Interpretation ID: aiam4419
Director
Office of Fleet Management
Delivery Services Department
United States Postal Service
475 L'Enfant Plaza
SW
Washington
DC 20260-7200;
Dear Mr. St. Francis: This is in reply to your letter of March 26, 1987, regarding deliver vans constructed to Postal Service specifications. You have asked for relief from the requirement that these vehicles be delivered with a license plate lamp because, except in the District of Columbia (DC), the Postal Service is not required to license its vehicles. According to contract specification with the manufacturer of the vehicles, Grumman Allied Industries, Inc., the license plate bracket and lamp assembly are not required, however, the Postal Service has required the wiring and identification of its location for installations for DC service, and for future use after disposal by the Postal Service.; As you know, Federal Motor Vehicle Safety Standard No. 108 *Lamps Reflective Devices, and Associated Equipment* requires motor vehicles to be manufactured with license plate lamps meeting the requirements of SAE Standard J587 OCT81; License Plate Lamps (Rear Registration Plate Lamps)*. Paragraph 2 o SAE J587 defines a license plate lamp as 'a lamp used to illuminate the license plate on the rear of a vehicle.' If a manufacturer knows that the vehicle, as sold it its first purchaser, will not be required to bear a rear registration plate, then it may produce the vehicle without a license plate lamp, and this omission will not constitute a failure to comply with Standard No. 108.; Sincerely, Erika Z. Jones, Chief Counsel