Interpretation ID: 21499.ztv

Mr. Walter Lewis
Senior Compliance Engineer
Porsche Cars North America, Inc.
980 Hammond Drive
Suite 1000
Atlanta, GA 30328

Dear Mr. Lewis:

We are responding to your letter of April 6, 2000, asking for an interpretation of S5.5.7(b) of Federal Motor Vehicle Safety Standard No. 108 as it applies to Porsche's "Coming Home Light."

Paragraph S5.5.7(b) requires that the taillamps, parking lamps, license plate lamps and side marker lamps be activated when the headlamps are activated in a steady-burning state. Porsche's "Coming Home Light" illuminates the environment around the car "by energizing the headlamps for a short period of time after the key is removed from the ignition." You believe that there is no safety benefit from illuminating these other lamps during the period that the "Coming Home Light" is in use, and ask for an interpretation that it is not subject to S5.5.7(b).

We agree with your conclusion. Devices of this nature have been installed on motor vehicles for over 20 years. The "Coming Home Light" feature is not in use when the vehicle is being operated on roadways, and is activated only when the vehicle is at rest and the ignition key removed. The purpose of Standard No. 108, as stated in S2, is "to reduce traffic accidents. . . by providing adequate illumination of the roadway and by enhancing the conspicuity of motor vehicles on the public roads so that their presence is perceived and their signals understood . . . ." The use of headlamps for a purpose other than those prescribed in S2 does not require compliance with the requirements of Standard No. 108. Thus, S5.5.7(b) does not apply in this instance, and the lamps listed therein need not be activated when the headlamps are activated in the "Coming Home Light" mode.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/19/00