DVN reported on NHTSA's request for comment on the agency's proposed addition of a crash-avoidance element to the US NCAP, including lighting and active-safety systems.
Then we analysed the proposed low-beam headlight performance protocol. The nominal deadline of 16 February has passed, but NHTSA—adhering to their custom—are still accepting and posting comments, including by some automakers and other high-profile commenters. So interested parties who haven't yet sent in comments shouldn't feel they've missed their chance; the comment portal remains open as of this writing. Now let's take a look at some of the lighting- and active-safety-related comments amongst the 288 sent in so far.
Commenters can be loosely categorised as follows, grouped a little differently than in other contexts, and with some degree of overlap:
• Automakers and parts suppliers, auto industry consortiums;
• Safety or research organisations and advocacy groups;
• Unaffiliated experts (here meaning individuals having relevant knowledge or training);
• General public (here meaning individuals not trained or educated in vehicle lighting or driver vision).
General Public & the Unaffiliated
Virtually all of the comments from the general public are to do with lighting and active safety. This is unsurprising; every traffic participant sees and interacts with vehicle lighting equipment virtually every day, but very few members of the general public have occasion to ponder the minutiæ of crashworthiness, pedestrian-protection standards, test dummies, and suchlike. There have been several comments from the general public and unaffiliated experts asking (or begging, pleading, scolding...) NHTSA, sometimes with analysis and documentary support, to go beyond their proposal and get amber rear turn signals onto all vehicles by requiring them, not merely encouraging them via NCAP. One member of the public, a professional driver, shared her thoughts on how the lack of uniform turn signals, as well as glare and poor performance from headlamps, create a hostile working environment for her.