Interpretation ID: aiam0903
Sales Coordinator - Direct Sales
Mobile Aerial Towers
Inc.
2314 Bowser Avenue
Fort Wayne
IN 46803;
Dear Mr. Bryan: This is in reply to the questions you asked in your letter of Octobe 24, 1972, to Mr. Wells of the Federal Highway Administration concerning compliance with Standard No. 108 of trucks to which mobile aerial towers are mounted.; '1. The aerial tower is considered a load rather than part of th vehicle to be included in determining the overall length. Correct?'; Correct. '2. Are amber *intermediate side marker* lights and/or reflector required on the body?'; If overall length of the vehicle is 30 feet or more, intermediate sid marker lamps and reflectors are required, and they must be located at or near the midpoint between the front and rear side marker lamps and reflectors.; '3. Are amber *side marker* lights and/or reflectors required on th body?'; Front amber side marker lamps and reflectors are required to be mounte as far to the front as practicable on a vehicle. Generally, this is somewhere on the front fender, though in some configurations a manufacturer might determine that a location on the truck body is as far to the front as practicable.; '4. Are amber *clearance* lights and/or reflectors required on th *front* of the body?'; Yes. Front clearance lamps are required to indicate the overall widt of the vehicle and to be mounted 'as close to the top [of the vehicle, exclusive of load] as practicable.'; '5. If a unit is over 30 ft. long, will amber *side marker* lights an reflectors suffice *also* as amber *intermediate side marker lights and reflectors*?'; No, they will not. As the above answers indicate, the locatio requirements are different for front and intermediate side markers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel