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Interpretation ID: wakley.2.wpd

    Mr. Mark Wakley
    25919 25th Lane South, Apt. E-201
    Kent, WA98032


    Dear Mr. Wakley:

    This is in response to your several e-mails in October 2003, concerning your desire to have the daytime running lights (DRLs) on your model year 2004 Chevrolet Cavalier disconnected. I understand that you discussed this issue at length with Eric Stas and other agency staff. You stated that your vehicle is equipped with DRLs that illuminate upon vehicle start-up and that there is no manual on-off switch. You stated that despite repeated requests, General Motors is unwilling to provide a means to disable the DRLs. Further, you described problems this has engendered in your delivery operations to military bases and other federal facilities, which require extinguishment of such lighting as a security measure.

    Because DRLs are not required motor vehicle equipment, we confirm that manufacturers, distributors, dealers, and motor vehicle repair businesses are free to disconnect the vehicles DRLs or to install an on-off switch, at customer request. As the vehicle owner, you are also free to disconnect the DRLs yourself. However, vehicle manufacturers are not required to provide a means to disable DRLs.

    By way of background, Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment, does not require vehicle manufacturers to install DRLs on new vehicles; however, if manufacturers choose to install such devices, paragraph 5.5.11 of the standard sets forth certain performance requirements. Paragraph S5.5.11(a) provides that DRLs are to be "automatically deactivated when the headlamp control is in any on position, and as otherwise determined by the vehicle manufacturer." In the context of paragraph S5.5.11(a), "headlamp control" refers to those position(s) of the master lighting switch that cause the headlamps themselves to be turned on.

    Because DRLs are not required by FMVSS No. 108, manufacturers, distributors, dealers, and motor vehicle repair businesses may disconnect DRLs or provide on-off switches without violating the statutory prohibition against knowingly making inoperative any device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard. 49 U.S.C.

    30122. However, these entities may not alter the performance specifications of DRLs in a manner that would make them not comply with the performance requirements specified for DRLs under the standard.

    I hope that this clarifies NHTSAs regulations related to DRLs. If you have any further questions regarding our regulations, please contact Eric Stas of my staff at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    ref:108
    d.1/22/04