Last week, we reported the publication of NHTSA’s proposed regulation on ADB. This week we take a first in-depth look at the proposal and some of its implications. It’s good to see progress of any kind on ADB in the USA—the only major developed country where it’s not yet allowed—but on the other hand it’s hard to celebrate very enthusastically. The provisions and particulars in NHTSA’s proposed rule differ significantly from the UN and SAE technical standards, and it’s difficult to see the divergence as grounded in a cogent, thoughtful rationale. It might be easier to accept NHTSA’s proposal, or at least understand it, if there were clear lines leading to its provisions from peculiarities of the vehicles, roadways, drivers, or market conditions in the United States.
But it’s hard to see those lines in this case, and that raises a batch of questions: Why did NHTSA propose what they did? UN Regulations do not comport with the American legal system, so adopting the R48 & R123 provisions was never going to happen, but why did NHTSA ask the SAE Lighting Systems Group to devise a technical standard for ADB, then ignore the carefully-thought-through J3069 standard the SAE group worked so dilligently, quickly, and efficiently to provide? Why do US regulators intend to apply static-beam photometric requirements to a system that exists to work around the limitations inherent to static-beam headlamps? Which of the objectionable points and questionable aspects of the proposal are worth fighting to fix? And given the short timeline involved, what should be the priorities in taking up the conversation with NHTSA?
The proposal is dismaying and disappointing, but at this stage it’s only a proposal. NHTSA will have the final word on the final rule—they’re in charge of writing, promulgating, and enforcing vehicle safety standards in the United States—but they’ve invited public comment. So now’s the time to urgently apply our expertise and insight to thoughtfully advise NHTSA in hopes of guiding them toward a thoughtful regulation that brings the maximum possible safety benefit for the maximum possible number of American drivers. Let’s get at it!