Herr Tilman Spingler
Robert Bosch GmbH
Automotive Equipment Div. 2
Postfach 13 42
D-72703 Reutlingen

Dear Herr Spingler:

This is in reply to your fax of February 3, 1999, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

You state that Figures 15-1 and 15-2, Figures 17-1 and 17-2, and Figures 28-1 and 28-1 show a position 10U-90U for a lower beam headlamp with a maximum intensity of 125 cd. In your view, it is not clear whether, for compliance testing, that means a scan on the vertical line from 10U to 90U or a scan of an area from e.g., 45L to 45R and from 10U to 90U.

Each of the Figures you reference specify a maximum of 125 candela for test points 10U-90U. The Figures do not state where in space from left to right to locate the vertical line, and thus, they do not specify that a line is to be measured. It follows that the only description of a set of test points is that of the entire area from 90L to 90R and 10U to 90U, i.e., an area from the extreme left of the test point grid to the extreme right of the test point grid, with an elevation of from 10U to 90U.

Frank Seales, Jr.
Chief Counsel