Dear Mr. Waldeck:
This is in reply to your FAX of October 15, 1996, to Rich Van Iderstine of this agency requesting
approval of a design proposal to place a combination front side marker lamp and reflector behind
the front wheel house.
As you noted, Table IV of Motor Vehicle Safety Standard No. 108 requires front side marker
lamps and reflectors to be located "as far to the front as practicable." The center of the
combination device shown on the drawing you enclosed is 1222.6 mm from the front of the
vehicle. In this location, it is behind the front wheel house. We surmise that this location is
otherwise used for a turn signal repeater lamp in markets other than the United States.
As a general rule, it is initially the vehicle manufacturer that determines whether a specific location
is "practicable" for its vehicle design. The agency will not contest that determination unless it is
clearly erroneous. In this instance, we believe that it would be clearly erroneous to place the
combination device at the location indicated. In that location, the combination device would not
fulfill its intended function of indicating the forward edge of the vehicle. There appears to be
ample room in front of the wheel house for location of the combination device so that it might
more nearly fulfill that function. Unless the manufacturer can demonstrate convincingly that a
location in front of the wheel house is not practicable, we would regard a location behind the
wheel house as noncompliant with the requirements of Standard No. 108.
If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).
Acting Chief Counsel