Dear Supporters,

The only action NHTSA is taking regarding LED lighting on vehicles is the Adaptive Driving Beam.  NHTSA's proposed rulemaking for ADB is entirely inadequate to protect us from the intensity of LEDs.  Below is the letter that I wrote to Brian Knieser the Legislative Fellow for US Representative Mike Thompson.  NHTSA will never solve the LED crisis on their own.  We must have an intervention by Congress.  Please tell your representative that NHTSA's ADB effort will not solve the problem and request that Congress hold a hearing to address this glaring problem.

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Dear Brian,

This document is NHTSA's proposed rule to allow Adaptive Driving Beam.
(https://www.softlights.org/wp-content/uploads/2024/03/2018-21853.pdf).  The document makes numerous mention of the need to protect the public from glare.  The document also mentions the regulatory authority of NHTSA to publish rules to protect public safety.  Yet, NHTSA makes no mention in this document of the nearly 60,000 individuals who have signed a petition demanding that NHTSA address glare from LED headlights and LED tail lights.  NHTSA makes no mention of the need to regulate blue wavelength light.  NHTSA makes no mention of the fact that no automaker has petitioned NHTSA for authorization to sell vehicles with LED headlights and no mention of the need to publish performance standards to match the intensity of LED technology.

In the ADB rulemaking document, NHTSA is proposing to INCREASE the maximum allowed intensity for low beams.  The ADB system is designed to INCREASE the use of high beams and is not designed to decrease the glare caused by low beams.  ADB systems only react AFTER an encounter with another vehicle or pedestrian.  Since light travels at the speed of light, the recipient of the unlimited intensity LED light will suffer the blinding glare first, and only then will the ADB reduce the intensity. The ADB system's fundamental design is to drive with the highest intensity light at all times, and only reduce the light when encountering an oncoming vehicle or pedestrian.  Contrast that fundamental premise with the basic premise that was used in 1960 and 1990, which is that we should drive at all times on low beam, and only switch to high beam when we knew it was safe to do so for other drivers.  NHTSA's ADB proposal is a seismic social shift, putting technology and speed ahead of protection of public health, safety and civil rights.

The photos below show LED brake lights and LED headlights.  Adaptive Driving Beam is only designed to work with headlights, not brake lights.  In other words, ADB will not solve the luminance problem of LEDs.  NHTSA is ignoring this issue entirely.  The only way that NHTSA is going to act to protect the public is with Congressional intervention or private lawsuits.

We are asking Rep. Mike Thompson to hold a hearing so that experts and the public can explain to Congress that NHTSA's rulemaking is entirely inadequate to protect the public from high-luminance LED lighting systems.
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Sincerely,

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