Fmvss: Lights 8" Apart Max!

[Elio Amazed]

"Paragraph S10.17.1.2.2 of FMVSS No. 108 specifies that if motorcycle headlamps are horizontally disposed about the vertical centerline, the distance between the closest edges of their effective projected luminous lens areas must not be greater than 200 mm."

https://www.regulations.gov/document?D=NHTSA-2013-0101-0004

Uh-oh. What the heck?

Before everyone starts yelling, "Autocycle!"...

This is from the Elio Motors Legislative Update: dated July 26, 2016... "The Elio, because it has three wheels, is currently classified as a motorcycle by the federal government."

Again... What... The... Heck!

 

[floydv]

What's the problem?

The high beam looks to be within 8 inches of the low beam.

The Slingshot doesn't seem to have an issue with this, maybe because they interpret the FMVSS language as allowing a dual hi/lo beam arrangement like the Elio's:

 

[Elio Amazed]

What's the problem?
View attachment 11637
The high beam looks to be within 8 inches of the low beam.

The Slingshot doesn't seem to have an issue with this, maybe because they interpret the FMVSS language as allowing a dual hi/lo beam arrangement like the Elio's:
View attachment 11638

That's not what it says. The headlights themselves are not supposed to be more than 8" apart if it's designated as a MC by the feds.

 

[W. WIllie]

"Not be greater than 200mm" is what I read.

 

[Elio Amazed]

This line is the key.
Paragraph S10.17.1.2.2 (applies only to the subject vehicles manufactured after December 1, 2012).

"If the headlamps are horizontally disposed about the vertical centerline, the distance between the closest edges of their effective projected luminous lens areas must not be greater than 200 mm."

It doesn't say that the MCs mfg. after December 1, 2012 must horizonally dispose the headlamps about the vertical centerline as those mfg prior to that date are required to do, it says "IF the headlamps are..."

The important part is are the placement of the headlamps considered to be "horizontally disposed about the vertical centerline" or not by the Feds.
How could you dispose them in any other way other than to be, "horizontally disposed about the vertical centerline"? I mean, they're equally distant from the centerline of the vehicle, right?

 

[floydv]

Ok, just read the link Elio Amazed provided (thanks for posting that). Seems to me there are a couple takeaways. First, the proper proactive step EM can do is to petition DOT to open a rulemaking to amend FMVSS No. 108. Morgan's mistake was to argue for an "inconsequentiality" finding rather than addressing the underlying problem with the standard (that it's not designed with modern, car-like autocycles in mind).

Second, even if it takes DOT a while to conduct that rulemaking, there's hardly a game-stopping penalty for noncompliance with the headlight standard. As DOT itself points out,

Today's denial requires Morgan to notify owners of the subject vehicles of the noncompliance and to remedy the noncompliance if and when a vehicle owner presents a vehicle for repair. Neither NHTSA's denial nor the recall and remedy requirements impose any obligations on vehicle owners. Today's denial simply ensures that vehicle owners will be notified of the noncompliance and will have the opportunity to have their vehicle remedied, if the vehicle owner so chooses.

So the worst that happens is that EM sends us a recall notice pointing out that the headlights don't meet the headlight standards for motorcycles, and EM would be happy, if the owner chooses to bring the vehicle in to get service under the recall, to replace them with ones in the Elio's grill that are 8 inches apart. I would bet most owners will simply ignore the recall notice in that case.

 

[Elio Amazed]

OK. I found what appears to be the current regulations.
Here's the link:. Requirement For Motorcycle Manufacturers

Page 34...

"LOCATION OF REQUIRED EQUIPMENT
Motorcycles, Motor Driven Cycles...

Motorcycles...

Headlamps...

On the front, on the vertical centerline, except that if two are used they shall be
symmetrically disposed about the vertical centerline.

***********************************************************************************************

Height above road surface measured from center of item on vehicle at curb weigh...

Not less than 22 inches (55.9 cm) nor more than 54 inches (137.2)"

***********************************************************************************************

Nowhere in the entire document does It does it say how far apart (min. or max.) they need to be.

Seems they've updated the regulations since 2013.

False alarm. Chicken little will go home now.

 

[Elio Amazed]

Ok, just read the link Elio Amazed provided (thanks for posting that). Seems to me there are a couple takeaways. First, the proper proactive step EM can do is to petition DOT to open a rulemaking to amend FMVSS No. 108. Morgan's mistake was to argue for an "inconsequentiality" finding rather than addressing the underlying problem with the standard (that it's not designed with modern, car-like autocycles in mind).

Second, even if it takes DOT a while to conduct that rulemaking, there's hardly a game-stopping penalty for noncompliance with the headlight standard. As DOT itself points out,



So the worst that happens is that EM sends us a recall notice pointing out that the headlights don't meet the headlight standards for motorcycles, and EM would be happy, if the owner chooses to bring the vehicle in to get service under the recall, to replace them with ones in the Elio's grill that are 8 inches apart. I would bet most owners will simply ignore the recall notice in that case.

If it were still the law of the land, I don't agree with your assessment of the theoretical situation.
That large of a recall for that serious of a re-engineer, would probably bankrupt Elio Motors. I commend you for deciding in advance that you would not be bullied by a recall into requiring EM to "fix" your Elio. I would follow suit. But, It would not be a certain thing that all Elio Owners (no pun intended) would do the same.

 

[Elio Amazed]

What's the problem?
View attachment 11637
The high beam looks to be within 8 inches of the low beam.

The Slingshot doesn't seem to have an issue with this, maybe because they interpret the FMVSS language as allowing a dual hi/lo beam arrangement like the Elio's:
View attachment 11638

I'd already looked it up. The Slingshot's got two lights in the center that are less than 8" apart.
Looks like they were covering all the bases ahead of time.

 

[floydv]

If it were still the law of the land, I don't agree with your assessment of the theoretical situation.
That large of a recall for that serious of a re-engineer, would probably bankrupt Elio Motors. I commend you for deciding in advance that you would not be bullied by a recall into requiring EM to "fix" your Elio. I would follow suit. But, It would not be a certain thing that all Elio Owners (no pun intended) would do the same.

And they lived happily ever after. Next crisis!