Dear Supporters,
The Soft Lights Foundation sent to the following letter to the US House of Representatives and US Senate. It will help our cause if you can follow up with your Representative and/or Senator and request a response to this letter.
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Dear House Energy and Commerce Committee,
Markus Price is the Chief, Visibility and Injury Prevention Division at NHTSA. Here is Mr. Price's LinkedIn profile:
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About
I have a special interest in motor vehicle lighting. This concentration of experience provides a unique opportunity to influence the general functionality, styling, and safety of the vehicle. As a regulator, with industry experience, I strive to apply real world knowledge to regulatory decision making actions. In my current position, I have a goal of creating safety regulations that protect the public, in a cost beneficial fashion, that encourages individual responsibility.
Specialties: Automotive Lighting, Product Design, FMVSS No. 108, DOT
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From his profile, you can see that his viewpoint is "cost beneficial fashion" and "individual responsibility", which is exactly the opposite of his duties of protecting public health and safety through systemic federal regulations. NHTSA's job is not to protect auto industry profits, but to protect the health and safety of the public. Individuals cannot protect themselves from blinding LED headlights, as Mr. Price recommends. It's the duty of NHTSA to publish the regulations that keep the public safe from harm.
The Soft Lights Foundation requests that the House Energy and Commerce Committee open an investigation into Mr. Price's decision making processes that have allowed LED headlights to become a dangerous scourge on our roads. Below are some proposed questions that the Committee may ask of Mr. Price.
1. Table XIX in FMVSS-108 has many locations where there is no limit on intensity. When these locations are mapped out in a diagram, the area where there are no limits on intensity is the area directly in front of the vehicle. Why is there no maximum, overall limit on intensity in FMVSS-108?
2. FMVSS-108 relies on "color" to regulate lamps. However, with the invention of LEDs, it's now necessary to regulate "spectral power distribution", which is the distribution of wavelengths in the visible part of the electromagnetic spectrum. Why does NHTSA not have any regulations on spectral power distribution to limit blue wavelength light which creates dangerous glare and is a photobiological hazard?
3. Pulse Width Modulation is a human health hazard and many people can see the flicker consciously. Why doesn't NHTSA have any regulations for PWM or why doesn't NHTSA simply ban PWM outright?
4. The Soft Lights Foundation submitted a petition to NHTSA to set an overall limit for intensity on March 1, 2024, but NHTSA hasn't approved the petition within the required 120 days. (https://www.softlights.org/wp-content/uploads/2024/03/NHTSA-Petition-to-Limit-Headlight-Intensity.pdf Why hasn't NHTSA approved this petition?
5. The Soft Lights Foundation submitted a petition to NHTSA to set a limit of 2900K for Correlated Color Temperature for headlamps to limit glare and blue light. (https://www.softlights.org/wp-content/uploads/2024/05/NHTSA-Petition-to-Limit-CCT.pdf Why hasn't NHTSA approved this petition?
6. 21 U.S.C. 360ii(a)(6)(A) requires NHTSA to maintain a liaison with the FDA to test and evaluate LED headlights, but this liaison doesn't exist and the neither the FDA nor NHTSA have published any performance standards for LED vehicle headlamps to ensure photobiological, neurological, psychological, hormonal, and physical safety. Why are NHTSA and the FDA not cooperating and publishing performance standards to protect public health and safety?
7. 49 U.S.C. 30118(c)(1) requires the automakers and NHTSA to address dangerous and defective technology. LED headlights are obviously dangerous and defective since over 64,000 people have signed a petition to NHTSA to ban blinding headlights and since the public comments make it clear that LED headlights are dangerous. Why aren't the automakers notifying NHTSA that LED headlights are dangerous and why isn't NHTSA issuing recalls for vehicles with LED headlights?
8. Adaptive Driving Beam is often touted as the miracle cure for the current LED headlight disaster. However, do you agree that ADB is designed to allow the vehicle to use high beams more often, and that ADB does nothing to eliminate the blinding glare of low beams that is the majority cause of public complaints?
9. NHTSA currently sets the height limit for vehicle headlamps in relation to the vehicle, instead of in relation to the ground. With so many tall trucks now on the road, this presents a very dangerous situation where headlamps are aimed directly into the windshield of shorter vehicles. Why doesn't NHTSA set the height limit for headlamps in relation to the ground?
Sincerely,
Mark Baker
President
Soft Lights Foundation
www.softlights.org
mbaker@softlights.org
X: @softlights_org
Bluesky: @softlights-org.bsky.social