Interpretation ID: aiam0653
Assistant Vice President
Mercedes-Benz of North America
Inc.
158 Linwood Plaza
Fort Lee
NJ 07028;
Dear Mr. Gerth:#On November 9, 1971, you wrote concerning th requirement in Standard No. 101 that a control be provided to adjust the intensity of control illumination, continuously variable from an 'off' position to a position providing illumination sufficient for the vehicle operator to readily identify controls under conditions of reduced visibility. You asked an interpretation that 'the term 'off' means a control position which provides minimal control illumination which is not distracting to the driver who has adapted to dark ambient roadway conditions.'#In our opinion, the word 'off' means a control position providing no illumination, and we therefore do not concur in your interpretation. You have asked, however, as an alternative, that your letter be considered as a petition for rulemaking to amend Standard No. 101 to provide an option permitting the type of control already incorporated in Mercedes-Benz vehicles.' We have tentatively determined that your petition has merit, and that quantitative levels for control illumination intensity should be established in Standard No. 101. We shall therefore initiate appropriate rulemaking with a proposed effective date of September 1, 1973.#Sincerely, Douglas W. Toms, Administrator;