Dear Carolyn Maloney, Chair, and Members, US House Oversight Committee,

On February 22, 2022, NHTSA published the final rule for Adaptive Driving Beam headlights: 
https://www.federalregister.gov/documents/2022/02/22/2022-02451/federal-motor-vehicle-safety-standards-lamps-reflective-devices-and-associated-equipment-adaptive

NHTSA's stated goal for approving ADB is to reduce glare.  The word "glare" is mentioned 586 times in the ADB final rule.  NHTSA states, "NHTSA is sensitive to concerns about glare due to the numerous complaints from the public it has received and its own research"

Glare is caused by blue wavelength light.  However, a search of the ADB final rule shows zero references to blue wavelength light.  NHTSA has no regulations for restricting blue wavelength light (approximately 450 nanometers)  that causes glare.  How can NHTSA possibly claim that they are sensitive to issues of glare without discussing blue wavelength light?

The ADB rule states that over 5,000 people have contacted NHTSA about glare from halogen headlights, so NHTSA "studied" the issue, but took little or no action.  However, the petition to ban blinding LED headlights, with their excessive amount of blue wavelength light, has over 30,000 signatures, which is 6 times as many people who were concerned about glare from halogen headlights, and yet NHTSA does not even mention these 30,000 signatures and comments in the final rule.  Comments include "Lights blind other drivers and cause deaths and accidents" and "These lights are blinding and make driving in the dark very difficult!" (https://www.change.org/p/u-s-dot-ban-blinding-headlights-and-save-lives/comments)

The Soft Lights Foundation has been notifying NHTSA about the dangers of glare from LED headlights for several years.  Ann Carlson, Chief Legal Counsel for NHTSA notified us that she has received our letters and would "follow up when we have additional information to share."  Acting NHTSA Director Steven Cliff told us, "Dr. Cliff is not currently available due to meeting constraints."

The ADB final rule states that NHTSA is willing to ignore the fact that ADB systems do not work on hills, as if there are no hills anywhere in the USA, and as if it's perfectly fine to blind drivers with blue wavelength light on hills. (See Section H.)

We have a situation where NHTSA leadership is acting recklessly, negligently, and without oversight.  To control glare from headlights, blue wavelength light must be restricted.  Yet, Steven Cliff and Ann Carlson have done nothing to regulate blue wavelength light from headlights.  Instead, they seem to be spending their time doing the bidding of the auto industry by approving ADB headlights.

The public is demanding that the US House Oversight Committee hold NHTSA administrators accountable.  NHTSA cannot continue simply being an extension of the auto industry.  NHTSA must be required to limit blue wavelength light, limit peak luminance, and limit flicker from headlight systems before authorizing ADB systems.  The only way to hold NHTSA leadership accountable is by holding public hearings.  We request that the US House Oversight Committee.  The Soft Lights Foundation is willing to testify at these hearings.

Sincerely,

Mark Baker
President
Soft Lights Foundation
www.softlights.org
mbaker@softlights.org