Interpretation ID: nht91-7.48

DATE: December 16, 1991

FROM: William R. Willen -- Managing Counsel, Product Legal Group, American Honda Motor Co., Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 1/28/92 from Paul Jackson Rice (Stephen P. Wood) to William R. Willen, Esq. (A39; Std. 123)

TEXT:

I am writing to you seeking an interpretation.

FMVSS 123, in section 5.2.1. contains the following language: "if a motorcycle is equipped with a self proportioning, or an antilock braking device utilizing a single control for both front and rear brakes, the control shall be located and operable in the same manner as a rear brake control."

Honda is in the final stages of developing an advanced version of their proportional braking system for motorcycles. It offers:

a) Full proportioning front and rear when utilizing either the front hand control, or the rear foot control.

In order to fully comply with the "letter" of the standard, this system would seem to be out of compliance when the front hand brake is applied.

Honda feels that it is an obvious safety advantage to offer the full extent of proportioning, with "any" brake application! Honda also feels that the authors of 123 did not foresee the possibility of proportioning, being available with the application of the right, front handlebar lever.

Since the "full spirit" of FMVSS 123 is being met, Honda is seeking an interpretation of this system that would permit the use of these advancements. Telephone conversations have taken place between Doug Toms, an advisor on the project, and Steve Wood. Honda stands ready to answer any questions, or provide additional technical detail should that be desired.

Honda will be conducting sales "decision meetings" on Jan. 22, and 23, 1992. It would be most helpful if some "feeling" for your response could be gained by telephone just prior to those dates.