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Well, this is certainly interesting. NHTSA has put out a proposal and requested public comment (anyone can comment, just hit Comment now here or on the regulations.gov page) on the idea of awarding NCAP points to vehicles with amber rear turn signals instead of red ones, low beam headlamps that give better seeing performance and glare control than the basic legal requirements, and automatic high/low beam selectors. The proposal is a giant document, covering much more than just lighting, with detailed rationale and evaluation of every technology or feature on the list for proposed new NCAP points. If you want to read just the lighting-related parts, search the page for visibility systems. The second search hit will skip you down to the lighting section of the proposal.
Some background:
These days there are numerous NCAPs around the world (Euro-NCAP, AustraliaNCAP, even China has one). The USA NCAP program was the first of its kind in the world when NHTSA introduced it in 1979. The NCAP goal is to improve safety by "developing and implementing comparative safety information that encourages manufacturers to voluntarily improve the safety of their vehicles." NHTSA says the program has "strongly influenced manufacturers to build vehicles that consistently achieve high ratings". Over time, NCAP has been broadened to cover more and more aspects of vehicle design, equipment, and performance.
The NCAP program grades vehicles on a 1-to-5 star system, but it would stop being helpful unless its criteria were made stricter, because if every car gets 4 or 5 stars, that's not really useful for consumers (and doesn't incentivize automakers to keep doing better). So the NCAP criteria are upgraded as new technologies prove their safety benefit and become cost-feasible.
NHTSA says, in public and in private, that it's easier to upgrade NCAP than to upgrade Federal Motor Vehicle Safety Standards, because NCAP can be changed without cost/benefit analysis and other impediments in the US regulatory process. Compared to regulations, NCAP is a "free market" way of herding automakers. But the downside of that is that automakers are free to wipe their butts with the NCAP tests if they want to. All they have to do is comply with FMVSS. On the other hand, if automaker A decides to ignore the NCAPs, automaker B or C or D will, and the idea is those companies will drain sales away from automaker A, thus incentivizing automaker A to get on board and design/equip their vehicles to get good NCAP ratings.
To a fair extent, this actually works; automakers do have a pretty good history of working toward 5-star ratings for their vehicles, even as the tests get tougher and expand to cover more things. So OK, there are good reasons for using market-based, voluntary ways of encouraging makers to make (and buyers to buy) safer cars. But there are limitations to what this kind of method can do. Again, all vehicle makers have to do is build vehicles that meet all applicable regulations. Even if every automaker works really hard to get a 5-star NCAP rating every time, NCAP doesn't apply to all types of vehicles, so NCAP doesn't exert any pressure with regard to vehicles that aren't looked at by NCAP.
OK, that's the background. Now here are my (initial) thoughts about the lighting proposals.
Turn signals:
This newest NHTSA analysis of turn signals is very detailed, finding amber ones are more effective than red ones in 11 of 32 kinds of crash-or-avoid situations. Test cars confirmed as having amber turn signals would receive six NCAP points that would not be available to cars with red ones.
The first thing that occurs to me is that it's kind of hard to call amber rear turn signals a new or advanced technology. Australia and Italy were first to require amber rear turn signals. That was in 1960, fifty-six years ago. By the mid-1970s, most of the world's vehicle lighting regulations required amber rear turn signals and rejected red ones. The exception, of course, was (and remains) the US regulation that still allows red or amber. Ask why, and for years the answer used to be "Wellll, there's really no proof amber is better, and red is cheaper, and automakers like the design flexibility". Then NHTSA did research in 2009 showing that amber is better than red. So then when we asked why red is still allowed, the answer was "Wellll, red is cheaper, and automakers like the design flexibility". But now in this new proposal, NHTSA says (emphasis mine):
To avoid imposing an unreasonable cost to society, NHTSA's lighting regulation continues to allow for low-cost signal and visibility configurations. The agency believes reduction in rear-end crashes with property damage or injury can be achieved with amber rear turn signal lamps at a cost comparable to red rear turn signal lamp configurations.
Hey, that's new. That 2009 research found that amber turn signals offer a 5.3% crash-avoidance benefit compared to red ones. That is better than the benefit of the Center High Mounted Stop Lamp (CHMSL, the 3rd brake light), which in the long term has shown to reduce crashes by 4.3%. So that kind of raises a question: Just quick back-of-envelope math suggests that adding a CHMSL to the design and production of a vehicle carries a cost at least as much as the cost of putting amber turn signals instead of red ones. So if amber turn signals prevent significant numbers of crashes, and they don't impose an unreasonable cost, why aren't amber turn signals mandatory like the CHMSL?
It's not just an rhetorical question, either. NCAP stars might nudge automakers to put amber turn signals on the kinds of vehicles NCAP looks like: passenger cars and SUVs. But again, NCAP won't nudge trucks, cargo vans, transit buses, tour buses, semi tractors and trailers, etc. There are lots of those vehicles on American roads, and they're larger and less maneuverable than passenger cars and SUVs. That makes their signals even more important, because a larger vehicle blocks a larger portion of the view of a larger number of nearby drivers. In effect, this means drivers are forced to depend on the signals of the view-blocking vehicle. I think that kind of makes it problematic that this NHTSA proposal will give makers no incentive to put safer amber signals on large vehicles.
I also think it's interesting that the substantive first public comment on the whole big proposal is a private citizen supporting amber turn signals and calling on NHTSA to make them mandatory, not just award NCAP points for them, or at least give more than 6 points. I think he's got a point, starting from his first three words: "As a motorist". The turn signal color affects everyone who has to drive in traffic with any given vehicle, and there's no real built-in incentive for automakers to charitably provide (say) amber turn signals instead of red ones. On the other hand, the design of a car influences a car buyer, and that's the line automakers are thinking along when they say their customers prefer red turn signals, see the last two paragraphs of this Canadian newspaper article (which gets some stuff wrong further up, e.g., the silly thing about the VW Tiguan). So this proposal to award NCAP points for amber turn signals, even though I think it falls short, is still a worthwhile thing if it gets even just some makers putting amber turn signals on even just some more cars.
OK, enough about turn signals, then there's the proposal about low-beam headlamps.
NCAP points, up to 15 of them, would be awarded to cars with low beams that give more light than the legal minimum and put out less glare than the legal maximum. Quoting from NHTSA again:
Lower beam headlamp performance beyond the minimum requirements of FMVSS 108 will result in additional safety benefits, increased vehicle luminance will reduce the risk of pedestrian fatalities at night. This additional light could have unintended consequences if it is not properly controlled to limit glare. As such, the test procedure grades a vehicle's lower beams for seeing light far down the road, but reduces the score for a headlighting system that produces glare. Unlike the current test procedure for the FMVSS No. 108 requirement that evaluates a headlamp in a laboratory, this NCAP test would evaluate the headlighting system as installed on the vehicle.
The proposed NCAP lower beam test (see it here) is interesting: it would establish the system's level of performance by measuring illuminance just above the road surface, 75 to 115 meters ahead of the vehicle. On a flat, straight road five detectors would be placed 20cm above the road surface, ahead and 4 meters to the right of the vehicle's centerline. One at 75m, one at 85m, one at 95m, one at 105m, and one at 115m. A sixth detector, for glare, would be placed 60m ahead of the car, 4m to the left of the vehicle's centerline, and 1m above the road surface.
The vehicle's fuel tank would be full, tires inflated to manufacturer specs, if it has halogen headlamps the new bulbs would be replaced by seasoned (aged) ones, the low beam headlamps would be aimed to manufacturer specifications and NHTSA-specified weight placed in the driver's seat area, and the low beam headlamps would be switched on. Then readings would be taken from each detector.
Each seeing detector that reads ≥ 3 lux counts as a +1 visibility score. Each seeing detector that reads < 3 lux counts as a 0 visibility score. All five visibility scores are totalled up. To get 3 lux at those locations, you need (from the pair of headlamps) 16,875 candela at 75m; 21,675 at 85m; 27,075 at 95m; 33,075 at 105m, and 39,675 at 115m.
If the glare detector reads ≥ 0.634 lux, then the vehicle's glare score is 1. If the glare detector reads < 0.634 lux, then the glare score is 0. (0.634 lux at 60 meters = just a hair over 2282 candela from the pair of headlamps at that location).
Again, these measurements are made with the headlamps installed on the vehicle, aimed to maker's specs, and pairwise...not an individual, single headlamp aimed to regulation specs in a test lab, so it's not possible to convert these locations into beam test points without knowing the headlamp height off the road surface and how far apart the left and right lamps are on the vehicle.
The vehicle's ranking is determined by [5x total visibility score] - [10x glare score]. So if three of the seeing detectors see at least 3 lux, and the glare detector sees no more than 0.634 lux, then that vehicle's overall score would be [5 x 3] - [10 x 0] = 15. If all five of the seeing detectors see at least 3 lux, and the glare detector sees more than 0.634 lux, then that vehicle's score would be [5 x 5] - [10 x 1] = 15. If all five seeing detectors see at least 3 lux and the glare detector sees no more than 0.634 lux, then that vehicle's score would be [5 x 5] - [10 x 0] = 25. And so on. It's a little unclear to me how these scores would translate to NCAP points, because they say the maximum number of points available for low beams is 15, but the best possible score for the low beam test is 25.
The third branch of the lighting part of this proposal is automatic high/low beam switching. Cars with auto high/low beam would be eligible for 9 NCAP points. NHTSA calls the system "semi-automatic" because FMVSS 108 requires a manual high/low beam control in every vehicle, even if it has an auto high/low beam system. This proposal to award points for auto high/low beam is probably a good one; drivers overwhelmingly use low beams when they should be using high beams, which means much shorter-than-appropriate seeing distance, and that causes crashes and pedestrian deaths. Not to mention the numskulls who drive around in traffic with their high beams on when they should be using low beam. There's a test procedure for determining if a vehicle has the system and whether it works well enough to be of real use.
Comments are due by 16 February; speak up and participate in the process if you have something to say about it.
-Virgil-
Well, this is certainly interesting. NHTSA has put out a proposal and requested public comment (anyone can comment, just hit Comment now here or on the regulations.gov page) on the idea of awarding NCAP points to vehicles with amber rear turn signals instead of red ones, low beam headlamps that give better seeing performance and glare control than the basic legal requirements, and automatic high/low beam selectors. The proposal is a giant document, covering much more than just lighting, with detailed rationale and evaluation of every technology or feature on the list for proposed new NCAP points. If you want to read just the lighting-related parts, search the page for visibility systems. The second search hit will skip you down to the lighting section of the proposal.
Some background:
These days there are numerous NCAPs around the world (Euro-NCAP, AustraliaNCAP, even China has one). The USA NCAP program was the first of its kind in the world when NHTSA introduced it in 1979. The NCAP goal is to improve safety by "developing and implementing comparative safety information that encourages manufacturers to voluntarily improve the safety of their vehicles." NHTSA says the program has "strongly influenced manufacturers to build vehicles that consistently achieve high ratings". Over time, NCAP has been broadened to cover more and more aspects of vehicle design, equipment, and performance.
The NCAP program grades vehicles on a 1-to-5 star system, but it would stop being helpful unless its criteria were made stricter, because if every car gets 4 or 5 stars, that's not really useful for consumers (and doesn't incentivize automakers to keep doing better). So the NCAP criteria are upgraded as new technologies prove their safety benefit and become cost-feasible.
NHTSA says, in public and in private, that it's easier to upgrade NCAP than to upgrade Federal Motor Vehicle Safety Standards, because NCAP can be changed without cost/benefit analysis and other impediments in the US regulatory process. Compared to regulations, NCAP is a "free market" way of herding automakers. But the downside of that is that automakers are free to wipe their butts with the NCAP tests if they want to. All they have to do is comply with FMVSS. On the other hand, if automaker A decides to ignore the NCAPs, automaker B or C or D will, and the idea is those companies will drain sales away from automaker A, thus incentivizing automaker A to get on board and design/equip their vehicles to get good NCAP ratings.
To a fair extent, this actually works; automakers do have a pretty good history of working toward 5-star ratings for their vehicles, even as the tests get tougher and expand to cover more things. So OK, there are good reasons for using market-based, voluntary ways of encouraging makers to make (and buyers to buy) safer cars. But there are limitations to what this kind of method can do. Again, all vehicle makers have to do is build vehicles that meet all applicable regulations. Even if every automaker works really hard to get a 5-star NCAP rating every time, NCAP doesn't apply to all types of vehicles, so NCAP doesn't exert any pressure with regard to vehicles that aren't looked at by NCAP.
OK, that's the background. Now here are my (initial) thoughts about the lighting proposals.
Turn signals:
This newest NHTSA analysis of turn signals is very detailed, finding amber ones are more effective than red ones in 11 of 32 kinds of crash-or-avoid situations. Test cars confirmed as having amber turn signals would receive six NCAP points that would not be available to cars with red ones.
The first thing that occurs to me is that it's kind of hard to call amber rear turn signals a new or advanced technology. Australia and Italy were first to require amber rear turn signals. That was in 1960, fifty-six years ago. By the mid-1970s, most of the world's vehicle lighting regulations required amber rear turn signals and rejected red ones. The exception, of course, was (and remains) the US regulation that still allows red or amber. Ask why, and for years the answer used to be "Wellll, there's really no proof amber is better, and red is cheaper, and automakers like the design flexibility". Then NHTSA did research in 2009 showing that amber is better than red. So then when we asked why red is still allowed, the answer was "Wellll, red is cheaper, and automakers like the design flexibility". But now in this new proposal, NHTSA says (emphasis mine):
To avoid imposing an unreasonable cost to society, NHTSA's lighting regulation continues to allow for low-cost signal and visibility configurations. The agency believes reduction in rear-end crashes with property damage or injury can be achieved with amber rear turn signal lamps at a cost comparable to red rear turn signal lamp configurations.
Hey, that's new. That 2009 research found that amber turn signals offer a 5.3% crash-avoidance benefit compared to red ones. That is better than the benefit of the Center High Mounted Stop Lamp (CHMSL, the 3rd brake light), which in the long term has shown to reduce crashes by 4.3%. So that kind of raises a question: Just quick back-of-envelope math suggests that adding a CHMSL to the design and production of a vehicle carries a cost at least as much as the cost of putting amber turn signals instead of red ones. So if amber turn signals prevent significant numbers of crashes, and they don't impose an unreasonable cost, why aren't amber turn signals mandatory like the CHMSL?
It's not just an rhetorical question, either. NCAP stars might nudge automakers to put amber turn signals on the kinds of vehicles NCAP looks like: passenger cars and SUVs. But again, NCAP won't nudge trucks, cargo vans, transit buses, tour buses, semi tractors and trailers, etc. There are lots of those vehicles on American roads, and they're larger and less maneuverable than passenger cars and SUVs. That makes their signals even more important, because a larger vehicle blocks a larger portion of the view of a larger number of nearby drivers. In effect, this means drivers are forced to depend on the signals of the view-blocking vehicle. I think that kind of makes it problematic that this NHTSA proposal will give makers no incentive to put safer amber signals on large vehicles.
I also think it's interesting that the substantive first public comment on the whole big proposal is a private citizen supporting amber turn signals and calling on NHTSA to make them mandatory, not just award NCAP points for them, or at least give more than 6 points. I think he's got a point, starting from his first three words: "As a motorist". The turn signal color affects everyone who has to drive in traffic with any given vehicle, and there's no real built-in incentive for automakers to charitably provide (say) amber turn signals instead of red ones. On the other hand, the design of a car influences a car buyer, and that's the line automakers are thinking along when they say their customers prefer red turn signals, see the last two paragraphs of this Canadian newspaper article (which gets some stuff wrong further up, e.g., the silly thing about the VW Tiguan). So this proposal to award NCAP points for amber turn signals, even though I think it falls short, is still a worthwhile thing if it gets even just some makers putting amber turn signals on even just some more cars.
OK, enough about turn signals, then there's the proposal about low-beam headlamps.
NCAP points, up to 15 of them, would be awarded to cars with low beams that give more light than the legal minimum and put out less glare than the legal maximum. Quoting from NHTSA again:
Lower beam headlamp performance beyond the minimum requirements of FMVSS 108 will result in additional safety benefits, increased vehicle luminance will reduce the risk of pedestrian fatalities at night. This additional light could have unintended consequences if it is not properly controlled to limit glare. As such, the test procedure grades a vehicle's lower beams for seeing light far down the road, but reduces the score for a headlighting system that produces glare. Unlike the current test procedure for the FMVSS No. 108 requirement that evaluates a headlamp in a laboratory, this NCAP test would evaluate the headlighting system as installed on the vehicle.
The proposed NCAP lower beam test (see it here) is interesting: it would establish the system's level of performance by measuring illuminance just above the road surface, 75 to 115 meters ahead of the vehicle. On a flat, straight road five detectors would be placed 20cm above the road surface, ahead and 4 meters to the right of the vehicle's centerline. One at 75m, one at 85m, one at 95m, one at 105m, and one at 115m. A sixth detector, for glare, would be placed 60m ahead of the car, 4m to the left of the vehicle's centerline, and 1m above the road surface.
The vehicle's fuel tank would be full, tires inflated to manufacturer specs, if it has halogen headlamps the new bulbs would be replaced by seasoned (aged) ones, the low beam headlamps would be aimed to manufacturer specifications and NHTSA-specified weight placed in the driver's seat area, and the low beam headlamps would be switched on. Then readings would be taken from each detector.
Each seeing detector that reads ≥ 3 lux counts as a +1 visibility score. Each seeing detector that reads < 3 lux counts as a 0 visibility score. All five visibility scores are totalled up. To get 3 lux at those locations, you need (from the pair of headlamps) 16,875 candela at 75m; 21,675 at 85m; 27,075 at 95m; 33,075 at 105m, and 39,675 at 115m.
If the glare detector reads ≥ 0.634 lux, then the vehicle's glare score is 1. If the glare detector reads < 0.634 lux, then the glare score is 0. (0.634 lux at 60 meters = just a hair over 2282 candela from the pair of headlamps at that location).
Again, these measurements are made with the headlamps installed on the vehicle, aimed to maker's specs, and pairwise...not an individual, single headlamp aimed to regulation specs in a test lab, so it's not possible to convert these locations into beam test points without knowing the headlamp height off the road surface and how far apart the left and right lamps are on the vehicle.
The vehicle's ranking is determined by [5x total visibility score] - [10x glare score]. So if three of the seeing detectors see at least 3 lux, and the glare detector sees no more than 0.634 lux, then that vehicle's overall score would be [5 x 3] - [10 x 0] = 15. If all five of the seeing detectors see at least 3 lux, and the glare detector sees more than 0.634 lux, then that vehicle's score would be [5 x 5] - [10 x 1] = 15. If all five seeing detectors see at least 3 lux and the glare detector sees no more than 0.634 lux, then that vehicle's score would be [5 x 5] - [10 x 0] = 25. And so on. It's a little unclear to me how these scores would translate to NCAP points, because they say the maximum number of points available for low beams is 15, but the best possible score for the low beam test is 25.
The third branch of the lighting part of this proposal is automatic high/low beam switching. Cars with auto high/low beam would be eligible for 9 NCAP points. NHTSA calls the system "semi-automatic" because FMVSS 108 requires a manual high/low beam control in every vehicle, even if it has an auto high/low beam system. This proposal to award points for auto high/low beam is probably a good one; drivers overwhelmingly use low beams when they should be using high beams, which means much shorter-than-appropriate seeing distance, and that causes crashes and pedestrian deaths. Not to mention the numskulls who drive around in traffic with their high beams on when they should be using low beam. There's a test procedure for determining if a vehicle has the system and whether it works well enough to be of real use.
Comments are due by 16 February; speak up and participate in the process if you have something to say about it.
-Virgil-
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