Interpretation ID: aiam4300
Director of Marketing
Sky-Top Sunroofs Ltd.
4700 Le Bourget Drive
St. Louis
MO 63134;
Dear Mr. Krieger: This responds to your letter of November 4, 1986, in which yo requested that this agency amend Federal motor vehicle safety standard (FMVSS) 118, *Power Operated Window Systems*.; In your letter, you mentioned an electronic touchpad, known as th DOORMAN keyless entry system, and stated that it is designed to be used by someone outside a vehicle to operate your power sunroof. You requested that this agency amend paragraph S3(c) of the standard, which currently permits the operation of power windows and vehicle exterior, to permit the operation of a sunroof by means of an electronic touchpad system.; There is no need to amend Standard 118 to permit the use of you touchpad since the reference in Standard 118 to power-operated window and partition systems does not include sunroofs. Windows include the typical power windows on the sides of many vehicles and to the power tailgate windows on station wagons. Partitions refer to movable surfaces, such as those found inside some taxicabs and limousines, which separate different portions of the vehicle interior from one another.; Since there is no need to amend Standard 118, we are treating you letter as a request for interpretation and trust that it is fully answered by this response.; Sincerely, Erika Z. Jones, Chief Counsel