Interpretation ID: nht94-3.71

TYPE: Interpretation-NHTSA

DATE: July 15, 1994

FROM: Guy Dorleans -- Legal Compliance Department, Valeo Vision (France)

TO: Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/31/94 from John Womack to Guy Dorleans (A42; Std. 108)

TEXT:

I am inquiring for information and assistance with the interpretation of Section 571.108 of the Federal Traffic Code. The attached sketch shows the front end of a vehicle which incorporates the following features:

Lamp A is a highbeam contributor with one monofilament light source. The wiring of the vehicle dies not allow this lamp to be lit alone in highbeam mode. Lamp A is 150 mm high, between level 750 and level 600 above the ground.

Lamp B is the lowbeam with one monofilament light source. Its light emitting area is 50 mm high, between level 650 and 700.

Lamp C is a combination of parking lamp and turn signal.

In highbeam mode, both filaments A and B are energized simultaneously and table 17a of FMVSS 108 is then fulfilled.

Lamp D is a foglamp.

As an alternative to the above description, we would like to know whether it is permissible to sell new cars in the United States with the foglamp replaced by an auxiliary driving beam. In this case, all three A, B and D filaments would be permanently e nergized together in high beam mode and table 17a of FMVSS 108 is then fulfilled. Lamp D alone, when tested in a laboratory, would satisfy the photometric requirements of SAE J581 June 89.

In another variant, two or three filaments could be switched on in highbeam mode depending on the position of a switch on the instrument panel, at the discretion of the driver. Whatever the position of the switch, table 17a of FMVSS 108 shall be fulfill ed. Would this be permissible?

Thank you in advance for your cooperation.

Graphics omitted.