Interpretation ID: aiam3317
Project Engineer
Vetter Corporation
1150 Laurel Lane
San Luis Obispo
CA 93401;
Dear Mr. Golde: This is in reply to your letter of May 28, 1980, with respect to you proposals for lighting requirements for a motorcycle sidecar currently under development. Your letter does not state so, but you indicated in your telephone conversation with Mr. Vinson of this office that the sidecar is detachable.; It has been the position of this agency that a detachable sidecar is a item of motor vehicle equipment to which no Federal motor vehicle safety standards apply. Conformance of the motorcycle therefore is judged without the sidecar attached. Therefore, the front turn signal configuration in Figure F2 would appear to meet Standard No. 108 but the asymmetrical one in Figures F1 and F3 would not. Similarly, the rear turn signal and stop lamp configurations in Figure R2 appear to comply, but those of Figures R1 and R3 do not. The configuration of Figure R4 is not prohibited by S4.1.2 since it does not appear to impair the effectiveness of the required lighting equipment. As for Figure R5, the reflective itself and its appearance solely on the sidecar, as indicated on your drawing, is improper. Finally, your Figure S1 depicts front and rear reflex reflectors mounted on the right side of the sidecar. This is not acceptable as a substitute for the required front and rear reflectors on the right side of the motor as you indicate but we believe it would enhance safety if you incorporated this idea into production.; If you have any further questions, please let us know. Sincerely, Frank Berndt, Chief Counsel