ID: nht74-1.28

DATE: 07/15/74

FROM: C. BAKER FOR E. T. DRIVER -- NHTSA

TO: Stanley Electric Co., Ltd.

COPYEE: L. C. OWEN

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 27 concerning the location of motorcycle turn signal lamps relative to a combination stop lamp and reflex reflector.

The minimum edge to edge separation distance specified in Table IV of FMVSS No. 108 for motorcycle turn signal lamps is to be measured from the edge of the illuminated surface of both lamps.

The answer to your question 2 is therefore applicable, "2. edge to edge of tail and stop lamp so drawn in sketch C?"

ID: nht74-1.29

DATE: 08/13/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Eric L. Clabourgh

COPYEE: L. OWEN

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your recent letter to the Administrator, National Highway Traffic Safety Administration, concerning the placement of front turn signal lamps on fire trucks.

Federal Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices, and Associated Equipment" (copy enclosed) requires that front turn signal lamps be located "at or near the front and be spaced "as far apart as practicable." We would, therefore, have no objection to moving the front turn signal lamps on the fire truck from the side to the front. Locating the lamps on the front could also reduce the chance of damage to them, which might occur if they were located on the side.

Sincerely,

ATTACH.

Administrator And Counsel N.H.T.S.A. Washington, D.C.

Gentlemen:

I am in need of urgent information deciding a standard, specifically, standard 108, I understand, applies to big trucks. All effective 1-1-68. Soon we, the city of (Illegible Word) town commissioners, will receive a fire truck chassis made by international and the rest by the American fire apparatus co. of (Illegible Word), Iowa.

In a few months it will be delivered and it was bought with (Illegible Words) sharing money.

We are in debate! the Fire (Illegible Text)

(Graphics omitted)

These International beauties won't make the taxpayers see red.

Fires and fire departments come in a lot of different sizes -- and so do international Fire Truck chassis.

There's one to fit your budget, sure, but more important they'll also fit the kind of community you serve and the kinds of fires you fight.

I like the CARGOSTAR(R) top right, a short wheel base lets you turn in tight spots. The cab-over design gives you better visibility, and the cab also tilts forward for quicker, handier engine access. You can get it equipped the way you want it, with power to pump up to 1,250 gallons a minute.

On the left is a customized FLEETSTAR* chassis it comes with GVW ratings from 23,000 to 54,000 pounds and pound for pound it's the most efficient, economical fire-fighter around.

Down front is international's LOADSTAR* it can be customized as an assist-type vehicle, rescue truck pumper, or ladder truck. And this one has an engine and fuel capacity big enough to keep on working till the smoke clears.

(Graphics omitted)

ID: nht74-1.3

DATE: 10/07/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Borg-Warner Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

OCT 7 1974 N40-30(ZTV)

Mr. Mike A. Read Design Engineer, Spring Division Borg-Warner Corporation 700 South 25th Avenue Bellwood, Illinois 60104

Dear Mr. Read:

This is in reply to your letter of September 13, 1974, pointing out discrepancies between our two standards covering motor vehicle hydraulic brake systems, Nos. 105-75 and 122.

We intend to amend Standard No. 122 in the near future to be consistent with Standard No. 105-75. This will clarify that the same interpretation will be given master cylinder reservoir and capacity requirements.

Thank you for pointing this out to us.

Yours truly,

Richard B. Dyson Acting Chief Counsel

ID: nht74-1.30

DATE: 02/15/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Maserati, S.p.A.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 22, 1974, asking whether paragraph S4.3.1 of Motor Vehicle Safety Standard No. 108 precludes the mounting of rear lamps in a transparent "Lexan" panel "not involved in the driver's rearward vision."

Paragraph S4.3.1 states in pertinent part that ". . . each lamp . . . shall be securely mounted on a rigid part of the vehicle other than glazing that is not designed to be removed except for repair . . . ." The "glazing" referred to is the glazing regulated by Standard No. 205, and refers generally to glazing used in windshields, windows, doors, and interior partitions. Accordingly, Standard No. 108 does not preclude the mounting of rear lamps in the "Lexan" panel.

Yours truly,

ATTACH.

OFFICINE ALFIERI MASERATI S.p.A.

January 22, 1974

National Highway Traffic Safety Administration -- Office of Chief Counsel;

Attention: Mr. Vinson

Subject: Request for clarification of MVSS No. 108, Paragraph S.4.3.1.

Gentlemen:

Since we are planning to introduce soon in the United States our new model, the "KHAMSIN" (model 120), we would very much appreciate your clarifying the intent of paragraph S.4.3.1. of Motor Vehicle Safety Standard No. 108 -- "Lamps, Reflective Devices and Associated Equipment."

Paragraph S.4.3.1 of MVSS No. 108 states that "each lamp . . . . . shall be securely mounted on a rigid part of the vehicle other than glazing that is not designed to be removed except for repair, . . .".

As you will see in the enclosed documents, the "KHAMSIN" is a two door GT coupe which embodies, as a new styling concept, a rear end panel made of transparent "Lexan" material. The two rear combination lamps are securely mounted on this Lexan panel.

The Lexan material is a polycarbonate sheet, produced by the General Electric Company under the designation "LEXAN MR-4000". It is especially treated on both sides in order to make it scratch resistant. It is completely collision proof and is classified by the "Underwriters' Laboratories Inc." as the sole transparent antilock-picking material.

The mounting of the rear combination lamps on the rear end panel is described in the enclosed blueprint No. 120 VS 83090 and shown on the 2 enclosed B & W photographs.

This tansparent rear end panel is not involved in the driver's rearward vision and it is transparent only for aesthetic purposes. It is permanently mounted on the vehicle and its replacement constitutes a major repair.

We believe that paragraph S.4.3.1 of Standard No. 108 was intended to prevent mounting of lamps on glazing material which concurs to the driver's vision (such as windows), but since the wording of this paragraph is not clear to us, we would appreciate very much your clarifying if mounting the rear lamps such as it is done on the KHAMSIN does comply with MVSS No. 108.

Thanking you very much in advance for a prompt answer, we remain at your disposal should you need more information on this matter.

Very truly yours,

Bernard Belier -- U.S. Resident Engineer for MASERATI S.p.A.

ID: nht74-1.31

DATE: 02/26/74

FROM: CERSAS FOR E.T. DRIVER, NHTSA

TO: Mack Trucks, Inc.

COPYEE: J. LEYSATH; MR. VINSON

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 4, 1974, concerning the location requirements of front identification lamps on certain solid-waste disposal vehicles.

You describe the vehicles in question as "short BBC low cab-ever-engine type vehicles -- equipped with a large volume body and a hydraulically operated front leader mechanism. This unit lifts containers of waste up and over the front of the cab and empties the waste into the top of the body. To prevent damage to the front of the vehicle and lamps, a protective guard is installed on the front centerline of the vehicle." You further state that "This guard could obstruct the center identification lamp."

You ask whether or not all three of the front identification lamps may be offset from the front centerline of the vehicle to ensure compliance with the visibility requirements of FMVSS No. 108. In accordance with paragraph S4.3.1. Table II of FMVSS No. 106 specifies that the front identification lamps be located "as close as practicable to the top of the vehicle, at the same height, as close as practicable to the vertical centerline." For the vehicles which you have described, it would appear that location of the front identification lamps either left or right of the vertical centerline would meet this requirement.

Sincerely,

ATTACH.

February 4, 1974

E.T. Driver -- National Highway Traffic Safety Administration, Office of Operating Systems

Dear Mr. Driver:

Subject: Request for Interpretation MVSS 108

Section S4.1.1 table I states that three identification lamps are required for vehicles of 80 or more inches overall width.

Section S4.3.1 table II requires that "three amber identification lamps be located on the front as close as practicable to the top of the vehicle, at the same height, and as close as practicable to the vertical centerline".

In addition, Section S4.3.1.1 requires that each lamp be located so that it meets the visibility requirements of applicable SAE Standards and that no part of the vehicle shall prevent the device from meeting the photometric output at any test point specified in any applicable SAE Standard.

Section S4.3.1.1 also states that if motor vehicle equipment prevents compliance, an auxiliary lamp or device meeting the requirement shall be provided.

The solid waste disposal industry use short BBC low cab-over-engine type vehicles (see Attachments 1 & 2) equipped with a large volume body and a hydraulically operated front loader mechanism. This unit lifts containers of waste up and over the front of the cab and empties the waste into the top of the body. To prevent damage to the front of the vehicle and lamps, a protective guard is installed on the front centerline of the vehicle. This guard could obstruct the center identification lamp. (See Attachment 3 through 6)

One of our customers has requested that we supply four identification lamps on the forward side of our MB series vehicle cab near the top so that he can mount a protective guard on the centerline of the cab and still meet the visibility and photometric requirements.

As we discussed during my visit of January 31st, use of four lamps will not be acceptable to the National Highway Traffic Safety Administration as it would defeat the identification function of these lamps for vehicles over 80" in width.

However, it was proposed that all three identification lamps could be moved to one side of the centerline, thereby permitting compliance with the visibility and photometric requirements when the units are in the installed position. This appears to us to be an effective solution to this problem and we, therefore, request your issuance of an interpretation for an installation of this type.

Very truly yours, MACK TRUCKS, INC.; A. M. Fischer -- Asst. to Exec. V.P.- Engineering & Product

Enclosure Omitted.

ID: nht74-1.32

DATE: 05/16/74

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Lt. Commander Robert H. Weldman, Jr.

COPYEE: LARSON; RANADER

TITLE: FMVSS INTERPRETATION

TEXT: This response to your letter of April 17, 1974, to the Department of Transportation requesting information on standards for (Illegible Word) Lighting systems. We have me record of your (Illegible Words)

In answer to your specific questions --

1. "Are there any federal or state regulations which specify sealed beam headlamps?"

Yes, this requirement has been effective either by Federal or State standards for more than three decades.

2. "Are both acceptable?"

A replacable bulb type headlamp is not acceptable.

3. "Is amber a permissible headlight (Illegible Word)

No, headlight must white light.

4. "Is white mandatory for backup lights?"

Yes, white is mandatory.

Sincerely,

ATTACH.

APRIL 17, 1974

U.S. Department of Transportation,

Attn: Federal Standards for Automobiles.

Dear Sirs,

I wrote you on 12 February 1974 to ask for information on Federal and state standards for automobile lighting systems. I have received no reply, so herewith a repeat of my request: are there any federal or state regulations which specify sealed beam headlamps, or are bulbs acceptable? Is amber a permissible headlight color? Is white mandatory for backup lights?

I will appreciate any information you can give me.

Sincerely,

Robert H. Weidman, Jr. -- LCDR USN,

Box 33 B753, FPO NEW YORK 09540

ID: nht74-1.33

DATE: 02/20/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Spartan Design Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 21, 1974 asking for our comments on your defect notification letter.

In describing the defect (your third paragraph) as required by Section 577.4(c), you should state specifically that the placement of the lamps fails to conform to Federal Motor Vehicle Safety Standard No. 103, and indicate, in general terms, what is the appropriate location. In addition, section 577.4(c) requires the inclusion of precautions the purchaser can take. We believe one precaution that should be included where a lighting problem is concerned is to recommend that night driving be limited as much as possible.

When we have received a corrected copy, we will close our files in this matter.

Sincerely,

ATTACH.

January 21, 1974

Lawrence R. Schneider -- Chief Counsel, U.S. Department of Transportation, National Highway Traffic Safety Adm.

Ref: #N40-30, (ZTV) CIR618

Dear Mr. Schneider:

Enclosed is a copy of the rewritter letter as you requested. (Illegible Word) read the letter and see if it meets with your approval and let us know so that we may then mail it to all our Converta-Trailer owners.

We are sorry to have caused you any inconvenience and if there is any further information you need please let us know.

Sincerely, SPARTAN DESIGN INC.;

Robert W. Borgert -- Vice President

enclosure

Spartan Design Inc.

Dear Converta-Trailer Owner:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

Spartan Design Inc. has determined that a defect which relates to Motor Vehicle Safety exists in Converta-Trailers manufactured between January 1, 1969 and December 8, 1971. According to our records, you are the owner of a 1971 Converta-Trailer bearing the vehicle serial number on the enclosed reply form which has this defect.

(Illegible Word) defect involves the combination rear lamps which are improperly located. Due to the poor visibility of these lamps, a rear end crash can occur.

To prevent the possibility of a rear end crash to your trailer, please contact Spartan Design Inc., who will remove the lights from back of fenders and reinstall them to the far rear of trailer frame, at no charge to you.

The actual time necessary to perform the labor required to install the rear lamps is approximately 2 hours. It is suggested that you make an appointment in advance so work can be scheduled in an orderly manner.

In the event you no longer own your trailer, or these modifications have been performed already, please complete and mail the enclosed form post-paid, in addressed reply envelope so that we may update our records.

We are sorry to cause you this inconvenience; however, we have taken this action in the interest of your safety and continued satisfaction with our product. Your prompt cooperation will be (Illegible Word).

Your truly, SPARTAN DESIGN INC.

ID: nht74-1.34

DATE: 01/10/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Trailmobile Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of October 25, and December 14, 1973. I regret that your earlier letter did not arrive.

You stated that your customer wishes to mount rear identification lamps at the same height from the ground as the rear turn signal, stop, tail and clearance lamps, and that, because of the shallowness of the rear header area it is not "practicable" to mount them there.

Although it may not be "practicable" to mount the Grote #272 lamp, specified by your customer, in the header area, there may be other conforming lamps that it would be "practicable" to mount in that location in a three-lamp identification array. If such lamps are available, then Standard No. 108 takes priority over contractual specifications, especially since the clearance lamps will be mounted at a point other than "as close as practicable to the top of the vehicle".

Yours truly,

ATTACH.

TRAILMOBILE TECHNICAL CENTER

December 14, 1973

Lawrence Schneider, Chief Counsel -- Dept. of Transportation

Dear Mr. Schneider:

Please find enclosed a copy of a letter dated October 25, 1973 in which I requested a ruling on the lowering of the identification lamps on the rear of a trailer under certain conditions of shallow header depth.

Today I talked with Mr. T. Vinson of your office and was advised that the letter must have been lost as he had not seen the request and further advised that I resubmit a copy of the original request.

Sincerely,

Evan Hammond -- Manager - Central Engineering

Encl.

cc: R. J. Deller; J. E. Cook; E. E. Lungren - Chicago

October 25, 1975

Lawrence Schneider, Chief Counsel -- Department of Transportation Dear Mr. Schneider:

Please find enclosed a sketch of a trailer rear end lighting arrangement, on which we are requesting a ruling with respect to conformance to M.V.S.S. no. 108.

In this particular case the customer is specifying a higher than normal rear door opening to facilitate easier loading and unloading of palatized cargo. Accomplishment of this end necessitates that the rear frame header be 2-5/8" deep. At the same time, the customer is specifying a Grote #272 lamp for the rear identification lamp function. It is not possible to mount these lamps on the shallow header in any "practicable" manner to (Illegible Word) the overall height of the trailer. We respectfully request that we may be allowed to mount the lamps to a lower level (same level as the turn signal, stop, tail and rear clearance lamps), this being "as close as practicable to the top of the vehicle" in this case.

We believe that the proposed installation is not in conflict with the intent of the safety standard as it will provide an easier and more reliable installation with simpler maintenance and at the same time, the rear lamp configuration is identical to thousands of platform trailers and container chassis safety in operation today on our highways.

A prompt reply to this request will be greatly appreciated.

Sincerely,

Evan Hammond -- Manager - Central Engineering

Encl. to all

cc: R. J. Deller; J. E. Cook; E. E. Lungren - Chicago

(Graphics omitted)

PROPOSED TRAILER REAR END LAMP CONFIGURATION WITH "SHALLOW HEADER" REAR FRAME

ID: nht74-1.35

DATE: 06/06/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Committee on Transportation, Florida House of Representatives

COPYEE: W. R. EASON; NHTSA REGIONAL ADMINISTRATOR -- ATLANTA

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 7, to Dr. James R. Gregory, Administrator, National Highway Traffic Safety Administration, concerning the activation of headlamps during periods of reduced visibility, and the automatic illumination of vehicle headlights when the windshield wipers are activated.

The National Committee on Uniform Traffic Laws and Ordinances is the custodian of the Uniform Vehicle Code. Any revision of @ 12-201 relating to operation of headlights in line with the Florida law could be duly considered by its Subcommittee on Vehicles and Highways. Perhaps you may wish to submit a proposal to revise this section of the UVC to Mr. Edward F. Kearney, Executive Director, National Committee on Uniform Traffic Laws and Ordinances, 1776 Massachusetts Avenue, M.W., Washington, D.C. 20036. If you choose to do so, this would be a timely action since the various Subcommittees of the National Committee will be meeting in the next few months to consider pending proposals to revise various chapters of the UVC.

With respect to automatic illumination of headlights with the windshield wipers, the NHTSA has conducted, and will continue to conduct, considerable research on improved headlighting. This research will include evaluations of means and features which will enhance the safety of driving during inclement weather, at which time the driver would normally use his windshield wipers. The simultaneous activation of headlights and windshield wipers would ensure that the headlights are in use during adverse weather conditions. This feature would, however, result in unnecessary use of the headlights under fair weather conditions; for example, when the driver is operating his windshield washer or when the windshield wiper is used while the vehicle is parked. Illuminated headlights under fair weather conditions will also decrease the conspicuousness of the front turn signal lamps which are normally located near the headlights. These and other factors must be carefully considered in determining the true merits of a feature which would provide for automatic illumination of the headlamps when the windshield wipers are activated. Based on the information available to date, we are not in a position to justify proposing a Federal requirement for such a feature.

Furthermore, since paragraph S4.5 of Federal Motor Vehicle Safety Standard No. 108 establishes special wiring requirements (including simultaneous activation of taillamps, parking lamps, license plate lamps, and side marker lamps, with the headlamps), we would view differing State wiring requirements as preempted by Section 103(d) of the National Traffic and Motor Vehicle Safety Act, and hence invalid.

An alternative approach to ensuring the use of headlights during adverse weather would be the strict enforcement of State regulations requiring the use of headlights curing periods of reduced visibility, normally less than 500 feet.

This approach might be more cost-effective, since the cost of the automatic feature would be precluded.

Thank you for bringing your Bill HB 3135 to my attention. If I can be of any further assistance, please do not hesitate to contact me.

Sincerely,

NHTSA CONTROL NO. 1496

ATTACH.

FLORIDA HOUSE OF REPRESENTATIVES

COMMITTEE ON TRANSPORTATION

May 7, 1974

James B. Gregory, Administrator -- National Highway Traffic Safety Administration

Re: Uniform Vehicle Code (Rev. 1971) Chapter 12-201 "When lighted lamps are required"

Dear Mr. Gregory:

I call your attention to the above cited requirement of the U.V.C. compared to Florida's law, Chapter 316.217, Florida Statutes. I will agree that Florida requires lamps to be lighted one hour per day longer than the U.V.C. does as well as Florida enumerates the conditions during which time lamps shall be lighted and the U.V.C. does not. We can therefore agree that Florida's law is more stringent in its requirements than your recommendations in the U.V.C.

As you can see from my efforts to change our law, HB 3135 and a timely letter to the editor in the Miami Herald, copies enclosed, we are having our problems in educating the people about and enforcing the provision of the law which requires head lamps to be lighted when it is raining. Rain is not a safety hazard peculiar only to Florida. Perhaps the distinguished drafters of the Code should speak more specifically to this problem, require all states to conform to this law and even require the automobile manufacturers to install the mechanism referred to in Section 2 of my bill which when the windshield wipers are activated, the head lamps will automatically be activated without any additional action required of the operator.

I fully realize just how impractical it is for only one state to have such a requirement placed on the manufacturers of automobiles. However, this is my way of impressing you with the gravity of the situation and that it is within your power to reduce this specific safety hazard by requiring the manufacturers install the aforesaid mechanism. The cost to install such an item will be very nominal, less than $ 2.00, yet the benefits can be very large indeed in the saving of lives and the reduction of property damage.

Sincerely, Vernon C. Holloway -- CHAIRMAN

Enclosures

cc: NHTSA Regional Administrator, Atlanta; Miami Herald, Miami

(Regular Session 1974)

By Representative Holloway

A bill to be entitled

An act relating to the operation of head lamps and windshield wipers during unfavorable atmospheric conditions; arending section 316.217(1), F. S., requiring head lamps and windshield wipers be operated under certain conditions; amending section 501.125, F. S., adding subsection (3) thereto and renumbering (3) as (4); requiring certain automobiles have specific equipment attached before they are sold and licensed in the state; providing an effective date.

Be It Enacted by the Legislature of the State of Florida:

Section 1. Subsection (1) of section 316.217, F. S., is amended to read:

316.217 When lighted lamps are required. --

(1) Every vehicle upon a highway within this state at any time from sunset to sunrise, during fog, smoke, or rain, or atmospheric conditions, are such that there is inadequate light, shall display lighted lamps and illuminating devices as hereinafter respectively required for different classes of vehicles, subject to exceptions with respect to parked vehicles. Stop lights, turn signals and other signaling devices shall be lighted as prescribed for the use of such devices. Whenever conditions are present which require the use of windshield wipers, headlamps shall be activated.

Section 2. Section 501.125, F. S., is amended by adding a new subsection (3) thereto and renumbering (3) as (4) to read:

501.125 Warranty on sale and manufacture of automobiles; energy absorption system, windshield wipers and head lamps. --

(3) Every private passenger automobile manufactured on and after September 1, 1975, and sold and licensed in the state shall be sold subject to the manufacturer's warranty that it is equipped with a mechanism which when the windshield wipers are activated, the head lamps are automatically activated without any additional required action on the part of the operator.

(4) The warranty provisions of this section shall not be applicable with respect to any private passenger automobile as to which the manufacturer files a written certification under oath with the department of highway safety and motor vehicles, on a form to be prescribed by that department, that the particular make and model described therein complies with the applicable standards of this section.

Section 3. This act shall take effect October 1, 1977.

LEGISLATIVE SUMMARY

Requires automobile headlight operation when there is inadequate light, at any time from sunset to sunrise, during fog, smoke or rain. Requires windshield wiper use whenever conditions necessitate. Requires every private passenger automobile manufactured on and after September 1, 1975 and sold and licensed in the state to be warrantied by the manufacturer that it is equipped with a mechanism which automatically activates the head lamps when the windshield wipers are activated.

The Miami Herald

Monday, April 22, 1974

Enforce 'Lights On in Rain' Law

To The Editor:

Is there any law less frequently enforced than the law requiring headlights on during a rainstorm?

I realize that it requires the police officer to get out of his car in the rain, but if nobody is going to enforce it then get the law off the books -- or enforce it.

BOB RESNIZK

ID: nht74-1.36

DATE: 09/09/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Societe de Signalisations Automobiles

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 17, 1974, concerning NHTSA's proposal to apply a manufacturer's identification code to motor vehicle lights.

Motor vehicle lights, including those imported in the United States, subject to MVSS No. 108, Lamps, reflective devices, and associated equipment, would be required to be marked with a manufacturer's identification code under the NHTSA proposal. Just as all motor vehicle lights must meet the performance requirements of Standard 108, if the proposal is adopted as a final rule they would be required to meet the manufacturer's identification code requirement as well.

Thank you for advising us of your views in this matter. We will take them into account in formulating further action.

Yours truly,

ATTACH.

July 17, 1974

Dear Sirs,

Further to the publication of your project in the Federal Register of the 5.6.74 modifying the mode of assigning an identification code we have to inform you that for the little trafic lights still existing nearly everywhere in the world, it will be very difficult to find an aera authorising all the markings.

Unfortunalty, we see no solution to suggest to you but we want to point out the difficulties there will be to account for all of the markings.

Yours faithfully

The Secretary General -- R. VIBART