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Comments to NHTSA on proposal to allow adaptive driving beam headlight systems on new cars

This proposal would alter FMVSS No. 108 to permit manufacturers the option of equipping vehicles with adaptive driving beam (ADB) technology, which actively modifies the headlamp beams to provide more illumination while not subjecting other drivers to excessive glare. The proposal also would establish performance requirements intended to ensure the safe introduction and operation of ADB headlighting systems if they are equipped on newly manufactured vehicles.

On the basis of research and testing of current headlamps on U.S. vehicles by Consumer Reports and other organizations; the recommendation by the National Transportation Safety Board for NHTSA to allow adaptive headlight systems; our understanding of ADB technology already on roads in Europe; and the evidence presented by NHTSA as a part of its notice of proposed rulemaking; Consumer Reports supports allowing ADB headlighting systems to be introduced on new vehicles in the United States. We agree with NHTSA that ADB technology likely enhances safety both by providing variable illumination sculpted to account for traffic on the road and by increasing usage of the greater illumination traditionally provided by upper beams, which are underutilized by drivers.

In general, NHTSA’s proposed amendments to equipment requirements in FMVSS No. 108 are sensible changes that would provide performance requirements that would allow ADB systems onto new U.S. vehicles while ensuring that they meet appropriate glare limits and visibility requirements currently applicable to lower beam and upper beam headlamps. As NHTSA completes rulemaking to amend FMVSS No. 108 and as ADB-equipped vehicles enter the U.S. marketplace, we urge NHTSA to collect information from manufacturers that would allow the agency to continue improving its understanding of the effects of ADB technology on motor vehicle safety and to strengthen and fine-tune requirements under FMVSS No. 108 as may be necessary. This would include evaluating the opportunities and risks of systems with particular abilities to detect, identify, and respond to pedestrians, cyclists, and other more vulnerable road users.

For the full comments, click here.