Interpretation ID: nht74-1.42

DATE: 06/20/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of May 30, 1974, you ask whether a rear lighting configuration intended for your 1975 vehicles, based upon a proposal in Docket No. 69-19, would meet the current requirement that stop lamps be "as far apart as possible."

The photographs you enclose show that the intent of the proposed S8.10 has been met by providing a separation distance between turn signal and stop lamps that is 5 inches or more, and by placing the stop lamp so that its optical axis is inboard of a vertical longitudinal plane passing through the optical axis of the taillamps. Although it is obviously "practicable" for you to retain the stop lamps in their present location, we consider that the reasons you wish to introduce the change support a determination of practicability under the current requirements, even though the proposal remains under consideration and may not be adopted.

Yours truly,

ATTACH.

BLUE BIRD BODY COMPANY

May 30, 1974

Richard B. Dyson -- Assistant Chief Counsel, U. S. Dept. of Transportation, NHTSA

Dear Mr. Dyson:

In the Federal Register Vol. 37, No 206, dated October 25, 1972, appeared a proposed change for FMVSS 108. This was identified as Docket 69-19, Notice 3. In paragraph S8.10 of this notice NHTSA proposed to physically separate the stop lamp, tail lamp and the turn signal functions. Blue Bird Body Company concurs with this proposed change and in fact, we would like to incorporate it into our 1975 model buses. The attached photographs show our current stop lamp location and our proposed stop lamp location. As you can see from the photographs, our proposed lighting configuration would physically separate the stop lamp and turn signal lamps by placing the back-up lamps between them.

Although we believe this lighting scheme will provide safer vehicles because of greater discrimination between the stop lamp and turn signal functions, we are concerned with the current requirement of FMVSS 108, table 2, which says that the stop lamps must be ". . . as far apart as practical."

Certainly NHTSA must be of the opinion that such a lighting configuration will provide safer vehicles or they would not have made this proposal. Therefore, it is our opinion that our proposed 1975 lighting configuration meets the intent of the current regulations as well as the proposed future regulation and request your approval of this change. Thank you for your consideration of this request and your early reply.

Yours very truly,

W. G. Milby -- Project Engineer

c Dave Phelps; Jim Moorman