
Dear Supporters,
On August 2, 2025, I sent the following letter to NHTSA and Ford.
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Dear Kerry Kolodziej, Assistant Chief Counsel for Litigation and Enforcement, NHTSA,
On November 13, 2024, NHTSA issued a Consent Order to Ford Motor Company for failing to comply with 49 U.S.C. § 30118(c). The Consent Order imposed a penalty of $165,000,000 against Ford for a recall related to a defective rear view camera. In the Order, NHTSA states, "A manufacturer must submit the DIR not more than 5 working days after it knew or should have known of a safety-related defect or noncompliance in its vehicles." (https://www.nhtsa.gov/sites/nhtsa.gov/files/2024-11/ford-consent-order-web.pdf)
Despite the requirement of 49 U.S.C. § 30118(c), and despite having known for years that LED headlight technology is defective, Ford has not submitted a Defect and Noncompliance Information Report to NHTSA. In addition, despite the fact that NHTSA has also known that LED headlamp technology is a threat to safety and therefore defective, and despite NHTSA having received a formal request to conduct a hearing into the matter from the Soft Lights Foundation, NHTSA has not initiated a hearing on defective LED headlamp technology.
As you are aware, the US House of Representatives Appropriations Committee approved the FY26 National Security, Department of State Appropriations Act with the following text: "Headlight Brightness -- The Committee urges the Secretary of Transportation to report to Congress on what gaps may exist related to the impact of the brightness of low beam headlamps on the vision and safety of drivers, pedestrians, and other road users, including the effect of varied terrain, including hills and curves."
The low beam headlamp report requested by Congress is one-and-the-same as the requested hearing on LED headlamps by the Soft Lights Foundation and this is the same issue that has been reported by over 70,000 individuals on the citizen petition which has been submitted to Ford and NHTSA multiple times. (https://www.change.org/p/u-s-dot-ban-blinding-headlights-and-save-lives).
There can be no doubt that Ford is in violation of 49 U.S.C. § 30118(c) for LED headlamps because Ford has not submitted the required DIR to NHTSA. Therefore, the Soft Lights Foundation requests that NHTSA issue a Consent Order to Ford imposing a penalty in the amount of $250,000,000 which is in line with the penalty imposed by NHTSA for Ford's failure to comply with 49 U.S.C. § 30118(c) for the rear view camera issue.
Sincerely,
Mark Baker
President
Soft Lights Foundation
www.softlights.org
mbaker@softlights.org
X: @softlights_org
Bluesky: @softlights-org.bsky.social