Interpretation ID: aiam3587
Vice President
Roberts Motor Company
550 N.E. Columbia Boulevard
Portland
OR 97211;
Dear Mr. DeVolder: This is in reply to your letter of July 16, 1982, asking for a interpretation of Motor Vehicle Safety Standard No. 108.; You enclose photos of a 1982 Kenworth truck which has two pairs o front turn signal lamps: one set (incorporating a side reflector) mounted 58 1/2 inches above the road surface and which are 83 inches apart, the other, mounted approximately 81 1/2 inches above the road surface and which are 110 inches apart. You have asked whether the vehicle would comply if the lower mounted set were removed and an amber reflex reflector placed on each side of the fender as far forward as practicable.; The answer is yes. The mounting height of 81 1/2 inches does not excee the limit of 83 inches imposed by Table II of Standard No. 108. In addition, the lamps appear to meet the two further requirements that they be located as far apart as practicable and at the same height.; Sincerely, Frank Berndt, Chief Counsel