Interpretation ID: nht88-4.22

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: M. IWASE -- TECHNICAL ADMINISTRATION DEPT. - KOITO MFG. CO. LTD.

TITLE: NONE

TEXT: This is to provide you with a clarification of my letter to you dated March 16, 1988. Your second question was whether the minimum edge to edge separation distance between turn signal lamps and tail/stop lamps is required on a rear lighting array for mo torcycles. I responded that "The answer is yes, and the separation distance you have depicted in your drawings appears to comply with this requirement."

In actuality, the agency has required this separation only where a single motorcycle stoplamp/taillamp is mounted on the vertical centerline, and not when dual lamps are mounted on either side of the vertical centerline, the configuration depicted in you r letter of January 25, 1988. Therefore, I am advising you that there is no legal requirement that the 4-inch separation distance be maintained in the configurations you depicted, and that we appreciate your continuing efforts to understand and comply w ith Federal Motor Vehicle Safety Standard No. 108.

I enclose a copy of a letter from this Office dated November 21, 1984, which explains our views on motorcycle rear lighting configurations in more detail.

Enclosure