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Making Sense of NHTSA's ADB Proposal PDF Print E-mail
Monday, 22 October 2018

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!

Sincerely,

 

In depth...

Addressing NHTSA's ADB Proposal PDF Print E-mail
Monday, 22 October 2018

First in a series

11 days ago, the US National Highway Transportation Safety Administration published a notice of proposed rulemaking to allow ADB in the world's largest developed market not yet allowing the technology. And six days ago, the SAE Lighting Systems Group ADB Task Force held their first meeting about it. With local participants in Michigan as well as remote participation by WebEx and phone from interested persons located across North America and parts of Europe, the meeting lasted over an hour and a half—and the plan is for meetings like this to convene on a weekly basis for the foreseeable future. Unless someone applies for an extension and NHTSA grants it, that future is just 49 days long; the public comment period on the proposal closes on 11 December. Right from go, there are mixed feelings about this state of affairs; on one hand, it can legitimately be said that a rule allowing ADB—any rule allowing any ADB—will be an improvement over the present total ban. On the other hand, there's that sinking-pit-of-stomach feeling of being stuck between bad and worse: it is felt that many points and provisions in NHTSA's proposal warrant a great deal more thought and care, and that it will take a great deal of time to run tests and experiments to generate the data needed to persuade NHTSA to make adjustments. The timing is difficult, too: if an extension is granted, a big chunk of the extra time will be unusable, as it would coincide with Christmas and New Year's when it's difficult to get any work done.

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