Interpretation ID: 27124.ztv

Mr. Dennis G. Moore
Sierra Products, Inc.
1113 Greenville Road
Livermore, CA 94550

Dear Mr. Moore:

This is in reply to your letter of May 25, 2000, asking for an interpretation of Standard No. 108 as it concerns Light-Emitting Diode (LED) lamps.

You believe that the agency is allowing manufacturers of LED lamps to "violate" the requirements of Federal Motor Vehicle Safety Standard No. 108 with respect to the "effective projected luminous lens area" specifications.

As you know, the agency has been engaged for some time in rulemaking to adapt Standard No. 108 to accommodate LED technology. In the Notice of Proposed Rulemaking that established Docket No. NHTSA-98-3967, we asked for comments on the issue that you raise. This issue will be discussed in the preamble to the final rule presently being prepared. In the meantime, I am sending your letter to this docket as a comment to be considered.

Thank you for your interest in motor vehicle safety.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.7/12/00