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

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ADMINISTRATION Docket Management, Room PL-401 400 Seventh Street Washington, D.C.

1 TRANSPORTRTION SAKTV c? UIPMCNT INSTITUT 1225 New York Avenue, NW-Suite 300 Washington, DC Phone: (202) 393-MEMA Fax: (202) October 7, 1998 DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Docket Management, Room PL Seventh Street Washington, D.C RE: Docket NPRM on LED Lighting Dear Sir or Madam: The Transportation Safety Equipment Institute (TSEI) appreciates the opportunity to comment on this proposed rule, which deals with new light sources, such as LED s. TSEI is a professional organization representing the best interest of the majority of North American Vehicular Safety Manufacturers across a diversified base. We agree with the agency s assertion that now is the appropriate time to formulate uniform procedures that will relieve the design restrictions that have inadvertently prevented the implementation of new technology light sources in motor vehicle lamps. The members of our organization have worked together to develop the following response to the issues that were raised in this NPRM. Determination of Lighted Sections: The current restrictive interpretation of what constitutes a lighted section needs to be changed. The idea that more than one LED or light unit constitutes more than one light section is a misunderstanding from incandescent terminology used in the past. Several members of TSEI are currently manufacturing LED lighting devices because the problem of determination of lighted sections was avoided for large vehicles by NHTSA s adoption of Heavy Duty SAE standards that eliminated the requirement for two and three section devices. These standards for wide vehicles require each legally required section, regardless of how many, to meet single section photometrics. Although this simplified the requirements for vehicles over 80 inch wide, some of these LED devices are also used on vehicles less than 80 inches wide. The agency has outlined three ways to define a lighted section as listed by Schefenacker. The first suggestion was endorsed by NHTSA and uses linear Manufacturers of Vehicle Lighting and Reflective Devices, Mirrors and Associated Equipment

2 -2- October 7, 1998 dimensions to designate one, two or three compartment lamps. NHTSA s preference is based on the current version of SAE J 1889 that employs a linear measuring method. However, TSEI believes that the Square Centimeter Area Method, as proposed in the latest SAE J-1889 draft, dated , is less restrictive and is adequate to cover designs for the future. Several comments came from our members that support for our preference for the J-l 889 area method: Some Heavy-Duty manufactures have designed L.E.D. lamps, which exceed the proposed 150-millimeter linear parameter for a single lighted section. These designs are permitted by heavy-duty standard presently referenced in 108. The luminous flux method is undesirable because it assumes that the efficiencies of all light designs are uniform and appears to confuse Candlepower and Lumens terminology. It would treat LED s in the same manner as bulbs although the light emission patterns are very different and require different optics. In other words, they should not be mixed by using this method. With the advent of light engines, the lighting section issue may become even more complex. We think that NHTSA should provide the maximum design freedom and lean toward a performance-based requirement rather than geometry. The new J square centimeter proposal is a good compromise for the present time. The Hewlett-Packard method seemed to have merit when it was initially proposed. With the advent of brighter LED s and better optics it becomes design restrictive in that it requires an arbitrarily high number of LED s. It could even appear as selfserving for manufacturers of LED s. Failure of Individual LED or Bulb Units. Although there was some discussion between our members regarding this issue, there was universal agreement that some negligible failure of LED s does not constitute a loss of signal or marking values. Several members referred to NHTSA s published comments that the human eye is incapable of detecting less than a 25 percent change in light output. Some suggested that NHTSA establish some factor allowing for some minimal loss of LED s. Others felt that present status quo of periodic inspections as referenced in Federal Regulations, Title 49, part would be sufficient. Both of these approaches would offer some latitude in dealing with LED outages. Effective Projected Luminous Area: NHTSA asked for comments as to whether lamps which used miniature light sources with narrow beams are more likely to have performance degraded then those lamps where the light is more evenly distributed over the lens. A related question was

3 -3- October 7, 1998 whether a lamp should have some specific minimum light emission from areas outside these narrow beams. Our members did not feel that L.E.D. lights were any more likely to suffer lens degradation than standard incandescent lights. They were also not in favor of trying to stipulate a light to dark differential or of developing a method to measure the difference. The main points of the rational for support of this position follow: Distance can affect the appearance of lens illumination. The pattern in a lens design disappears beyond a couple of vehicle lengths. UMTRI tests results (UMTRI Report NO ) provided to SAE Lighting Committee members indicated that non-uniform signal lamps are more effective than uniform devices of the same size and shape. (They may not have been so aesthetically pleasing, however.) Not all areas of high intensity on a lens are likely to become blocked at the same time. In addition, the bright areas are bright enough to burn their way through a considerable amount of fog, dust or even dirt on the lens. This is an advantaae over so-called uniformly illuminated lenses. We believe UMTRI has also addressed this concept. The output of lights is governed by performance requirements which are stipulated by the NHTSABAE photometric pattern(s). This is irrespective of Light and Dark areas. Light and dark areas on lenses also occur on incandescent devices. Even areas of Low illumination provide signal value and can be compared to side marker lamp illumination levels. Measurement of dark areas as well as their determination would be difficult and subjective. Regulations in this area will certainly be design restrictive and will likely increase the cost of lighting devices without demonstrating improvement in safety. Heat Performance of LED s NHTSA has wisely decided against the photometric testing of lamps at elevated [or reduced!] temperatures. TSEI supports the rationale for this. NHTSA submitted a proposal which in which they suggest that the maximum Candela be recorded within 60 seconds after the device is energized and that the photometric minimum readings be recorded after the heat buildup has stabilized or after 30 minutes, whichever occurs first. Our members have strong views on this issue and have adopted procedures

4 -4- October 7, 1998 based on normal usage and on information obtained from NHTSA correspondence. Our comments are summarized as follows: TSEI believes that the 30-minute warm-up seems logical for testing devices that are operated continuously, such as marker and taillights. It does not seem logical for stoplights or turn signals, which are used intermittently or in a flashing mode. This logic is illustrated in the SAE J575 warpage test referenced by FMVSS-108, where lights are tested for heat resistance according to their operating mode, i.e. 5 minutes on and 5 minutes Off'. The 30-minute warm-up seems to disregard the fact that lamps used intermittently or in a flashing mode do not get as warm as lamps, which are steady burn. Implementation of a 30 minute warm-up for lights used intermittently tends to defeat the unique (and often costly) heat dissipating designs manufactures have placed in their LED devices to dissipate the heat for normal (shorter) on times. After 30 minutes, these devices often reach a soak temperature that renders the heat sink, Ect, ineffective. There was also discussion regarding appropriate timing for recording maximums. Some suggested that maximums on steady-burn devices should be taken after 5 minutes, however most agreed with the 60-second time for all LED devices. Everyone felt they would be able to find the location within 1 minute, especially after there had been some preliminary evaluation of the photometric pattern of the device. An omission may have been made in the in the proposed new paragraph S on pg It appears that the agency meant to say that the maximum would be recorded at 60 seconds after being energized. This change would make the meaning clearer. A 30 minute warm-up for intermittently used devices will increase the cost of future and existing lights (because more LED s will be required), without any proven increase in safety. Of lesser importance is the fact that if the 30,minute warm-up is used for all devices, it will greatly increase laboratory test time. These longer times will certainly tie up expensive test equipment and increase costs. TSEI is aware of several activities that could affect decisions regarding warm-up timing. There is a TSEI Round Robin Test involving the consistency of several laboratories in measuring LED device output after Sminutes and 30 minutes. In

5 -5- October 7, 1998 addition there is the outcome of J-1889 rewrite discussions. These should conclude with a meeting on Dec.gth and 10th. Several manufacturers of LED lighting devices may also have test data to present by that time. We urge NHTSA to extend their comment period to take advantage of data that may become available or at least agree to review the data, as it becomes available. Optical Combinations We believe the present SAE J387 definition adequately covers LED applications, that is, assuming NHTSA plans to change its present interpretation of lighted sections where one LED is one section, two LED s are two sections, etc. We understand that the proposed revisions in J1889 may also help clarify the industry s understanding of LED optical combinations. TSEI is appreciative of the opportunity to offer its comments on this important docket. NHTSA should carefully consider the ramifications of any changes that could affect the legality of currently manufactured products. Any existing products that meet current regulations should certainly be Grandfatherd. We would be pleased to discus any of these issues in more detail should NHTSA wish to do so. We would like the to reserve the right to submit additional comments, should we feel the need to do so. Thank you. Sincerely, %adle$ C. Van Riper, Chairman Vehicle Conspicuity Committee Transportation Safety Equipment Institute cc: Michael Giannelli; Brian Duggan; Edward Zimmer; Lawrence F. Henneberger, Esq.; NHTSA (9 additional copies)

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