Interpretation ID: aiam2914
Esq.
Messrs. Brownfield
Kosydar
Bowen
Bally & Sturtz
140 East Town Street
Columbus
OH 43215;
Dear Mr. Bally: We understand that you are interested in an interpretation of th relationsip (sic) of a rear lighting system, developed by your client Mr. Leno Bevilacqua, to Federal motor vehicle lighting requirements. As you described this device in your letter of September 29, 1978, to the Nevada Department of Highways:; >>>'The device will project a green light for the vehicle which woul be in a constant or accelerated speed, a yellow light for the vehicle in a decelerated moving state and a red light for the vehicle which would be stopping.'<<<; Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflectiv Devices, and Associated Equipment*, (49 CFR 571.108) neither requires nor expressly prohibits a lighting device of this nature as original equipment on motor vehicles. One section of the standard, however, S4.1.3, prohibits the installation of all original lighting equipment not mandated by the standard 'that impairs the effectiveness of lighting equipment required by this standard.' While we make no judgment with respect to Mr. Bevilacqua's 18-inch long 1 1/2 inch high rectangular device, I think it important to note that the agency's research into rear green signal lights indicate that there may be disadvantages rather than advantages to such a lighting system. One major disadvantage is the problem of confusing the unfamiliar colored rear lamps in urban environments having multicolored lights.; Standard No. 108 does not cover this device as an aftermarket item, an it would therefore be subject to regulation by the individual States.; Sincerely, Joseph J. Levin, Jr., Chief Counsel