Interpretation ID: aiam3056
Esq.
Legal Counsel
Engineering Division
Yamaha Motor Corporation U.S.A.
P.O. Box 6555
Cypress
CA 90630;
Dear Mr. Schmitt: This is in reply to your letter of July 2, 1979, to our former Chie Counsel, Joseph Levin asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.; You have quoted Column 3 of Table IV with respect to motor cycl headlamps and the specification that the one headlamp the standard requires be located 'on the vertical centerline, except that if two are used they shall be symmetrically disposed about the vertical centerline'. Yamaha would like to equip certain motor cycles with two headlamps, one to be mounted above the other on the vertical centerline with the hope that 'this may increase conspicuity and facilitate safety'. You have asked whether this mounting arrangement conforms with Standard No. 108.; The arrangement you have in mind is not permitted by the Federa lighting standard. 'Symmetrically disposed about the vertical centerline' means that each headlamp is an equal distance from the vertical centerline at the same horizontal location. We believe that this provides better and more evenly distributed forward illumination than the system Yamaha proposes, while being the equivalent in conspicuity.; Sincerely, Frank Berndt, Chief Counsel