Interpretation ID: aiam3863
Head
Regulations & Emissions Laboratory
Government Relations Department
U.S Suzuki Motor Corp.
3251 East Imperial Highway
Brea
CA 92621;
Dear Mr. Walsh: This is in reply to your letter of October 31, 1984, to Mr. Vinson o this office, asking for confirmation of a 1972 agency interpretation of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; In pertinent part, Table III of Standard No. 108 requires that, at minimum, a motorcycle be equipped with one taillamp, one stop lamp, and four turn signal lamps. Table IV directs that the stop lamp and taillamp be placed on the vertical centerline, and that the turn signal lamps be placed on each side of the vertical centerline with a minimum edge to edge separation distance of 4 inches between the turn signal lamp 'and tail or stop lamp.' Table IV expressly permits dual stop and taillamps 'symmetrically disposed about the vertical centerline.' No express exception is made to the 4-inch spacing requirement if dual stop or taillamps are installed, raising the question whether the minimum distance must be maintained no matter what the rear lighting configuration may be.; You have called our attention an (sic) interpretation of July 1, 1972 that Motor Vehicle Programs of this agency provided Stanley Electric Company Ltd. In that instance the proposed rear lighting configuration consisted of two combination stop, turn signal, and taillamps placed on either side of the vertical centerline. The agency opined that the minimum separation distance was not applicable to combination lamps when there was 'no tail or stop lamp mounted on the vertical centerline.' You have asked for confirmation that this remains the agency's view.; As you have pointed out Suzuki's proposed design of a unit combinin amber turn signal lamps with red stop and taillamps is similar to current passenger car practice where the minimum distance requirement does not exist. Therefore, this will confirm that the minimum edge to edge separation distance of 4 inches between turn signals and stop and taillamps applies when single stop and taillamps are installed on the vertical centerline, but not when dual stop and taillamps are installed on either side of the centerline.; Sincerely, Frank Berndt, Chief Counsel