Morgan 3 Wheeler Limited, Denial of Petition for Decision of Inconsequential Noncompliance, 21663-21666 [2016-08360]
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Federal Register / Vol. 81, No. 70 / Tuesday, April 12, 2016 / Notices
inches narrower and three inches
smaller in diameter than the nontemporary tires that would be used on
the vehicle for which the subject tires
are also intended.
Finally, neither CTA nor NHTSA are
aware of any crashes, injuries, customer
complaints or field reports associated
with the omitted labeling.
NHTSA’s Decision: In consideration
of the foregoing, NHTSA finds that CTA
has met its burden of persuasion that
the subject FMVSS No. 109
noncompliance in the affected tires is
inconsequential to motor vehicle safety.
Accordingly, CTA’s petition is hereby
granted and CTA is consequently
exempted from the obligation of
providing notification of, and a free
remedy for, that noncompliance under
49 U.S.C. 30118 and 30120.
NHTSA notes that the statutory
provisions (49 U.S.C. 30118(d) and
30120(h)) that permit manufacturers to
file petitions for a determination of
inconsequentiality allow NHTSA to
exempt manufacturers only from the
duties found in sections 30118 and
30120, respectively, to notify owners,
purchasers, and dealers of a defect or
noncompliance and to remedy the
defect or noncompliance. Therefore, this
decision only applies to the subject tires
that CTA no longer controlled at the
time it determined that the
noncompliance existed. However, the
granting of this petition does not relieve
equipment distributors and dealers of
the prohibitions on the sale, offer for
sale, or introduction or delivery for
introduction into interstate commerce of
the noncompliant tires under their
control after CTA notified them that the
subject noncompliance existed.
Authority: 49 U.S.C. 30118, 30120:
delegations of authority at 49 CFR 1.95 and
501.8.
Jeffrey M. Giuseppe,
Director, Office of Vehicle Safety Compliance.
[FR Doc. 2016–08362 Filed 4–11–16; 8:45 am]
BILLING CODE 4910–59–P
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety
Administration
asabaliauskas on DSK3SPTVN1PROD with NOTICES
[Docket No. NHTSA–2013–0101; Notice 2]
Morgan 3 Wheeler Limited, Denial of
Petition for Decision of
Inconsequential Noncompliance
National Highway Traffic
Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Denial of petition.
AGENCY:
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Morgan 3 Wheeler Limited
(Morgan) has determined that certain
model year (MY) 2012 and 2013 Morgan
model M3W three-wheeled motorcycles
do not comply with all of the
requirements of Federal Motor Vehicle
Safety Standard (FMVSS) No. 108,
Lamps, reflective devices, and
associated equipment. Specifically, the
vehicles’ headlamps are spaced further
apart than permitted, and do not have
the required ‘‘DOT’’ marking. Morgan
has petitioned for an exemption from
the recall notification and remedy
requirements of 49 U.S.C. Chapter 301—
‘‘Motor Vehicle Safety’’ (Vehicle Safety
Act) on the grounds that the
noncompliances are inconsequential to
motor vehicle safety. This notice
announces and explains NHTSA’s
denial of Morgan’s petition.
FOR FURTHER INFORMATION CONTACT: For
further information on this decision
contact Mike Cole, Office of Vehicle
Safety Compliance, National Highway
Traffic Safety Administration (NHTSA),
telephone (202) 366–2334, facsimile
(202) 366–5930.
SUPPLEMENTARY INFORMATION:
I. Overview: Pursuant to 49 U.S.C.
30118(d) and 30120(h) and the rule
implementing those provisions at 49
CFR part 556, Morgan has petitioned for
an exemption from the notification and
remedy requirements of 49 U.S.C.
Chapter 301 on the basis that the
noncompliances are inconsequential to
motor vehicle safety.
Notice of receipt of the petition was
published, with a 30-day public
comment period, on December 9, 2013
in the Federal Register (78 FR 73920).
One comment was received from Peter
C. Larsen of Liberty Motors, LLC. To
view the petition and all supporting
documents log onto the Federal Docket
Management System Web site at:
https://www.regulations.gov/. Follow the
online search instructions to locate
docket number ‘‘NHTSA–2013–0101.’’
II. Vehicles involved: Approximately
150 MY 2012 and 2013 Morgan model
M3W three-wheeled motorcycles
manufactured from August 1, 2012 to
August 14, 2013 (subject vehicles) are
affected.
III. Noncompliances: Morgan’s
petition concerns two requirements in
FMVSS No. 108.1 Both noncompliances
involve the vehicles’ headlights. Morgan
states that the noncompliances are a
result of a configuration error in its
production line. The first
noncompliance involves the spacing
between the headlights. Paragraph
S10.17.1.2.2 of FMVSS No. 108 specifies
SUMMARY:
1 49
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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.2 Morgan states in its
petition that the subject motorcycles do
not comply with this requirement
because they are equipped with dual
horizontally-mounted headlamps
mounted 29 inches (737 mm) apart (lens
edge to lens edge).
The second noncompliance concerns
the lack of a required marking on the
headlamps. Paragraph S6.5.1 of FMVSS
No. 108 requires that the lens of each
original equipment and replacement
headlamp be marked with the symbol
‘‘DOT,’’ either horizontally or vertically,
to indicate certification under 49 U.S.C.
30115.3 Morgan states in its petition that
the subject vehicles do not include this
marking.
IV. Rule Text: Paragraphs S7.9.6.2(b)
and S10.17.1.2.2 of FMVSS No. 108
require in pertinent part:
Paragraph S7.9.6.2(b) (applies only to the
subject vehicles manufactured before
December 1, 2012).
If the system consists of two headlamps,
each of which provides both an upper and
lower beam, the headlamps shall be mounted
either at the same height and symmetrically
disposed about the vertical centerline or
mounted on the vertical centerline. If the
headlamps are horizontally disposed about
the vertical centerline, the distance between
the closest edges of their effective projected
luminous lens areas shall not be greater than
200 mm (8 in.).
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.
V. Summary of Morgan’s Petition and
Comments: Morgan petitions for relief
from the recall provisions of the Vehicle
Safety Act with respect to both of these
noncompliances. Morgan makes several
arguments to support its assertion that
these noncompliances are
inconsequential to motor vehicle safety.
With respect to the headlamp spacing
noncompliance, Morgan contends that
2 In a December 2007 final rule, NHTSA rewrote
and reorganized FMVSS No. 108 to provide a more
straightforward and logical presentation of the
regulatory requirements. 72 FR 68234, Dec. 4, 2007.
Those amendments became effective on December
1, 2012. 74 FR 58214, Nov. 12, 2009. The rewrite
was not intended to make any substantive changes
to the standard. The subject vehicle population
includes vehicles manufactured both before and
after this effective date. Prior to the effective date
of the reorganized standard, the headlight spacing
requirement was contained in S7.9.6.2(b).
3 This provision was located at S7.2(a) in the prerewrite version of FMVSS No. 108.
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the headlamps meet the ‘‘technical
requirements’’ of FMVSS No. 108.
Morgan also states that it does not
believe that this noncompliance will
increase the safety risk to vehicle
occupants or approaching drivers.
Morgan argues that the current
horizontal spacing of 29 inches (737
mm) is in the best interests of road
safety, because if the M3W complied
with the existing motorcycle head lamp
spacing requirement, other road users
would not have an accurate indication
of the width of an oncoming M3W.
Morgan also argues that NHTSA has
previously found a lighting separation
noncompliance to be inconsequential.4
Morgan contends that the lens
marking noncompliance is
inconsequential to motor vehicle safety
because the lamps meet the substantive
requirements of FMVSS No. 108.
Morgan also states that owners of
Morgan vehicles almost exclusively go
to Morgan dealers for replacement parts;
the agency assumes that Morgan is
implying that because the vehicle owner
is likely to obtain a replacement part
directly from a dealer, the owner can be
confident that the headlamp complies
with all applicable requirements, even
though it lacks the proper ‘‘DOT’’
marking.
With respect to both noncompliances,
Morgan asserts, based on its reading of
previous inconsequentiality petition
grants by NHTSA, that its
noncompliances should be found to be
inconsequential because the M3W is an
exotic vehicle with no roof or doors,
produced in very low numbers, driven
a low number of miles, and likely to be
operated on a limited basis, as opposed
to an ordinary passenger automobile
designed to be used as a family’s
primary passenger vehicle. Morgan also
states that there have been no reports of
any safety issues or injuries related to
the subject noncompliances. NHTSA
received one comment on Morgan’s
petition from Peter Larsen. Mr. Larsen
makes several arguments in support of
Morgan’s petition. First, Mr. Larsen
asserts that a NHTSA-published
guidebook on motorcycle requirements
does not contain the 200 mm spacing
requirement. Second, Mr. Larsen argues
that when NHTSA promulgated this
requirement it did not contemplate
three-wheeled vehicles with the frontal
aspect of a small automobile, for which
headlights spaced more than 200 mm
apart help to indicate the size and shape
of the vehicle. Accordingly, Mr. Larsen
contends that the 200 mm requirement,
as applied to the subject vehicles, is not
in the interest of safety. Third, Mr.
4 See
64 FR 28864, May 27, 1999.
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Larsen suggests that if the subject
vehicles are remedied so that the dual
headlights are replaced with a
compliant center headlight, owners and
dealers of the subject vehicles would
likely remove the single center light and
replace it with the dual, widely-spaced
lights; and that a recall or design
revision, Mr. Larsen asserts, would
‘‘criminalize’’ these actions. Finally, Mr.
Larsen argues that many existing threewheeled vehicles have similarly-spaced
dual headlights, and it would be unjust
to penalize Morgan’s similar design. Mr.
Larsen requests that NHTSA ‘‘properly
amend’’ FMVSS No. 108.
NHTSA’s Decision
General Principles: Federal motor
vehicle safety standards are adopted
only after the agency has determined,
following notice and comment, that the
performance requirements are objective,
practicable, and meet the need for motor
vehicle safety.5 There is a general
presumption that the failure of a motor
vehicle or item of motor vehicle
equipment to comply with an FMVSS
increases the risk to motor vehicle safety
beyond the level determined
appropriate by NHTSA through the
rulemaking process. To protect the
public from such risks, manufacturers
whose products fail to comply with an
FMVSS are normally required to
conduct a safety recall under which
they must notify owners, purchasers,
and dealers of the noncompliance and
provide a remedy without charge.6
Congress has, however, recognized
that under some limited circumstances
a noncompliance may be
‘‘inconsequential’’ to motor vehicle
safety. Neither NHTSA’s statute nor its
regulations define ‘‘inconsequential.’’
NHTSA determines whether a particular
noncompliance is inconsequential to
motor vehicle safety based on the
specific facts before the agency. The key
issue in evaluating an
inconsequentiality petition is whether
the noncompliance is likely to increase
the safety risk to individuals who
experience the type of injurious event
against which the standard was
designed to protect.7 The agency is not
aware of any prior inconsequentiality
petitions concerning either of the two
requirements that are the subject of
Morgan’s petition.
NHTSA’s analysis: The agency has
determined that Morgan has not met its
burden of persuasion that the
U.S.C. 30111(a).
U.S.C. 30118–30120.
7 General Motors Corp., Ruling on Petition for
Determination of Inconsequential Noncompliance,
69 FR 19897, Apr. 14, 2004.
noncompliances are inconsequential to
safety. The agency is therefore denying
Morgan’s petition with respect to both
noncompliances. The agency’s reasons
for the denial are discussed below.
NHTSA is not persuaded by the
arguments of Morgan or Mr. Larsen
regarding the noncompliance with the
headlamp spacing requirement in
S10.17.1.2.2. Morgan’s assertion that the
subject vehicles meet the ‘‘technical
requirements’’ of FMVSS No. 108 is
inaccurate because the distance
requirement for headlamp configuration
is clearly stated in the regulation as one
of the requirements for compliance.8
Morgan acknowledges in its Part 573
defect notification report that the
headlamps on the subject vehicles do
not comply with this requirement.
The agency is also not persuaded by
Morgan and Mr. Larsen’s arguments that
the noncompliance not only does not
increase the safety risk, but is, in fact,
safety-enhancing, because the widerspaced headlamps convey a more
accurate impression of the vehicle’s
width to other motorists. An
inconsequentiality petition is not the
appropriate means to challenge the basis
or appropriateness of a requirement
specified in an FMVSS. The appropriate
venue for such an argument is a petition
for rulemaking to amend the current
safety standard. Nevertheless, neither
Morgan nor Mr. Larsen have offered
persuasive evidence that either the
standard or market conditions have
changed to undermine the basis for the
spacing limitation. The 200 mm
maximum spacing requirement was
added to the standard in 1998 in
response to a petition for rulemaking. In
the preamble to the final rule, NHTSA
explained the rationale for the
motorcycle headlight requirements:
‘‘[A]t the time that the motorcycle
headlight requirements in Standard No.
108 were originally issued, the
predominant concern was that the
headlighting system clearly identify a
motorcycle as such when the vehicle
was being operated at night.’’ 9 The
wider space between the headlamps on
the subject vehicles could impair the
ability of other motorists to identify the
subject vehicle as a motorcycle. Such
identification is important because
motorists may be more alert or alter
their driving in response to the presence
of a motorcycle, since motorcycles are
smaller, less enclosed, and less stable
than passenger cars and other motor
vehicles.10 Even if the Morgan vehicle’s
5 49
6 49
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8 S10.17.1.2.2.
9 63
FR 42582, 42582, Aug. 10, 1998.
noncompliance is also not de minimis. The
headlamps on the subject vehicles are 29 inches
10 The
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front end is wider than that of a typical
two-wheeled motorcycle, the vehicle is
still smaller, less enclosed, and less
stable than passenger cars and other
motor vehicles with which it shares the
road. In addition, to further distinguish
motorcycles from larger vehicles,
NHTSA’s regulations also allow
modulation of motorcycle headlamp
intensity to provide increased
conspicuity.11 If the subject Morgan
motorcycles were equipped with
modulators on its headlamps, the wide
spacing of the headlamps could be
perceived by other drivers as an
emergency or police vehicle. If Morgan
believed that lighting indicating the
width of the vehicle would enhance the
safety of the vehicle, Morgan could have
accomplished this by adding
supplemental lighting to the vehicle
(e.g., parking lamps), keeping in mind
that supplemental lighting may not
impair the effectiveness of required
lighting equipment.12 We also note that
the space between the headlamps is less
than the wheel-to-wheel width of the
vehicle, so the existing headlights do
not accurately indicate the actual width
of the vehicle.
Similarly, Mr. Larsen asserts that
when NHTSA promulgated this
headlamp spacing regulation it did not
contemplate three-wheeled vehicles
such as the subject vehicles, which, he
states, display the frontal aspect of a
small automobile. The initial Federal
Motor Vehicle Safety Standards,
published in 1967, defined a
‘‘motorcycle’’ as ‘‘a motor vehicle with
motive power having a seat or saddle for
the use of the rider and designed to
travel on not more than three wheels in
contact with the ground.’’ 13 This
definition, which is in effect today,14
clearly includes the subject vehicles.
While the M3W may be an unusual
design, the vehicle configuration is
unequivocally a motorcycle; as Mr.
Larsen notes in his comment, ‘‘the
Morgan 3 Wheeler follows the classic
lighting scheme.’’ Again, as we noted
above, a petition for rulemaking, not an
inconsequentiality petition, is the
proper mechanism if Morgan or Mr.
Larsen believes that the existing
requirement is not appropriate for the
subject vehicles.15
apart, while the maximum spacing permitted by the
standard is 200 mm (7.9 in).
11 S10.17.5.
12 S6.2.1.
13 32 FR 2408, 2409, Feb. 3, 1967.
14 49 CFR 571.3.
15 We note that subsequent to filing the present
inconsequentiality petition, Morgan did file a
petition for rulemaking on this issue. The agency
is currently evaluating this petition.
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Morgan also cites, in support of its
petition, a prior agency decision
granting a General Motors
inconsequentiality petition.16 That
inconsequentiality petition concerned a
noncompliance with a minimum
required separation distance between a
daytime running lamp (DRL) and a front
turn signal. The purpose of that spacing
requirement is to prevent masking of the
turn signal lamp by the DRLs. The
agency found that masking would not be
an issue in that case because those
vehicles incorporated front turn signals
that were five times the required
minimum area and four times brighter
than the minimum required photometry.
NHTSA went on to state that its
research showed that high turn signal
intensity was very important to prevent
masking. Because the requirements at
issue in the General Motors petition are
intended to address a fundamentally
different safety issue than the
requirement from which Morgan is
seeking a grant of inconsequential
noncompliance, we do not find the
General Motors petition to be relevant
for our consideration of Morgan’s
petition; as discussed above, we believe
that the greater than allowed distance
between the headlamps might hinder
other motorists from identifying the
subject vehicles as motorcycles.
Mr. Larsen also states that he
developed a motorcycle on which the
subject vehicle is based, and states that
the headlamp location was configured
as described in NHTSA’s published
guidebook entitled ‘‘Requirements of
Motorcycle Manufacturers.’’ Mr. Larsen
did not further identify this guide, but
he appears to refer to the NHTSA guide
entitled ‘‘Requirements for Motorcycle
Manufacturers,’’ published in February
2000.17 This guide states that it ‘‘merely
highlights the major requirements for
manufacturers; each manufacturer
should consult the specific statutes,
regulations, and standards to determine
its responsibilities.’’ 18 The lighting
standard (FMVSS No. 108) contains
many motorcycle lighting requirements
in addition to the limited subset of
requirements that are summarized in
Table IV of the NHTSA guide.
Mr. Larsen also suggests that if
NHTSA were to deny Morgan’s petition,
it would ‘‘criminalize’’ owners and
dealers of the subject vehicles (who, he
asserts, will likely replace a single
center light and replace it with dual,
widely-spaced lights). This is incorrect.
16 64
FR 28864, May 27, 1999.
at https://www.nhtsa.gov/
Laws+&+Regulations/Manufacturer+Info/
Requirements+for+Motorcycle+Manufacturers.
18 Id. at pages 3 and 4.
17 Available
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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.19
Finally, the agency is not persuaded
by Mr. Larsen’s argument that it would
be unjust to ‘‘suddenly penalize’’ and
require Morgan to recall the subject
vehicles because, he asserts, there are
many three-wheeled vehicles with
wide-spaced dual headlights similar to
the subject vehicles. The spacing
regulation at issue has been in effect
since 1998. Moreover, it does not apply
to all three-wheeled motorcycles
currently on the road. It applies to
vehicles manufactured or imported into
the United States after the effective date
of the 1998 final rule. Accordingly, it
does not apply, for example, to vintage
vehicles that were manufactured before
the effective date of the final rule.
Regarding the ‘‘DOT’’ marking
requirement, the agency is also not
persuaded by Morgan’s arguments. In
the past, NHTSA has granted
inconsequentiality petitions for lighting
components that did not have certain
required markings.20 As we noted
earlier, however, we are not aware of
any prior inconsequentiality petitions
concerning the ‘‘DOT’’ marking
requirement at issue in Morgan’s
petition. We are not persuaded that the
absence of the ‘‘DOT’’ mark is
inconsequential to motor vehicle safety
in this case. The ‘‘DOT’’ mark on a
headlamp indicates that the lamp
manufacturer has certified the lamp as
conforming to all applicable
requirements. Morgan has provided no
information or data to demonstrate that
the headlamps otherwise comply with
the requirements of FMVSS No. 108.
Morgan asserts that the lamps meet the
19 NHTSA encourages vehicle owners to have
recalled vehicles promptly remedied. We also note
the statutory prohibition on making required safety
elements inoperative. 49 U.S.C. 30122. This
prohibition, however, applies only to
manufacturers, distributors, dealers, and motor
vehicle repair businesses. § 30122. It does not apply
to individual vehicle owners. See Letter from
NHTSA Chief Counsel Frank Seales, Jr. to Hamsar
Diversco Inc., Jan. 22, 1999, available at https://
isearch.nhtsa.gov/search.htm.
20 See, e.g., 78 FR 22943, Apr. 17, 2013 (grant of
inconsequentiality petition from Osram Sylvania
Products, Inc. for noncompliance with the light
source marking requirements of FMVSS No. 108
S7.7.).
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‘‘substantive’’ requirements of FMVSS
No. 108, but has provided no
information as to which requirements it
considers ‘‘substantive’’ and which it
does not. Morgan has submitted no
compliance testing data or information
showing that the lamps comply with all
relevant requirements. Without such
information and data, and without a
‘‘DOT’’ mark on the headlamp to imply
that such information and data exist, the
agency is unable to conclude that the
lack of the ‘‘DOT’’ mark is the only
noncompliant aspect of the headlamps.
In addition to the arguments
addressed above, the agency is also not
persuaded by two additional arguments
Morgan makes for why it believes
NHTSA should grant the petition with
respect to both noncompliances. First,
Morgan argues that its petition should
be granted because the subject vehicle is
an exotic vehicle produced in very low
numbers and likely to be operated on a
limited basis, as opposed to a passenger
automobile designed to be used as a
family’s primary passenger vehicle. In
support of this argument, Morgan cites
two previous agency decisions granting
inconsequentiality petitions.21 Both
petitions concerned noncompliances
with automatic restraint requirements in
FMVSS No. 208. The agency’s decisions
in those situations were based on the
fact that it had already granted
temporary exemption petitions from
both manufacturers for the vehicle
models at issue in those
inconsequentiality petitions. The agency
has not previously granted Morgan a
temporary exemption for the
noncompliances at issue in the present
petition. Moreover, the ‘‘vehicle
attributes’’ that Morgan implies those
grants were based on—that the vehicles
were exotic vehicles likely operated on
a limited basis—were simply arguments
made by the petitioners in those cases,
and not, as Morgan’s petition implies,
the basis for the agency’s decision.
NHTSA expects manufacturers to fulfill
their duties and responsibilities to
provide vehicles that meet all safety
standards regardless of production
volume or estimated consumer use.
Second, Morgan states that there have
been no reports of any safety issues or
injuries related to the subject
noncompliances. NHTSA does not
consider the absence of complaints to
show that the noncompliances are
inconsequential to safety. The subject
vehicle population is small, so the lack
of reports or complaints may not be
21 60 FR 27593, May 24, 1995 (grant of
inconsequentiality petition from Excalibur
Automobile Corp.); 61 FR 9517, Mar. 8, 1996 (grant
of inconsequentiality petition from Cantab Motors,
Ltd.).
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surprising. Further, vehicle lighting
functions as a signal to other motorists
and pedestrians; if other motorists
found the noncompliant lighting
confusing, it is unlikely that those
motorists would have been able to
identify the subject vehicle and make a
complaint to either NHTSA or Morgan.
Most importantly, the absence of a
complaint does not mean there have not
been any safety issues, nor does it mean
that there will not be safety issues in the
future.
Finally, the agency observes that
although Morgan’s Part 573 report and
inconsequentiality petition only
concern the headlamp spacing and
headlamp marking noncompliances, the
subject vehicles may also fail to comply
with other applicable FMVSSs. For
example, a motorcycle headlamp that
incorporates a replaceable light source
that does not comply with FMVSS No.
108, paragraph S11 (e.g., an H4 light
source which is only permitted on
motorcycle specific headlamps) is also
required to have the headlamp lens
permanently marked ‘‘motorcycle.’’ This
marking may not have appeared on the
headlamps of one of the subject vehicles
the agency observed.
Morgan’s proposed remedy: Morgan
proposes to add a single FMVSS No. 108
compliant headlamp on the M3W’s
vertical centerline and have the original,
noncompliant headlamps remain as
separately switched auxiliary lamps.
Paragraph S6.2.1 of FMVSS No. 108
requires that any additional lighting
elements (i.e., lighting elements that are
not required by the standard) installed
on a vehicle must not impair the
effectiveness of lighting equipment
required by the standard. A motorcycle
equipped with both a compliant single
headlighting system and an auxiliary
(supplemental) dual-headlamp system
might be prohibited by the impairment
provision. The proximity of the
auxiliary lamps to the required front
turn signal lamps might also raise
impairment concerns. We strongly
encourage Morgan to review the
standard to ensure that its remedy does
indeed comply with all applicable
requirements.
NHTSA’s Decision: After carefully
considering the arguments presented on
this matter, NHTSA finds that the
petitioner has not met its burden of
persuasion in establishing that the
described noncompliances in the
subject vehicles are inconsequential to
motor vehicle safety. Accordingly,
Morgan’s petition is hereby denied, and
Morgan must notify owners, purchasers
and dealers pursuant to 49 U.S.C. 30118
and provide a free remedy in
accordance with 49 U.S.C. 30120.
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Authority: 49 U.S.C. 30118, 30120:
delegations of authority at 49 CFR 1.95 and
501.8.
Gregory K. Rea,
Associate Administrator for Enforcement.
[FR Doc. 2016–08360 Filed 4–11–16; 8:45 am]
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SUMMARY:
E:\FR\FM\12APN1.SGM
12APN1
Agencies
[Federal Register Volume 81, Number 70 (Tuesday, April 12, 2016)]
[Notices]
[Pages 21663-21666]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-08360]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2013-0101; Notice 2]
Morgan 3 Wheeler Limited, Denial of Petition for Decision of
Inconsequential Noncompliance
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Denial of petition.
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SUMMARY: Morgan 3 Wheeler Limited (Morgan) has determined that certain
model year (MY) 2012 and 2013 Morgan model M3W three-wheeled
motorcycles do not comply with all of the requirements of Federal Motor
Vehicle Safety Standard (FMVSS) No. 108, Lamps, reflective devices, and
associated equipment. Specifically, the vehicles' headlamps are spaced
further apart than permitted, and do not have the required ``DOT''
marking. Morgan has petitioned for an exemption from the recall
notification and remedy requirements of 49 U.S.C. Chapter 301--``Motor
Vehicle Safety'' (Vehicle Safety Act) on the grounds that the
noncompliances are inconsequential to motor vehicle safety. This notice
announces and explains NHTSA's denial of Morgan's petition.
FOR FURTHER INFORMATION CONTACT: For further information on this
decision contact Mike Cole, Office of Vehicle Safety Compliance,
National Highway Traffic Safety Administration (NHTSA), telephone (202)
366-2334, facsimile (202) 366-5930.
SUPPLEMENTARY INFORMATION:
I. Overview: Pursuant to 49 U.S.C. 30118(d) and 30120(h) and the
rule implementing those provisions at 49 CFR part 556, Morgan has
petitioned for an exemption from the notification and remedy
requirements of 49 U.S.C. Chapter 301 on the basis that the
noncompliances are inconsequential to motor vehicle safety.
Notice of receipt of the petition was published, with a 30-day
public comment period, on December 9, 2013 in the Federal Register (78
FR 73920). One comment was received from Peter C. Larsen of Liberty
Motors, LLC. To view the petition and all supporting documents log onto
the Federal Docket Management System Web site at: https://www.regulations.gov/. Follow the online search instructions to locate
docket number ``NHTSA-2013-0101.''
II. Vehicles involved: Approximately 150 MY 2012 and 2013 Morgan
model M3W three-wheeled motorcycles manufactured from August 1, 2012 to
August 14, 2013 (subject vehicles) are affected.
III. Noncompliances: Morgan's petition concerns two requirements in
FMVSS No. 108.\1\ Both noncompliances involve the vehicles' headlights.
Morgan states that the noncompliances are a result of a configuration
error in its production line. The first noncompliance involves the
spacing between the headlights. 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.\2\ Morgan states in its petition that the subject motorcycles
do not comply with this requirement because they are equipped with dual
horizontally-mounted headlamps mounted 29 inches (737 mm) apart (lens
edge to lens edge).
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\1\ 49 CFR 571.108.
\2\ In a December 2007 final rule, NHTSA rewrote and reorganized
FMVSS No. 108 to provide a more straightforward and logical
presentation of the regulatory requirements. 72 FR 68234, Dec. 4,
2007. Those amendments became effective on December 1, 2012. 74 FR
58214, Nov. 12, 2009. The rewrite was not intended to make any
substantive changes to the standard. The subject vehicle population
includes vehicles manufactured both before and after this effective
date. Prior to the effective date of the reorganized standard, the
headlight spacing requirement was contained in S7.9.6.2(b).
---------------------------------------------------------------------------
The second noncompliance concerns the lack of a required marking on
the headlamps. Paragraph S6.5.1 of FMVSS No. 108 requires that the lens
of each original equipment and replacement headlamp be marked with the
symbol ``DOT,'' either horizontally or vertically, to indicate
certification under 49 U.S.C. 30115.\3\ Morgan states in its petition
that the subject vehicles do not include this marking.
---------------------------------------------------------------------------
\3\ This provision was located at S7.2(a) in the pre-rewrite
version of FMVSS No. 108.
---------------------------------------------------------------------------
IV. Rule Text: Paragraphs S7.9.6.2(b) and S10.17.1.2.2 of FMVSS No.
108 require in pertinent part:
Paragraph S7.9.6.2(b) (applies only to the subject vehicles
manufactured before December 1, 2012).
If the system consists of two headlamps, each of which provides
both an upper and lower beam, the headlamps shall be mounted either
at the same height and symmetrically disposed about the vertical
centerline or mounted on the vertical centerline. If the headlamps
are horizontally disposed about the vertical centerline, the
distance between the closest edges of their effective projected
luminous lens areas shall not be greater than 200 mm (8 in.).
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.
V. Summary of Morgan's Petition and Comments: Morgan petitions for
relief from the recall provisions of the Vehicle Safety Act with
respect to both of these noncompliances. Morgan makes several arguments
to support its assertion that these noncompliances are inconsequential
to motor vehicle safety.
With respect to the headlamp spacing noncompliance, Morgan contends
that
[[Page 21664]]
the headlamps meet the ``technical requirements'' of FMVSS No. 108.
Morgan also states that it does not believe that this noncompliance
will increase the safety risk to vehicle occupants or approaching
drivers. Morgan argues that the current horizontal spacing of 29 inches
(737 mm) is in the best interests of road safety, because if the M3W
complied with the existing motorcycle head lamp spacing requirement,
other road users would not have an accurate indication of the width of
an oncoming M3W. Morgan also argues that NHTSA has previously found a
lighting separation noncompliance to be inconsequential.\4\
---------------------------------------------------------------------------
\4\ See 64 FR 28864, May 27, 1999.
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Morgan contends that the lens marking noncompliance is
inconsequential to motor vehicle safety because the lamps meet the
substantive requirements of FMVSS No. 108. Morgan also states that
owners of Morgan vehicles almost exclusively go to Morgan dealers for
replacement parts; the agency assumes that Morgan is implying that
because the vehicle owner is likely to obtain a replacement part
directly from a dealer, the owner can be confident that the headlamp
complies with all applicable requirements, even though it lacks the
proper ``DOT'' marking.
With respect to both noncompliances, Morgan asserts, based on its
reading of previous inconsequentiality petition grants by NHTSA, that
its noncompliances should be found to be inconsequential because the
M3W is an exotic vehicle with no roof or doors, produced in very low
numbers, driven a low number of miles, and likely to be operated on a
limited basis, as opposed to an ordinary passenger automobile designed
to be used as a family's primary passenger vehicle. Morgan also states
that there have been no reports of any safety issues or injuries
related to the subject noncompliances. NHTSA received one comment on
Morgan's petition from Peter Larsen. Mr. Larsen makes several arguments
in support of Morgan's petition. First, Mr. Larsen asserts that a
NHTSA-published guidebook on motorcycle requirements does not contain
the 200 mm spacing requirement. Second, Mr. Larsen argues that when
NHTSA promulgated this requirement it did not contemplate three-wheeled
vehicles with the frontal aspect of a small automobile, for which
headlights spaced more than 200 mm apart help to indicate the size and
shape of the vehicle. Accordingly, Mr. Larsen contends that the 200 mm
requirement, as applied to the subject vehicles, is not in the interest
of safety. Third, Mr. Larsen suggests that if the subject vehicles are
remedied so that the dual headlights are replaced with a compliant
center headlight, owners and dealers of the subject vehicles would
likely remove the single center light and replace it with the dual,
widely-spaced lights; and that a recall or design revision, Mr. Larsen
asserts, would ``criminalize'' these actions. Finally, Mr. Larsen
argues that many existing three-wheeled vehicles have similarly-spaced
dual headlights, and it would be unjust to penalize Morgan's similar
design. Mr. Larsen requests that NHTSA ``properly amend'' FMVSS No.
108.
NHTSA's Decision
General Principles: Federal motor vehicle safety standards are
adopted only after the agency has determined, following notice and
comment, that the performance requirements are objective, practicable,
and meet the need for motor vehicle safety.\5\ There is a general
presumption that the failure of a motor vehicle or item of motor
vehicle equipment to comply with an FMVSS increases the risk to motor
vehicle safety beyond the level determined appropriate by NHTSA through
the rulemaking process. To protect the public from such risks,
manufacturers whose products fail to comply with an FMVSS are normally
required to conduct a safety recall under which they must notify
owners, purchasers, and dealers of the noncompliance and provide a
remedy without charge.\6\
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\5\ 49 U.S.C. 30111(a).
\6\ 49 U.S.C. 30118-30120.
---------------------------------------------------------------------------
Congress has, however, recognized that under some limited
circumstances a noncompliance may be ``inconsequential'' to motor
vehicle safety. Neither NHTSA's statute nor its regulations define
``inconsequential.'' NHTSA determines whether a particular
noncompliance is inconsequential to motor vehicle safety based on the
specific facts before the agency. The key issue in evaluating an
inconsequentiality petition is whether the noncompliance is likely to
increase the safety risk to individuals who experience the type of
injurious event against which the standard was designed to protect.\7\
The agency is not aware of any prior inconsequentiality petitions
concerning either of the two requirements that are the subject of
Morgan's petition.
---------------------------------------------------------------------------
\7\ General Motors Corp., Ruling on Petition for Determination
of Inconsequential Noncompliance, 69 FR 19897, Apr. 14, 2004.
---------------------------------------------------------------------------
NHTSA's analysis: The agency has determined that Morgan has not met
its burden of persuasion that the noncompliances are inconsequential to
safety. The agency is therefore denying Morgan's petition with respect
to both noncompliances. The agency's reasons for the denial are
discussed below.
NHTSA is not persuaded by the arguments of Morgan or Mr. Larsen
regarding the noncompliance with the headlamp spacing requirement in
S10.17.1.2.2. Morgan's assertion that the subject vehicles meet the
``technical requirements'' of FMVSS No. 108 is inaccurate because the
distance requirement for headlamp configuration is clearly stated in
the regulation as one of the requirements for compliance.\8\ Morgan
acknowledges in its Part 573 defect notification report that the
headlamps on the subject vehicles do not comply with this requirement.
---------------------------------------------------------------------------
\8\ S10.17.1.2.2.
---------------------------------------------------------------------------
The agency is also not persuaded by Morgan and Mr. Larsen's
arguments that the noncompliance not only does not increase the safety
risk, but is, in fact, safety-enhancing, because the wider-spaced
headlamps convey a more accurate impression of the vehicle's width to
other motorists. An inconsequentiality petition is not the appropriate
means to challenge the basis or appropriateness of a requirement
specified in an FMVSS. The appropriate venue for such an argument is a
petition for rulemaking to amend the current safety standard.
Nevertheless, neither Morgan nor Mr. Larsen have offered persuasive
evidence that either the standard or market conditions have changed to
undermine the basis for the spacing limitation. The 200 mm maximum
spacing requirement was added to the standard in 1998 in response to a
petition for rulemaking. In the preamble to the final rule, NHTSA
explained the rationale for the motorcycle headlight requirements:
``[A]t the time that the motorcycle headlight requirements in Standard
No. 108 were originally issued, the predominant concern was that the
headlighting system clearly identify a motorcycle as such when the
vehicle was being operated at night.'' \9\ The wider space between the
headlamps on the subject vehicles could impair the ability of other
motorists to identify the subject vehicle as a motorcycle. Such
identification is important because motorists may be more alert or
alter their driving in response to the presence of a motorcycle, since
motorcycles are smaller, less enclosed, and less stable than passenger
cars and other motor vehicles.\10\ Even if the Morgan vehicle's
[[Page 21665]]
front end is wider than that of a typical two-wheeled motorcycle, the
vehicle is still smaller, less enclosed, and less stable than passenger
cars and other motor vehicles with which it shares the road. In
addition, to further distinguish motorcycles from larger vehicles,
NHTSA's regulations also allow modulation of motorcycle headlamp
intensity to provide increased conspicuity.\11\ If the subject Morgan
motorcycles were equipped with modulators on its headlamps, the wide
spacing of the headlamps could be perceived by other drivers as an
emergency or police vehicle. If Morgan believed that lighting
indicating the width of the vehicle would enhance the safety of the
vehicle, Morgan could have accomplished this by adding supplemental
lighting to the vehicle (e.g., parking lamps), keeping in mind that
supplemental lighting may not impair the effectiveness of required
lighting equipment.\12\ We also note that the space between the
headlamps is less than the wheel-to-wheel width of the vehicle, so the
existing headlights do not accurately indicate the actual width of the
vehicle.
---------------------------------------------------------------------------
\9\ 63 FR 42582, 42582, Aug. 10, 1998.
\10\ The noncompliance is also not de minimis. The headlamps on
the subject vehicles are 29 inches apart, while the maximum spacing
permitted by the standard is 200 mm (7.9 in).
\11\ S10.17.5.
\12\ S6.2.1.
---------------------------------------------------------------------------
Similarly, Mr. Larsen asserts that when NHTSA promulgated this
headlamp spacing regulation it did not contemplate three-wheeled
vehicles such as the subject vehicles, which, he states, display the
frontal aspect of a small automobile. The initial Federal Motor Vehicle
Safety Standards, published in 1967, defined a ``motorcycle'' as ``a
motor vehicle with motive power having a seat or saddle for the use of
the rider and designed to travel on not more than three wheels in
contact with the ground.'' \13\ This definition, which is in effect
today,\14\ clearly includes the subject vehicles. While the M3W may be
an unusual design, the vehicle configuration is unequivocally a
motorcycle; as Mr. Larsen notes in his comment, ``the Morgan 3 Wheeler
follows the classic lighting scheme.'' Again, as we noted above, a
petition for rulemaking, not an inconsequentiality petition, is the
proper mechanism if Morgan or Mr. Larsen believes that the existing
requirement is not appropriate for the subject vehicles.\15\
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\13\ 32 FR 2408, 2409, Feb. 3, 1967.
\14\ 49 CFR 571.3.
\15\ We note that subsequent to filing the present
inconsequentiality petition, Morgan did file a petition for
rulemaking on this issue. The agency is currently evaluating this
petition.
---------------------------------------------------------------------------
Morgan also cites, in support of its petition, a prior agency
decision granting a General Motors inconsequentiality petition.\16\
That inconsequentiality petition concerned a noncompliance with a
minimum required separation distance between a daytime running lamp
(DRL) and a front turn signal. The purpose of that spacing requirement
is to prevent masking of the turn signal lamp by the DRLs. The agency
found that masking would not be an issue in that case because those
vehicles incorporated front turn signals that were five times the
required minimum area and four times brighter than the minimum required
photometry. NHTSA went on to state that its research showed that high
turn signal intensity was very important to prevent masking. Because
the requirements at issue in the General Motors petition are intended
to address a fundamentally different safety issue than the requirement
from which Morgan is seeking a grant of inconsequential noncompliance,
we do not find the General Motors petition to be relevant for our
consideration of Morgan's petition; as discussed above, we believe that
the greater than allowed distance between the headlamps might hinder
other motorists from identifying the subject vehicles as motorcycles.
---------------------------------------------------------------------------
\16\ 64 FR 28864, May 27, 1999.
---------------------------------------------------------------------------
Mr. Larsen also states that he developed a motorcycle on which the
subject vehicle is based, and states that the headlamp location was
configured as described in NHTSA's published guidebook entitled
``Requirements of Motorcycle Manufacturers.'' Mr. Larsen did not
further identify this guide, but he appears to refer to the NHTSA guide
entitled ``Requirements for Motorcycle Manufacturers,'' published in
February 2000.\17\ This guide states that it ``merely highlights the
major requirements for manufacturers; each manufacturer should consult
the specific statutes, regulations, and standards to determine its
responsibilities.'' \18\ The lighting standard (FMVSS No. 108) contains
many motorcycle lighting requirements in addition to the limited subset
of requirements that are summarized in Table IV of the NHTSA guide.
---------------------------------------------------------------------------
\17\ Available at https://www.nhtsa.gov/Laws+&+Regulations/Manufacturer+Info/Requirements+for+Motorcycle+Manufacturers.
\18\ Id. at pages 3 and 4.
---------------------------------------------------------------------------
Mr. Larsen also suggests that if NHTSA were to deny Morgan's
petition, it would ``criminalize'' owners and dealers of the subject
vehicles (who, he asserts, will likely replace a single center light
and replace it with dual, widely-spaced lights). This is incorrect.
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.\19\
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\19\ NHTSA encourages vehicle owners to have recalled vehicles
promptly remedied. We also note the statutory prohibition on making
required safety elements inoperative. 49 U.S.C. 30122. This
prohibition, however, applies only to manufacturers, distributors,
dealers, and motor vehicle repair businesses. Sec. 30122. It does
not apply to individual vehicle owners. See Letter from NHTSA Chief
Counsel Frank Seales, Jr. to Hamsar Diversco Inc., Jan. 22, 1999,
available at https://isearch.nhtsa.gov/search.htm.
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Finally, the agency is not persuaded by Mr. Larsen's argument that
it would be unjust to ``suddenly penalize'' and require Morgan to
recall the subject vehicles because, he asserts, there are many three-
wheeled vehicles with wide-spaced dual headlights similar to the
subject vehicles. The spacing regulation at issue has been in effect
since 1998. Moreover, it does not apply to all three-wheeled
motorcycles currently on the road. It applies to vehicles manufactured
or imported into the United States after the effective date of the 1998
final rule. Accordingly, it does not apply, for example, to vintage
vehicles that were manufactured before the effective date of the final
rule.
Regarding the ``DOT'' marking requirement, the agency is also not
persuaded by Morgan's arguments. In the past, NHTSA has granted
inconsequentiality petitions for lighting components that did not have
certain required markings.\20\ As we noted earlier, however, we are not
aware of any prior inconsequentiality petitions concerning the ``DOT''
marking requirement at issue in Morgan's petition. We are not persuaded
that the absence of the ``DOT'' mark is inconsequential to motor
vehicle safety in this case. The ``DOT'' mark on a headlamp indicates
that the lamp manufacturer has certified the lamp as conforming to all
applicable requirements. Morgan has provided no information or data to
demonstrate that the headlamps otherwise comply with the requirements
of FMVSS No. 108. Morgan asserts that the lamps meet the
[[Page 21666]]
``substantive'' requirements of FMVSS No. 108, but has provided no
information as to which requirements it considers ``substantive'' and
which it does not. Morgan has submitted no compliance testing data or
information showing that the lamps comply with all relevant
requirements. Without such information and data, and without a ``DOT''
mark on the headlamp to imply that such information and data exist, the
agency is unable to conclude that the lack of the ``DOT'' mark is the
only noncompliant aspect of the headlamps.
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\20\ See, e.g., 78 FR 22943, Apr. 17, 2013 (grant of
inconsequentiality petition from Osram Sylvania Products, Inc. for
noncompliance with the light source marking requirements of FMVSS
No. 108 S7.7.).
---------------------------------------------------------------------------
In addition to the arguments addressed above, the agency is also
not persuaded by two additional arguments Morgan makes for why it
believes NHTSA should grant the petition with respect to both
noncompliances. First, Morgan argues that its petition should be
granted because the subject vehicle is an exotic vehicle produced in
very low numbers and likely to be operated on a limited basis, as
opposed to a passenger automobile designed to be used as a family's
primary passenger vehicle. In support of this argument, Morgan cites
two previous agency decisions granting inconsequentiality
petitions.\21\ Both petitions concerned noncompliances with automatic
restraint requirements in FMVSS No. 208. The agency's decisions in
those situations were based on the fact that it had already granted
temporary exemption petitions from both manufacturers for the vehicle
models at issue in those inconsequentiality petitions. The agency has
not previously granted Morgan a temporary exemption for the
noncompliances at issue in the present petition. Moreover, the
``vehicle attributes'' that Morgan implies those grants were based on--
that the vehicles were exotic vehicles likely operated on a limited
basis--were simply arguments made by the petitioners in those cases,
and not, as Morgan's petition implies, the basis for the agency's
decision. NHTSA expects manufacturers to fulfill their duties and
responsibilities to provide vehicles that meet all safety standards
regardless of production volume or estimated consumer use.
---------------------------------------------------------------------------
\21\ 60 FR 27593, May 24, 1995 (grant of inconsequentiality
petition from Excalibur Automobile Corp.); 61 FR 9517, Mar. 8, 1996
(grant of inconsequentiality petition from Cantab Motors, Ltd.).
---------------------------------------------------------------------------
Second, Morgan states that there have been no reports of any safety
issues or injuries related to the subject noncompliances. NHTSA does
not consider the absence of complaints to show that the noncompliances
are inconsequential to safety. The subject vehicle population is small,
so the lack of reports or complaints may not be surprising. Further,
vehicle lighting functions as a signal to other motorists and
pedestrians; if other motorists found the noncompliant lighting
confusing, it is unlikely that those motorists would have been able to
identify the subject vehicle and make a complaint to either NHTSA or
Morgan. Most importantly, the absence of a complaint does not mean
there have not been any safety issues, nor does it mean that there will
not be safety issues in the future.
Finally, the agency observes that although Morgan's Part 573 report
and inconsequentiality petition only concern the headlamp spacing and
headlamp marking noncompliances, the subject vehicles may also fail to
comply with other applicable FMVSSs. For example, a motorcycle headlamp
that incorporates a replaceable light source that does not comply with
FMVSS No. 108, paragraph S11 (e.g., an H4 light source which is only
permitted on motorcycle specific headlamps) is also required to have
the headlamp lens permanently marked ``motorcycle.'' This marking may
not have appeared on the headlamps of one of the subject vehicles the
agency observed.
Morgan's proposed remedy: Morgan proposes to add a single FMVSS No.
108 compliant headlamp on the M3W's vertical centerline and have the
original, noncompliant headlamps remain as separately switched
auxiliary lamps. Paragraph S6.2.1 of FMVSS No. 108 requires that any
additional lighting elements (i.e., lighting elements that are not
required by the standard) installed on a vehicle must not impair the
effectiveness of lighting equipment required by the standard. A
motorcycle equipped with both a compliant single headlighting system
and an auxiliary (supplemental) dual-headlamp system might be
prohibited by the impairment provision. The proximity of the auxiliary
lamps to the required front turn signal lamps might also raise
impairment concerns. We strongly encourage Morgan to review the
standard to ensure that its remedy does indeed comply with all
applicable requirements.
NHTSA's Decision: After carefully considering the arguments
presented on this matter, NHTSA finds that the petitioner has not met
its burden of persuasion in establishing that the described
noncompliances in the subject vehicles are inconsequential to motor
vehicle safety. Accordingly, Morgan's petition is hereby denied, and
Morgan must notify owners, purchasers and dealers pursuant to 49 U.S.C.
30118 and provide a free remedy in accordance with 49 U.S.C. 30120.
Authority: 49 U.S.C. 30118, 30120: delegations of authority at
49 CFR 1.95 and 501.8.
Gregory K. Rea,
Associate Administrator for Enforcement.
[FR Doc. 2016-08360 Filed 4-11-16; 8:45 am]
BILLING CODE 4910-59-P