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Thread: What's the inner amber compartment for?

  1. #1

    Default What's the inner amber compartment for?

    The 99 Sienna has inner amber taillamps compartments. They have no bulbs in the inner amber compartment. The lenses don't appear to be retroreflective. Are the amber inner lenses just a styling feature, or some artifact from rest-of-world Sienna's?


    https://cs.copart.com/v1/AUTH_svc.pd...bde1701572.JPG

  2. #2

    Default Re: What's the inner amber compartment for?

    Just a styling feature. It would look weird without it.

  3. #3

    Default Re: What's the inner amber compartment for?

    Thanks. I was trying to figure out why any car would have a auxiliary, directly rear facing amber light. I was barking up the wrong tree.

  4. #4

    Default Re: What's the inner amber compartment for?

    Styling may be in order to attract the new customers. LOL!

  5. #5

    Default Re: What's the inner amber compartment for?

    Reminds me of our 2017 VW Tiguan. It has amber lenses in the tail lights for the turn signals. Only upon getting it home and looking closely, I was disappointed to find they are not used. The red brake lamp doubles as a turn signal. I went online to see if I could find any info and read somewhere that the amber portion doesnít comply with a regulation here in Canada having to do with minimum surface area of a signalling lamp. So VW just uses the brake lamps instead. I much prefer dedicated amber turn signals.
    Last edited by seadragon; 09-16-2019 at 05:29 AM.

  6. #6

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by seadragon View Post
    Reminds me of our 2017 VW Tiguan. It has amber lenses in the tail lights for the turn signals. Only upon getting it home and looking closely, I was disappointed to find they are not used.
    That's different. The Tiguan's amber turn signals are actual lamps; the Sienna item being asked about is just a decorative trim panel.

    I went online to see if I could find any info and read somewhere that the amber portion doesnít comply with a regulation here in Canada having to do with minimum surface area of a signalling lamp.
    That area requirement (50 square centimeters, 7.75 square inches for the brake lights and the rear turn signals) is a US and Canadian requirement not found in regulations elsewhere in the world. Automakers seem to ignore it at whim lately. At first they provided tiny brake lights and pretended to meet the area requirement by also turning on the tail light when the driver steps on the brake (Lexus NX, various Mazda models, etc) or, if the tails were already lit, making them very slightly brighter when the driver steps on the brake. Now they seem to have dropped even that pretense...the latest Toyota RAV4, US model, has itty-bitty brake lights that cannot possibly come anywhere near the area requirement, and they don't even bother turning on the tail when the driver brakes.

  7. #7

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by -Virgil- View Post
    itty-bitty brake lights that cannot possibly come anywhere near the area requirement, and they don't even bother turning on the tail when the driver brakes.
    I've always wondered if my sense of area perception was lacking each time I passed one of the cars you mentioned with the itty-bitty brake lamps; I always had trouble counting out 50 square centimeters on those lamps!

    So, in your estimation, will Toyota and Mazda one day atone for their sins, or is it more likely that this issue will be ignored?
    Last edited by Ls400; 09-17-2019 at 07:48 AM.

  8. #8
    Moderator Alaric Darconville's Avatar
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    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Ls400 View Post
    So, in your estimation, will Toyota and Mazda one day atone for their sins, or is it more likely that this issue will be ignored?
    It depends on the severity of the accident, and whether the NHTSA catches wind of it. A lot of items of consequential noncompliance can go under the radar for years until something bad happens and people investigate more. I suppose if someone owned one, and then filed a complaint about their vehicle (including the VIN) to the NHTSA to complain about it, that might also get it looked into. Maybe.

  9. #9

    Default Re: What's the inner amber compartment for?

    Is it really consequential non-compliance with LEDs? I remember reading about how EPLLA was outmoded in the present era of LEDs, as in, the regulation is no longer effectively achieving its original purpose of indirectly limiting brake lamp intensity.

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    Moderator Alaric Darconville's Avatar
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    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Ls400 View Post
    Is it really consequential non-compliance with LEDs? I remember reading about how EPLLA was outmoded in the present era of LEDs, as in, the regulation is no longer effectively achieving its original purpose of indirectly limiting brake lamp intensity.
    There is UMTRI research on the subject of perhaps mostly regulating light intensity only (although luminance control and area perhaps can't be eliminated completely), and perhaps setting a standard 225mm2 area, but until the law itself changes, the EPLLA of the Tiguan's yellow turn signal makes it noncompliant in a consequential way.

  11. #11

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Ls400 View Post
    Is it really consequential non-compliance with LEDs? I remember reading about how EPLLA was outmoded in the present era of LEDs, as in, the regulation is no longer effectively achieving its original purpose of indirectly limiting brake lamp intensity.
    Luminance -- not intensity.

  12. #12

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Alaric Darconville View Post
    the EPLLA of the Tiguan's yellow turn signal makes it noncompliant in a consequential way.
    That's unfortunate. Back to the new RAV4s: if you had to purchase or lease a new CUV tomorrow, would the size of the brake lamps disqualify the RAV4 from consideration for you? Or would it just knock it down a few notches? I get that it is technically non-compliant/illegal, but I'm curious as to how big of an actual deal it is for consumers like us, who aren't likely to be prosecuted for running non-compliant equipment handed to us by Toyota.
    Last edited by Ls400; 09-17-2019 at 11:53 PM.

  13. #13
    Moderator Alaric Darconville's Avatar
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    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Ls400 View Post
    That's unfortunate. Back to the new RAV4s: if you had to purchase or lease a new CUV tomorrow, would the size of the brake lamps disqualify the RAV4 from consideration for you?
    This is a weird hypothetical!

    It wouldn't sit well with me for sure, but I'm sure I would be an outlier for rejecting a car based on the stop lamps like that. Only Virgil and Daniel Stern and maybe 5 other people in the world would really look closely at that (although a good many more might think the lamps look rather small, they wouldn't think there's a law about it or consider that it's really a safety issue).

    I'd be more likely (in fact, I already just plain have) to reject the new Avalon for having incorporated their turn/stop/tail lamps (as well as doing stupid turn signal tricks otherwise). A saving grace for the RAV4 is that the turn signals are separate amber ones. And nothing stops me from adding carefully selected auxiliary stop lamps, although that would be a real pain to accomplish and to make it look decent. It shouldn't be *my* job to bring a brand new vehicle into compliance with the law, though.

    (Off topic: If you can't afford to buy a vehicle you can't afford to lease it)

    I'm curious as to how big of an actual deal it is for consumers like us, who aren't likely to be prosecuted for running non-compliant equipment handed to us by Toyota.
    The consumer isn't expected to know that a vehicle is noncompliant; the onus is on Toyota for having manufactured here and/or imported (or otherwise introduced into interstate commerce) a vehicle that does not comply with FMVSS 108. It's on them that they essentially certified the vehicle as compliant when it's not.

    More off topic: The same goes for people that get suckered into buying CHMSL flasher/pulser; they're goaded into it by a salesman, assured that it's legal and "safer" and "X collisions are prevented a year" and even that they are specifically "legal in some states*", or they pretty much have no choice since it's on the vehicle they want to buy. They're victims here and while lack of knowledge of the law is not a defense, in this case it's something of a defense.

    *The states that have "legalized" them did so due to extensive lobbying by the device manufacturers; their hope is to get enough states to legalize them that they ultimately are legalized Federally, but in the mean time it also works as a selling point "See? California recognizes their safety benefit!" and similar handwaving. However, they are not legal because of Federal preŽmption. But this is straying far from the original topic, essentially about the styling decision made by Toyota for the Sienna
    Last edited by Alaric Darconville; 09-18-2019 at 01:24 PM. Reason: Already knew of Federal preŽmption, clarifying in this post

  14. #14

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Alaric Darconville View Post
    'd be more likely (in fact, I already just plain have) to reject the new Avalon for having incorporated their turn/stop/tail lamps (as well as doing stupid turn signal tricks otherwise). A saving grace for the RAV4 is that the turn signals are separate amber ones. And nothing stops me from adding carefully selected auxiliary stop lamps, although that would be a real pain to accomplish and to make it look decent. It shouldn't be *my* job to bring a brand new vehicle into compliance with the law, though.
    I've noticed that Toyota has switched from amber to red and red to amber turn signals without much rhyme or reason across generations of vehicles. And I remember reading, perhaps on here, about how Toyota has similarly bounced between LED and non-LED brake lamps across generations, again, with little rhyme or reason. The only consistency, oddly enough, that I've seen, is that all Lexus vehicles appear to have separate amber turn signals, like Saab (and Volvo up to 2016.)

  15. #15

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Ls400 View Post
    Back to the new RAV4s: I get that it is technically non-compliant/illegal, but I'm curious as to how big of an actual deal it is for consumers like us, who aren't likely to be prosecuted for running non-compliant equipment handed to us by Toyota.
    I'd worry more about getting rear-ended than getting prosecuted.

  16. #16

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Alaric Darconville View Post
    people that get suckered into buying CHMSL flasher/pulser; they're goaded into it by a salesman, assured that it's legal and "safer" and "X collisions are prevented a year" and even that they are specifically legal in some states
    ...except sort of not really, because under a principle of the US vehicle safety regulations known as federal preemption, if an aspect of motor vehicle design or equipment is federally regulated, states are not permitted to have or enforce a regulation of that same aspect, that differs from the federal regulation. Take headlight color: the federal standard says they have to be white, so a state can't require them to be yellow. Or turn signal color: the federal standard says red or amber, so states can't require only one of those colors. Or stop (brake) light operation: the federal standard says they all (including the CHMSL) have to be steady-burning, which means light of substantially unchanging intensity. So a state law allowing CHMSL flasher/blinker/"pulser" devices is null and void.

    Caveats? Yeah, plenty: in practice, there's very little enforcement of this, except in adjudication of single-issue lawsuits and stuff like that. The feds almost never send a letter to a state legislature saying "Cut that shіt out!". The last time there was a big fight between the feds and the states was in the 1970s when certain states legalized European headlamps, which sent Joan Claybrook (head of NHTSA at that time) into a tizzy.

    More generally, the way preemption tends to work is that states are prevented (more by industry pressure than by federal enforcement) from having requirements stricter than the federal standard, but not much, if anything, prevents them from having requirements more permissive than the federal standard. This is how states get away with "white to amber" for front turn signals, or New York State's eye-poppingly snotty/scornful language on the books about side marker lights*, etc. So don't look for the feds to tap any of the few CHMSL-flasher-"legalizing" states on the shoulder about it...until someone connects the dots between these dumb gadgets and collisions, which I imagine will probably happen on or around the first of Octember.

    *On the other hand, New York began requiring rear defrosters effective with the 1974-model cars. This did not violate federal preemption, because no Federal Motor Vehicle Safety Standard requires rear defrosters. And for awhile, NY required quieter "city horns". This, too, didn't violate federal preemption because the applicable federal standard just calls for the horns to emit an "adequate warning" with no specification. This raises some interesting lighting questions: can a state require rear fog lamps? Or side turn signal repeaters? Legally, probably so! Industry would scream murder, and would try their best, probably successfully, to quash it, though.

  17. #17
    Moderator Alaric Darconville's Avatar
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    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by -Virgil- View Post
    ...except sort of not really, because under a principle of the US vehicle safety regulations known as federal preemption
    Knew that already, but edited the post to make it clearer to those new to the topic.

    So don't look for the feds to tap any of the few CHMSL-flasher-"legalizing" states on the shoulder about it...until someone connects the dots between these dumb gadgets and collisions, which I imagine will probably happen on or around the first of Octember.
    Sadly, very little data exists on the matter, not like the study that showed the efficacy of separate amber turn signals. Very few accident reports will ever contain "vehicle equipped with PulseProtects device".

    On the other hand, New York began requiring rear defrosters effective with the 1974-model cars. This did not violate federal preemption, because no Federal Motor Vehicle Safety Standard requires rear defrosters.
    But you'd be hard-pressed to find a car made nowadays without one. Is it because the New York market was large enough to warrant just putting it on more and more models? Did people finally notice how great it is to have them and clamor to have them?

    Can a state require rear fog lamps
    In some ways I'd like them to, as well as enact toothy laws for their misuse (including disuse when conditions require them), but unlike "California Emissions" it seems rather undemocratic to require someone to have additional motor vehicle equipment that other states, and the Federal regulations, don't require. This isn't quite the same as, say, Colorado requiring tire chains in certain areas at certain times unless the vehicle has severe-service rated winter tires.

  18. #18

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Alaric Darconville View Post
    you'd be hard-pressed to find a car made nowadays without one. Is it because the New York market was large enough to warrant just putting it on more and more models? Did people finally notice how great it is to have them and clamor to have them?
    Most cars have air conditioning and power locks and windows, now, too.

    unlike "California Emissions" it seems rather undemocratic to require someone to have additional motor vehicle equipment that other states, and the Federal regulations, don't require.
    It's exactly like California emissions, actually. California has unique geographical and meteorological and populational (is that a word?) conditions that made auto exhaust a bigger, earlier problem than in other places, so that state arranged for a waiver from federal preemption so they could set their own emissions standards at the more stringent levels necessary to address the conditions in California effectively. That's the waiver President Trump has just announced he would cancel. A state could try and make a legal case for a waiver from federal preemption so as to allow them to set a more stringent requirement for lighting (or whatever). Whether they'd get the waiver or not is a different question, and would probably depend on who's in the White House.

    Now, I'm not a lawyer, but it sure looks to me like there's no certainty that a waiver would even be needed for a state to require side turn signal repeaters or rear fog lamps on every new car sold in that state, or to ban front fog lamps. None of those items are mentioned in FMVSS 108 -- they are not federally regulated, so there's no federal standard to preempt a state standard. This would be exactly like New York's 1974 requirement for rear defrosters.

    This isn't quite the same as, say, Colorado requiring tire chains in certain areas at certain times unless the vehicle has severe-service rated winter tires.
    That's an equipment usage standard, and states are free to set those. It's up to each state to issue requirements as to how and when various equipment has to be used. Back to fog lamps: a state can ban their use completely, ban their use at speeds over whatever miles per hour, specify their min and max mount height and their aim, require that they be covered with an opaque cover when not in use...whatever the state wants to do. Each state says when you have to use your headlamps, whether you have to have them on when the car's wipers are on, how far from another car you have to dim your high beams. Each state says if/when/where you have to have winter-traction tires or chains. Etc.

  19. #19

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by -Virgil- View Post
    I'd worry more about getting rear-ended than getting prosecuted.
    I'm curious as to how this non-compliance came to see the light of day on what is America's best-selling SUV. Did no one have the gumption or sufficient job security to say "Hey, this is going to possibly expose a significant portion of American car-buyers to an increased risk of accidents? This isn't a one-off, limited-edition car...why not get it right?" I'm guessing that for a project like the RAV4, there would have been multiple people overseeing the development of the parts that light up. Did some directive come from above, and everyone fell in line with the fig leaf of "following orders," or were things perhaps more sinister, a la Hanna Ardent? I'm guessing that no matter what, there's basically a 0.0% chance that anyone at Toyota and its subsidiaries will be personally affected.
    Last edited by Alaric Darconville; 09-19-2019 at 09:21 AM. Reason: Removed toxic masculinity

  20. #20

    Default Re: What's the inner amber compartment for?

    Quote Originally Posted by Ls400 View Post
    I'm curious as to how this non-compliance came to see the light of day
    Well, obviously Toyota doesn't feel it's noncompliant. It's the automaker's responsibility to satisfy themselves that the vehicle and all its regulated components, design elements and features comply with all the applicable regs. FMVSS 108 does not specify a procedure for measuring the effective projected luminous lens area (EPLLA, which is what we're talking about here), it just says it has to be 5000 mm2. I'm sure if NHTSA were to tap Toyota on the shoulder and say "Justify your assertion of compliance", Toyota can walk NHTSA through whatever measurement method they came up with. NHTSA has a long policy of not challenging automakers' certifications of compliance except if they're "clearly erroneous" (which is also not defined or specified). So the question is whether NHTSA would consider Toyota's certification "clearly erroneous". It looks that way to me, but happily I don't work for NHTSA!

    This isn't a one-off, limited-edition car...why not get it right?
    Generally, the number of cars produced doesn't impact on "how required" the requirements are. They apply whether an auto maker is producing 500 cars or 500,000 cars of a given model. There are provisions where a maker can petition for exemption from certain standards based on limited production and financial hardship, but it has to be done in advance on a case-by-case basis, it's not necessarily granted, and it's generally reserved for very small makers of very small quantities of very unusual cars.

    I'm guessing that for a project like the RAV4, there would have been multiple people overseeing the development
    Yes...it is fairly certain that these lights were designed the way they were, on purpose. Not accidentally. Probably not a case of "Whoah, how could nobody notice this?!", probably more like a case of "USA/Canada is the only market with this EPLLA rule. The whole rest of the world manages to do fine without it. Our designers want the lights to look this way, so come up with a way to count that light up to 50 cm2 in case NHTSA asks us about it, which they probably aren't going to". Kind of a gamble, but probably a pretty good risk in the Trump Administration, which doesn't like government telling industry what to do.

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