Interpretation ID: nht88-3.78

TYPE: INTERPRETATION-NHTSA

DATE: 10/28/88

FROM: THOMAS A COZ -- NORTH AMERICAN VAN LINES LAW DEPARTMENT

TO: JIM LUTES -- KENTUCKY TRAILER

TITLE: CALIFORNIA CITATIONS-HIGH MOUNTED TRAILER STOP LAMPS

ATTACHMT: ATTACHED TO LETTER DATED 06/19/88 FROM STEPHEN P. WOOD -- NHTSA TO JAMES A. LUTES; REDBOOK A33 [4]; VSA 102; STANDARD 108; LETTER DATED 11/09/88 FROM JAMES A. LUTES TO ERIKA Z. JONES -- NHTSA

TEXT: Dear Jim:

I understand you spoke by telephone on Friday, October 28, 1988, with Jack Sawrey, Vice President of NAVL's Fleet Service Division, concerning traffic citations which NAVL owner-operators have received in the state of California for pulling NAVL trail ers with high mounted lamps. Copies of four tickets are enclosed.

Based upon my conversation with Jack, I understand that you plan to contact the U.S. Department of Transportation and obtain written correspondence from DOT to the State of California regarding this issue. Specifically, I hope DOT is willing to write a letter which says that high mounted trailer stop lamps/turn signals are legal under federal laws and regulations. A question has been raised by California, for example, concerning the legality of such high mounted lamps under the terms of Federal Mot or Vehicle Safety Standard 108.

Thank you in advance for your assistance in soliciting such a letter from DOT. If possible, please send a copy of whatever letter is finally generated to both Jack Sawrey and to me at our NAVL address listed above.

Sincerely,

Enclosures [4 CALIFORNIA HIGHWAY PATROL TRAFFIC TICKETS OMITTED]