Interpretation ID: aiam0380
Esq.
Volkswagen of America
Inc.
Englewood Cliffs
NJ 07632;
Dear Mr. Riechel:#This is in replay to your letter of June 2 requestin confirmation of certain matters concerning compliance of the 1973 model Volkswagen Type I (Beetle) and Type II (Station Wagon) vehicles with Motor Vehicle Safety Standard No. 101.#We confirm that the arrangement, identification, and illumination of the heater and defroster controls as described at the meeting of May 25 between representatives of this agency and Volkswagen, and as presented in your letter of June 2, appear to meet the intent of Standard No. 101. Specifically, the requirement of paragraph S4.3 that control identification 'shall be illuminated whenever the headlamps are activated' does not necessarily require the installation of a separate light source to illuminate the identification of each control. Thus, if the ambient illumination emanating from the dash panel provides sufficient illumination to identify heater and defroster controls mounted on the drive shaft tunnel, then the illumination requirement would appear to be met. We agree that the use of contrasting lettering on the control knobs increases the likelihood that this method of compliance would meet the intent of Standard No. 101.#Sincerely, Robert L. Carter, Acting Associate Administrator, Motor Vehicle Programs;