Interpretation ID: aiam3788
Counsel
Yamaha Motor Corporation
USA
6555 Katella Avenue
Cypress
CA 90630;
Dear Mr. Schmitt: This is in response to your letter asking for an interpretation on th permissibility of using two type 2A1 headlamps mounted symmetrically disposed about the vertical centerline of the motorcycle.; Federal Motor Vehicle Safety Standard (FMVSS) No. 108, 'Lamps Reflective Devices, and Associated Equipment (sic) states in S4.1.1.34 that a motorcycle may be equipped with one of the following headlamp systems, one of which is the 'A' type headlamp system described as follows:; >>>Type 1A1 or Type 1A . . . . 1 lamp and either Type 2A1 or Type 2A . . . . 1 lamp<<<< The standard is specified this way because the 2A1 lamp is a lower bea lamp and the 1A1 is an upper beam lamp. While the 2A1 lamp does have an 'upper beam', photometrically it provides only 'fill-in' light. The 1A1 lamp provides the high output upper beam. It is not possible to achieve safe upper beam light using only the 2A1 lamp, regardless of how many are used. Therefore, your proposed headlighting application would not be permitted by FMVSS No. 108.; Sincerely, Barry Felrice, Acting Associate Administrator for Rulemaking