However, this is only true for what you refer to as "complete blackout" or "truly opaque" areas. The dot fade area is not truly opaque, and is not analogous to moldings. Thus, daylight opening is measured to the edge of complete blackout area.

    I hope this information is helpful. If you have any further questions, please contact Ms. Dorothy Nakama this address or at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    ref:104
    d.5/6/03