Interpretation ID: 22203.ztv

Mr. Thomas V. Wolcott
Test Engineering Manager
Nevada Automotive Test Center
P.O. Box 234
Carson City, NV 89702-0234

Dear Mr. Wolcott:

This is in reply to your letter of September 26, 2000, requesting an interpretation concerning a motorcycle braking configuration.

You state that the master cylinder in the system "would be actuated hydraulically using the standard handlebar mounted lever." You further describe the system in some detail and inform us that your vehicle will comply with "all regulations regarding volume and wording on the cap." The intent of the design is "to be able to remote mount the master cylinder unit to a more protected and less visible area of the motorcycle." You have not been able to find a regulation or standard that would not allow this configuration.

The Federal motor vehicle safety standards (FMVSS) are intended to establish performance requirements, leaving the design of systems to the manufacturer. There is nothing in the Federal motorcycle braking standard (FMVSS No. 122), controls and displays standard (FMVSS No. 123) or any other FMVSS or regulation that would prohibit the motorcycle brake system configuration described in your letter.

Sincerely,
Frank Seales, Jr.
Chief Counsel

ref:122
d.11/1/00