Transportation Safety Equipment Institute INTRODUCTION

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Transportation Safety Equipment Institute September 10, 2012 National Highway Traffic Safety Administration U.S. Department of Transportation Docket Management Facility, M 30 West Building Ground Floor, Room W12 140 1200 New Jersey Avenue, SE Washington, D.

1 Transportation Safety Equipment Institute September 10, 2012 National Highway Traffic Safety Administration U.S. Department of Transportation Docket Management Facility, M 30 West Building Ground Floor, Room W New Jersey Avenue, SE Washington, D.C Re: Docket No. NHTSA , Federal Motor Vehicle Safety Standard No. 108; Lamp, Reflective Devices, and Associated Equipment; Request for Comments on Technical Report Dear Sir or Madam: The Transportation Safety Equipment Institute (TSEI) is a non profit trade association representing North American manufacturers of vehicle safety equipment, including headlighting and signal lighting products, rearview mirrors, reflex reflectors, emergency warning triangles, emergency lighting, and other safety equipment for trucks, trailers, passenger vehicles, and emergency equipment. INTRODUCTION We appreciate and support the Agency s ongoing efforts to simplify and modernize Federal Motor Vehicle Safety Standard (FMVSS) No As an organization whose membership consists predominately of manufacturers of lighting products, we have a deep interest in ensuring that any changes to FMVSS 108 are adopted in a measured and deliberate manner, do not impose undue burdens on industry (and, where possible, perhaps reduce existing burdens), and increase design flexibility, while retaining a primary focus on motor vehicle safety. To that end, we welcome the Agency s current initiative to evaluate the possible transition of FMVSS 108 to a more performance based (versus primarily design based) safety standard. Indeed, we understand the Agency s view that doing so may render FMVSS 108 more accommodating to new and evolving technologies and, hopefully, make the standard easier to interpret and apply. Further, we share the Agency s goal of making the standard more rational and closely aligned with its safety objectives (such as glare control, seeing light, and sign light). While we believe there is general validity to a performance based approach to vehicular lighting standards, we (and the Agency) must recognize that there remain, at this early stage of the process, numerous unanswered questions concerning how these standards might be implemented and the potential burdens and benefits associated with such a transition. As the Agency continues to explore and evaluate ways to improve FMVSS 108, we hope it will do so in a studied, collaborative manner in order to avoid unintended consequences, burdens and costs. These comments are intended to be the initial installment of significant input from our membership and other industry participants as this important process advances SE 32 nd Street Topeka, KS (785) (866) FAX

2 DISCUSSION Our comments on each of the six focus areas identified in the Agency s request for comments are set forth below. Given the limited amount of time provided by the notice for receiving comments, these comments identify potential questions and issues, but we are not yet in a position to provide alternatives or recommendations. Only after the industry conducts additional testing, such as further headlamp testing to be conducted by UMTRI (with the cooperation of SAE), which we anticipate could take many months, will we be able to offer a more complete and definitive view on these various issues. As an initial matter, we do not believe the UMTRI report provides sufficient distinction between wholevehicle vs. performance based testing. For example, performance could be based on the current required lighting, but could include common lighting used throughout the industry, such as fog lamps and cornering lamps. With a systems approach, all potential lighting must be considered, especially those used for Driver Visibility. Furthermore, the UMTRI report does not fully address the issue of signal lighting. This may be because the nature of the current signal function regulations is such that a performance based approach would have little impact. However, we believe that more emphasis should be placed on signal lamps, including further research. Moreover, we believe strong consideration should be given to an incremental approach to this rulemaking. For example, the Agency might consider taking different approaches to different vehicle types, based upon their unique design characteristics and market realities. Comments on Specific Items Identified in Request for Comments A. Whole vehicle testing (lower and upper beam headlighting) We are seeking comment on the approach that closely aligns potential requirements with the ability of a vehicle lighting system to provide visibility for vehicle navigation while limiting the impacts of glare. Our current standard primarily treats a headlamp as a separate piece of safety equipment that is installed on a motor vehicle with various height and width restrictions. Based on various assumptions, the report translates the angular photometric requirements for each lamp in the current standard into areas in three dimensional space around the vehicle. These areas around the vehicle are then easily correlated to various objects on the roadway, such as oncoming driver eye locations and overhead signs positions. Whole vehicle testing has several potential benefits. It may better reflect real world driving and operating conditions, reduce performance variance based on type of light source, provide design flexibility and provide a framework for implementation of new technologies. Moreover, we believe the whole vehicle approach provides benefits from a customer standpoint because the customer buys a vehicle, not a lamp. Finally, whole vehicle testing can take advantage of the Law of Large Numbers, which would permit production of lamps with small anomalies in the photometric pattern that would still meet the requirements due to the ability to average over the large number of test points. While there are several potential benefits to this approach, there are numerous potential burdens, pitfalls and unanswered questions. First and foremost is the uncertainty over how wholevehicle testing will be accomplished, given the vast number of vehicles and vehicle configurations (e.g., options, trim levels, etc.) in the market. For example, how does this affect the ability of a manufacturer to change vehicle options over model years and utilize already existing lighting?

3 Instead of investing in new equipment, the UMTRI report suggests that manufacturers take a lamp and run it through a goniometer test similar to what is done today. In the case of a headlamp, the UMTRI report indicates that the testing would involve 2200 points (which is considerably higher than the current requirement) and inputting the data into software that would apply the data from the tested lamp to the vehicle/lamp system model provided by vehicle manufacturers. The software would simulate the output for the entire lighting system. This approach presents potential burdens on vehicle manufacturers and suppliers, as they must constantly ensure they have all vehicle data up to date and available to the lighting supplier. It is not very clear in the UMTRI report what vehicle configurations would require recertification. Moreover, this approach raises issues related to software availability (vendors), control (validation, verification, calibration), and NHTSA acceptance (validation criteria). In any event, TSEI supports any approach such as software simulation that does not require significant investment in new test equipment or infrastructure. We recognize that, at this stage, the Agency has focused its attention on headlamps, rather than signal lamps, but the Agency should consider whether and how these concepts might apply to signal lamps, taking into consideration the various costs and benefits in applying a performance based approach to these types of lamps. A recurring issue that will require significant additional development is how the whole vehicle testing concept would apply to universal and replacement lamps. A wholevehicle testing compliance model raises questions concerning how (if at all) a manufacturer of such lamps would certify compliance. Such an approach could potentially hinder the ability of manufacturers to produce and market universal lights. This concern is especially relevant in the heavy vehicle and trailer market, where OEMs rely heavily on such lamps. This market segment involves numerous vehicle types (heavy trucks, commercial trailers, recreational and utility trailers, step vans, emergency equipment, etc.) manufactured by hundreds of large and small manufacturers. Production of compliant universal lamps, or compliant/compatible replacement lamps, could prove extremely difficult, given that many lighting suppliers have catalogs consisting of tens of thousands of universal/replacement products. Furthermore, we anticipate that this would present a substantial burden for many small trailer and specialty vehicle manufacturers that do not have the resources to maintain this type of modeling data readily available for certification. Such manufacturers have historically relied on catalog or commodity items that, when installed, will allow the vehicle to comply with FMVSS 108. The financial and competitive impact on the aftermarket must therefore be carefully considered. We must also consider how the system is defined and what roles do other regulated lamps (e.g., parking lamps) and currently unregulated lamps (e.g., fog lamps) play under the new approach. Without a good definition of the system, compliance under a performance based approach could be easily disrupted by the addition or deletion of other lighting. Also of note is the fact that the UMTRI report states that whole vehicle testing could move us from design to conform to conform. This is a critical issue for the lighting industry. Due to technical limitations that make 100 percent conformity to specific requirements impractical or impossible, FMVSS 108 has used a design to conform approach since the earliest days of the standard, and the industry has worked well under this model for decades. Any proposal to move the industry to a strict conform approach could meet with a large amount of opposition from the industry and must be fully understood. In some ways, the new approach could be construed not as whole vehicle testing, but rather whole vehicle certification, as it would be difficult to identify individual failures in the whole vehicle testing approach.

4 We also note that the performance base approach is not harmonized or compatible with world standards (e.g., ECE). Thus, without parallel efforts to develop a Global Technical Regulation that maps closely to any proposed U.S. performance based standard, we run the risk of further de harmonization of the lighting standard. We understand SAE is working with UMTRI to provide a larger scope of lamps to test and analyze. TSEI supports SAE and UMTRI s additional research and testing efforts, which are crucial in better understanding the benefits and challenges of a performance based approach to the lighting standard. TSEI will supplement these comments after this additional testing has been completed. B. Headlamp test voltage We are seeking comment on ways to closely align the test input parameters of headlamps with those experienced on vehicles in the real world. Currently, headlamps are required to meet our photometry requirements when tested at 12.8 V. Many vehicles currently operate above this voltage by design. Accordingly, the report recommends a test voltage of 13.2 V because it would closely represent the way headlamps operate on the road. TSEI recognizes that the recommended test voltage of 13.2 V is intended to more closely align headlamp testing and certification conditions to the real world, since most vehicle lamps no longer operate at 12.8 V as currently specified in the standard. A test voltage of 13.2 V would also align headlamp testing with current ECE requirements. However, the Agency should bear in mind that the trend has been to use more electronic controls in vehicle design and to reduce voltage for various reasons, including improved fuel economy. Therefore, in the future, real world voltage could revert closer to 12.8 or even below. We note that the study used by UMTRI to recommend 13.2 V is relatively old, so we recommend that more research be conducted to affirm or modify this figure. Testing at 13.2 V presents potential challenges that must be better understood, both for headlighting (which is the current focus of the Agency s questions) and for any future application to signal lighting. For example, in the real world, a vehicle charging system is typically running at 14 V, but the battery with no load is closer to 12.8 V. When looking at the whole vehicle approach, would a 13.2 V requirement present problems for manufacturers to keep supply voltages at 13.2 V with all the potential line losses and the real ability of a battery? Furthermore, what does a move to 13.2 V (or some other voltage) mean for manufacturers current catalog of thousands of universal and replacement lamps, which have been on the market for years? Will these lamps be grandfathered at their current test status (e.g., at 12.8 volts)? How would the standard correlate performance under the old and new standards, as well as the real world? Another issue that presents itself is that although the requirements will be performance based and technology neutral, the actual testing will still utilize technology similar to today. Under the current testing method, for some technologies (e.g., halogen), the amount of light output is greatly impacted by changes in voltage, but for other technologies (e.g., LED), voltage changes may have little or no impact. We are concerned that the transition to the performance based simulation might negatively impact lamp sources that have a closer tie between input voltage and light output. We strongly advocate that further studies be run to obtain real world current voltages (the data in the UMTRI Report is over 20 years old). C. Asymmetrical headlighting We would like comments from the public on the merits and practicality of allowing significantly different performance from different headlamps mounted on the

5 vehicle. The report investigates the potential for such headlighting systems to provide superior glare control; however, it also notes potential issues when considering the current marking functions of headlamps as well as the current redundancy within photometry. We agree that asymmetrical headlighting could provide several benefits, including design flexibility. Indeed, this is a technology that is still being defined and TSEI supports the Agency s efforts to assess the merits and practicality of such systems. At this stage, there appear to be several potential pitfalls that must be further evaluated and considered. For example, such headlighting systems could present oncoming driver perception issues, whereby oncoming drivers may be confused about what type of vehicle is approaching (e.g., motorcycle). Furthermore, if multiple lamps are being used to fill out a System Light Pattern, the loss of one lamp from the system may render the system unsafe (e.g., no light available to see pedestrians). Moreover, lamp or whole vehicle testing could become even more complex due to the wide variety of potential lamps. (This, of course, raises many of the same issues discussed above regarding software, etc.). D. Adaptive forward lighting We are seeking comment with respect to the regulation of headlamps that adapt to roadway conditions. This report does not evaluate the benefits of the various methods of adaptive forward lighting. The report notes that the whole vehicle testing approach discussed above may provide a natural framework for which adaptive forward lighting requirements could be established in the future. The report notes that given that the current standard addresses headlamp photometry independent of the specifics of the vehicle on which it is installed, it may be difficult to evaluate the effectiveness of modifying the aim, or beam pattern of the headlighting system in a dynamic environment. We are seeking comment on how the approaches presented in the report could provide a foundation for dynamic evaluation of the headlighting system in the future. As with many of the other aspects of a performance based approach to FMVSS 108, TSEI believes that applying performance standards to adaptive forward lighting can have significant design flexibility benefits, with significant potential for increased safety by ensuring that light is directed where it is most needed during various driving conditions. AFL raises some of the same issues as asymmetrical headlighting, such as understanding oncoming driver perception and how glare will be controlled under a performance based approach. We note that ECE has already issued Regulation 123 Uniform provisions concerning the approval of adaptive front lighting systems (AFS) for motor vehicles. We have seen that this technology is something that OEM manufacturers intend to offer in vehicles in the near future. E. Headlamp aim We are seeking comment on the expected impacts of the approaches investigated in this report on headlamp aim. While it is clear that headlamp aim can be a critical factor in determining the ability of a headlighting system to adequately illuminate the roadway as well as limit glare, our current standard does not require that headlamps be aimed as installed on a new motor vehicle. The report notes that under the whole vehicle testing approach discussed above, headlamp aim would not be considered separately from headlamp photometry as the measurement of the headlighting system would take into account and measure the amount of light directed toward various regions of space surrounding the vehicle. Accordingly, headlamp aim would become an integral part of the headlighting system performance.

6 TSEI agrees that maintaining proper headlamp aim is critical in ensuring continued headlamp performance and for reducing glare. However, due to the multiple potential variables that can affect headlamp aim, such as suspension, vehicle options, vehicle heights, tires, and load, we question whether headlamp aim can be practicably incorporated into a performance based standard. Specifically, how would a standard be developed, how will each of these variables be controlled, and how will aim be incorporated into the whole vehicle testing concept that relies on software instead of actual vehicle testing? (On this latter point, will the testing software need to take all of these potential variables into account?) F. Signal lamp luminance We are seeking comment on how to measure the ability to see signal lighting beyond measuring intensity and the number of lighted sections. The judgment of brightness is most similar to the measurement of luminance; that is, luminous intensity, measured in candela, divided by the area from which light is emitted, measured in cm 2. Our current standard addresses signal lamp luminance in a somewhat indirect way. While we directly measure the luminous intensity of a lamp, for the purposes of luminance, we approximate the area from which the light is emitted based on the number of lighted sections. We are seeking comment on the ability for new computer based design systems to more directly measure the area from which light is emitted and any potential benefits of directly calculating signal lamp luminous as well as any potential issues associated with the approaches presented in the report. Regulation of signal lighting is a major area of interest to TSEI members. We believe there is significant room for improvement to the existing approach to signal lighting under FMVSS 108. Of foremost concern is the current use of compartments or lighted sections to define the photometric requirements for signal lamps. We support a move way from compartments/sections to an area approach that is technology (and light source) neutral. To the extent that such standards would go beyond an equipment level requirement to a wholevehicle requirement, this approach would raise many of the same issues surrounding testing and software identified above in the headlighting discussion, as well as concerns over universal and replacement lamps, which are common in the heavy vehicle and trailer industries (e.g., a 4 inch round lamp that currently meets the requirements at any position). Several additional points should be noted: It is apparent to us that the heavy duty industry was not heavily considered in the UMTRI report or in this initial request for comments. Does NHTSA intend to conduct further research in this area? Currently, the signal lighting on heavy duty vehicles does more than provide intention (e.g., stop or turn) signals; it also provides conspicuity (e.g., conspicuity triangle created between the ID Cluster and the STT). We want to ensure that any changes to FMVSS 108 do not infringe upon the longstanding relationship between the signal and conspicuity aspects of heavy duty lighting. Some of the technologies mentioned in the UMTRI report, such as photo imaging, are still under development and have not yet been proven in our industry.

7 How will the Agency merge the current performance based measurement methods for signal/conspicuity lamps? With the ever changing dynamics of vehicles (e.g., models, ride heights, etc.), mounting is not as performance based. We believe this is an area that could be improved to allow more technology and light source flexibility. * * * In the request for comments, the Agency asked if there were any priorities among the six areas of focus. For TSEI members, the number one priority would be the transition away from photometric compartments and light sources to an area method, as has been long suggested by SAE and mentioned in the UMTRI report. The next priority for TSEI members would be any improvement to the standard that allows more flexibility for the introduction of new technologies (e.g., light source neutral). Finally, we believe that the advancement of AFS requires some action in the near future, inasmuch our ECE counterparts have already introduced regulations for AFS. CONCLUSION TSEI appreciates the opportunity to provide these comments and looks forward to working with the Agency to further understand and resolve these and other issues raised by a possible performancebased approach to FMVSS 108. We believe that all affected parties must better understand the current shortcomings that a performance based approach is intended to resolve, how such an approach may improve motor vehicle safety (if at all), and the cost to industry of transitioning to a vehicle or systembased approach. While these issues have not yet been fully addressed, we assume all affected parties will focus on these and other questions as the Agency proceeds in its evaluation. Sincerely, Kristen Goodson President cc: Markus Price, Office of Crash Avoidance Standards

TRANSPORTRTION SAKTV c? UIPMCNT INSTITUT 1225 New York Avenue, NW-Suite 300 Washington, DC Phone: (202) 393-MEMA Fax: (202)

TRANSPORTRTION SAKTV c? UIPMCNT INSTITUT 1225 New York Avenue, NW-Suite 300 Washington, DC 20005 Phone: (202) 393-MEMA Fax: (202) 737-3742 October 7, 1998 DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY