Interpretation ID: aiam3838
Intec
23132 La Cadena
Laguna Hills
CA 92653;
Dear Mr. Moore: This responds to your April 24, 1984 letter regarding the installatio of a closed circuit television viewing system in new vehicles, as an alternative to rearview mirror systems. The television system provides a view of the area behind the vehicle from a monitor screen placed on or near the dash.; As you note in your letter, Federal Motor Vehicle Safety Standard 11 specifies the use of rearview mirrors to provide improved rearward and side visibility in new motor vehicles. No provision is made for alternative means of compliance such as closed circuit television systems, so such alternative systems are not authorized. However, the closed circuit system could be used as a supplement to a mirror system which meets the requirements of Standard 111.; The only options available to a vehicle manufacturer seeking to use closed circuit system as a replacement for the required mirror system would be to file a petition to amend the standard or a petition for an exemption from the standard. Requirements applicable to these petitions are set forth in Title 49 of the Code of Federal Regulations, Parts 552 and 555, respectively,. These petitions are only granted in the limited circumstances set forth in those regulations.; If you have further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel