Dear Supporters,
Today I wrote the following letter to NHTSA (otto.matheke@dot.gov)
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Dear Otto Matheke III, Director, Office of Vehicle Safety Compliance, NHTSA,
I am providing additional evidence for cases: NHTSA-220815-006, NHTSA-220818-001, and NHTSA-220919-008
A) - Here is a link to an Oct. 26, 2022 article about the GMC Terrain Headlight recall.
https://www.autoblog.com/2022/10/26/gmc-terrain-headlight-recall-fix-frosted-sticker/ - NHTSA directed GMC to recall 740,581 units due to a tiny beam of light that was not landing on the roadway. NHTSA has taken the correct and legal action by requiring GMC to comply with FMVSS-108.
In the case of LED headlights from GMC, however, NHTSA has not taken the correct and legal action. LED headlights do not comply with FMVSS-108 because 1) GMC never petitioned NHTSA to use LED headlights, 2) NHTSA has no regulations for peak luminance, spatial non-uniformity, spectral power distribution, or square wave flicker from flat surface light sources, and 3) LED headlights do not comply with Table XIX in FMVSS-108 due to the use of approximately 100,000,000 nit LED chips.
NHTSA is legally bound to apply the same level of care to the issue of non-compliant LED headlights. NHTSA must again do the right thing and direct GM, Ford, Tesla, Rivian and others to recall their vehicles with LED headlights just as NHTSA did for the GMC Terrain.
B) - Here is a link to an Oct. 26, 2022 article about the US DOJ investigating Tesla in a criminal probe.
https://www.caranddriver.com/news/a41781263/tesla-us-criminal-investigation-full-self-driving/ - Because the DOJ is investigating Tesla criminally, NHTSA must notify the DOJ about Tesla's use of non-compliant LED headlights because it shows a pattern of behavior by Tesla of ignoring federal safety laws and false advertising. The Soft Lights Foundation will also be notifying the US DOJ about this issue.
Sincerely,
Mark Baker
President
Soft Lights Foundation
www.softlights.org
mbaker@softlights.org