[Federal Register Volume 87, Number 35 (Tuesday, February 22, 2022)]
[Rules and Regulations]
[Pages 9916-10026]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-02451]
[[Page 9915]]
Vol. 87
Tuesday,
No. 35
February 22, 2022
Part V
Department of Transportation
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National Highway Traffic Safety Administration
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49 CFR Part 571
Federal Motor Vehicle Safety Standards; Lamps, Reflective Devices, and
Associated Equipment, Adaptive Driving Beam Headlamps; Final Rule
Federal Register / Vol. 87, No. 35 / Tuesday, February 22, 2022 /
Rules and Regulations
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
49 CFR Part 571
[Docket No. NHTSA-2022-0013]
RIN 2127-AL83
Federal Motor Vehicle Safety Standards; Lamps, Reflective
Devices, and Associated Equipment, Adaptive Driving Beam Headlamps
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Final rule.
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SUMMARY: This document amends NHTSA's lighting standard to permit the
certification of adaptive driving beam (ADB) headlamps. ADB headlamps
utilize technology that actively modifies a vehicle's headlamp beams to
provide more illumination while not glaring other vehicles. The
requirements adopted today are intended to amend the lighting standard
to permit this technology and establish performance requirements for
these systems to ensure that they operate safely. ADB has the potential
to reduce the risk of crashes by increasing visibility without
increasing glare. The agency initiated this rulemaking in response to a
petition for rulemaking from Toyota Motor North America, Inc.
DATES:
Effective date: The effective date of this final rule is February
22, 2022. The incorporation by reference of certain publications listed
in the rule was approved by the Director of the Federal Register as of
February 6, 2012.
Compliance date: The compliance date for the amendments in this
final rule is February 22, 2022.
Petitions for reconsideration: Petitions for reconsideration of
this final rule must be received not later than April 8, 2022.
ADDRESSES: Petitions for reconsideration of this final rule must refer
to the docket and notice number set forth above and be submitted to the
Administrator, National Highway Traffic Safety Administration, 1200 New
Jersey Avenue SE, Washington, DC 20590. Note that all petitions
received will be posted without change to www.regulations.gov,
including any personal information provided.
Privacy Act: Please see the Privacy Act heading under Rulemaking
Analyses and Notices.
FOR FURTHER INFORMATION CONTACT: Mr. Markus Price, NHTSA Office of
Crash Avoidance Standards. Telephone: 202-366-1810; Email:
[email protected]; or Mr. John Piazza, Office of Chief Counsel.
Telephone: 202-366-2992; Email: [email protected]. You may send mail
to these officials at: National Highway Traffic Safety Administration,
1200 New Jersey Avenue SE, Washington, DC 20590.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Executive Summary
II. Background and Safety Need
III. NHTSA's Statutory Authority
IV. ADB Rulemaking Mandate in the Infrastructure, Investment and
Jobs Act
V. Summary of the NPRM
VI. Overview of Comments
VII. NHTSA Research and Testing
VIII. Final Rule and Response to Comments
A. Summary of the Final Rule and Modifications to the NPRM
B. Interpretation of FMVSS No. 108 as Applied to ADB Systems
C. Track Testing Requirements and Procedures
1. Practicability of Proposed Test Scenarios
2. Test Fixtures vs. Stimulus Vehicles
3. Justification for Testing on Curves and General Approach for
Scenario Selection
4. Maximum Illuminance Criteria (Glare Limits)
5. ADB Adaptation Time
6. Test Fixture Specifications
7. Test Fixture Placement
8. Test Scenarios
a. Scenario 1: Oncoming Straight
b. Scenario 2: Oncoming Small Left Curve
c. Scenario 3: Oncoming Medium Left Curve
d. Scenario 4: Oncoming Large Left Curve
e. Scenario 5: Oncoming Medium Right Curve
f. Scenario 6: Oncoming Large Right Curve
g. Scenario 7: Preceding Straight
h. Scenario 8: Preceding Medium Left Curve
i. Decision Not To Include Oncoming Short Right Curve Scenario
9. Other Test Parameters and Conditions
a. Radius of Curvature
b. Test Vehicle Speed and Acceleration
c. Headlamp Aim
d. Road Surface
e. Ambient and Reflected Light
f. Superelevation
g. Lane Divisions
h. Hills
10. Data Acquisition and Measurement
a. Photometers
b. Sampling Rate
c. Noise and Filtering
d. Allowance for Momentary Glare Exceedances
e. Vehicle Pitch
11. Repeatability
D. Laboratory (Component-Level) Testing
1. Need for Laboratory Testing
2. Definitions of Areas of Reduced and Unreduced Intensity
3. Requirements for Area of Reduced Intensity
4. Requirements for Area of Unreduced Intensity
5. Transition Zone
6. Veiling Glare
E. Minimum Activation Speed
F. Operator Controls, Indicators, Malfunction Detection, and
Operating Instructions
G. Accommodation of Different Technologies
H. Requirements for Semiautomatic Beam Switching Devices Other
Than ADB and Applicability of Compliance Options
I. Physical Test Requirements
J. Other Requirements
K. Information Reporting
L. Aftermarket Compliance
M. Exemption Petitions
N. Compliance Date
O. Regulatory Alternatives
P. Overview of Benefits and Costs
IX. Appendix to FMVSS No. 108 (Table of Contents)
X. Rulemaking Analyses and Notices
Appendix A. Comparison of Oncoming Glare Limits to Table XIX Right-
Side Photometric Maxima
Appendix B. Example of Laboratory Photometric Testing of Adaptive
Driving Beam
Appendix C. ADB Performance With Motorcycle Test Fixture
Appendix D. List of Comments Cited in Preamble
I. Executive Summary
This final rule amends Federal Motor Vehicle Safety Standard (FMVSS
or Standard) No. 108, ``Lamps, reflective devices, and associated
equipment,'' to enable the certification of adaptive driving beam (ADB)
headlighting systems on vehicles sold in the United States. NHTSA is
issuing this final rule under the National Traffic and Motor Vehicle
Safety Act (Safety Act), 49 U.S.C. Chapter 301, Motor Vehicle Safety
(49 U.S.C. 30101 et seq.).
Glare, Visibility, and Adaptive Driving Beam Technology
Adaptive driving beam headlamps utilize technology that actively
modifies the headlamp beams to provide more illumination while not
glaring other vehicles. The requirements adopted today are intended to
amend FMVSS No. 108 to permit this technology and ensure that it
operates safely.
Vehicle headlamps must satisfy two different safety needs:
Visibility and glare prevention. The primary function of headlamps is
to provide forward visibility for drivers. At the same time, there is a
risk that intense headlamp illumination may be directed towards
oncoming or preceding vehicles. Such illumination, referred to as
glare, can reduce the ability of other drivers to see and can cause
discomfort. Headlighting has therefore traditionally entailed a
tradeoff between long-distance visibility and glare prevention. This is
reflected in Standard No. 108's requirement that
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headlighting systems have both upper and lower beams. The existing
headlamp requirements regulate the beam pattern (photometry) of the
upper and lower beams; they ensure sufficient visibility by specifying
minimum amounts of light in certain areas on and around the road, and
prevent glare by specifying maximum amounts of light in directions that
correspond to where oncoming and preceding vehicles would be.
ADB systems are an advanced type of headlamp technology that
optimizes beam patterns without driver action. Semiautomatic beam
switching technology was first introduced on vehicles in the United
States in the 1950s and has become increasingly popular in the last few
decades. The semiautomatic beam switching technology currently
available in the United States (commonly referred to as ``auto hi-
beam'' or ``high beam assist'') automatically switches between the
lower and upper beams. This provides safety benefits because research
has shown that most drivers underutilize the upper beams, and
semiautomatic beam switching facilitates increased upper beam use in
situations where drivers of other vehicles will not be glared.
ADB systems are an improvement over ``auto hi-beam'' technology
currently available in the United States because they are capable of
providing more illumination than a lower beam without increasing glare.
When operating in automatic mode, instead of simply switching between
the upper and lower beams, an ADB system is able to provide a dynamic,
adaptive beam pattern that changes based on the presence of other
vehicles or objects, providing less illumination to occupied areas of
the road and more illumination to unoccupied areas of the road. ADB
systems can therefore provide more illumination than existing lower
beams without glaring other motorists (if operating correctly). ADB
systems achieve this enhanced performance by utilizing advanced
sensors, data processing software, and headlamp hardware.
ADB systems are available in foreign markets but are not currently
offered on vehicles in the United States. This final rule amends FMVSS
No. 108 to permit ADB systems on vehicles in the United States and
ensure that they operate safely. ADB, like other headlamp technologies,
implicates the twin safety needs of visibility and glare prevention.
This final rule does three main things that, taken together, allow ADB
systems and ensure that they meet these safety needs.
First, it amends FMVSS No. 108 to allow ADB systems. It amends,
among other things, the existing headlamp requirements so that ADB
technology is permitted.
Second, this final rule adopts requirements to ensure that ADB
systems do not increase glare to other motorists beyond current lower
beams. ADB systems are capable of providing a variable, adaptive beam
in the presence of other vehicles that provides more illumination than
the currently allowed lower beam. However, if ADB systems do not
accurately detect other vehicles on the road and shade them
accordingly, other motorists will be glared.\1\ The rule addresses this
safety need by including vehicle-level track-test requirements
specifically tailored to evaluate whether an ADB system functions
safely and limits glare for other motorists.
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\1\ NHTSA is sensitive to concerns about glare due to the
numerous complaints from the public it has received and its own
research (prompted, in part, by these complaints and a 2005
Congressional mandate to study the risks from glare).
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Third, it adopts component-level laboratory-tested requirements
related to both glare and visibility, as well as a limited set of other
system requirements, such as requirements for manual override and fail-
safe operation.
In drafting this final rule, NHTSA considered two major regulatory
alternatives. One was the Economic Commission for Europe (ECE)
regulations that apply to ADB systems, including a vehicle-level test
on public roads. However, the ECE road test is not appropriate for
adoption as an FMVSS because it does not provide sufficiently objective
performance criteria. We also considered a Society for Automotive
Engineers (SAE) recommended practice, J3069 JUN2016, Surface Vehicle
Recommended Practice; Adaptive Driving Beam, as well as the updated
version of this practice (published in March 2021). The final rule
follows SAE J3069 in many significant respects, but also differs from
it in significant ways.
NHTSA published the notice of proposed rulemaking (NPRM) preceding
this final rule on October 12, 2018 (83 FR 51766). Many industry
comments to the NPRM urged closer harmonization with SAE J3069. These
comments focused primarily on costs from dis-harmonization due to the
resulting need for market-specific hardware and components. In response
to the comments, NHTSA conducted additional vehicle-level testing to
validate modifications to the proposal to harmonize more closely with
SAE J3069 while still retaining sufficient realism. As a result, NHTSA
has changed some aspects of the proposal. The final rule more closely
conforms to SAE J3069 in a number of respects but continues to deviate
from it for reasons discussed in detail in this preamble.
Differences Between This Final Rule and the Proposal
The following discussion highlights the more noteworthy differences
between the final rule and the NPRM. All changes from the proposal are
discussed in the appropriate sections of this preamble.
Vehicle-Level Track Test To Evaluate Glare
Stimulus test fixtures instead of stimulus vehicles. The final rule
specifies test fixtures instead of stimulus vehicles. This change will
result in a less complex test that is more closely harmonized with SAE
J3069, while still ensuring that ADB systems operate safely. While the
test fixture specifications follow SAE J3069 with respect to the
locations of the photometers and stimulus lamps, the final rule
requires the use of more real-world representative lighting in the
compliance test by specifying original equipment vehicle headlamps and
taillamps.
More efficient test scenarios. The final rule simplifies the number
and complexity of test scenarios. The final rule continues to differ
from SAE J3069 by specifying test scenarios with actual curves because
this is necessary to evaluate how an ADB system would perform in the
real world. We have, however, modified many of the curved-path test
scenarios. NHTSA believes that the final scenarios meet the need for
motor vehicle safety by containing a broad range of realistic road
geometries and vehicle interactions.
Data measurement and allowances. The final rule changes how NHTSA
will measure and evaluate ADB system illuminance. This includes an
added specification for a data filter and replacing the proposed
International Roughness Index parameter with an explicit adjustment for
vehicle pitch.
Component-Level Laboratory Photometric Testing
The final rule retains, in modified form, the proposed requirements
for component-level laboratory testing.
Defining ``adaptive driving beam'' as a new beam type. The final
rule defines a new beam type, ``adaptive driving beam.'' The final rule
also provides manufacturers flexibility to determine when to provide an
area of reduced or unreduced intensity (subject to several requirements
or constraints, such as the
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track test that evaluates glare). This will enable systems to provide
an area of reduced intensity not only to prevent glare to oncoming or
preceding vehicles, but also in other situations in which reduced
intensity would be beneficial.
Requirements for areas of reduced intensity. The final rule follows
the NPRM and specifies the existing lower beam photometric test points
(both minima and maxima). The minima are important because the final
rule does not include any ``false positive'' tests to ensure that an
ADB system does not mistakenly dim the beam in the absence of other
vehicles, and the maxima are necessary to help ensure that other
motorists are not subject to glare beyond that experienced with lower
beams.
Requirements for areas of unreduced intensity. The final rule
follows the NPRM and specifies the existing upper beam photometric test
points (both minima and maxima). Requiring a minimum level of
illumination is important to ensure a minimum level of visibility. The
final rule does not adopt the higher ECE upper beam maxima.
Transition zone. The final rule allows for a 1-degree transition
zone between an area of reduced intensity and an area of unreduced
intensity. The lower and upper beam photometric test points will not
apply within a transition zone (except for the upper beam maximum at H-
V, which still applies). Manufacturers essentially will be free to
determine the areas of reduced and unreduced intensity and, therefore,
the boundaries of the transition zone.
Other System Requirements
The final rule retains many of the proposed system requirements.
However, the minimum activation speed has been decreased from 25 mph to
20 mph to give greater flexibility to manufacturers wishing to provide
for hysteresis in the system design. The final rule also exempts ADB
systems from many of the vehicle headlamp aiming device requirements,
which would add unnecessary costs to ADB systems.
Benefits and Costs
This final rule is not significant and so was not reviewed by OMB
under E.O. 12866. NHTSA has determined that quantifying the benefits
and costs is not practicable in this rulemaking because of limitations
on the agency's ability to accurately estimate the target population
and the effectiveness of ADB. We have, however, identified the problem
this rule is intended to address, considered whether existing
regulations have contributed to the problem, qualitatively assessed the
costs and benefits, and considered alternatives. This final rule
appropriately balances the needs for visibility and glare prevention,
and adopts requirements that are both practicable and sufficient to
assess whether an ADB system operates safely. This final rule does not
require manufacturers to provide ADB systems, but only specifies the
requirements the systems must meet if equipped on vehicles.
II. Background and Safety Need
On October 12, 2018, NHTSA published the NPRM (83 FR 51766)
underlying this final rule. NHTSA is publishing this final rule to set
forth the amendments to FMVSS No. 108 (49 CFR 571.108), summarize the
comments received in response to the proposal, and provide the agency's
responses to those comments.
This section provides a brief introduction to the safety needs
addressed in this rulemaking, ADB technology, the relevant industry and
international standards for ADB systems, the petition for rulemaking
that prompted the NPRM, and related exemption petitions and NTSB
recommendations. For additional detailed background information
(including an explanation of the headlamp photometric requirements and
regulatory history and research efforts related to glare), the reader
is referred to the NPRM.\2\
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\2\ See pp. 51768-51774.
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Safety Needs: Visibility and Glare Prevention
Vehicle headlamps primarily satisfy two safety needs: Visibility
and glare prevention. Headlamps illuminate the area ahead of the
vehicle and provide forward visibility.\3\ Headlamp illumination,
however, has the potential to glare other motorists. Accordingly,
headlighting systems have traditionally consisted of lower beams and
upper beams. The lower beams (also referred to as passing beams or
dipped beams) are designed to provide relatively high levels of light
in the close-in forward visibility region, and to provide reduced light
intensity in longer-distance regions, where oncoming or preceding
vehicles would be glared. The lower beams are intended for use during
lower-speed driving or when meeting or closely following another
vehicle. Upper beams (also referred to as high beams, main beams, or
driving beams) are designed to provide relatively high levels of
illumination in both close-in and longer distance regions. They are
intended primarily for distance illumination and for use when not
meeting or closely following another vehicle. (FMVSS No. 108
establishes maximum levels of intensity the upper beam may not exceed.)
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\3\ They also make the vehicle more visible to other road users.
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Visibility and glare are both related to motor vehicle safety.
Visibility has an obvious, intuitive relation to safety: The better
drivers can see the road, the better they can react to road conditions
and obstacles to avoid crashes. Although the qualitative connection to
safety is intuitive, quantifying the effect of visibility on crash risk
is difficult because of many confounding factors (for example, was a
late-night crash caused by diminished visibility or driver fatigue?).
Still, evidence suggests that diminished visibility likely increases
the risk of crashes, particularly crashes at higher speeds involving
pedestrians, animals, trains, and parked cars.\4\ The NPRM (in Appendix
A) included an analysis estimating the target population that could
benefit from the increased visibility provided by ADB systems.
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\4\ Nighttime Glare and Driving Performance, Report to Congress
(2007), National Highway Traffic Safety Administration, Department
of Transportation [hereinafter ``2007 Report to Congress''], p. 6. A
2016 study by the Insurance Institute for Highway Safety noted that
``[t]wenty-nine percent of all fatalities during 2014 occurred in
the dark on unlit roads. Although factors such as alcohol impairment
and fatigue contributed to many of these crashes, poor visibility
likely also played a role.'' Ian J. Reagan, Matthew L. Brumbelow &
Michael J. Flannagan. 2016. The Effects of Rurality, Proximity of
Other Traffic, and Roadway Curvature on High Beam Headlamp Use
Rates. Insurance Institute for Highway Safety, pp. 2-3 (citations
omitted). See also Michael J. Flannagan & John M. Sullivan. 2011.
Feasibility of New Approaches for the Regulation of Motor Vehicle
Lighting Performance. Washington, DC: National Highway Traffic
Safety Administration, p. 5 (NHTSA-2018-0090-0002) (``The conclusion
of our analysis was that pedestrian crashes were by far the most
prevalent type of crash that could in principle be addressed by
headlighting.'').
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Glare is related to safety because it can degrade important aspects
of driving performance. Glare is a sensation caused by bright light in
an observer's field of view. Headlamp illumination can glare drivers of
oncoming or preceding vehicles (via the rearview or side mirrors).
Empirical evidence suggests that headlamp glare decreases visibility
distance, increases reaction time, and reduces detection probability,
among other things.\5\ It can
[[Page 9919]]
also cause discomfort. Despite this evidence, it remains difficult to
quantify the effect of glare on crash risk. Unlike drug or alcohol use,
there is usually no way to determine precisely the amount of glare that
was present in a given crash. Nevertheless, some police crash reports
mention glare as a potential cause, and it is reasonable to expect that
glare can reduce visibility, and reductions in visibility caused by
headlamp glare increase crash risk.\6\ Discomfort attributable to glare
might also indirectly affect crash risk (for example, if a driver
reacts to glare by changing their direction of gaze).\7\ In addition,
discomfort caused by glare may induce some drivers, particularly older
drivers, to avoid driving at night or simply increase their
annoyance.\8\
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\5\ 2007 Report to Congress, pp. iv, 11-14. See also, e.g., John
D. Bullough et al. 2003. An Investigation of Headlamp Glare:
Intensity, Spectrum and Size, DOT HS 809 672. Washington, DC: U.S.
Department of Transportation, National Highway Traffic Safety
Administration [hereinafter ``Investigation of Headlamp Glare''], p.
1. (``It is almost always the case that headlamp glare reduces
visual performance under driving conditions relative to the level of
performance achievable without glare.'')
\6\ John D. Bullough et al. 2008. Nighttime Glare and Driving
Performance: Research Findings, DOT HS 811 043. Washington, DC: U.S.
Department of Transportation, National Highway Traffic Safety
Administration, p. I-4.
\7\ Id., p. 33. But see Investigation of Headlamp Glare, p. 3
(``Very few studies have probed the interactions between discomfort
and disability glare, or indeed any driving-performance related
factors . . . .'').
\8\ 2007 Report to Congress, p. iv.
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The potential problems associated with glare are highlighted by the
thousands of complaints NHTSA has received from the public on the
issue, as well as congressional interest. The introduction of halogen
headlamp technology in the late 1970s and high-intensity discharge and
auxiliary headlamps in the 1990s was accompanied by a marked upswing in
the number of glare complaints to NHTSA. In response to increased
consumer complaints in the late 1990s, NHTSA published a Request for
Comments in 2001 on issues related to glare from headlamps, fog lamps,
driving lamps, and auxiliary headlamps.\9\ NHTSA received more than
5,000 comments, most of which concerned nighttime glare from front-
mounted lamps.\10\ In 2005 Congress directed DOT to study the risks of
glare.\11\ NHTSA subsequently initiated a multipronged research program
to examine the causes of, and possible solutions to, glare.\12\
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\9\ 66 FR 49594 (Sept. 28, 2001).
\10\ 69 FR 54255 (Sept. 8, 2004).
\11\ Safe, Accountable, Flexible, Efficient Transportation
Equity Act: A Legacy for Users, Public Law 109-59, Sec. 2015 (2005).
\12\ For more information, see the NPRM at p. 51771.
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Adaptive Driving Beam Technology
ADB systems are an advanced type of headlamp technology that
optimizes beam patterns without driver action. Semiautomatic beam
switching technology was first introduced on vehicles in the United
States in the 1950s and has become increasingly popular in the last few
decades with the wider deployment of camera-based driver assistance
technologies. The semiautomatic beam switching technology currently
available on vehicles in the United States is commonly referred to as
``auto hi-beam'' or ``high beam assist,'' among other terms. This
currently-available technology automatically switches between the lower
and upper beams (while still allowing the driver to manually switch
beams).\13\ Semiautomatic beam switching enhances safety because it
facilitates increased use of the upper beams in situations where
drivers of other vehicles will not be glared. Research has shown that
most drivers under-utilize the upper beams,\14\ despite the fact that
``driving with lower-beam headlamps can result in insufficient
visibility for a number of driving situations,'' \15\ particularly at
higher speeds.\16\
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\13\ Under FMVSS No. 108 this technology is classified as a
``semiautomatic beam switching device'' because it provides either
automatic or manual control of switching between the lower and upper
beams at the option of the driver. See S4 (definition of
``semiautomatic headlamp beam switching device'') and S9.4.
\14\ See, e.g., John D. Bullough, Nicholas P. Skinner, Yukio
Akashi, & John Van Derlofske. 2008. Investigation of Safety-Based
Advanced Forward-Lighting Concepts to Reduce Glare, DOT HS 811 033.
Washington, DC: National Highway Traffic Safety Administration, p.
63. (finding that ``abundant evidence suggests that most drivers use
lower beams primarily, if not exclusively.'') See also, e.g., Mary
Lynn Mefford, Michael J. Flannagan & Scott E. Bogard. 2006. Real-
World Use of High-Beam Headlamps, UMTRI-2006-11. University of
Michigan, Transportation Research Institute, p. 6 (finding that
``high-beam headlamp use is low . . . consistent with previous
studies that used different methods'').
\15\ Investigation of Safety-Based Advanced Forward-Lighting
Concepts to Reduce Glare (DOT HS 811 033), p. 63.
\16\ Michael J. Flannagan & John M. Sullivan. 2011. Preliminary
Assessment of The Potential Benefits of Adaptive Driving Beams,
UMTRI-2011-37. University of Michigan, Transportation Research
Institute, p. 2.
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ADB systems are an improvement over the ``auto hi-beam'' technology
currently available in the United States because they are capable of
providing more illumination than a lower beam without increasing glare.
When operating in automatic mode, instead of simply switching between
the upper and lower beams, the ADB system is able to provide a dynamic,
adaptive beam pattern that changes based on the presence of other
vehicles or objects, providing less illumination to occupied areas of
the road and more illumination to unoccupied areas of the road.\17\ The
portions of the adaptive beam directed to areas of the roadway occupied
by other vehicles are at or (for some systems deployed in Europe) even
below levels of a lower beam.\18\ The portions of the adaptive beam
directed at unoccupied areas of the road are typically equivalent to an
upper beam. When the roadway ahead is fully occupied by oncoming or
preceding vehicles, the adaptive beam is essentially a lower beam. When
there are no oncoming or preceding vehicles, the adaptive beam is
essentially an upper beam.\19\
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\17\ When operating in manual mode--which the driver may obtain
at any time--the driver is able to switch between the lower and
upper beams.
\18\ SAE J3069 JUN 2016, pp. 1-2.
\19\ There are, however, situations in which it may be
appropriate to provide less than a full upper beam even in the
absence of oncoming or preceding vehicles. For example, it may be
optimal to direct less light at a retroreflective sign or wet
roadway, in order to minimize glare to the driver of the ADB-
equipped vehicle from reflected light. This is discussed in more
detail in Section VIII.D.2.
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So, for example, when an ADB-equipped vehicle (operating in
automatic mode) travelling on an otherwise unoccupied roadway
encounters an oncoming vehicle, it switches from an upper beam
providing high light levels in both close-in and longer distance
regions to an adaptive beam providing reduced intensity (similar to a
lower beam) near the oncoming vehicle and unreduced intensity (similar
to an upper beam) elsewhere. Because the system is able to provide
unreduced intensity to unoccupied areas of the roadway, while at the
same time providing reduced intensity to areas near other vehicles, it
provides more illumination than a conventional lower beam would
provide. ADB therefore has the potential to reduce the risk of crashes
by increasing visibility without increasing glare. The adaptive beam is
particularly useful for distance illumination of pedestrians, animals,
and objects in or near the road when other vehicles are present and
thus preclude use of the upper beam.
ADB systems achieve this enhanced performance by utilizing advanced
sensors, data processing software, and headlamp hardware (such as
shutters or LED arrays). Many current ADB systems utilize a camera with
a typical field of view of approximately 25 degrees left and right to
detect objects.\20\ High-resolution ADB systems are capable of
classifying objects and placing optimized levels of light on all
objects in the driver's view (such as
[[Page 9920]]
retroreflective signs or pedestrians). ADB systems typically use the
existing headlamps that are modified either with a mechanical shade
that blocks part of the beam, or (for light-emitting diode [LED]
headlamps) extinguish individual LEDs. The ADB systems NHTSA tested
required the driver to select the ADB mode using the headlighting
system control. Once in ADB mode, the systems were designed to activate
the adaptive beam at speeds between 20 mph and 40 mph and deactivate
the adaptive beam (and provide a lower beam) from 15 mph to 25 mph.
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\20\ SAE comment (NHTSA-2018-0090-0167), p. 9 (``The forward
camera vision on today's vehicles only extends to approximately 25
degrees left and right[.]''). We assume this is the camera's field
of view for the illustrative examples in the discussions of the
curve scenarios.
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European ADB Requirements
ADB was first permitted in Europe by amendments to ECE Regulation
No. 48 in 2006.\21\ ECE regulations allow ADB systems under the
umbrella of adaptive front lighting systems (AFS). There are a variety
of requirements for AFS generally and adaptive lighting in particular.
Unlike the FMVSS, which rely on manufacturer self-certification, ECE
requirements for ADB systems utilize the type approval framework used
throughout the ECE standards. Under the type approval framework,
production samples of new model cars must be approved by regulators
before being offered for sale. This approval is based, in part, on
testing whole vehicles on public roadways to verify performance. The
ECE requirements specify that the adaptation of the main-beam not cause
any discomfort, distraction or glare to the driver of the ADB-equipped
vehicle (for example, glare to the driver cause by excessive
illumination of retroreflective signs) or to oncoming and preceding
vehicles. This is demonstrated through the technical service performing
a test drive on various types of roads (e.g., urban, multi-lane roads,
and country roads), at a variety of speeds, and in a variety of
specified traffic conditions. The performance of the ADB system is
evaluated based on the subjective observations of the type approval
engineer during this test drive. The ECE road test is therefore not
appropriate for adoption as an FMVSS because it does not provide
objective performance criteria. However, the proposed track test
scenarios were based, in part, on the ECE road-test scenarios.
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\21\ Uniform provisions concerning the approval of vehicles with
regard to the installation of lighting and light-signalling devices
(R48) and Regulation No. 123, Uniform provisions concerning the
approval of adaptive front-lighting systems (AFS) for motor vehicles
(R123) of the Economic Commission for Europe (ECE).
---------------------------------------------------------------------------
SAE J3069
In June 2016, SAE International (SAE) published SAE J3069 JUN2016,
Surface Vehicle Recommended Practice; Adaptive Driving Beam (SAE
J3069).\22\ The recommended practice, which is based, in part, on
NHTSA's research (described in Section VII below), includes (among
other requirements) a track test to evaluate ADB system performance in
avoiding excessive glare to other vehicles. It specifies a straight
test path with a single lane, on either side of which it specifies the
placement of test fixtures simulating an opposing or preceding vehicle.
See Figure 1. The test fixtures are fitted with lamps having a
specified luminous intensity, color, and size intended to simulate the
taillamps and headlamps on a typical car, truck, or motorcycle. Four
different test fixtures are specified: An opposing (i.e., oncoming)
car/truck; an opposing motorcycle; a preceding car/truck; and a
preceding motorcycle. In addition to simulated vehicle lighting, the
test fixtures are fitted with photometers \23\ to measure the
illumination from the ADB headlamps. Although the test does not specify
any scenarios with a curved test path, the placement of the fixtures
relative to the straight test path, along with a sudden appearance
test, are intended to simulate curves.
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\22\ SAE has recently published a revised version of this
recommended practice (SAE J3069 MAR2021). These limited revisions,
where potentially relevant to this final rule, are identified and
discussed in subsequent sections of this preamble.
\23\ A photometer, or illuminance meter, is an instrument that
measures light.
[GRAPHIC] [TIFF OMITTED] TR22FE22.001
SAE J3069 sets out a total of 18 different test drive scenarios.
The scenarios vary the test fixture, the placement of the fixture, and
whether the lamps on the test fixture are illuminated for the entire
test drive, or are instead suddenly illuminated when the ADB vehicle
reaches a specified distance from the test fixture. During each of
these test drives, the illuminance \24\ recorded at 30 meters (m), 60
m, 120 m, and 155 m must not exceed the maximum allowed illuminance
specified for each distance. See Table 1. These illuminance maxima are
based on and similar (but not identical) to the maximum illuminance
limits developed in NHTSA's published research and proposed in the
NPRM. If there is no recorded illuminance value at any of these
distances, interpolation is used to estimate the illuminance at that
distance. For sudden appearance tests, the system is given a maximum of
2.5 seconds to react and adjust the beam to reduce illumination to a
level within the applicable maximum. If any recorded (or interpolated)
illuminance value exceeds the applicable maximum illuminance, SAE J3069
provides for an
[[Page 9921]]
allowance: The same test drive scenario is run with the lower beam
activated. The ADB system can still be deemed to have passed the test
if any of the ADB exceedances do not exceed 125% of the measured (or
interpolated) illuminance value(s) for the lower beam.
---------------------------------------------------------------------------
\24\ Illuminance is the amount of light falling on a surface.
The unit of measurement for illuminance is lux.
Table 1--SAE J3069 Maximum Allowed Illuminance
------------------------------------------------------------------------
Maximum Maximum
illuminance, illuminance,
Range from headlamp to photometer (m) oncoming preceding
(lux) (lux)
------------------------------------------------------------------------
30...................................... 1.8 18.9
60...................................... 0.7 8.9
120..................................... 0.3 4.0
155..................................... 0.3 4.0
------------------------------------------------------------------------
In addition to the dynamic track test, SAE J3069 contains a number
of other system requirements, such as a physical test (e.g., a
corrosion test) and telltale requirements. It also requires the system
to comply with a limited set of component-level laboratory-based
photometry requirements. For example, for the portion of the adaptive
beam that is directed at areas of the roadway unoccupied by other
vehicles, the lower beam minimum values specified in the relevant SAE
standard must be met.\25\ Specific provisions of SAE J3069 are
discussed in more detail in the responses to the comments.
---------------------------------------------------------------------------
\25\ As explained in the NPRM, FMVSS No. 108 also contains
laboratory-based photometric requirements. SAE J3069 refers not to
these requirements, but to analogous requirements specified in other
SAE standards.
---------------------------------------------------------------------------
Toyota Petition for Rulemaking, ADB Exemption Petitions, and NTSB
Recommendation
While ADB systems have been available in Europe for a number of
years, they have not yet been deployed in the United States, largely
because of industry uncertainty about whether FMVSS No. 108 allows ADB
systems.\26\ Prior to the NPRM, NHTSA had not formally addressed
whether the lighting standard allows ADB systems. Accordingly, in 2013,
Toyota Motor North America, Inc. (Toyota) petitioned NHTSA for
rulemaking to amend FMVSS No. 108 to give manufacturers the option of
equipping vehicles with ADB systems.\27\ In its petition, Toyota
described how its system works, identified potential safety benefits of
the system, and discussed its view of how ADB should be treated under
the agency's regulations. NHTSA granted Toyota's petition and the NPRM
was NHTSA's action on that grant.
---------------------------------------------------------------------------
\26\ See, e.g., SAE J3069 (``However, in the United States it is
unclear how ADB would be treated under the current Federal Motor
Vehicle Safety Standard (FMVSS) 108.'').
\27\ Letter from Tom Stricker, Toyota Motor North America, Inc.
to NHTSA (Mar. 29, 2013). Toyota requested confidential treatment
for portions of its submission. A redacted copy of the petition has
been placed in the docket for this rulemaking.
---------------------------------------------------------------------------
After receiving Toyota's petition, but prior to the NPRM, NHTSA
received two exemption petitions (under 49 CFR part 555) for ADB-
equipped vehicles. In 2016, Volkswagen Group of America (Volkswagen)
submitted a petition for a temporary exemption from some of the
requirements of FMVSS No. 108 to sell a limited number of ADB-equipped
vehicles. NHTSA published a notice of receipt of this petition on
September 11, 2017, and provided a 30-day comment period.\28\ BMW of
North America, LLC (BMW) subsequently submitted a similar petition,
dated October 27, 2017. On March 22, 2018, NHTSA published a notice of
receipt of the BMW petition and requested additional information from
both petitioners.\29\ Both Volkswagen and BMW subsequently submitted
additional information to the docket. Prior to today, NHTSA has not
made a decision on either petition; as we explain later in the
preamble, NHTSA is denying the petitions in a separate notice published
today.
---------------------------------------------------------------------------
\28\ 82 FR 42720 (Docket No. NHTSA-2017-0018).
\29\ 83 FR 12650 (Docket No. NHTSA-2017-0018).
---------------------------------------------------------------------------
Shortly before the NPRM was published in October 2018, the National
Transportation Safety Board (NTSB) published a special investigation
report that examined pedestrian crashes and related phenomena.\30\ The
report covered, among other things, vehicle headlighting system
performance. The NTSB found that the FMVSS should not limit advanced
vehicle lighting systems that have been shown to have safety benefits.
It also found that vehicle headlighting systems require an evaluation
that is more advanced than laboratory bench-testing. The report went on
to recommend that NHTSA revise FMVSS No. 108 to allow adaptive
headlight systems. This final rule responds to these NTSB
recommendations.
---------------------------------------------------------------------------
\30\ National Transportation Safety Board. 2018. Pedestrian
Safety. Special Investigation Report NTSB/SIR-18/03. Washington, DC.
---------------------------------------------------------------------------
III. NHTSA's Statutory Authority
NHTSA is issuing this final rule under the Motor Vehicle Safety Act
(Safety Act), 49 U.S.C. Chapter 301, Motor Vehicle Safety (49 U.S.C.
30101 et seq.). Under the Safety Act, the Secretary of Transportation
is responsible for prescribing motor vehicle safety standards that are
practicable, meet the need for motor vehicle safety, and are stated in
objective terms.\31\ ``Motor vehicle safety'' is defined in the Safety
Act as ``the performance of a motor vehicle or motor vehicle equipment
in a way that protects the public against unreasonable risk of
accidents occurring because of the design, construction, or performance
of a motor vehicle, and against unreasonable risk of death or injury in
an accident, and includes nonoperational safety of a motor vehicle.''
\32\ ``Motor vehicle safety standard'' means a minimum performance
standard for motor vehicles or motor vehicle equipment.\33\ When
prescribing such standards, the Secretary must consider all relevant,
available motor vehicle safety information.\34\ The Secretary must also
consider whether a proposed standard is reasonable, practicable, and
appropriate for the types of motor vehicles or motor vehicle equipment
for which it is prescribed and the extent to which the standard will
further the statutory purpose of reducing traffic accidents and
associated deaths.\35\ The responsibility for promulgation of Federal
Motor Vehicle Safety Standards is delegated to NHTSA.\36\ The agency
carefully considered these statutory requirements in developing this
final rule. We evaluate this rule with respect to these requirements in
subsequent sections of this preamble.
---------------------------------------------------------------------------
\31\ 49 U.S.C. 30111(a).
\32\ 49 U.S.C. 30102(a)(9).
\33\ 30102(a)(10).
\34\ 30111(b)(1).
\35\ 30111(b)(3)-(4).
\36\ See 49 CFR 1.95.
---------------------------------------------------------------------------
IV. ADB Rulemaking Mandate in the Infrastructure, Investment and Jobs
Act
Congress has recently passed, and the President has signed, the
Infrastructure, Investment and Jobs Act (``IIJA'').\37\ Section 24212
of IIJA contains a mandate for a variety of headlamp rulemakings,
including an ADB rulemaking. Specifically, IIJA requires in paragraph
(b) of Sec. 24212 that ``[n]ot later than 2 years after the date of
enactment of this Act, the Secretary shall issue a final rule amending
Standard 108'' to, among other things, ``allow for the use on vehicles
of adaptive driving beam headlamp systems.'' Paragraph (a) of Sec.
24212 defines ``adaptive driving beam headlamp'' to mean a headlamp
``that meets the performance requirements specified in SAE
International Standard J3069, published on June 30, 2016.'' Paragraph
(c) of Sec. 24212 states that ``[n]othing in this section precludes
the
[[Page 9922]]
Secretary from--. . . (2) revising Standard 108 to reflect an updated
version of SAE International Standard J3069, as the Secretary
determines to be--(A) appropriate; and (B) in accordance with section
30111 of [the Safety Act].'' Today's final rule satisfies both that ADB
mandate and the core Safety Act requirement that FMVSSs, among other
things, ``meet the need for motor vehicle safety,'' \38\ which, as
explained throughout this notice, would not be met by a standard that
solely codified SAE J3069.
---------------------------------------------------------------------------
\37\ H.R. 3684 (117th Congress) (2021).
\38\ 49 U.S.C. 30111(a).
---------------------------------------------------------------------------
Paragraphs (a) and (b) of Sec. 24212, taken together, instruct
NHTSA to amend FMVSS No. 108 to allow ADB systems that at least meet
the requirements of SAE J3069. Paragraph (b) instructs NHTSA to
``amend[ ] Standard 108.'' Standard 108 is an FMVSS, and FMVSSs are
subject to the criteria in Sec. 30111 of the Safety Act, which
include, importantly, meeting the need for motor vehicle safety. The
directive to ``amend[ ] Standard 108'' in paragraph (b) would conflict
with the specification of SAE J3069 in paragraph (a) if SAE J3069 did
not meet the need for safety and NHTSA were limited to allowing any
systems that met that standard. We also do not believe Sec. 24212
means that Congress determined that SAE J3069 satisfies Sec. 30111, as
the codified text does not express this conclusion nor is there such a
finding elsewhere in the IIJA statute or legislative history.
Therefore, reading paragraphs (a) and (b) as requiring NHTSA to amend
FMVSS No. 108 so that ADB systems that meet SAE J3069 can also meet the
requirements of the revised Standard 108 harmonizes the directive in
paragraph (b) to ``amend[ ] Standard 108'' with the specification of
SAE J3069 in paragraph (a). It also harmonizes with the Safety Act, as
well as with the National Technology Transfer and Advancement Act,\39\
which, while generally requiring the use of consensus standards,
importantly reserves to an agency the ability to decline using a
consensus standard that it determines does not meet the agency's
governing statutes.
---------------------------------------------------------------------------
\39\ Public Law 104-113, 110 Stat. 775 (1996). See Section X,
Rulemaking Analyses and Notices.
---------------------------------------------------------------------------
As the Supreme Court has explained, statutes should be construed
harmoniously, so that ``when two statutes are capable of coexistence,''
they should be construed as each having effect.\40\ The interpretation
taken in this final rule achieves that goal. In contrast, an
interpretation that would require NHTSA to amend the standard to permit
any ADB system conforming to SAE J3069 would be an implicit repeal of
the Safety Act in this instance--and there is a strong presumption
against implied repeals.\41\ As the Supreme Court has repeatedly
pointed out, ``repeals by implication are not favored and will not be
presumed unless the intention of the legislature to repeal is clear and
manifest.'' \42\ Due to this ``relatively stringent standard,'' implied
repeals are ``rare,'' \43\ and have generally been limited to
situations ``where provisions in two statutes are in irreconcilable
conflict, or where the latter Act covers the whole subject of the
earlier one and is clearly intended as a substitute.\44\ But ``in
either case, the intention of the legislature to repeal must be clear
and manifest.'' \45\ Here, Congress has shown no such manifest
intention in Sec. 24212. In particular, as NHTSA had already published
an NPRM tentatively determining that SAE J3069 does not meet the need
for safety, the Agency expects that a Congressional override of this
tentative determination would have been far clearer, given NHTSA's
general authority and role in determining that adequate level of
safety. Moreover, neither of the two categories of repeal by
implication apply here because there is a way to harmonize Sec. 24212
and the Safety Act, and Sec. 24212 does not ``cover the whole subject
matter'' of the Safety Act and is not clearly intended as a substitute.
Therefore, we read paragraphs (a) and (b) to permit NHTSA to amend
FMVSS No. 108 to impose requirements more stringent than SAE J3069 as
long as those requirements are not inconsistent with SAE J3069.
---------------------------------------------------------------------------
\40\ J.E.M. AG Supply, Inc. v. Pioneer Hi-Bred Int'l, Inc., 534
U.S. 124, 143-144 (2001) (``[W]hen two statutes are capable of
coexistence, it is the duty of the courts, absent a clearly
expressed congressional intention to the contrary, to regard each as
effective.'') (quotations and citations omitted).
\41\ See Norman J. Singer & Shambie Singer, 2B Sutherland
Statutory Construction Sec. 51:2 (7th ed.) (``Courts assume that a
legislature always has in mind previous statutes relating to the
same subject when it enacts a new provision. In the absence of any
express repeal or amendment, the new provision is presumed to accord
with the legislative policy embodied in those prior statutes[.]'').
See also, e.g., U.S. v. City of New York, 359 F.3d 83, 98 (2nd. Cir.
2004) (``The courts are not at liberty to pick and choose among
congressional enactments, and when two statutes are capable of co-
existence, it is the duty of the courts, absent a clearly expressed
congressional intention to the contrary, to regard each as
effective.'') (citations and quotations omitted).
\42\ Nat'l Ass'n of Home Builders v. Defenders of Wildlife, 551
U.S. 644, 662 (2007) (quotations, alterations, and citations
omitted). See also, e.g., Branch v. Smith, 538 U.S. 254, 273 (2003)
(``We have repeatedly stated, however, that absent a clearly
expressed congressional intention, repeals by implication are not
favored[.]'') (citations and quotations omitted); Athey v. U.S., 123
Fed. Cl. 42, 52 (2015) (``[T]the law is clear that repeals by
implication are not favored absent clear congressional intent[.]'')
(quotations and citations omitted).
\43\ J.E.M. AG Supply, Inc., 534 U.S. at 142.
\44\ Branch, 538 U.S. at 273 (citations and quotations omitted).
See also, e.g., Carcieri v. Salazar, 555 U.S. 379, 395 (2009)
(same); Nat'l Ass'n of Home Builders, 551 U.S. at 662 (``We will not
infer a statutory repeal unless the later statute expressly
contradict[s] the original act or unless such a construction is
absolutely necessary . . . in order that [the] words [of the later
statute] shall have any meaning at all.'') (quotations and citations
omitted, alterations in original); J.E.M. AG Supply, Inc., 534 U.S.
at 142-43 (``The only permissible justification for a repeal by
implication is when the earlier and later statutes are
irreconcilable.'').
\45\ Radzanower v. Touche Ross & Co., 426 U.S. 148, 154 (1976).
See also N.Y. Republican State Comm. v. SEC, 927 F.3d 499, 507 (D.C.
Cir.2019) (quoting Radzanower).
---------------------------------------------------------------------------
Next, we do not believe the specific mention of Sec. 30111 in
paragraph (c), and the absence of such an explicit reference to Sec.
30111 in paragraphs (a) or (b), should be read to suggest that Congress
intended the Sec. 30111 criteria to apply only to subsequent revisions
of FMVSS No. 108 (i.e., amendments to FMVSS No. 108 after NHTSA
completes the ADB rulemaking mandated in paragraph (b)). The Agency
acknowledges that, when Congress includes particular language in one
section of a statute and omits it in another section of that statute,
one canon of statutory construction (sometimes referred to as expressio
unius est exclusio alterius) holds that Congress acts intentionally and
purposely in the disparate inclusion or exclusion.\46\ However, to
begin with, this canon is not clearly applicable here because paragraph
(b) directs the agency to ``amend[ ]'' ``Standard 108.'' Because an
FMVSS is required to meet the Sec. 30111 criteria, paragraph (b)
implicitly references Sec. 30111, including, among other things, the
requirement that the standard meet the need for safety.
---------------------------------------------------------------------------
\46\ See, e.g., Cheney Railroad. Co., Inc. v. ICC, 902 F.2d 66,
68 (D.C. Cir. 1990) (``[E]xplicit direction for something in one
provision, and its absence in a parallel provision, implies an
intent to negate it in the second context.'') (quotations and
citations omitted). But see, e.g., Carter v. Office of Workers'
Comp. Programs, 751 F.2d 1398 (D.C. Cir. 1985) (``That maxim has
force, however, only when there is no apparent reason for the
inclusion of one disposition and the omission of a parallel
disposition except the desire to achieve disparate results'').
---------------------------------------------------------------------------
Moreover, to construe the reference to Sec. 30111 in paragraph (c)
and the omission of such an explicit reference in paragraph (b) as
implying that the omission in (b) was intentional and evinced a
Congressional intent that the Safety Act not apply to the ADB
rulemaking would be to read paragraph (c) as implicitly repealing the
Safety Act in this instance. Courts have recognized that it is
especially inappropriate to apply the expressio canon when its
application would result in an implied repeal, explaining ``when one
possible
[[Page 9923]]
interpretation of a statutory provision has the potential to render
another provision inert . . . the canon's relevance and applicability
must be assessed within the context of the entire statutory
framework.'' \47\ Accordingly, ``the canon is a poor indicator of
Congress' intent'' when ``counterveiled by a broad grant of authority
contained within the same statutory scheme.'' \48\ A negative
inference, therefore, should only be drawn if there is an ``unambiguous
suggest[ion that] Congress intended to strip'' an agency of its
counterveiling ``broad grant of authority.'' \49\ As we have discussed
above, such an intent is not present here. Further, it would not make
sense to say that Sec. 30111 applies to revisions to the 2016 version
of SAE J3069 but not to the 2016 version itself. And it would be odd to
view paragraph (c) as a limitation on agency authority when it
expressly reserves agency authority. We therefore conclude that
paragraph (c) should not be read to preclude NHTSA from issuing a final
rule that imposes requirements beyond SAE J3069 if the agency concludes
that SAE J3069 does not meet the need for safety under the Safety Act.
---------------------------------------------------------------------------
\47\ Adirondack Med. Ctr. v. Sebelius, 740 F.3d 692, 697 (D.C.
Cir. 2014).
\48\ Id.
\49\ Id. at 697-698. See also id. at 697 (``The expressio unius
canon is a feeble helper in an administrative setting, where
Congress is presumed to have left to reasonable agency discretion
questions that it has not directly resolved . . . The dizzying array
of other canons that could shift the analysis one way or another--
e.g., . . . the presumption against implied repeals, militates
against finding unambiguous congressional intent here'') (quotations
and citations omitted). See also, e.g., Cheney Railroad. Co., Inc.
at 69-69 (same); U.S. v. City of New York, 359 F.3d 83, 98 (2nd.
Cir. 2004) (``[S]ince not every silence is pregnant, expressio unius
is an uncertain guide to interpretation.'') (quotations and
citations omitted).
---------------------------------------------------------------------------
In addition, we are unaware of any instances in which Congress
required NHTSA to issue or amend an FMVSS to enact or incorporate by
reference a consensus standard without reference to the Sec. 30111
criteria. The closest precedent of which we are aware is that the 1966
Safety Act directed NHTSA's predecessor agency to issue initial FMVSS
``based on existing safety standards.'' \50\ Those ``existing
standards'' ``were understood to be the [General Services
Administration] standards then in effect for government vehicles.''
\51\ However, the initial standards were not required to be identical
to those ``existing standards,'' only to be ``based on'' them;
consistent with this, the initial FMVSS did not simply copy existing
standards.\52\ Moreover, the 1966 Act went on to direct that, after
issuing the initial FMVSS, the agency ``shall issue new and revised
Federal motor vehicle safety standards under this title'' within two
years from the enactment of the Act.\53\ This shows, if anything, a
general Congressional preference for providing NHTSA with at least some
discretion over the content of the standards.
---------------------------------------------------------------------------
\50\ National Traffic and Motor Vehicle Safety Act of 1966,
Public Law 89-563, 103(h) (1966) (``The Secretary shall issue
initial Federal motor vehicle safety standards based upon existing
safety standards on or before January 31, 1967. On or before January
31, 1968, the Secretary shall issue new and revised Federal motor
vehicle safety standards under this title.'').
\51\ Jerry L. Mashaw & David L. Harfst, From Command And Control
To Collaboration And Deference: The Transformation Of Auto Safety
Regulation, 34 Yale J. on Reg. 167, 199 n. 106 (2017).
\52\ See, e.g., 32 FR 10812 (July 22, 1967) (NPRM for initial
FMVSS 109) (``In drafting these proposed standards, the Bureau
considered the comments received in response to the Advance Notice
of Proposed Rule Making published in the Federal Register on
February 3, 1967 (32 FR. 2417) and consultation with the National
Motor Vehicle Safety Advisory Council and with representatives of
the Federal Trade Commission, the General Services Administration,
the National Bureau of Standards, and tire and auto industry
associations, both domestic and foreign.'').
\53\ National Traffic and Motor Vehicle Safety Act of 1966,
Public Law 89-563, 103(h) (1966).
---------------------------------------------------------------------------
Today's final rule is therefore consistent with the Sec. 24212
mandate. The rule amends FMVSS No. 108 to allow for the use of ADB
systems. While NHTSA has modified the proposal to follow SAE J3069 more
closely where warranted, the final rule includes some requirements
(such as test scenarios) not included in SAE J3069. NHTSA has concluded
that these deviations from SAE J3069 are--pursuant to the Safety Act--
necessary for the final rule to meet the need for motor vehicle safety,
because SAE J3069 does not adequately address the safety needs of
visibility and glare prevention. The final rule, however, does not
conflict with ADB systems that meet the performance requirements of SAE
J3069 because a headlamp designed to comply with NHTSA's final rule can
also be designed to conform with SAE J3069. The differences between the
final rule and SAE J3069, as well as our test data on the performance
of ADB systems tested to both the final rule and J3069 are described in
detail throughout this preamble.
V. Summary of the NPRM
Proposed Requirements and Test Procedures
NHTSA tentatively concluded that because ADB technology has the
potential to provide safety benefits in preventing collisions with
pedestrians, animals, and roadside objects--while not increasing
glare--FMVSS No. 108 should be amended to permit it.
NHTSA further tentatively concluded that to ensure ADB systems
operate safely, the standard should be amended to include additional
requirements specific to ADB systems. The existing headlamp
requirements (including the requirements for semiautomatic beam
switching devices) have two features that make them ill-suited to
evaluate ADB performance. First, they are component-level requirements
that involve testing the performance of an individual headlamp in a
laboratory; they do not evaluate the performance of the headlamp system
on the vehicle as it is driven on the road, which is particularly
important for ADB because it adapts to roadway conditions. Second, the
preexisting semiautomatic beam switching device requirements are only
related to which of two beams (upper or lower) are appropriate. They do
not contemplate an adaptive beam that is capable of dynamically
producing many different beam patterns in response to vehicles and
other object in the road. For example, the sensitivity test for
semiautomatic beam switching devices currently tests the ability of the
device to switch between a lower and upper beam when exposed to a light
source in a controlled laboratory setting.
These requirements would accordingly not evaluate the performance
of an ADB system as it adapts the beam when driven on an actual road in
the presence of other vehicles. In particular, because ADB systems use
relatively new technology to dynamically change the beam to accommodate
the presence of other vehicles, they have the potential--if not
designed otherwise--to glare other motorists. This could create safety
risks for those other motorists. We therefore proposed amending the
standard to include vehicle-level track-tested requirements
specifically tailored to evaluate whether an ADB system functions
safely and limits glare for other motorists. We also proposed a set of
component-level laboratory-tested requirements to ensure that ADB
systems always provide adequate visibility; some of these requirements
were also related to glare. Below, we briefly summarize the proposed
requirements. For additional information and detail, the reader is
referred to the NPRM.\54\
---------------------------------------------------------------------------
\54\ See pp. 51777-51789.
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[[Page 9924]]
Vehicle-Level Track Test To Evaluate Glare
The centerpiece of the proposal was a vehicle-level track test to
evaluate ADB performance in recognizing and limiting glaring for other
vehicles. We proposed evaluating the performance of an ADB-equipped
vehicle (test vehicle) in a variety of different types of interactions
with either an oncoming or preceding vehicle (referred to as a
``stimulus'' vehicle because it stimulates a response from the ADB
system). The stimulus vehicle would be equipped with sensors near the
driver's eyes (or rearview mirrors) to measure the illuminance from the
ADB headlamps. The illuminance falling on the stimulus vehicle would be
measured and recorded throughout the test run.
To evaluate ADB performance, we proposed a set of maximum allowed
illuminance values (glare limits). These are numeric illuminance values
that would be the maximum illuminance the ADB system would be permitted
to cast on the stimulus vehicle during the track test. See Table 2. We
proposed sampling illuminance values throughout the proposed
measurement ranges (also referred to in this document as measurement
distances). The proposed compliance criterion was that any recorded
illuminance value greater than the applicable glare limit would be
considered a test failure, except that values above the applicable
glare limit lasting no longer than 0.1 second(s) or over a distance of
no longer than 1 m would not be considered test failures. This
adjustment was intended to allow for electric noise in the photometers
(i.e., any electrical signal whose source is not a result of changes in
illuminance) as well as momentary changes in vehicle pitch.
Table 2--Proposed Maximum Illuminance Criteria
------------------------------------------------------------------------
Maximum illuminance
Measurement distance oncoming direction Maximum illuminance
(m) (lux) same direction (lux)
------------------------------------------------------------------------
15.0 to 29.9 3.1 18.9
30.0 to 59.9 1.8 18.9
60.0 to 119.9 0.6 4.0
120.0 to 220 0.3 N/A
------------------------------------------------------------------------
The proposal specified a broad set of potential stimulus vehicles.
We proposed using any FMVSS-certified vehicle from the five model years
preceding the model year of the test vehicle, subject to a specified
height constraint that was intended to exclude unusually high- or low-
riding vehicles.
We proposed a variety of scenarios to dynamically assess ADB system
performance. We proposed three basic maneuvers for testing compliance:
oncoming (where the test and stimulus vehicles approach each other
traveling in opposite directions); same direction/same lane (where the
stimulus vehicle precedes the test vehicle in the same lane); and same
direction/passing with one vehicle (either the stimulus or test
vehicle) traveling faster than and overtaking the other vehicle. We
also proposed scenarios where the stimulus vehicle was stationary.
We proposed to test each type of maneuver at various test and
stimulus vehicle speeds (from 0 to 70 mph) on both a straight test path
and on left and right curves of varying radii: A ``short'' curve (with
radii from 98 m to 116 m), a ``medium'' curve (223 m to 241 m), and a
``large'' curve (335 m to 396 m). The proposal also included a variety
of related test procedures and conditions, such as adjusting for
ambient light, the condition of the road surface, and the number of
lanes. The proposed glare limits and test procedures were based on
extensive agency research and testing.\55\
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\55\ See Section VII, NHTSA Research and Testing.
---------------------------------------------------------------------------
Component-Level Laboratory Photometric Testing
The NPRM also proposed component-level laboratory-tested headlamp
photometry requirements for the adaptive beams. We proposed to require
that the part of the adaptive driving beam that is cast near other
vehicles (the area of reduced intensity) must conform to the Table XIX
lower beam photometry requirements (i.e., maxima and minima). We
similarly proposed that the part of the adaptive beam cast onto areas
of the roadway not occupied by other vehicles (area of unreduced
intensity) conform with the Table XVIII upper beam photometric maxima
and minima.\56\ These proposed requirements were intended to act as a
complement to the track test in ensuring other motorists were not
glared (the photometric maxima) and to ensure a minimum level of
visibility (the photometric minima), an aspect not evaluated in the
track test.
---------------------------------------------------------------------------
\56\ While the NPRM used the terms ``dimmed area'' and
``undimmed area,'' this document and the final regulatory text use
the terms ``area of reduced intensity'' and ``area of unreduced
intensity'' to more closely follow the terminology in SAE J3069.
---------------------------------------------------------------------------
Other System Requirements
The standard has long specified a variety of requirements
specifically for semiautomatic beam switching devices (in S9.4.1 and
S14.9.3.11). The proposal extended some but not all of these
requirements to ADB systems.
The proposal extended the existing requirements for manual
override, fail-safe operation (i.e., a failure of the automatic control
portion of the device must not result in loss of manual beam switching
control), and an automatic dimming indicator.\57\
---------------------------------------------------------------------------
\57\ S9.4.1.
---------------------------------------------------------------------------
The proposal did not extend the existing semiautomatic beam
switching device requirements for lens accessibility or mounting
height. It also did not extend any of the existing physical test
requirements to ADB systems.\58\ These include the sensitivity test
mentioned above, as well as tests such as a corrosion test and a
temperature test. We proposed not subjecting ADB systems to these
requirements for two reasons. First, as noted above, those requirements
date from the 1960s and, accordingly, many of them (such as the
sensitivity test) do not usefully extend to modern ADB technologies.
Second, we tentatively believed that market forces would ensure an ADB
system's switching device will operate robustly with respect to
environmental conditions.
---------------------------------------------------------------------------
\58\ S14.9.3.11.
---------------------------------------------------------------------------
We also proposed additional requirements for ADB systems that are
not currently required for semiautomatic beam switching devices. This
included requirements related to fault detection and a requirement that
the ADB system must produce a lower beam at speeds below 25 mph.
Regulatory Alternatives
The NPRM identified two main alternatives to the proposed
[[Page 9925]]
requirements and test procedures: the ECE ADB requirements and SAE
J3069. As noted earlier, however, the ECE requirements are not
sufficiently objective to be incorporated into an FMVSS. Accordingly,
the main regulatory alternative we considered was SAE J3069.
The proposal followed SAE J3069 in many respects but deviated from
it in several significant ways. These differences are briefly discussed
below and summarized in Table 3. The proposal identified the deviations
from SAE J3069 and provided a tentative justification for those
deviations. The proposal sought comment on the relative merits of the
proposal and SAE J3069 in all of these respects.
Vehicle-level track test to evaluate glare. Both the proposal and
SAE J3069 specified a vehicle-level track test to evaluate glare. The
proposed glare limits were essentially identical to the glare limits in
SAE J3069. The proposed track test, however, significantly differed
from the SAE standard in four main ways: it utilized actual stimulus
vehicles, not test fixtures; it proposed actual curves, not simulated
curves; it included a large set of test scenarios, including scenarios
with a moving stimulus vehicle, and complex vehicle maneuvers (e.g.,
passing scenarios); and, finally, it specified different data
measurement and allowance procedures.
Component-level laboratory photometric testing. The proposal
applied more of the current component-level photometric requirements to
the ADB system to regulate both glare and visibility. With respect to
glare, while we proposed to require that the area of reduced intensity
not exceed the current lower beam maxima, and the area of unreduced
intensity not exceed the current upper beam maxima, SAE J3069 requires
only the former. With respect to visibility, we proposed that the area
of reduced intensity meet the lower beam minima and the area of
unreduced intensity meet the upper beam minima; SAE J3069 only
specifies the lower beam minima for the area of unreduced intensity.
Other system requirements. The proposed telltale and malfunction
requirements were similar to the requirements in SAE J3069. The
proposal mainly differed from SAE J3069 in specifying a minimum
activation speed, and in not applying any physical test requirements to
ADB systems.
Table 3--Summary of Major Differences Between the NPRM and SAE J3069
----------------------------------------------------------------------------------------------------------------
Test elements NPRM SAE J3069
----------------------------------------------------------------------------------------------------------------
Vehicle-level track test to
evaluate glare:
Stimulus........................... Broad range of stimulus vehicles..... Test fixtures.
Test track geometry................ Specifies actual curves of various Specifies a straight path and uses
sizes. fixture placement to simulates
curves.
Test scenarios..................... Specified scenarios with moving and Specified smaller set of less
stationary stimulus vehicles and a complex scenarios.
variety of road geometries.
Data measurement and glare limit Applies the glare limits throughout Applies the glare limits only at 30
applicability. the measurement range specified for m, 60 m, 120 m, and 155 m.
each scenario. Sampling rate of at least 10 Hz.
Sampling rate of at least 200 Hz.....
Compliance criteria................ Specified allowance for momentary Allows measured illuminance to
glare exceedances. exceed an applicable glare limit if
it does not exceed 125% of the
lower beam illuminance under the
same conditions.
Component-level laboratory test:
Area of reduced intensity.......... Specified lower beam (Table XIX) Specifies lower beam maxima.
minima and maxima.
Area of unreduced intensity........ Specified upper beam (Table XVIII) Specifies lower beam minima.
minima and maxima.
Minimum activation speed........... 25 mph............................... Not specified.
----------------------------------------------------------------------------------------------------------------
VI. Overview of Comments
NHTSA received 217 comments on the proposal. This included comments
from 32 vehicle and equipment manufacturers, industry groups,\59\ and
test laboratories, as well as 5 comments from public interest groups.
We also received comments from 19 owner/operators of drive-in movie
theatres, including the United Drive-In Theatre Owners Association. The
balance of the comments was from individual members of the public. An
index of comments cited in this preamble along with the comment
identification numbers is provided in Appendix D.
---------------------------------------------------------------------------
\59\ Global Automakers and the Alliance of Automobile
Manufacturers each commented during the comment period. After the
comment period had ended, they merged to form the Alliance for
Automotive Innovation. The Alliance for Automotive Innovation
subsequently commented on this rulemaking. Comments from each of
these three entities are summarized and identified by reference to
the entity that submitted the comment.
---------------------------------------------------------------------------
All industry and public-interest commenters supported amending the
standard to allow the introduction of ADB systems. A majority of the
industry commenters and the Competitive Enterprise Institute (CEI)
strongly supported closer harmonization with SAE J3069 (or with the ECE
requirements).\60\ These comments focused primarily on costs from
disharmonization due to the resulting need for market-specific
hardware, components, and/or software. Several commenters argued that
the increased costs associated with the proposal would increase
consumer costs and hinder ADB adoption and the concomitant safety
benefits. Several industry commenters and the Insurance Institute for
Highway Safety (IIHS) stated that the proposal did not maximize overall
benefits because it prioritized glare prevention over enhanced
visibility, and opined that the final rule should place greater weight
on the benefits associated with enhanced visibility.
---------------------------------------------------------------------------
\60\ SAE, on behalf of the SAE lighting systems group (which
developed SAE J3069) submitted a detailed comment that touched on
harmonization as well as a variety of other issues. A majority of
industry commenters explicitly supported SAE's comments.
---------------------------------------------------------------------------
Drive-in theatre owner/operators stressed the importance of the ADB
system providing a means for manual headlamp control. Many indicated
some level of support for the rule (assuming
[[Page 9926]]
it provides for manual control). The majority of comments from
individual members of the public supported the proposal, often on the
grounds that it would likely reduce glare or increase safety. A number
of these commenters noted the availability of this technology in
Europe. Several individuals who opposed the proposal thought that it
would increase glare.
With respect to specific aspects of the proposal, while most
industry and public-interest groups supported a track test, many of
these commenters argued that the specific track test in the proposal
was impracticable and excessively burdensome, especially with respect
to the number and complexity of test scenarios and the use of stimulus
vehicles instead of fixtures. These commenters especially focused on
the broad set of proposed stimulus vehicles. Some industry commenters
also raised concerns with the objectivity and repeatability of the test
procedure. Many industry commenters also opposed the use of a curved
test path; they recommended that curved test paths be simulated with
the placement of test fixtures relative to a straight test path. Many
of these commenters also stated that the final rule should provide less
stringent compliance criteria and provide a greater allowance for
illuminance levels above the proposed glare limits (for example, by
evaluating the ratio of ADB illuminance to lower beam illuminance or
allowing additional time for an ADB system to react to the test
stimulus). Industry commenters also raised issues about other aspects
of the test procedures, such as data filtering and vehicle pitch.
The agency also received comments about the proposed component-
level laboratory test requirements. A few industry commenters
(including SAE) contended that component-level testing is unnecessary,
while some industry members and public-interest groups supported
aspects of the laboratory test requirements. Many industry commenters
pointed out the need for a transition zone between areas of reduced and
unreduced intensity. Multiple industry commenters and some public-
interest commenters recommended not requiring the lower beam minima in
areas of reduced intensity in order to realize the full glare-reducing
potential of ADB technology. Several industry commenters also suggested
specifying the lower beam minima, not the upper beam minima, in areas
of unreduced intensity. Some industry and public-interest commenters
supported increasing the maxima in an area of unreduced intensity to
the higher level allowed in Europe. Several industry commenters
requested NHTSA clarify certain terms in the regulatory text.
We also received comments about other system requirements,
including the minimum ADB activation speed, operator controls,
telltales, and headlamp mounting requirements.
VII. NHTSA Research and Testing
Research Before the NPRM
Two NHTSA research studies formed the basis for the NPRM. (This
research was necessary because, among other things, the current
photometry requirements are laboratory-tested component-level
requirements, not vehicle-level requirements tested on a track.) In
2012, the agency published a study (Feasibility Study) \61\ exploring
the feasibility of new approaches to regulating vehicle lighting
performance, including headlamp photometry. Among other things, the
study presented vehicle-based headlamp photometry requirements derived
from the current component-level photometry requirements in Tables
XVIII (upper beam) and XIX (lower beam). This included vehicle-based
photometry requirements to ensure that other vehicles are not glared.
NHTSA then built on this effort by developing a vehicle-level track
test to evaluate whether an ADB system conforms with the derived
photometry requirements for glare prevention (2015 ADB Test
Report).\62\ For more information on this research, the reader is
referred to the NPRM \63\ and the docketed research reports.
---------------------------------------------------------------------------
\61\ Michael J. Flannagan & John M. Sullivan. 2011. Feasibility
of New Approaches for the Regulation of Motor Vehicle Lighting
Performance. Washington, DC: National Highway Traffic Safety
Administration (NHTSA-2018-0090-0002). See also 77 FR 40843 (July
11, 2012) (request for comments on the report).
\62\ Elizabeth Mazzae, G.H. Scott Baldwin, Adam Andrella, &
Larry A. Smith. 2015. Adaptive Driving Beam Headlighting System
Glare Assessment, DOT HS 812 174. Washington, DC: National Highway
Traffic Safety Administration (NHTSA-2018-0090-0003).
\63\ See NPRM, pp. 51773-51774.
---------------------------------------------------------------------------
Research After the NPRM
After reviewing the comments on the NPRM, NHTSA explored
opportunities to modify the proposal to resemble SAE J3069 more
closely, while at the same time retaining a sufficient degree of
realism the agency believes the SAE standard lacks. Most significantly,
NHTSA explored using stationary test fixtures instead of dynamic
stimulus vehicles. NHTSA developed and fabricated test fixtures that
were similar to the fixtures specified in SAE J3069 but differed in
some important respects (this is discussed below). NHTSA developed a
modified version of the NPRM test procedure (including a simplified set
of test scenarios) using the test fixtures. NHTSA then carried out a
series of preliminary and full-scale vehicle tests to develop and
validate those test procedures. Those test procedures are the same test
procedures specified in this final rule. The research also documented
testing details to support the laboratory test procedure manual that
will be used by NHTSA's Office of Vehicle Safety Compliance (OVSC).\64\
---------------------------------------------------------------------------
\64\ The OVSC laboratory procedures are not part the regulatory
text. Published separately by OVSC, they are intended to provide
laboratories contracted by NHTSA with additional guidelines for
obtaining compliance test data.
---------------------------------------------------------------------------
NHTSA used the following three vehicles in the test program.
2019 Ford Fusion equipped with FMVSS-certified halogen
headlamps;
[cir] Selected because it was a high-sales vehicle with halogen
headlamps compliant with FMVSS No. 108, and the vehicle was readily
available at NHTSA's Vehicle Research and Testing Center (VRTC).
2016 Volvo XC90 equipped with FMVSS-certified LED
headlamps;
[cir] Selected because it was equipped with LED headlamps rated
``Acceptable'' by IIHS, and the vehicle was readily available at
NHTSA's VRTC.
2018 Lexus NX300 (European mass production model) equipped
with ADB LED headlamps modified by the manufacturer to be consistent
with a visually optically aligned right (VOR) beam pattern used in the
United States.
[cir] Selected because it was equipped with an ADB system, modified
to project lower and upper beam patterns compliant with FMVSS No. 108.
Preliminary Test Development and Validation
NHTSA created a test fixture to accommodate both the NHTSA and SAE
test procedures. The test fixture positioned a vertical array of
illuminance meter light sensors (i.e., receptor heads) in specified
positions and provided accurate positioning for the various NHTSA and
SAE lamp configurations. The configurations included stimulus lamps
specified in today's final rule: MY 2018 Ford F-150 headlamps and
taillamps, MY 2018 Toyota Camry headlamps and taillamps, and a MY 2018
Harley Davidson motorcycle taillamp,\65\ and the lamps
[[Page 9927]]
specified in SAE J3069 intended to simulate headlamps and taillamps.
This single test fixture was able to accommodate needed light sensor
configurations for both oncoming and same direction test scenarios.
---------------------------------------------------------------------------
\65\ To represent a motorcycle headlamp, this testing used a
5.75 inch bullet headlamp kit from a 2018 Harley Davidson Roadster
using an HB2 replaceable light source (part #68593-06). After this
testing and before the publication of this final rule, that part
went out of production and has been replaced with part #68297-05B.
---------------------------------------------------------------------------
As an important initial step as part of the research, NHTSA
evaluated the stability of the measured illuminance values without a
test vehicle present to determine the level of noise (if any) in the
measurement system that was not dependent on the vehicle being tested.
For each stimulus lamp condition, illuminance data were recorded for a
period of 30 seconds in typical test conditions. The results indicated
that both the analog and digital data, measured at frequency over time,
demonstrated low standard deviations for each of the receptor heads for
each of the ten test lamp conditions, suggesting very little system
noise or fluctuation from ambient conditions. In fact, each lamp
condition had at least two receptor heads that exhibited no variability
(standard deviation = 0) in the digital data. Thus, the illuminance
meter outputs appeared to be stable.
Testing of the three vehicle models with headlighting systems
operating in lower beam mode showed that the measurement system and the
headlamp types tested, halogen and LED, were compatible with the test
equipment (i.e., no abnormalities in measurements were observed based
upon the type of headlighting system).
NHTSA performed tests to assess whether test scenarios could be
executed with sufficiently steady vehicle dynamics such that, in lower
beam mode, headlamp illumination measured during the dynamic test
scenario would match that measured in the same location with the
vehicle stationary. Measured illuminance and pitch data values were
extracted for both dynamic and static test trials at specific scenario
path points corresponding to an end of a glare limit distance range.
This study found that dynamically-influenced variation was not a major
contributor to variability in the test. Pitch was found to have a major
influence on illuminance measurements; however, the sources of pitch
variance were primarily static in nature (resulting from waviness in
the track pavement) and not dynamic (acceleration, or dynamic
oscillations).
Full-Scale Validation Testing
After successfully completing this preliminary evaluative testing,
NHTSA proceeded to validate the final test procedure by performing
three sets of full-scale tests.
In the first set of tests, the ADB-equipped Lexus NX300 was
subjected (in ADB mode) to the final rule test procedure as well as the
SAE test procedure. We also evaluated ADB system performance using a
full F-150 vehicle as a stimulus instead of a test fixture. In general,
the ADB system installed on the tested vehicle responded similarly to
the test fixture as it did to the full stimulus vehicle.
In the second set of tests, the agency subjected all three test
vehicles with headlighting systems operating in lower beam mode to the
NHTSA ADB test procedure. Measured illuminance values were evaluated
with respect to the glare limit criteria. The lower beams of the Ford
Fusion had passing results below the glare limits in all test
scenarios, while the lower beams of the Lexus NX300 did not pass
several of the test scenarios when illuminance values were compared to
the glare limits. The Volvo lower beams performed well under the limits
for the straight and left curve scenarios, but exceeded the limits
finalized today for the right curves.
In the third set of validation tests, the agency conducted a series
of tests using the 2016 Volvo XC90 with the lower beams activated to
determine the repeatability of measured illuminance values and test
outcomes for both the final rule and SAE test procedures. Testing
involving multiple runs of each test scenario was conducted to permit
different types of repeatability analyses, including same night
(gauge); different night (test procedure); and different headlamp
aiming technician (reproducibility). The repeated testing was performed
to support an assessment of the repeatability of measured illuminance
values and test outcomes for the final rule's ADB test procedure (as
well as the SAE test procedure). A summary of the agency's
repeatability analysis is presented in Section VIII.C.11. The full
results of NHTSA's test procedure repeatability and reproducibility
analyses are detailed in the repeatability report docketed with this
final rule.\66\ The test procedures reported in that document are the
same as the procedures used in the first and second sets of validation
tests described above. NHTSA is also docketing a full test report more
fully describing the agency's testing.\67\
---------------------------------------------------------------------------
\66\ Mazzae, E.N., Baldwin, G.H.S., Satterfield, K., & Browning,
D.A. 2021. Adaptive Driving Beam Headlamps Test Repeatability
Assessment. Washington, DC: National Highway Traffic Safety
Administration.
\67\ Mazzae, E.N., Baldwin, G.H.S., Satterfield, K., Browning,
D.A., & Andrella, A.T. 2021. Adaptive Driving Beam Headlighting
Systems Rulemaking Support Testing. Washington, DC: National Highway
Traffic Safety Administration.
---------------------------------------------------------------------------
VIII. Final Rule and Response to Comments
A. Summary of the Final Rule and Modifications to the NPRM
The major components of the final rule are summarized below,
including the most significant differences between the final rule and
the NPRM. Less significant changes are discussed in the appropriate
sections of the preamble.
Vehicle-Level Track Test To Evaluate Glare
The final rule retains the track test but departs from the proposal
in a few ways.
Stimulus test fixtures instead of stimulus vehicles. The final rule
specifies the use of test fixtures instead of stimulus vehicles. This
change will result in a less complex test more closely harmonized with
SAE J3069, while still ensuring that ADB systems operate safely. While
the test fixture specifications follow the SAE J3069 specifications
with respect to the locations of the photometers and stimulus lamps,
the final rule requires the use of more real-world representative
lighting by specifying original equipment vehicle headlamps and
taillamps.
More efficient test scenarios. The final rule substantially
simplifies the number and complexity of test scenarios. Because the
final rule specifies stimulus test fixtures and not stimulus vehicles,
all scenarios involving a moving stimulus vehicle (e.g., passing
scenarios) were eliminated. While the final rule retains oncoming and
preceding scenarios \68\ with a curved test path, the agency modified
the measurement distances and eliminated some scenarios entirely
because they were deemed unnecessary. With respect to oncoming
scenarios, the straight and large left curve scenarios are retained
essentially as proposed, and the short-radius right curve scenario has
been eliminated. The final rule retains scenarios with other proposed
curves but truncates the distances at which ADB illuminance is
evaluated. With respect to preceding glare scenarios, the final rule
retains (with truncated measurement distances) the straight and medium
left curve scenarios. These modifications, summarized in Table 4,
respond to comments that expressed concern about the complexity of the
proposed testing. NHTSA believes that
[[Page 9928]]
the finalized test scenarios meet the need for motor vehicle safety by
containing a broad range of realistic road geometries--including
curves--and vehicle interactions while addressing possible
redundancies.
---------------------------------------------------------------------------
\68\ The final rule regulatory text uses the terms ``same
direction'' and ``opposite direction'' to reflect that the final
rule uses fixtures and not stimulus vehicles.
Table 4--Summary of Modifications to the Proposed Track Test Scenarios
--------------------------------------------------------------------------------------------------------------------------------------------------------
NPRM Final rule
--------------------------------------------------------------------------------------------------------------------------------------------------------
Stimulus Test Test
Measurement vehicle vehicle Radius (size- Final Measurement vehicle Radius (size-
NPRM test # distance (m) speed speed direction) \69\ test # distance (m) speed direction) \70\
(mph) (mph) (mph)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Oncoming (adjacent lane):
--------------------------------------------------------------------------------------------------------------------------------------------------------
1........................... 15-220 60-70 60-70 Straight............ ......... Dropped
------------------------------------------------
2........................... 15-220 0 60-70 Straight............ 1 15-220 60-70 Straight
------------------------------------------------
5a.......................... 15-220 25-30 25-30 Small--R............ ......... Dropped
5b.......................... 15-220 25-30 25-30 Small--L .........
6a.......................... 15-220 0 25-30 Small--R .........
------------------------------------------------
6b.......................... 15-220 0 25-30 Small--L............ 2 15-59.9 25-30 Small--L
------------------------------------------------
7a.......................... 15-220 40-45 40-45 Med--R ......... Dropped
7b.......................... 15-220 40-45 40-45 Med--L .........
------------------------------------------------
8a.......................... 15-220 0 40-45 Med--R.............. 5 15-50 40-45 Med--R
------------------------------------------------
8b.......................... 15-220 0 40-45 Med--L.............. 3 15-150 40-45 Med--L
------------------------------------------------
11a......................... 15-220 50-55 50-55 Large--R ......... Dropped
11b......................... 15-220 50-55 50-55 Large--L .........
------------------------------------------------
N/A......................... N/A N/A N/A N/A................. 6 15-70 50-55 Large--R
------------------------------------------------
N/A......................... N/A N/A N/A N/A................. 4 15-220 50-55 Large--L
--------------------------------------------------------------------------------------------------------------------------------------------------------
Same Direction Same Lane:
--------------------------------------------------------------------------------------------------------------------------------------------------------
1........................... 15-220 60-70 60-70 Straight ......... Dropped
5a.......................... 15-220 25-30 25-30 Small--L .........
5b.......................... 15-220 25-30 25-30 Small--R .........
7a.......................... 15-220 40-45 40-45 Med--L .........
7b.......................... 15-220 40-45 40-45 Med--R .........
11a......................... 15-220 50-55 50-55 Large--L .........
11b......................... 15-220 50-55 50-55 Large--R .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Same Direction Adjacent Lane
Fast ADB:
--------------------------------------------------------------------------------------------------------------------------------------------------------
2........................... 15-119.9 0 60-70 Straight............ 7 15-100 60-70 Straight
------------------------------------------------
3........................... 15-119.9 40-45 60-70 Straight............ ......... Dropped
6a.......................... 15-119.9 0 25-30 Small--R .........
6b.......................... 15-119.9 0 25-30 Small--L .........
8a.......................... 15-119.9 0 40-45 Med--R .........
------------------------------------------------
8b.......................... 15-119.9 0 40-45 Med--L.............. 8 15-100 40-45 Med--L
------------------------------------------------
9a.......................... 15-119.9 30-35 40-45 Med--R.............. ......... Dropped
9b.......................... 15-119.9 30-35 40-45 Med--L .........
13a......................... 15-119.9 40-45 50-55 Large--R .........
13b......................... 15-119.9 40-45 50-55 Large--L .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Same Direction Fast Stimulus:
--------------------------------------------------------------------------------------------------------------------------------------------------------
4........................... 30-119.9 60-70 40-45 Straight............ ......... Dropped
--------------------------------------------------------------------------------------------------------------------------------------------------------
Data measurement and allowances. The final rule makes some changes
to how NHTSA will measure and evaluate ADB system illuminance. NHTSA
has added a specification for a data filter. It has deleted the
proposed International Roughness Index parameter and replaced it with
an explicit adjustment for vehicle pitch. The proposed 0.1 second (or 1
m) allowance for momentary glare exceedances has been modified by
deleting the distance component and more clearly specifying how this
adjustment will be applied. The final rule also includes additional
specifications for the photometer.
---------------------------------------------------------------------------
\69\ Small = 98 m-116 m; Med = 223 m-241 m; Large = 335 m-396 m.
\70\ Small = 85 m-115 m; Med = 210 m-250 m; Large = 335 m-400 m.
---------------------------------------------------------------------------
Component-Level Laboratory Photometric Testing
The final rule retains the proposed requirements for component-
level laboratory testing but has modified them to give manufacturers
greater design flexibility.
Defining ``adaptive driving beam'' as a new beam type. The final
rule defines a new beam type, an ``adaptive driving beam,'' as ``a beam
consisting of area(s) of reduced intensity, unreduced intensity, and
transition zone(s).'' We eliminated the proposed regulatory text that
referred to an area of reduced intensity as being ``designed to be
directed towards oncoming or preceding vehicles'' and to an area of
unreduced
[[Page 9929]]
intensity as being directed ``in other directions.'' The final rule is
intended to provide manufacturers flexibility to decide which portions
of the roadway will receive an area of reduced or unreduced intensity,
subject to several requirements or constraints (such as the track test
that evaluates glare). This will enable systems to provide an area of
reduced intensity not only to prevent glare to oncoming or preceding
vehicles, but also in other situations in which reduced intensity would
be beneficial (for example, towards retroreflective signs, or on a wet
roadway).
Transition zone. In response to comments, the final rule also
allows for a 1-degree transition zone between an area of reduced
intensity and an area of unreduced intensity.
Requirements for areas of reduced intensity. The final rule retains
the requirement that an area of reduced intensity not exceed the lower
beam maxima in order to help ensure that other motorists are not
subject to glare. It also continues to require that an area of reduced
intensity meet the lower beam minima; NHTSA believes this requirement
is important because neither the proposal nor the final rule include
any ``false positive'' tests to ensure that an ADB system does not
mistakenly dim the beam in the absence of any oncoming or preceding
vehicles.
Requirements for areas of unreduced intensity. The final rule
follows the NPRM and specifies the existing upper beam minima and
maxima. In response to comments that suggested not specifying the upper
beam minima in this area (in order to allow less illumination in
situations in which it would be appropriate, such as towards a
retroreflective sign), we have, as explained above, eliminated the
proposed regulatory text that implied that an area of unreduced
intensity should be directed towards areas of the roadway not occupied
by other vehicles. This will allow manufacturers to design systems that
provide an area of reduced intensity to areas of the road that are not
occupied by other vehicles but for which it may be appropriate to
provide less illumination than would be required by the upper beam
minima.
As was proposed, the final rule does not adopt the higher ECE upper
beam maxima. While NHTSA agrees with the commenters that higher
intensity upper beams might lead to potential safety benefits in the
form of increased visibility in the absence of other road users, the
agency remains concerned about the associated potential safety
disbenefits, due to increased glare, that might result from higher
intensity upper beams, particularly in situations in which an ADB
system might not recognize and shade other vehicles.
Other System Requirements
ADB minimum activation speed. The final rule retains a minimum
activation speed but this has been decreased from 25 mph to 20 mph to
give greater flexibility to manufacturers wishing to provide for
hysteresis in the system design.
Exemption from some horizontal aimability performance requirements.
The final rule amends the headlamp horizontal aimability performance
requirements to exempt ADB systems from many of the vehicle headlamp
aiming device (VHAD) requirements. These requirements are not necessary
for ADB systems and exempting ADB systems will lower costs and
facilitate ADB deployment in the United States.
B. Interpretation of FMVSS No. 108 as Applied to ADB Systems
Prior to the publication of the NPRM, NHTSA had not directly
addressed whether FMVSS No. 108 permits ADB systems. In the NPRM, we
tentatively concluded that ADB systems are not currently permitted
under the standard because they are part of the required headlamp
system, and, as such, would not comply with at least some of the
headlamp requirements.\71\ We included this tentative interpretation in
the NPRM because some manufacturers had argued that ADB systems should
be considered supplemental lighting.\72\
---------------------------------------------------------------------------
\71\ For a more detailed discussion, see NPRM, 83 FR 51774-
51777.
\72\ FMVSS No. 108 specifies, for each class of vehicle,
required and optional (if-equipped) lighting elements. The standard
sets out various performance requirements for the required and
optional lighting elements. The standard also allows vehicles to be
equipped with lighting not otherwise regulated as required or
optional equipment. This type of lighting equipment is referred to
as ``supplemental'' or auxiliary lighting. Supplemental lighting is
permitted if it does not impair the effectiveness of lighting
equipment required by the standard. S6.2.1.
---------------------------------------------------------------------------
In the NPRM we went on to also consider the status of ADB
technology if we were, instead, to consider it supplemental equipment.
We concluded that this still might not obviate the need for this
rulemaking because it would be difficult for NHTSA to verify that the
system did not impair the effectiveness of any of the required
lighting. That is, whether an ADB system is functioning properly
depends on whether it accurately detects oncoming and preceding
vehicles in actual operation on the road, and there would be no way to
test this under FMVSS No. 108 as the standard had existed prior to this
final rule.
Comments
Several commenters (General Motors, LLC [GM], American Honda Motor
Co., Inc. [Honda], Global Automakers [Global], Ford Motor Company
[Ford], and the Alliance of Automobile Manufacturers [Alliance])
disagreed with NHTSA's proposed interpretation, and contended that ADB
systems should be considered supplemental lighting.
Agency Response
The interpretation set out in the NPRM (which concerned the version
of the standard in effect prior to this final rule) is now moot because
the final rule amends the standard to expressly allow and regulate ADB
systems. For the same reason, ADB systems can no longer be considered
(as suggested by the commenters) ``supplemental'' lighting because the
rule amends the standard to expressly allow ADB systems, while at the
same time subjecting them to a variety of requirements expressly
intended for and unique to these systems.\73\
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\73\ The interpretation set out in the NPRM assumed that the
adaptive beam would always be a ``lower beam'' under the version of
the standard predating this final rule because a ``lower beam'' is
defined in the standard as ``a beam intended to illuminate the road
and its environs . . . when meeting or closely following another
vehicle.'' This assumed that in the absence of other vehicles ADB
systems would provide a full upper beam, and not an adaptive beam.
However, some of the commenters pointed out that an adaptive beam
(i.e., less than a full upper beam) might also be provided in the
absence of other vehicles (for example, in order to minimize glare
to the driver from retroreflective signs). As we explain later in
this preamble, the final rule allows for this type of beam design.
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C. Track Testing Requirements and Procedures
1. Practicability of Proposed Test Scenarios
The NPRM proposed a wide range of track test scenarios, including a
large set of potential stimulus vehicles, varying road geometries
(curves, straight paths), and varying vehicle speeds.\74\ NHTSA
tentatively concluded that the proposed ranges of stimulus vehicles and
test scenarios were appropriate to ensure that an ADB system functions
robustly
[[Page 9930]]
and avoids glaring other drivers in a wide variety of real-world
circumstances. The agency explained its concerns about a test procedure
permitting an ADB system designed to accommodate only a narrow range of
vehicles and explained that the proposed scenarios would require ADB
systems to be able to negotiate a variety of real-world conditions.
NHTSA tentatively concluded that the proposed testing was practicable
but acknowledged that certain scenarios might be challenging for some
ADB systems. The agency also explained its decision not to propose some
common scenarios. For example, we explained that the proposal did not
include testing ADB performance when approaching a vehicle at an
intersection oriented perpendicular to the ADB vehicle's direction of
travel because existing ADB systems would have a difficult time meeting
the performance criteria in such scenarios and the magnitude and effect
of glare in this situation would be relatively minimal (because the
vehicle illuminated by the ADB system would be stopped or preparing for
a stop).
---------------------------------------------------------------------------
\74\ The test matrix specifies ranges for the various test
parameters. Other provisions in the final regulatory text also
specify ranges of values at which various testing parameters may be
set. The larger the range of values, the broader the parameters for
which the vehicle much perform. Where a range of values is
specified, the vehicle must be able to meet the requirements at all
values within the range. In addition, the word ``any,'' used in
connection with a range of values or set of items in the
requirements, conditions, and procedures of an FMVSS means generally
the totality of the items or values, any one of which may be
selected by the agency for testing. See 49 CFR 571.4, Explanation of
Usage.
---------------------------------------------------------------------------
Comments
The agency received a number of comments on the practicability of
the proposed test scenarios. Many of the commenters, including many
vehicle and equipment manufacturers and trade associations, agreed with
the need for track testing, but most stated that the proposed testing
was unnecessarily broad and impracticable. Intertek supported a more
rigorous dynamic roadway test than specified in SAE J3069, but stated
that the full set of proposed scenarios may not be necessary and
estimated testing costs to be two-to-four times higher than testing to
SAE J3069. Consumer Reports and IIHS also supported a vehicle-level
track test but stated that the proposed track test was too broad. Many
industry members (Honda, Global, GM, SAE, Competitive Enterprise
Institute (CEI), Toyota, Alliance, Mobileye, OSRAM Sylvania Inc.
(OSRAM), the Motor & Equipment Manufacturers Association (MEMA),
Infineon Technologies Americas Corp. (Infineon), Valeo Lighting Systems
(Valeo), and NAFA Fleet Management Association (NAFA)) supported the
use of SAE J3069, which includes a more limited track test, and/or
specifically supported a more limited track test than proposed.
Commenters made a variety of arguments for why they believed the
proposed track test was not practicable.
A number of commenters \75\ stated that the proposed track test was
not practicable because of the number and complexity of the proposed
scenarios. For example, SAE stated that testing over 34 different
maneuvers on various road geometries with multiple variations is
excessive and not practicable. IIHS similarly commented that the number
of scenarios could be reduced to a more manageable set without
sacrificing the tests' ability to identify systems unable to adequately
mitigate glare. IIHS estimated that testing every scenario with all
four types of stimulus vehicle would require 272 tests, and that
testing at different speeds would require even more tests. Toyota
estimated that the proposal resulted in 10,000 possible test scenarios.
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\75\ These were MEMA, IIHS, Toyota, Alliance, SAE, Auto
Innovators, Honda, Global, Valeo, Volkswagen, the International
Organization of Motor Vehicle Manufacturers (OICA), GM, Ford, and
the Transportation Safety Equipment Institute (TSEI).
---------------------------------------------------------------------------
Several commenters claimed that the proposal would necessitate
testing capabilities beyond those available at existing test
facilities. The Alliance for Automotive Innovation (Auto Innovators)
conducted a series of tests based on the proposed scenarios and
commented that it found that the proposed scenarios were unnecessary
and beyond the capabilities of many proving grounds. Volkswagen, the
Alliance, Valeo, and Auto Innovators commented that the proposed test
scenarios necessitated test tracks with characteristics (e.g.,
specified radii of curvature, road surface conditions, test track
length necessary for attaining specified speeds) that were not within
the capabilities of existing proving grounds. SAE, Auto Innovators,
OICA and the Society of Motor Manufacturers and Traders (SMMT)
contended that the proposed track test would necessitate data
measurement capabilities beyond those which are currently available at
test facilities, with Auto Innovators arguing that the proposal would
require up to 476 data elements. Auto Innovators also commented that
the amount of time needed for data collection and processing was longer
than expected, and it recommended that NHTSA develop software or other
compliance tools to expedite data processing. To address these issues,
Auto Innovators recommended (among other things) adopting fixed
lighting stimuli, limiting the number of eligible stimulus vehicles,
and limiting the number and complexity of test scenarios.
A few commenters suggested eliminating redundant scenarios and/or
testing only the most stringent scenarios. Auto Innovators suggested
that by adopting the most stringent test scenarios at the extremes of
the testing range, the intermediate tests could be eliminated. For
example, Auto Innovators suggested only specifying straight and small-
radius curve scenarios because the small-radius curve was the most
stringent test with 46 failures out of 127 valid test runs (36.2%
failure rate), while the failure rates for the straight, mid, and large
radius test scenarios were 26.6%, 26.7%, and 22.4%, respectively. IIHS
stated that while the volume of proposed test scenarios might be
justified if each scenario presented substantially different conditions
for the ADB system, that is not the case with the proposal; an
algorithm based on a camera sensor has limited ability to compute
distance and vehicle type solely using another vehicle's headlamps or
taillamps. For example, from the camera's perspective, a larger vehicle
farther away will look the same as a smaller vehicle at a closer
distance. As a result, ADB algorithms will be designed to the boundary
cases of the range of scenarios NHTSA finalizes, which should allow the
intermediate scenarios to be eliminated.
The Truck and Engine Manufacturers Association (EMA) commented that
the NPRM did not consider the significant barriers and expense of the
proposal on the heavy-duty market. EMA stated that the heavy-duty
market presents unique challenges for ADB development because of the
wide variation of potential vehicle configurations due to extensive
customization and low volume.\76\ EMA commented that these varied
configurations determine the height and angle of the vehicle, and in
the case of incomplete vehicles the angle of the chassis may change
upon completion of the vehicle by a body-builder. EMA also commented
that performing track-level testing on hundreds of vehicle
configurations would be cost-prohibitive, and track-testing facilities
are not readily accessible to manufacturers. EMA also commented that
the NPRM did not include any data specific to heavy-duty vehicles and
stated that such testing would be necessary before finalizing the rule.
EMA stated it was unable to fully evaluate the proposal due to the
immaturity of ADB technology for the heavy-duty market.
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\76\ EMA also commented about the impact of the driver's eye
point and sensor positions in heavy-duty vehicles, but NHTSA was
unsure of the meaning of this comment.
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[[Page 9931]]
Global commented that NHTSA should justify the fact that the
proposal was more stringent than the current semiautomatic beam
switching device requirements (which are limited to a test of the
``camera'' device and do not test the overall system).
Agency Response
NHTSA agrees that the proposal included redundant scenarios and
that the final rule can more closely follow SAE J3069 without
sacrificing the robustness of the test. The final rule specifies
stationary test fixtures outfitted with vehicle lamps instead of
dynamic stimulus vehicles. The test fixture specifications are similar
to those specified in SAE J3069, but differ by specifying original
equipment vehicle lamps. Accordingly, the final rule eliminates all
scenarios involving a moving stimulus vehicle.
NHTSA also modified the specified road geometries. The final rule
retains scenarios with actual curves. However, considering lower beam
and ADB system capabilities, NHTSA has narrowed down the curve
scenarios by eliminating the short right-curve scenario and truncating
the measurement distances for all but the large left curve scenario.
NHTSA similarly modified the measurement distance for the preceding
scenarios. We believe that the final test scenarios are sufficient to
determine whether an ADB system prevents glare to other motorists. The
reasons for these modifications are discussed in more detail in Section
VIII.C.8, Test Scenarios and Section VIII.O, Regulatory Alternatives.
The agency narrowed down the test scenarios by identifying aspects
of performance that an acceptable ADB system should meet and choosing
scenarios that would be the most challenging with respect to those
aspects of performance. For example, the final rule includes a same-
direction left curve scenario in order to test the ability of an ADB
system to recognize dim red lamps at wide angles.
However, the agency's testing showed that it was not possible to
identify a radius of curvature (e.g., shortest) that would necessarily
present a ``worst-case'' for all aspects of an ADB system. For example,
with the oncoming car/truck test fixture outfitted with the Camry
headlamps on a left curve, the shorter-radius curve was, in fact, more
challenging for the ADB system used for testing as evidenced by the
fact that it nearly exceeded the glare limit. See Figure 2.\77\
However, when tested with the preceding motorcycle fixture in a left
curve test scenario, the ADB system tested failed the test on a larger-
radius curve but passed the test on a smaller-radius curve. See Figure
3. On the larger-radius curve, the system failed to recognize the
motorcycle taillamp for the entirety of the test (the detectors are
saturated at the end of the test, so it is not possible to interpret
the results from 30 m-15 m). This suggests that a variety of test
scenarios, including a range of different curves, are needed to test
the variety of factors that contribute to a properly-performing ADB
system. While in many instances, shorter-radius curves will be a worst-
case scenario, the agency does not believe such curves will necessarily
represent the worst-case for all ADB systems; complexities in the
recognition system can create a far more complex set of test results.
The final rule therefore retains curves with a range of radii of
curvature.
---------------------------------------------------------------------------
\77\ The agency saw a similar result in its 2015 data. See
Adaptive Driving Beam Headlighting System Glare Assessment, DOT HS
812 174, August 2015, NHTSA U.S. Department of Transportation, p.168
(Fig. 74). The vehicles tested as part of that research demonstrated
a similar performance with respect to curve radius and closing
speed. The glare was higher for the moving stimulus vehicle as
compared to a stationary one.
[GRAPHIC] [TIFF OMITTED] TR22FE22.002
[[Page 9932]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.003
NHTSA implemented the finalized test scenarios using readily-
available photometric measurement and processing equipment.
Accordingly, the agency has concluded that it is within the
capabilities of current testing facilities to test to the final
requirements.
The agency is not persuaded by EMA's comments regarding heavy-duty
vehicles. Because ADB systems are not required, heavy-duty vehicle
manufacturers may take time to fully develop ADB technologies for use
on these vehicles. Moreover, while the development of ADB systems for
heavy-duty vehicles is less mature than for passenger cars, the agency
does not believe these challenges to be insurmountable, or that meeting
the requirements of this final rule is impracticable. There are a few
reasons for this. First, the ability of the ADB system to dynamically
track other vehicles is independent of the specific characteristics of
the ADB-equipped vehicle, so the fact that the ADB system would be on a
heavy-vehicle would not be consequential. Second, the test procedures
specify that NHTSA will aim the headlamps on the test vehicle according
to the manufacturer's instructions, which provides manufacturers with a
means to mitigate the effects of chassis-specific features that might
affect system performance by establishing chassis-specific aim
specifications. Third, the final rule's extensive modifications to the
proposed track test, resulting in a streamlined set of test scenarios,
should also help address concerns about heavy-vehicle testing.\78\
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\78\ We also note that NHTSA was unable to perform testing on
heavy-duty vehicles because it was not aware of any such vehicles
that are ADB-equipped. In any case, for the reasons given above, we
do not believe that it is necessary to test heavy-duty vehicles
prior to adopting this rule.
---------------------------------------------------------------------------
Finally, while the requirements and test procedures in the final
rule are an increase in stringency from the longstanding requirements
for semiautomatic beam switching devices, this final rule is
appropriate because ADB systems are capable of providing an enhanced
beam that is brighter than the lower beam, which presents an increased
risk for glare if the system is not designed appropriately.
2. Test Fixtures vs. Stimulus Vehicles
NHTSA identified two main alternatives to the proposed broad range
of eligible stimulus vehicles that would be used to elicit an ADB
system response. First, the agency considered specifying a small set of
specifically-identified stimulus vehicles, but tentatively decided that
a broad range of potential stimulus vehicles was necessary to ensure
that an ADB system can recognize multiple headlamp/taillamp
configurations on vehicles of different sizes and shapes.
Second, NHTSA considered specifying test fixtures, including those
specified in SAE J3069.\79\ The NPRM noted SAE's rationale that
fixtures represent a worst-case scenario because some cameras use
movement to identify objects as vehicles. It also noted SAE's
explanation that the fixture lamps would represent a ``reasonable worst
case for intensity and location and should promote test
repeatability.'' \80\ NHTSA also noted that test fixtures could be
easier to use than actual vehicles.
---------------------------------------------------------------------------
\79\ See NPRM at p. 51782-51783.
\80\ SAE J3069, p. 3.
---------------------------------------------------------------------------
However, the proposal identified several potential concerns with
test fixtures. The major concern was the lack of realism, so that
fixtures might not indicate whether the ADB system would recognize
actual vehicles and instead could permit ADB systems to be tuned to
detect fixtures. Another concern related to possible difficulties in
tuning out non-vehicle objects. Also of concern was the possibility
that the fixture characteristics might not represent a worst case.
The NPRM therefore proposed a large set of eligible stimulus
vehicles. The agency tentatively concluded that it would be practicable
for manufacturers to design ADB systems to recognize and
[[Page 9933]]
shade any vehicle satisfying the proposed selection criteria. NHTSA
noted that the lighting configurations an ADB system would have to
recognize would not be unreasonably large, as front and rear lighting
designs are limited by the requirements of FMVSS No. 108 and the
realities of vehicle design. NHTSA also reasoned that there is a
limited, and not exceptionally large, number of makes and models of new
vehicles offered for sale in the United States every year
(approximately 420), and that the set of eligible stimulus vehicles
would be further limited by the proposed vehicle height constraint.
Comments
Vehicle and equipment manufacturers opposed the use of stimulus
vehicles and commented that NHTSA should instead follow SAE J3069 and
use test fixtures. These commenters identified a variety of specific
concerns with stimulus vehicles.
Several commenters (Mobileye, EMA, Volkswagen, SMMT, Ford, Toyota,
SAE, the Alliance, Global, and Honda) contended that the proposed
stimulus vehicle specifications would result in an impracticably large
set of potential vehicles. For example, SAE and the Alliance commented
that the NPRM specified an unmanageable and exceptionally large number
of potential stimulus vehicles, exacerbated by the fact that many
vehicles have multiple headlamp and/or taillamp trim levels, and that
the proposal does not account for motorcycles or heavy-duty vehicles.
They estimated that this could result in a set of up to 1,000 eligible
stimulus vehicles. The Alliance also contended that it would be
impossible for a manufacturer to choose a worst-case scenario and
guarantee that testing with the other thousands of vehicle choices
would exhibit reproducible results for the multitude of requirements.
MEMA, Volkswagen, and the Alliance commented that the proposal would
cause manufacturers to incur costs from repeated testing as the
stimulus vehicles need to be refreshed every year. Volkswagen also
commented that obtaining stimulus vehicles would be especially
burdensome for foreign original equipment manufacturers (OEMs) and test
facilities.
Mobileye, SAE, Honda, and Ford commented that an FMVSS requiring a
manufacturer certification to account for the various configurations
and performance of thousands of vehicles in the market would be
unreasonable and unprecedented, as opposed to other FMVSS which
simulate real-world conditions with standardized test apparatus. As an
example, SAE, Ford, and Honda pointed to FMVSS No. 208, which uses a
fixed barrier to simulate a stimulus vehicle crashing head on into the
test vehicle within one specified range of speeds and does not require
selecting actual vehicles from a large population available in the
market to conduct this testing. Honda also pointed to FMVSS No. 214
(side impact) and FMVSS No. 301 (rear impact), and various New Car
Assessment Program (NCAP) test procedures that standardize the device
used to assess the crashworthiness of the test vehicle. SAE and Honda
contended that this approach allows the test to be practicable and
objective, and SAE suggested such an approach would be sufficiently
realistic because, as the NPRM noted, the lighting configurations an
ADB system would have to recognize are limited by the requirements of
FMVSS No. 108 and realities of vehicle design.
Commenters also raised concerns related to vehicle production
cycles. SAE and Ford commented that the cycle plans of any given
vehicle design can last many years, with those designs solidified many
months prior to production, making it impossible for manufacturers to
account for other manufacturers' vehicles in any manageable timeframe.
A manufacturer would not be aware of which vehicles may pose compliance
challenges for its ADB system prior to these vehicles being sold to the
public, especially considering the extremely conservative and
challenging requirements associated with the NPRM. Honda made similar
comments.
Mobileye commented that the proposal would lead OEMs to over-tune
the ADB system in order to ensure compliance, resulting in non-optimal
and overly sensitive system behavior and diminished safety benefits.
Several commenters (Global, Mobileye, Valeo, the Alliance, MEMA,
and Volkswagen) raised concerns regarding the repeatability and/or
reproducibility of compliance test results. SAE, the Alliance, SMMT,
and Honda commented that the proposal was not objective.
A few commenters did support using stimulus vehicles. Consumer
Reports supported a broad range of stimulus vehicles as reasonable to
adequately ensure ADB systems detect, identify, and shade vehicles of
different size, shape, and lighting configurations; however, it also
urged that testing be practical and efficient. Intertek commented that
a simple static test fixture may not be sufficient, and that using any
make or model within defined physical constraints is preferable to
adding an appendix with a list of eligible test vehicles. AAA commented
that no certified motor vehicle should be excluded from use as a
stimulus vehicle, and that the proposed limitation to the past five
model years together with the vehicle height constraints were practical
and acceptable.
Several commenters, while not supporting the use of actual
vehicles, commented that if NHTSA were to use actual vehicles, it
should further limit the set of eligible stimulus vehicles. SL
Corporation (SL) commented that detailed criteria for stimulus vehicles
(such as light source, luminous intensity of the stimulus vehicle's
headlamp and rear lamp), specified by vehicle type, is needed. Global
commented about a need for consistency in any testing, further arguing
that the rule could bookend the vehicle population's performance (i.e.,
lowest/highest, narrowest/widest) to constrain the massive number of
stimulus vehicles. Toyota suggested that NHTSA limit the number of
stimulus vehicles to a practical and manageable list by only using the
top three U.S. selling vehicle models for each of the vehicle types
identified in Table XXI of the NPRM in the fifth model year prior to
the model year of the certified vehicle. Honda stated that if NHTSA
does not adopt test fixtures, it should test with a single stimulus
vehicle chosen by the manufacturer. Valeo suggested specifying a
standard stimulus vehicle. Mobileye suggested modifying SAE J3069 by
defining the use of a standardized dummy stimulus vehicle with lamps
representative of those approved by FMVSS No. 108 instead of the static
fixtures specified in SAE J3069. Mobileye also recommended
complementing the (modified) SAE test with a requirement for an
additional test drive by a test engineer to ensure stable detection and
reaction to vehicles of different makes and models in additional real-
world scenarios not specified in the track test.
Agency Response
After evaluating the comments and considering the requirements of
the Safety Act and the National Technology Transfer and Advancement Act
(NTTAA),\81\ NHTSA has decided to specify test fixtures instead of
stimulus vehicles. The NTTAA directs agencies to use voluntary
consensus standards unless, among other things, doing so would be
inconsistent with applicable
[[Page 9934]]
law. We believe the test fixtures specified in the final rule are
consonant with both the Safety Act and the NTTAA.\82\ In particular, we
believe the test fixtures both meet the need for safety and better
align with SAE J3069 and other countries' standards.
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\81\ National Technology Transfer and Advancement Act of 1995,
Public Law 104-113, 110 Stat. 775 (1996). See Section X, Rulemaking
Analyses and Notices.
\82\ We also note that the final rule does not adopt Mobileye's
suggestion to supplement the track test with an evaluative drive by
a test engineer, because such a requirement would not satisfy the
Safety Act requirement of objectivity.
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Most importantly, we concluded that the test fixtures specified in
the final rule meet the need for safety. There are two main reasons for
this. First, in this case the need for safety requires us to balance
visibility and glare prevention. As some commenters pointed out, a too-
demanding track test to evaluate glare, including a large set of
eligible stimulus vehicles, could lead manufacturers to tune the system
to provide sub-optimal forward illumination. Second, we concluded that
using real vehicles would generally not challenge ADB systems any more
robustly than properly-specified fixtures. In the NPRM we expressed the
concern that insufficiently realistic test fixtures could lead to ADB
systems with performance tuned to the fixtures, not to real vehicles,
resulting in a test that does not sufficiently replicate real-world
performance. To address this concern, NHTSA developed test fixtures
fitted with original manufacturer replacement equipment vehicle
headlamps and taillamps, instead of the lamps specified in SAE J3069
that are intended to simulate vehicle lighting. (See Section VIII.C.6
for a discussion of the final fixture specifications.) NHTSA then
tested whether an ADB system performed differently with these fixtures
than with an actual vehicle. As explained below, this testing showed
that the ADB system detected and responded to the finalized test
fixtures in generally the same way it did to an actual vehicle.
NHTSA's recent research compared ADB performance when tested with
the finalized stimulus fixtures versus a stationary stimulus (i.e.,
actual) vehicle. For the most part, differences in performance were not
observed. For example, in straight oncoming and preceding test
scenarios, the ADB system recognized both the stimulus vehicle and test
fixture before either stimulus entered the measurement range. See
Figures 4 and 5.
[GRAPHIC] [TIFF OMITTED] TR22FE22.004
[[Page 9935]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.005
One exception to this was observed for the smallest-radius left
curve (oncoming) at the highest speed. In this case, the ADB system
performed better (recognized and adjusted sooner) when exposed to the
test fixture. For the fixture, the test vehicle adjusted its light
output at around 44 m and did not exceed the glare limits. For the real
vehicle, it reacted at 39 m, resulting in a glare exceedance. This
suggests that this ADB system likely relies on light source detection
rather than using supplemental systems such as radar or LIDAR to detect
a vehicle structure. Although we did not systematically test this
hypothesis, we suspect that the performance differences observed in
this case are caused by small differences in headlamp mounting heights
between the fixture and the real vehicle. See Figure 6. The agency did
not observe any situations in which the full vehicle was recognized,
but the test fixture was not.
[[Page 9936]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.006
The test fixtures specified in the final rule more closely align
with SAE J3069 and better harmonize with other countries' standards
than the proposed broad range of eligible stimulus vehicles. This
should help facilitate deployment of ADB systems in the United States
because manufacturers are already familiar with SAE J3069 and because
it harmonizes with the Canadian regulations, which permit ADB systems
designed to meet either ECE R123 or SAE J3069. This approach also
results in a more manageable set of test scenarios and stimulus
vehicles to which manufacturers must certify,\83\ which will also
result in a less complex and costly test. Test fixtures will reduce the
test burden by establishing a consistent stimulus for testing, reducing
the cost of acquiring and maintaining the test stimulus, reducing the
test time, and more closely harmonizing with SAE J3069. NHTSA's testing
showed that fixtures simplified the coordination of each test run. A
single test driver was required to drive the test vehicle as opposed to
two drivers required for tests involving dynamic stimulus vehicles.
Additionally, no start and stop coordination was needed between the two
drivers. The use of fixtures also facilitates set-up for different
scenarios.\84\
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\83\ Specific to this rulemaking, NHTSA has concluded that using
test fixtures better balances the safety needs of visibility and
glare prevention, and is more practicable and appropriate, than
using a broad range of potential stimulus vehicles. We are not
implying that a large set of potential stimulus vehicles is
necessarily impracticable for an FMVSS. We also note that we do not
agree with the commenters who claimed that the proposal raised
issues with respect to objectivity, repeatability, or
reproducibility.
\84\ NHTSA developed a single test fixture that was capable of
mounting both the motorcycle and the car/truck vehicle lamps; the
various lamps could be switched between test runs of different
scenarios.
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3. Justification for Testing on Curves and General Approach for
Scenario Selection
In addition to testing ADB performance in a straight-path scenario,
the NPRM proposed testing ADB systems on curved-path scenarios (both
left and right curves) with a variety of radii of curvature. The agency
proposed testing on a ``small'' curve with radii of curvature from 98
m-116 m (320-380 ft); a ``medium'' curve with radii of curvature of 223
m-241 m (730-790 ft); and a large curve, 335 m-396 m (1100-1300 ft).
The NPRM explained that the small curve was chosen because it
corresponded (approximately) to the shortest radii of curvature
appropriate for a vehicle traveling 25-35 mph, approximately the
minimum speed for which we proposed to allow ADB activation. The medium
curve corresponded to the shortest radii of curvature appropriate for
the higher ADB minimum activation speeds of some of the ADB-equipped
vehicles NHTSA tested. Finally, the large curve was intended to
correspond to a curve appropriate for vehicles traveling at higher
speeds, to test ADB performance on curves at higher speeds. Values for
speed and radius of curvature were selected to be consistent with the
simplified curve formula.\85\
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\85\ This is a standard formula used in road design that
specifies the relationship between vehicle speed and the radius of
curvature. See infra n.142 and accompanying text.
---------------------------------------------------------------------------
The NPRM recognized that curves might present engineering
challenges for ADB systems. For example, on a curve an oncoming vehicle
enters the ADB system's field of view (FOV) from the edge; in a tight
curve, an oncoming vehicle will enter the field of view at a closer
distance than in a larger-radius curve. Performing adequately on large-
radius curves at relatively high speeds consequently presents a
slightly different engineering challenge than performance on tight
curves at lower speeds.
Comments
Consumer Reports supported testing using curved path scenarios of
various curvatures. Intertek supported a more rigorous dynamic roadway
test than specified in SAE J3069 (which specifies straight test drive
paths) because the SAE J3069 approach may not be sufficient to validate
the performance of the ADB sensor over the range of situations that it
will normally encounter.
[[Page 9937]]
On the other hand, several commenters opposed or raised issues with
testing on actual curves. SAE commented that NHTSA should follow SAE
J3069 and simulate curves using a straight path and varying the
placement of the test fixtures. SAE contended that curves are not
necessary because continuous tracking of the angular location of the
test fixture in straight scenarios is required, and that removing
curves would greatly reduce the testing burden. SAE noted that it
considered including curves in SAE J3069 but concluded that attempting
to capture hundreds of potential road geometries would make the test
excessively burdensome because ADB systems would function similarly
over many of these geometries and including them all would provide no
added value. SAE further determined that testing on a straight path
with one lane to the right and more than one lane to the left of the
ADB-equipped vehicle would capture the conditions necessary to
determine whether an ADB system functions appropriately and ensures an
adequate response to a wide variety of road geometries, while allowing
the test method to be simple enough to be objective and repeatable. For
example, SAE J3069 requires that in a straight-line encounter, an ADB
system must continuously track the angular location of an opposing
vehicle fixture as that angular position becomes increasingly further
from the center of the camera's field of view with decreasing distance
to the opposing vehicle. SAE commented that such an approach allows
evaluation of vehicles encountered on curves to be captured without
using actual curves.
SAE, ALNA, Toyota, and the Alliance stated that the proposal would
require ADB systems to produce less glare than current FMVSS No. 108-
compliant lower beams, and that this issue was particularly acute on
curves. They argued that the proposed approach would reduce lower beam
visibility and negatively impact safety. SAE provided analyses and
graphs based on IIHS data on lower beam performance on different road
geometries, from straight roads to left and right curves of various
radii. Stanley and Intertek also asserted that the final rule should
account for the fact that current lower beams would not comply with the
glare limits on right curves.\86\
---------------------------------------------------------------------------
\86\ The commenters' data and arguments on these points are
discussed in more detail in the sections below discussing each of
the test scenarios in the final rule.
---------------------------------------------------------------------------
Agency Response
The final rule does not adopt some commenters' recommendation to
forgo actual curved-path scenarios, but it does reduce the measurement
distances in many of the test scenarios for which curves are specified.
The agency is not persuaded that the SAE J3069 approach of
simulating curves by varying fixture placement relative to a test
vehicle's straight path adequately replicates curves. Two features of
the SAE test are intended to replicate what the system would encounter
in an actual curve. First, the fixtures are placed to the side of the
test vehicle's path. Second, the sudden appearance scenario is intended
to roughly replicate a curve in that the fixture's stimulus lamps
become visible at a close distance, which would happen on a relatively
tight curve. (The sudden appearance scenario is also intended to
exercise the ability of the ADB system to react to real world
situations such as another road user turning on their lights, turning
onto the road, or cresting a hill at distances as close as 100 m.) This
approach, however, does not accurately replicate real curves in at
least two respects.
One is the trajectory of the fixture as it is tracked by the ADB
system (see Figure 7). An approaching vehicle on an actual curve enters
the ADB system's field of view from the edge, at a relatively far
distance; moves towards the center of the field of view as the distance
to the fixture closes; and then moves out towards the edge of the field
of view at a close distance. The trajectory is different, however, when
attempting to replicate a curve using a straight path and fixtures
placed out to the side. There, the fixture is first detected by the ADB
system near the center of the camera's field of view at a far distance,
and then moves out towards the edge of the field of view at closer
distances.
For example, on an actual left curve with a radius of 230 m, the
fixture enters the FOV at the edge (25L) at a relatively far distance
(191 m) and moves towards the center of the FOV until around 35 m at
which point it moves out towards the edge of the FOV again (see Figure
7). In comparison, in the SAE test run, at 155 meters (the start of the
SAE test), Fixture 1 is near the center of the FOV at approximately 2.5
degrees left, and as the test vehicle approaches the fixture the
fixture moves out to the edge of the field of view.
As another example, this time on a right curve with a radius of 230
m, the fixture enters the FOV at the right edge of the field of view
(25R) at about 205 m and moves towards and then across the center of
the FOV. In comparison, in the SAE test, at 155 meters (the start of
the SAE test), Fixture 3 is near the center of the FOV (at about 3
degrees right), and as the test vehicle approaches the fixture the
fixture trajectory moves out to the right edge of the field of view.
The SAE test evaluates rather large angles to the right of the beam
pattern, almost entirely to the right of where the NHTSA test method
examines the beam pattern performance. The agency believes this to be
unusual in reality, particularly for oncoming encounters.
Because the SAE test does not accurately replicate the fixture
trajectory, it does not test how the system will need to actually
function. For example, one way to ``optimize'' optical recognition is
to focus on where an object is most likely to appear. The speed and
accuracy of image recognition software can be increased without
increasing computing power if systems are trained to look in smaller
portions of an image for key elements, as opposed to looking at the
entire image continuously. Including test scenarios with actual curves
will discourage manufacturers from taking ``shortcuts'' and designing
ADB systems that do not react until the stimulus vehicle enters narrow
angles within the camera's FOV.
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Second, the SAE approach does not accurately replicate real curves
with respect to the speed at which the fixture traces its trajectory.
On an actual curve, the fixture travels horizontally across the FOV
relatively quickly at longer distances than on a simulated curve. For
instance, a left curve requires the headlamp to start shading on the
left side of the pattern, quickly move to the right; briefly hold the
shade near the middle; and very quickly move the shade back to the far
left. A simulated curve, on the other hand, simply necessitates that
the system starts shading the middle of the pattern; hold nearly that
same angle; and then quickly move the shade either left or right at
closer distances. Including actual curved-path scenarios will
discourage manufacturers from very accurately following the straight
path pattern but less accurately following the paths required for real-
world curves; it should therefore result in better real-world
performance than would the SAE J3069 fixture placements.
NHTSA's recent testing confirmed that the SAE scenarios do not
accurately model how an ADB system will perform on an actual curve. For
example, the agency tested ADB system performance on an 85 m left curve
as well as the most closely analogous SAE scenario, with the fixture
place in Fixture Position 1. (Fixture Position 1 is the closest
analogue to this scenario because it is the leftmost fixture position
in the SAE test.) See Figure 8. On the actual curve, the system did not
recognize and adjust to the fixture until 45 m. On the most closely
analogous SAE scenario (Fixture Position 1), the system was able to
continuously track the fixture from 150 m away. Even when the agency
repeated the same SAE scenario at a much higher speed of 61 mph, the
SAE test did not challenge the system's image recognition in an
observable way. This shows that an ADB system's initial image
recognition capability is not challenged by the SAE test as it is in a
more realistic curve test, meaning that NHTSA is less confident that
the SAE test would result in an equivalent level of safety as the
actual-curve test that NHTSA is finalizing. The practical implications
of this is that glare will not be sufficiently controlled by the SAE
test compared to the actual-curve test adopted in this final rule.
[[Page 9939]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.008
As another example, SAE J3069 does include a sudden appearance test
(using the oncoming and preceding motorcycle fixtures) in which the
fixture lamps are activated when the test vehicle is between 155 m and
100 m from the fixture. The agency found, however, that this also does
not realistically simulate a curve. See Figure 9. On an 85 m left curve
at 26 mph, the ADB system recognized the final rule oncoming motorcycle
fixture at 20 m. On the SAE sudden appearance scenario, in contrast,
the ADB system performed better, activating a shaded area at 70 m.
Additional comparative data from the final rule scenarios and the SAE
test scenarios are presented and discussed in Section VIII.C.8, Test
Scenarios.
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NHTSA disagrees with SAE's comment to the extent that it suggests
that a final rule incorporating actual curves might not be objective or
repeatable. The final rule sets out a rational test procedure that
yields a clear answer based upon readings obtained from measuring
instruments and is capable of producing identical results when test
conditions are exactly duplicated.\87\ The final rule specifies the
specific scenarios NHTSA may test, including ranges and values for key
[[Page 9940]]
testing parameters (e.g., differing radii of curvature), and specific
numeric limits for the maximum allowable illuminance at certain
distances; there is thus no ambiguity with respect to the parameter
values NHTSA may select in compliance testing. Moreover, NHTSA has
conducted a repeatability analysis and has concluded that the finalized
test scenarios and procedures are repeatable (see Section VIII.C.11,
Repeatability).
---------------------------------------------------------------------------
\87\ See, e.g., Chrysler Corp. v. Dept. of Transp., 472 F.2d
659, 676 (6th Cir. 1972).
---------------------------------------------------------------------------
NHTSA did, however, agree that some of the proposed curve scenarios
were too stringent. With respect to oncoming glare scenarios, the final
rule eliminates the short right curve scenario and reduces the
distances at which glare on the medium and large right curves and the
short and medium left curves is evaluated. With respect to preceding
glare scenarios, the final rule includes a straight-path scenario and a
medium left curve scenario. The specifications for the radii of
curvature have also been slightly modified. These modifications and
other choices are explained in more detail later in the preamble.
In general, NHTSA selected the final scenarios based on three
criteria:
The scenario represents commonly-encountered roadway geometries and
vehicle interactions. To ensure that ADB systems operate safely, the
final scenarios should include at least the most common road geometries
and vehicle interactions. Because the adaptive driving beam is intended
for distance illumination at speeds at which the lower beam does not
provide adequate illumination--typically above 20 mph--these geometries
and interactions should be those common at these speeds.\88\
---------------------------------------------------------------------------
\88\ See NPRM, pp. 51787-51788.
---------------------------------------------------------------------------
A compliant lower beam could pass the scenario. We also generally
chose scenarios such that a compliant lower beam would be able to pass
the scenario. There were several reasons for this. First, this (in
conjunction with the requirement that areas of reduced intensity meet
the corresponding lower beam laboratory photometric requirements)
ensures that an area of reduced intensity, up to and including a full
lower beam, will meet the same level of safety (with respect to both
visibility and glare prevention) as current lower beams certified to
FMVSS No. 108. Second, this is consistent with the concept for the
proposal: Extending the current laboratory-based lower beam photometric
requirements (specifically, the photometric maxima regulating oncoming
and preceding glare) for use in a vehicle-level test to evaluate the
ability of an ADB system to minimize glare (both oncoming and
preceding).\89\ Because the track test was intended as an extension of
the current laboratory photometric requirements, the track test
requirements should (generally) be such that a lower beam (or area of
reduced intensity) that complies with the current laboratory
photometric requirements will also comply with the track test
requirements.
---------------------------------------------------------------------------
\89\ See NPRM, pp. 51770, 51773.
---------------------------------------------------------------------------
The scenario is generally within the capabilities of robustly-
designed internationally-available ADB systems. As noted above, the
field of view for current ADB systems is typically 25 degrees to the
left and right of the camera, and, as explained below,\90\ ADB
adaptation time--the time it takes an ADB system to recognize a
stimulus (once the stimulus is within the camera's field of view) and
dim the beam to a level that falls within the applicable glare limit--
is generally about 1 second. Therefore, NHTSA generally chose scenarios
such that it would be possible for an ADB system with such field of
view and response capabilities to pass the scenario. This is not to say
that all current ADB systems would necessarily be able to pass all the
final scenarios without any modifications. However, the agency intended
to select scenarios that were generally within the reach of current
technology (perhaps necessitating some additional improvements,
adjustments, or optimizations, depending on the ADB technology), to
facilitate timely deployment of ADB systems. NHTSA also recognized that
these systems have been in use in foreign markets for several years
with few, if any, apparent safety issues.\91\ We discuss and apply
these criteria in more detail in Section VIII.C.8, Test Scenarios.
---------------------------------------------------------------------------
\90\ See Section VIII.C.5, ADB Adaptation Time.
\91\ The fact that the final rule does not include all the
proposed scenarios does not mean that NHTSA has concluded that only
a relatively small set of narrowly circumscribed scenarios is
permissible in an FMVSS. In this case, NHTSA has concluded that
adopting a smaller set of test scenarios appropriately addresses
both the need for safety (including facilitating the timely
deployment of ADB systems) and practicability. This also does not
imply that FMVSS requirements must be tailored to the capabilities
of currently existing systems. See, e.g., Chrysler Corp. v. Dept. of
Transp., 472 F.2d 659, 673 (6th Cir. 1972) (``[T]he Agency is
empowered to issue safety standards which require improvements in
existing technology or which require the development of new
technology, and it is not limited to issuing standards based solely
on devices already fully developed.'').
---------------------------------------------------------------------------
4. Maximum Illuminance Criteria (Glare Limits)
The NPRM included a set of photometric maxima to evaluate an ADB
system's ability to minimize glare in the track test (glare limits).
Because the current photometric test points from which the proposed
glare limits were derived are maxima, the agency proposed applying the
derived glare limits as maxima, so that any measured exceedance of an
applicable glare limit (except for momentary spikes) would be used to
determine compliance. The NPRM also extended the standard's ``design to
conform'' language to the proposed requirements, including the glare
limits.\92\ The NPRM also summarized the basis for the glare limits
(the full explanation for the derivation is given in the Feasibility
Study).
---------------------------------------------------------------------------
\92\ As we explained in the NPRM, the proposal extended the
standard's longstanding ``design to conform'' language to the
proposed requirements because the concept of the rulemaking was to
extend the current headlamp requirements to ADB systems. We
therefore considered the continued appropriateness of ``design to
conform'' to be outside the scope of this rulemaking. However, this
extension in no way limits NHTSA's ability to revisit the issue of
design to conform in the future. Furthermore, if NHTSA were to
reconsider the design to conform language, it might not come to the
same conclusion it did when it originally adopted that language. As
we explained in the NPRM, NHTSA adopted the ``design to conform''
language when the standard was introduced in 1967 because it
accepted industry's contemporaneous representation that vehicle
lamps could not be manufactured to meet every single test point
without a substantial cost penalty unjustified by safety. We further
explained that, because lighting equipment design, technology, and
manufacturing have evolved and advanced since the late 1960's, NHTSA
might not come to the same conclusion were it to revisit this issue.
---------------------------------------------------------------------------
The NPRM explained that the proposed glare limits deviate from SAE
J3069 in a few respects. First, two of the glare limits differ
slightly. At 60 m, SAE J3069 uses glare limits of 0.7 lux (oncoming)
and 8.9 lux (preceding) compared to the proposed 0.6 lux and 4.0 lux.
Second, SAE J3069 applies to a narrower range of distances (30 m-155 m)
than the proposed glare limits (15 m-220 m). Third, SAE J3069 applies
the glare limits only at the endpoints of the measurement ranges (i.e.,
155 m, 120 m, 60 m, and 30 m), while the NPRM applied the glare limits
throughout the entire measurement range. The proposal explained the
reasons for these deviations from SAE J3069.
Comments
A few commenters (AAA, Consumer Reports, and Zoox) supported the
glare limits as proposed. Intertek agreed that the baseline glare limit
requirements should extend to the full distance ranges rather than only
at the four individual distances specified in SAE J3069. Several
commenters, however, contended that the glare limits were too stringent
and suggested a variety of modifications.
[[Page 9941]]
SAE, Global, Ford, Toyota, the Alliance, and Auto Innovators
commented that the proposed glare limits were conservative and that
using absolute measurements of discomfort glare (the aspect of glare
that is painful or annoying, as opposed to the aspect of glare that
limits the ability to see other objects) is unreasonable and not
practicable. They recommended the final rule include reasonable
allowances for an ADB system to momentarily exceed the glare limits,
especially given the large number of proposed test scenarios. They also
stated that the proposed glare limits are well below the illuminance
provided by contemporary lower beams, including Insurance Institute for
Highway Safety (IIHS) top-rated lower beams for MY 2017 vehicles,
especially on curves. As noted earlier, SAE provided analyses and
graphs based on IIHS data on lower beam performance on different road
geometries, from straight roads to left and right curves of various
radii.\93\
---------------------------------------------------------------------------
\93\ Auto Innovators also supplied an apparently somewhat
similar analysis of IIHS data (on pp. 12-13 of its comment).
However, the comment did not identify the geometry of the road (the
orientation of the headlamps to the photometer) for the
measurements, so the agency is unable to evaluate this submission.
In any case, NHTSA addresses this issue using the IIHS data
submitted by SAE and the agency's own testing of lower beams to the
scenarios included in the final rule.
---------------------------------------------------------------------------
For those reasons, SAE, the Alliance, and Toyota argued that NHTSA
should evaluate the ratio of the ADB to lower beam illuminance. SAE
noted that this procedure is specified in SAE J3069, which requires the
measured illuminance to be no more than 25% above the measured lower
beam illuminance. SAE further stated that NHTSA's 2015 ADB Test Report
used a similar procedure, and that an UMTRI report found that 25% was
an acceptable maximum limit above the lower beam.\94\ Toyota commented
that following SAE J3069 in this respect would facilitate ADB
deployment across a wider range of vehicles.\95\ Auto Innovators also
argued for a similar 25% allowance (discussed below).
---------------------------------------------------------------------------
\94\ DOT HS 808 209, Sept. 1994.
\95\ SAE and other commenters also argued that comparing the
ratio of the illuminance from the adaptive beam to the lower beam
would also compensate for unaccounted for test variability such as
dips and bumps in the road. This is discussed below in Section
VIII.C.10.d, Allowance for Momentary Glare Exceedances.
---------------------------------------------------------------------------
A few commenters expressed interest in the final rule accounting
for glare dosage. Toyota commented that there is no clear evidence that
exceeding the maximum illuminance for longer than 0.1 second leads to a
safety hazard any greater than what occurs with existing headlighting
systems on U.S. roads today. Mobileye similarly commented that a
distinction needs to be introduced between glaring that may cause
discomfort to other drivers and glaring which may pose a safety risk.
It asserted that, while the NPRM assumes that any glare exceedances for
more than 0.1 seconds are not acceptable, drivers commonly use
intentional, limited glaring as a signaling mechanism to other drivers.
Accordingly, Mobileye suggested allowing glare exceedances longer than
0.1 seconds. AAA commented that the final rule should not permit glare
exceedances lasting longer than 1 second because its research showed
that glare from an oncoming vehicle lasting approximately 1 second was
rated as highly distracting. Intertek believed that proposed 0.1 second
allowance would account for the majority of the issues related to glare
dosage, exposure, or perceptibility because any longer exceedance is
detectable by the human eye. Auto Innovators also asserted that the
final rule should account for glare dosage. (This is discussed further
below.)
NHTSA received a few comments about the proposed measurement
distances. Intertek commented that regulating glare for distances
extending out to 220 m is unnecessary because the angular size and
position of oncoming headlamps at distances greater than 155 m mitigate
any harmful effects of glare. Intertek commented that testing out to
220 m creates additional complexity and testing costs. In contrast, AAA
suggested regulating glare beyond 220 m. They noted that European
specifications require camera recognition and reaction at distances of
400 meters (1,312 feet), and that intensity limits could be increased
from the current maximum of 150,000 cd to the European maximum of
430,000 cd if ADB systems are effective at this distance. SAE commented
that the proposed requirements for preceding glare are too stringent,
given the detection distance (120 m vs. 100 for the ECE) and the
minimum photometric requirements for rear lamps (2 cd vs. 4 cd for the
ECE).
Valeo commented that the proposed maximum illuminance requirements
would result in wildly varying light output, especially compared to the
current ECE requirements, which result in a much more constant and
consistent light intensity. Valeo also suggested that the final rule
clarify that the requirements apply to the entire ADB system (both
left-hand and right-hand headlamps).
Intertek suggested measuring luminance \96\ from the ADB system
headlamps rather than illuminance at the test fixture would provide
several benefits, including: The data collected from the test would
have a record which is very closely matched, and can be perceived and
analyzed in much the same way as what an actual driver of the stimulus
vehicle would have experienced; the recorded data can be viewed as a
map of luminous intensity (candela) emitted from the test vehicle,
which would be directly comparable to the existing photometry
requirements, and can be plotted as a function of time or approach
distance; over time, if this data is collected carefully and attention
is paid to those scenarios in which the driver of the stimulus vehicle
feels glared, a better quantitative baseline for and understanding of
glare can be established.
---------------------------------------------------------------------------
\96\ ``Luminance'' refers to the luminous intensity produced by
a light source in a particular direction per solid angle, while, as
noted earlier, ``illuminance'' refers to the amount of light falling
on a surface. The unit of measurement for luminance is candela,
while the unit of measurement for illuminance is lux. A measure of
luminous intensity in candela can be converted to a lux equivalent
(and vice versa), given a specified distance.
---------------------------------------------------------------------------
Auto Innovators stated that NHTSA should adopt a modified version
of the IIHS right-curve glare exposure criteria for all oncoming
scenarios.\97\ See Table 5. Auto Innovators contended that this would
be appropriate because the IIHS glare limits are intended to provide
consumers with a relative assessment of headlamp performance and it is
possible for a vehicle to drastically exceed the glare criteria in the
IIHS test and still comply with FMVSS No. 108; the IIHS protocol allows
exceedances in the form of cumulative exposures as opposed to hard
pass/fail limit at a single point in time, resulting in a series of
demerits (based on the percentage over the limit) for which it is
possible for a vehicle to achieve a ``Good'' rating while still
offering small amounts of glare. Auto Innovators recommended adopting a
similar method for establishing an allowable time exceedance for each
test range.
---------------------------------------------------------------------------
\97\ Insurance Institute for Highway Safety. Headlight Test and
Rating Protocol, Version III (July 2018); Rationale and Supporting
Work for Headlight Test and Rating Protocol. (August 2015).
Table 5--Auto Innovators' Modified Maximum Illuminance Criteria Based on
IIHS Protocol
------------------------------------------------------------------------
Illuminance
Distance (m) limit (lx)
------------------------------------------------------------------------
30 to 59.9................................................ 6
[[Page 9942]]
60 to 119.9............................................... 3.4
120 to 220................................................ 1
------------------------------------------------------------------------
Auto Innovators gave a few different arguments for adopting its
proposed glare limits. First, it claimed that the IIHS glare limits
better reflect modern headlighting systems. It noted that the proposed
glare limits are based, in part, on headlamps typical of the 1997 model
year, whereas the IIHS protocol is based on contemporary headlighting
systems. Next, Auto Innovators contended that the IIHS protocol
accounts for research indicating that the harmful effects of glare
depend on both peak illuminance and overall dosage of glare exposure.
Finally, Auto Innovators contended that the IIHS methodology accounts
for glare effects due to incidence angle whereas the Feasibility Study
does not. Auto Innovators recommended eliminating the 15-29.9 m
measurement range (for both oncoming and preceding scenarios) because
its test data showed not only that the least amount of failures
occurred in this interval but that the exceedance durations for all
failures in this range were 1.0 second or less.\98\
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\98\ Auto Innovators also argues that glare exceedances at these
short distances may be caused by swiveling of the headlamps. While
this only applies to swiveling beam ADB systems, Auto Innovators
believes that any safety standard should remain technology neutral.
---------------------------------------------------------------------------
In addition to recommending NHTSA adopt its suggested glare limits,
Auto Innovators recommended that the final rule require passage of a
percentage of averaged individual illuminance readings to achieve
compliance instead of looking to the maximum recorded illuminance in
each measurement range. Specifically, Auto Innovators appeared to
suggest that NHTSA perform three test runs for each scenario and
average the maximum illuminance in each measurement range recorded for
each scenario. Then, it asks that NHTSA allow up to 15% of the averaged
illuminance readings to exceed its recommended glare limits by up to
25%. Auto Innovators cited the same UMTRI and NHTSA reports referenced
earlier, as well as three inconsequentiality petition grants as the
basis for the 25% allowance.\99\ Auto Innovators commented that the 15%
allowance comes from the turn signal test requirements in S14.9.3 of
FMVSS No. 108. It contended that this amount of performance variation
is consistent with the challenges of outdoor dynamic testing where
little previous experience exists, especially compared to the highly-
controlled laboratory photometric testing that has previously been
used. Auto Innovators commented that it would be difficult not to
attribute failures of illuminance readings to variances that could
appear in the novel and unique aspects of the test procedure, rather
than to quality control issues, particularly where the time and
complexity of the testing preclude conducting it on multiple ADB-
equipped vehicles. It also asserted that this approach is consistent
with the standard's design to conform language. Mobileye similarly
suggested specifying a pass/fail ratio for the measured illuminance
values in each specified measurement interval.
---------------------------------------------------------------------------
\99\ 85 FR 39678 (July 1, 2020) (grant of petition for
inconsequential noncompliance for side marker lamp below photometric
minima); 85 FR 39679 (July 1, 2020) (grant of petition for
inconsequential noncompliance for rear reflectors below minima); 55
FR 37601 (Sept. 12, 1990) (grant of petition for inconsequential
noncompliance for taillamp exceeding maxima).
---------------------------------------------------------------------------
Agency response
NHTSA agrees with the commenters that the proposed glare limits
were overly stringent at some geometries and measurement distances in
that a current, FMVSS No. 108-compliant lower beam would not have
complied with some of these requirements. The agency has therefore
modified the proposal by deleting the short right curve scenario and
modifying measurement distances for other specified radii of curvature.
NHTSA believes that these modifications reasonably ensure that a lower
beam that complies with the current FMVSS No. 108 photometry
requirements would be within the glare limits as applied in the
specified measurement ranges in each of the final scenarios. This is
discussed in further detail in Section VIII.C.8, Test Scenarios.\100\
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\100\ NHTSA anticipates that ADB systems could provide better
glare protection than current lower beams if dynamic vertical aim is
incorporated into the systems. Current lower beams will produce
glare on hills and undulating roads. Because of the nature of the
adaptive beam's area of unreduced intensity, it does not have the
same sensitivity to aim as a lower beam with respect to seeing
distance. For example, an ADB pattern could be aimed down more than
a lower beam (preventing glare even when the vehicle pitches) while
still providing appropriate seeing distance in directions where
glare protection is not required. However, the agency decided not to
require additional glare protection performance from ADB systems
beyond that currently produced by lower beams (except on right
curves) and anticipates aiming strategies might be incorporated into
ADB systems in order to maintain reasonable compliance margins.
---------------------------------------------------------------------------
NHTSA disagrees with some commenters' suggestions to follow SAE
J3069 and only consider an ADB system as not complying with the glare
limits if the measured ADB illuminance exceeds 25% of lower beam
illuminance. The final rule differs from the proposal by eliminating
overly stringent scenarios and providing additional adjustments to
account for testing variability, including data filtering procedures
and an adjustment for vehicle pitch, in addition to the proposed
allowance for momentary glare exceedances. The agency believes that
these modifications obviate the need for any further glare limit
allowances. While more relaxed test requirements might facilitate ADB
deployment, they would not ensure that ADB systems function properly.
We believe that the final requirements and test procedures strike a
reasonable balance between visibility and glare prevention.
Neither the UMTRI report nor the comments relating to the NHTSA
research cited by the commenters are persuasive. The UMTRI report
concerned the evaluation of inconsequentiality petitions, not the
appropriate magnitude of the lower beam maxima, which is the relevant
issue when considering the appropriate level for the glare limits.\101\
As explained in the NPRM, the proposed glare limits were based on FMVSS
No. 108's longstanding Table XIX photometric maxima. While the 2015 ADB
Test Report did examine how close the observed ADB illuminance values
were to the relevant glare limit, including an analysis of the effect
on the results of increasing the glare limits by up to 25%,\102\ the
analysis did not concern ``just noticeable differences'' or state or
imply that exceedances of up to 125% of the relevant glare limit were
inconsequential. Instead, the purpose of this analysis was to ``see
whether increasing the glare limit would have changed an exceeding
result to a non-exceeding result.'' \103\ The 2015 ADB Test Report also
examined the ratio of ADB illuminance to lower beam illuminance. This
analysis was intended to evaluate ADB functionality, not as a means of
evaluating ADB compliance. This was particularly useful because some of
the lower beam headlighting systems tested in the 2015 study were not
designed to meet the requirements
[[Page 9943]]
of FMVSS No.108. Using a ratio allowed for the comparison of basic ADB
functionality against the lower beam regardless of the photometric
standard to which the lower beam was designed.\104\
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\101\ See DOT HS 808 209, Sept. 1994, p. 9 (concluding that
``using 25% as a criterion for inconsequential noncompliance'' is
appropriate for lower-beam headlamps) (emphasis added).
\102\ 2015 ADB Test Report, p. 133.
\103\ Id.
\104\ Although commenters did not suggest it, we also decided
not to adopt an adjustment such that if ADB illuminance exceeds an
applicable glare limit, the exceedance would be considered a
noncompliance only if the ADB illuminance exceeded the lower beam
illuminance (i.e., without a 25% cushion). The reasons for this are
the same as the reasons for not adopting the commenters'
recommendations.
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Regarding the distances at which to regulate glare, regulating
oncoming glare out to 220 m is appropriate. As the Feasibility Study
explained, at greater distances a smaller glare limit is appropriate
because, at greater distances, ``the glare source will be seen by the
oncoming driver at a smaller angle.'' \105\ NHTSA was able to test the
final scenarios out to this distance (where applicable) and did not
encounter any testing difficulties related to this distance. On the
other hand, NHTSA did not develop testing scenarios for oncoming glare
at distances greater than 220 m, and so is not prepared to test beyond
that distance. The reasons for regulating oncoming glare out to 220 m
are discussed in greater detail in Section VIII.D.4, Requirements for
area of unreduced intensity. NHTSA does agree with SAE that it is more
appropriate to test preceding glare only out to 100 m, and not the
proposed 120 m. The reasons for this are discussed in more detail in
Section VIII.C.8.g, Scenario 7: Preceding Straight.
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\105\ Feasibility Study, p. 23.
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The agency disagrees with Valeo's assertion that specifying the
glare limits as a stepwise (discontinuous) function of distance will
result in dramatic fluctuations in light output. The glare limits are
photometric maxima, not design requirements, and there is no reason to
think that manufacturers will design headlamps that suddenly increase
or decrease in brightness for reasons unrelated to road conditions.
Moreover, the laboratory requirements that reference the Table XIX
photometric maximum intensity limits preclude manufacturers from
producing areas of reduced intensity that vary as Valeo would suggest.
In fact, the output limits specified in Table XIX require lower beam
intensities (which is what the agency requires the ADB systems to
produce in the area of reduced intensity) well below those calculated
by Valeo at the further distances of the measurement subrange.
While the final rule could have specified the glare limits as a
continuous function of distance, this would have been more complicated.
In any case, the stepwise specification is less stringent than
specifying glare limits as a continuous function of the closing
distance between the test vehicle and the test fixture. The glare
limits for each of the four specified ranges was derived from the
shortest distance in the range, and then applied to all the (further)
distances in the range. As the Feasibility Study explained, however,
the glare limits are derived to decrease as distance increases.\106\
Therefore, if the glare limits were specified as a continuous function
of distance, they would decrease throughout the interval as distance
increased. By specifying the glare limits as a stepwise function, the
glare limits are higher at the further distances in the interval than
they would have been if we specified them as a continuous function of
distance. This has the benefit of simplicity. It also essentially gives
manufacturers an additional margin for error than they would have had
if we specified the limits as a continuous function of distance. The
final rule has, however, incorporated Valeo's suggestion to clarify
that the requirements apply to the entire ADB system.
---------------------------------------------------------------------------
\106\ Id.
---------------------------------------------------------------------------
Intertek makes an interesting suggestion for quantifying perceived
glare. However, based on the agency's stated goals of minimizing the
cost impact of the regulation and providing a pathway for introduction
of ADB systems for use on U.S. roadways as quickly as possible, the
final rule does not adopt Intertek's suggestion. To do so would require
additional research to inform the agency on how such changes would
affect the glare and photometry limits specified, as well as any costs
associated with requiring the agency and the industry to switch from
test methods designed around measuring illuminance at the test vehicle
to measuring luminance. The agency simply has no data to support such a
change at this time.
NHTSA understands Auto Innovators' suggestion to adopt the IIHS
glare limits as related to their general argument that the proposed
glare limits and test scenarios were too stringent. As explained
earlier, NHTSA agreed with this point to some extent and modified the
measurement distances, test scenarios, and allowances accordingly.
However, the agency does not adopt Auto Innovators' glare limits for
two reasons.
First, the glare limits suggested by Auto Innovators are three
times the proposed limits, which are based on the current photometry
requirements. The intent of this rulemaking is to permit ADB without
increasing glare from levels currently on the road. NHTSA's testing
showed that Auto Innovators' suggested limits do not represent glare
produced by compliant lower beams under the controlled driving
situations that are part of the ADB test, particularly for straight and
left curve scenarios. For the left curve and straight path scenarios,
testing of the Fusion and Volvo demonstrated that a considerable margin
is achieved with the proposed glare limits.\107\ See Table 6. These
same types of margins are present throughout our lower beam testing.
This confirms that these limits provide a boundary to protect the
public from additional glare beyond what is currently experienced on
the roads today. See also the discussions of lower beam performance on
various scenarios in Section VIII.C.8, Test Scenarios. The commenter's
suggested limits would significantly increase that boundary and permit
substantially higher glare on the roads.
---------------------------------------------------------------------------
\107\ The Fusion used had not been rated by IIHS. The Volvo was
rated ``acceptable'' by IIHS.
Table 6--Lower Beam Illuminance Margin for Proposed Glare Limits
----------------------------------------------------------------------------------------------------------------
Range (m) Glare limit Max illum. Margin (%)
----------------------------------------------------------------------------------------------------------------
Volvo 210 m left curve at 42 mph
----------------------------------------------------------------------------------------------------------------
150.0-120.0..................................................... 0.3 0.051 83
119.9-60.0...................................................... 0.6 0.158 74
59.9-30.0....................................................... 1.8 0.788 56
29.9-15.0....................................................... 3.1 2.118 32
----------------------------------------------------------------------------------------------------------------
[[Page 9944]]
Fusion 400 m right curve at 54 mph
----------------------------------------------------------------------------------------------------------------
70.0-60.0....................................................... 0.6 0.415 31
59.9-30.0....................................................... 1.8 0.933 48
29.9-15.0....................................................... 3.1 1.394 55
----------------------------------------------------------------------------------------------------------------
Second, the agency believes the proposed oncoming glare limits
(which are derived from the Table XIX left side photometric maxima) are
most appropriate for any oncoming scenario--including right curves--
because they were derived from limits designed specifically for
oncoming traffic (which in the United States are typically to the left,
except on right curves). Auto Innovators' suggested limits may be
appropriate for the right side of lower beams where the compromise
between seeing distance and glare places greater value on seeing toward
the right side. This is appropriate for a static beam pattern that
limits glare in all horizontal directions no matter where the other
road user is located. If one thinks of oncoming interactions as being
oriented in terms of either straight, left curve, or right curve, two
of these three (straight and left curve) have the other vehicle toward
the left of the subject vehicle's headlamps. So, for those two
situations, it is better to allow more potential glare to the right
side of the road (where other road users are less likely to be) in
order to provide some seeing light in that direction. For the remaining
right curve situation, the beam is still limited, but less so, and some
glare is expected to account for better seeing distance toward the
right for the other two situations. No such compromise needs to be
applied for ADB. The ADB pattern creates a reduced illumination area to
the left when the other vehicle is to the left and an unreduced area to
the right. When the other vehicle is toward the right, the same
protection can now be applied to those encounters as to the straight
and left, without sacrificing seeing distance. As such, the agency is
using the glare limits derived for the left side oncoming curve
scenario for the right curve scenario.
The agency acknowledges the relationship between dosage (the
product of illuminance and duration) and the disabling effects of
glare. For glare control, the IIHS headlamp rating procedure uses a
derivative of dosage (distance for which a limited illuminance is
exceeded). However, the quantified crash risks associated with
exceeding these limits is not clear. Research the agency conducted in
2008 began to explore this relationship, noting that ``specification of
the integrated (summed) values throughout the segment would be more
likely to provide control for glare recovery, but would involve
headlamp light measurement procedures that are more complex than those
currently used to determine if a headlamp meets the FMVSS 108
requirements.'' \108\ Until this final rule, the basic structure of the
headlighting regulation (goniometer--photometry) did not provide a
foundation for which glare dosage could be readily measured and
regulated. As such, the agency has not focused its research in this
area. While NHTSA agrees that a qualitative relationship exists, the
agency has not established, and does not know of, a quantified
relationship between glare dosage and crash risk.
---------------------------------------------------------------------------
\108\ DOT HS 811 043 Nighttime Glare and Driving Performance:
Research Findings, 2008.
---------------------------------------------------------------------------
Another limitation of IIHS's method is that it considers all glare
doses equal (except for distances between 5 m and 10 m). The impacts of
glare, however, are also related to the angle between the glare source
and the line of sight of the viewer. The glance pattern of drivers in
nighttime glare situations is not well understood, as some drivers may
be inclined to look toward the glare source effectively causing the
angle between the line of sight and the glare source to be zero.\109\
To the extent that a driver follows driver's education recommendations
and does not look at the glare source, glare doses in roadway
interactions are not equally impactful at all distances, as the angle
between the glare source and the line of sight is smaller at far
distances. Such an effect is reflected in the current photometric
tables and was, in fact, taken into account in the glare limits
derivation in the Feasibility Study, in that the glare limits are
smaller at greater distances.\110\ NHTSA therefore disagrees with Auto
Innovators that the IIHS study accounts for glare effects due to
incidence angle.\111\
---------------------------------------------------------------------------
\109\ 2007 Report to Congress, pg. iv.
\110\ See Feasibility Study, p. 23.
\111\ In addition, we note that the negative impacts of glare
are not limited to disabling glare, but are also related to the
annoyance and even painful experience of other roadway users.
NHTSA's 2008 research concluded that ``the peak illuminance, rather
than the dosage, was the primary factor associated with rated
discomfort.'' DOT HS 811 043 Nighttime Glare and Driving
Performance: Research Findings, 2008.
---------------------------------------------------------------------------
NHTSA is therefore finalizing the glare limits as proposed. Future
development of glare dosage as full vehicle dynamic testing for
headlighting systems continues to mature is of interest to the agency.
With respect to Auto Innovators' comments regarding specifying an
allowance of 25% over the glare limits, we disagree with this for the
reasons given above regarding the evaluation of the ratio of adaptive
driving beam to lower beam illuminance. NHTSA also does not find the
cited inconsequentiality petition grants to be persuasive because they
did not concern headlamps, and, except for one of the petitions, did
not concern glare. The agency was also not persuaded by the suggestions
by Auto Innovators and Mobileye to adopt a pass/fail ratio or to
average a number of test runs in order to mitigate test-related
variability. Such procedures, while occasionally specified in an FMVSS,
would be unusual. In any case, we do not believe this is necessary here
for two reasons. First, we believe the final test procedure already has
sufficient allowances for test-related variability (an allowance for
momentary glare exceedances, a vehicle pitch adjustment, and the
application of a low-pass filter with a cutoff frequency of 35
Hz).\112\ Second, we conducted a repeatability analysis and found the
final test procedure to be repeatable.\113\
---------------------------------------------------------------------------
\112\ See Section VIII.C.10, Data Acquisition and Measurement.
\113\ See Section VIII.C.11, Repeatability.
---------------------------------------------------------------------------
5. ADB Adaptation Time
The NPRM included a 0.1 second or 1 m magnitude allowance for
momentary glare exceedances. This was intended to account for
variations in illumination due not to the ADB system but to
uncontrolled or uncontrollable
[[Page 9945]]
testing variables. This differs from an allowance for an adaptation
time, which would account for the operation of the ADB system--
specifically, the time it takes an ADB system to recognize a stimulus
(once the stimulus is within the camera's field of view) and respond by
dimming the beam, switching from an area of unreduced intensity to an
area of reduced intensity. SAE J3069 specifies a 2.5 second maximum ADB
adaptation time during the sudden appearance test drive. (The NPRM did
not include a ``sudden appearance'' scenario because the system's
ability to respond quickly is exercised by the shorter-radii curve
scenarios.) The NPRM did not propose a time limit within which an ADB
system would be required to respond to a stimulus, but sought comment
on whether one should be included in the regulation.
Comments
Some commenters interpreted the 0.1 second allowance for momentary
glare exceedances as an adaptation time allowance.\114\ Mobileye, Ford,
Honda, Volkswagen, and Auto Innovators contended that 0.1 second is not
technically feasible and the final rule should specify a duration
greater than 0.1 second because ADB systems need time to recognize the
stimulus and modify the beam. Mobileye and Ford stated that without
this, ADB systems would behave erratically, and Mobileye stated that it
would result in many more false positives, leading to reduced
visibility. Honda asserted that an insufficient time allowance would
dis-incentivize the deployment of systems that operate over a wide
range of conditions, and might especially be an issue on curves with a
radius of 320-380 ft, on which an opposing vehicle will enter the ADB
vehicle's field of view suddenly at a close distance. Honda suggested
an allowance for an adaptation time sufficient to ensure that ADB
systems have an appropriate amount of time to react to the sudden
appearance of other vehicles or when environmental lighting changes
dynamically when driving.
---------------------------------------------------------------------------
\114\ The proposed allowance for momentary glare exceedances
(intended to account for uncontrolled test-related variability) is
discussed in Section VIII.C.10.d.
---------------------------------------------------------------------------
Mobileye, Ford, Volkswagen, and Auto Innovators specifically
supported the 2.5 second ``reaction time'' specified in SAE J3069. Ford
commented that 2.5 seconds is reasonable based on its extensive
experience with auto beam switching systems similar to ADB systems
available internationally. Mobileye also noted that ECE R48 defines the
minimal distance below which glaring is not allowed. Auto Innovators
commented that its test data showed that a majority of exceedances were
less than 2.0 seconds, with only a few exceedances over 2.5 seconds
(limited to scenarios in which the stimulus vehicle was difficult to
detect, such as the stationary motorcycle). Mobileye, Volkswagen, and
Auto Innovators commented that 2.5 seconds would still be an
improvement over human-driver reaction time.
In contrast, AAA asserted that 2.5 seconds is inordinately long,
and that the reaction time should be decreased to approximately 1
second, based on its research which showed that glare from an oncoming
vehicle lasting approximately 1 second was rated as highly distracting.
Agency Response
Although the final rule does not specify an allowable ``adaptation
time,'' the agency does agree that the final rule should generally take
into account how long it takes a typical, well-designed ADB system to
respond. Typical ADB adaptation times are a little over 1 second. An
ADB test report published by SAE in 2016 reported a reaction time of
about 1.1 seconds.\115\ NHTSA's testing showed comparable times,
ranging from .56 seconds to 1.22 seconds when suddenly exposed to a
stimulus.\116\ These reported adaptation times are much less than the
2.5 seconds specified in SAE J3069.
---------------------------------------------------------------------------
\115\ Assessment of Adaptive Driving Beam Photometric
Performance (SAE 2016-01-1408), p. 3. This included the time it took
for an experimenter to turn on the stimulus vehicle headlamps at a
predetermined distance, so the actual system response time was
shorter than this.
\116\ 2015 ADB Test Report, p. 92.
---------------------------------------------------------------------------
In addition, at the speeds the track tests are conducted, the test
vehicles will cover a significant amount of the measurement distance
within an adaptation time of 2.5 seconds (nearly 28 m at 25 mph, or 55
m at 50 mph). For example, the SAE sudden appearance scenarios specify
that the fixture lamp be suddenly exposed when the test vehicle is
between 155 m and 100 m from the fixture. At 55 mph (24.6 m/s) the test
vehicle will have traveled 61.5 m in 2.5 s. If the fixture lamps were
activated at 100 m, this means that the test vehicle would be about 40
m from the fixture by the time the 2.5 second allowance had elapsed.
This would mean that only one illuminance value (at 30 m) would be
evaluated by the SAE test. Similarly, in a real-world vehicle
interaction, with two vehicles approaching each at 70 mph (31.3 m/s)
each, if the ABD system takes 2.5 s to react, the two vehicles will
have traveled 157 m before the ADB system reacts.
After consideration of the studies and data discussed above, NHTSA
believes that an ADB adaptation time of 2.5 seconds is exceedingly
long. The final rule does not specify an adaptation time, however,
because the final scenario parameters have generally been specified so
that glare is not regulated until the fixture has been within the field
of view of a typical ADB system (25 degrees to each side) long enough
for the system to react (for example, in the small left curve scenario
the fixture is within the camera's field of view for approximately 1.24
s before the fixture enters the measurement distance range for that
scenario). There are some exceptions to this. For some of the smaller-
radii curve scenarios, the final rule begins regulating glare at a
distance at which a typical ADB system might not have had time to
react. Even here, however, there is not a need for an adaptation time
because a typical ADB system would not exceed the glare limits even at
these distances. At these further distances, because there will be a
relatively wide angle between the test vehicle headlamps and the test
fixture, the upper beam illuminance at those angles (and distances) is
not likely to exceed the applicable glare limit. There is also no
apparent safety need for directing high illuminance at such wide
angles. These points are covered in more detail in the sections below
for the various test scenarios.
6. Test Fixture Specifications
The NPRM identified test fixtures, including those specified in SAE
J3069, as a regulatory alternative. The NPRM explained that SAE J3069
specifies four test fixtures: An opposing car/truck fixture; an
opposing motorcycle fixture; a preceding car/truck fixture; and a
preceding motorcycle fixture. The NPRM explained that the SAE fixtures
are fitted with lights intended to simulate actual vehicle lamps; the
lamps are intended to represent reasonable worst-case for intensity and
location and promote repeatability. For headlamp representations, the
SAE standard specifies a lamp projecting 300 cd of white light in a
specified manner and angle instead of actual headlamps. In addition to
being intended to represent a reasonable worst-case condition, the SAE
J3069 rationale also states a ``concern that if the actual lower beam
headlamps were used on the opposing vehicle test fixture the large
gradients present in typical lower beam patterns would cause
unnecessary test
[[Page 9946]]
variability.'' \117\ For the taillamp representations, SAE J3069
specifies lamps emitting no more than 7 cd of red light in a specified
manner and angle. The fixtures are fitted with photometers positioned
near where a driver's eyes or the rearview/side mirrors would be
located to measure illumination from the ADB test vehicle
headlamps.\118\ The lamp and photometer locations are based on ``median
location values provided by [the University of Michigan Transportation
Research Institute].'' \119\
---------------------------------------------------------------------------
\117\ SAE J3069, p. 4.
\118\ SAE J3069 5.5.2 and Figures 1 and 2 (opposing vehicle
fixture); 5.5.3 and Figures 3 and 4 (preceding vehicle fixture).
\119\ SAE J3069, p. 3.
---------------------------------------------------------------------------
The NPRM identified and sought comment on potential issues with the
SAE J3069 fixture specifications, particularly whether using simulated
lamps instead of actual vehicle lamps was sufficiently realistic. We
stated that test fixtures may encourage an ADB system designed to
ensure identification of test fixtures rather than actual vehicles,
which might not adequately ensure that the system performs
satisfactorily when faced with a wide range of real-world vehicles and,
particularly, real-world vehicle lighting. We stated that we were not
confident that the lamps specified in SAE J3069 represented a worst-
case scenario. As one example of this, we noted that the minimum
intensity allowed for a taillamp is 2.0 cd at H-V and as low as 0.3 cd
at an angle of 20 degrees. These values are considerably lower than the
7.0 cd lamp specified in SAE J3069. We therefore sought comment on the
extent to which narrowly-defined lamps can be used to establish
performance requirements that reasonably ensure an ADB system will
recognize and adapt appropriately to the wide range of lighting
configurations permitted under FMVSS No. 108. We also noted, with
respect to the concern raised in SAE J3069 that using actual lower beam
headlamps on the opposing vehicle fixtures would lead to test
variability, that in the real world an ADB system must be able to
identify headlamps from many different types and models of vehicles; if
an ADB system was so sensitive to actual headlamp gradients that those
gradients affected ADB system performance, the variability would be
attributable to the ADB system, not the test.
Comments
The agency received several comments relating to test fixture
specifications. While many manufacturers urged NHTSA to adopt SAE
J3069,\120\ some commenters identified potential concerns with the SAE
J3069 fixtures. Mobileye commented that the major drawback of SAE J3069
is the use of synthetic stimulus light sources, which presents a
challenge because in actual driving scenarios, the system is trained to
ignore the types of synthetic light sources specified in SAE J3069
because they are more likely to be lights from houses, driveways, or
other non-vehicle sources. Mobileye pointed out that vehicle headlamps
differ from the SAE fixtures in shape, power source (DC), and having a
distinct non-uniform light dispersion pattern. Mobileye suggested that
placing lamps on static fixtures will force an ADB system to react to
light sources even when it positively recognizes them as not being part
of a vehicle. Mobileye recommended that the fixture closely resemble a
``uniform'' or ``standard'' vehicle with lamps representative of those
approved by FMVSS No. 108 instead of the static fixtures specified in
SAE J3069, so as not to force the ADB system to downgrade its real-life
performance to comply with a synthetic test.\121\ Intertek commented
that it is possible for image recognition software to be adjusted to
specifically identify and respond to the SAE J3069 test fixture and
test track without necessarily ensuring adequate real-world
performance.
---------------------------------------------------------------------------
\120\ See Section VIII.O, Regulatory Alternatives.
\121\ Auto Innovators also suggested using standardized
headlamps and taillamps in lieu of the proposed broad range of
actual stimulus vehicles.
---------------------------------------------------------------------------
We also received comments on the proposed stimulus vehicle lighting
that are equally relevant to test fixture lighting. Bosch recommended
that, to ensure system robustness, NHTSA specify stimulus vehicles with
a wide variety of light source technologies and consider utilizing a
reference publication such as the Ward's Automotive Yearbook to stay
current with rapidly evolving headlamp technology. Honda noted that the
NPRM did not specify which headlamp beams should be activated on the
stimulus vehicle and suggested that the final rule clarify that this is
the lower beam. Auto Innovators raised the possibility of a situation
where the regulation specifies a specific vehicle or vehicle component,
but the item is later determined to be noncompliant or subject to
manufacturer in-cycle design changes or modifications. Auto Innovators
suggested that this potential for non-compliance presents an
unforeseeable uncertainty to the compliance process, because such
changes will not always be known at the time a manufacturer of the ADB
vehicle conducts self-certification testing or to a third-party
conducting compliance testing for the agency.
Agency Response
The final rule specifies test fixtures conforming to SAE J3069 with
respect to the types of fixtures and photometer placement. The final
rule departs from SAE J3069 by specifying vehicle lamps from high-
selling vehicles instead of lamps intended to simulate vehicle
lighting.
The final rule specifies the same four types of fixtures specified
in SAE J3069: An oncoming car/truck fixture; a preceding car/truck
fixture; an oncoming motorcycle fixture; and a preceding motorcycle
fixture. The final rule follows the SAE specifications for the
locations of the stimulus lighting. SAE based these locations on data
regarding the typical mounting locations of vehicle lighting. NHTSA
agrees that these locations are appropriate, and within the FMVSS No.
108 mounting location requirements.
The rule also follows SAE J3069 for the locations of the
illuminance meters. SAE based these locations on data regarding typical
driver's eye heights and mounting locations for the rearview/side
mirrors. The illuminance meter locations specified in the final rule
are the same as in the proposal, with one exception. In its recent
revisions to SAE J3069, SAE revised the specifications for the
placement of the illuminance meters (corresponding to two side-view
mirrors) on the preceding motorcycle fixture. The revision notes that
the figure depicted in the prior version of the practice showed the
mirrors to be 0.2 m from the centerline of the rear position lamp,
which is not consistent with the FMVSS No. 111 required minimum. FMVSS
No. 111 requires that each motorcycle have a mirror ``mounted so that
the horizontal center of the reflective surface is at least 279 mm
outward of the longitudinal centerline of the motorcycle.'' \122\ The
revised version of SAE J3069 shows the motorcycle mirror separation to
be 0.4 m, which is consistent with the FMVSS No. 111 required minimum.
The specification in the final rule adopts this revised specification.
---------------------------------------------------------------------------
\122\ S10.1.
---------------------------------------------------------------------------
We did, however, agree with Mobileye that--as we also tentatively
concluded in the NPRM--the simulated lamps specified in SAE J3069 would
not be sufficiently realistic. We therefore agreed with Mobileye's and
Auto Innovators' suggestions to use standardized vehicle lamps on the
fixtures. The final rule therefore departs
[[Page 9947]]
from SAE J3069 and specifies actual vehicle lamps for the fixtures. The
reasons for this choice are explained in more detail below. The final
rule specifies headlamp assemblies from a 2018 Ford F-150 (halogen) and
a 2018 Toyota Camry (LED). For motorcycles, the final rule specifies a
5.75 inch headlamp assembly from a 2018 Harley Davidson Sportster using
an HB2 replaceable light source.\123\ The rule specifies right and left
taillamp assemblies from a 2018 Ford F-150 incandescent rear
combination lamp and right and left tail lamp assemblies from a 2018
Toyota Camry combination lamp. For motorcycles, the final rule
specifies a layback LED taillamp assembly from a 2018 Harley Davidson
Roadster.
---------------------------------------------------------------------------
\123\ This is different than the motorcycle headlamp used in
NHTSA recent testing. For that testing, NHTSA used a 5.75 inch
bullet headlamp kit from a 2018 Harley Davidson Roadster using an
HB2 replaceable light source (part #68593-06). After that testing
and before the publication of this final rule, that part went out of
production and has been replaced with part #68297-05B.
---------------------------------------------------------------------------
There were several reasons for specifying actual vehicle lamps.
NHTSA agrees with the concerns Mobileye identified regarding the use of
synthetic fixture lighting and with Intertek that specifying synthetic
lighting could result in vehicle manufacturers programming systems to
recognize unrealistic fixtures, thus decoupling compliance test
performance from actual performance.\124\ The agency's intent was to
specify a variety of light source technologies that are common in the
market in order to assess how an ADB system performs with respect to
light systems it will encounter while in actual use on the roads. This
will discourage manufacturers from designing specifically to fixture
lamps lacking characteristics typical of actual automotive lamps (e.g.,
non-uniform illuminance, variations in shape). Using actual vehicle
lamps also reduces the cost of manufacture of the test fixture (since
the highly specialized SAE fixture lighting is much more expensive).
The agency agrees with Bosch that it is important that the lamps on the
fixtures continue to be representative of vehicle lamps in use. To that
end, NHTSA envisions future technical rulemakings to amend the lamps
specified in the regulatory text.
---------------------------------------------------------------------------
\124\ SAE J3069 MAR2021 added a note requiring that any pulse
width modulation or similar frequency control be sufficiently above
the commercial power grid frequency and updated the conical angle
specification. Even with these changes, NHTSA still believes that
the finalized vehicle lighting is more appropriate.
---------------------------------------------------------------------------
The agency also does not believe that the synthetic light sources
specified in SAE J3069 represent a worst-case scenario. As NHTSA
explained in the NPRM, the minimum taillamp intensities allowed by
FMVSS No. 108 (2.0 cd at H-V and as low as 0.3 cd at 20 degrees) are
considerably lower than the 7.0 cd lamp specified in SAE J3069. NHTSA
also does not agree with SAE that specifying actual vehicle headlamps
would result in excessive variability, but continues to believe, as
stated in the NPRM, that gradients in typical headlamp beam patterns
would likely only affect the repeatability of the test if the reaction
by the ADB system changes based on this difference. If this is the
case, the ADB system will have this issue in actual use (especially
since the specified headlamps are from high-selling vehicles and
therefore common on the road), and this should not be considered
variability attributable to the test, but a failing of the ADB system.
In any case, NHTSA's testing showed that the tested ADB system was
generally able to recognize the fixtures fitted with these lamps.
Comparative test data for the SAE fixtures and the final rule fixtures
is presented in the discussions for each scenario (see Section
VIII.C.8).
The final rule also clarifies various aspects of the test
procedures related to the fixture lamps. It clarifies that the stimulus
headlamps will have the lower beam activated and aimed per the SAE
Recommended Practice J599 Lighting Inspection Code (J599) procedures,
as applicable. The final rule also specifies how to power the fixture
lamps. SAE J3069 does not specify how to power the test-fixture
lighting; this could leave open the possibility of powering the fixture
in ways that are dissimilar to how actual automotive head and taillamps
are powered, and potentially lead to ambiguities in how performance is
measured. Accordingly, the final rule specifies that the lamps will
have been energized for at least 5 minutes before each test scenario
trial is performed.
The agency considered Mobileye's comment that the fixture should
resemble a ``standard'' vehicle but decided not to adopt this. Using a
fixture incorporating vehicle elements (e.g., hood, grill) raises
issues of which elements to specify and how to specify them. NHTSA did
consider implementing a portion of a vehicle in the fixtures, such as a
partial front or rear section of a vehicle that would include the
original equipment lamps as mounted in the production vehicle.
Including a portion of the actual vehicle body would provide a more
real-world stimulus with the added detail of some elements of vehicle
shape and light reflections on the body surfaces. However, while this
option was not examined in NHTSA's research, our research did not
demonstrate any significant difference in ADB response between actual
stimulus vehicles and the test fixtures we are specifying, suggesting
that adding detail elements to the fixture is not necessary.\125\
---------------------------------------------------------------------------
\125\ SAE J3069 MAR2021 allows the fixture to be ``constructed
in a manner that represents the intended vehicle type to avoid false
readings that the stimulus fixture is not a vehicle'' (sections
5.5.2.1 and 5.5.3.1). As noted in the text, we considered but did
not examine this alternative. However, we believe, based on the
results of our testing (see Section VIII.C.2, Test Fixtures vs.
Stimulus Vehicles), that specifying actual vehicle lamps makes the
fixtures sufficiently realistic so that the ADB system will
recognize the fixture as a vehicle.
---------------------------------------------------------------------------
With respect to Auto Innovators' comment regarding the possibility
of a noncompliance of actual vehicle components used as a stimulus in a
compliance test, NHTSA recognizes this possibility, but anticipates
that the laboratory test procedures will provide for confirming that
the vehicle lamps used on the test fixture comply with the applicable
FMVSS No. 108 photometry requirements.
7. Test Fixture Placement
The proposal specified stimulus vehicles in the adjacent left lane
to evaluate oncoming glare. To evaluate preceding glare, it essentially
specified the stimulus vehicle either in the same lane as the test
vehicle or in the adjacent left lane.
The final rule, while specifying test fixtures, generally follows
the NPRM approach. The test fixture will be placed in the adjacent left
lane (from the perspective of the test vehicle) to evaluate both
oncoming glare and preceding glare, essentially the same placement as
proposed.\126\ See Figure 10 (Figures 27-28 in the regulatory text).
This corresponds to Fixture Position 2 in SAE J3069. The final rule
does not specify fixtures situated similarly to SAE Positions 1 and 3.
In the SAE test method, fixtures placed in those locations are
primarily intended to simulate curves; the final rule includes curved-
path scenarios, so simulating curves with strategic fixture placement
is not necessary. The final rule also specifies that the projection of
the fixture lamp's optical axis onto the road surface should be tangent
to the road edge at the location of the photometer, and that the
fixture be centered in the lane.
---------------------------------------------------------------------------
\126\ The test vehicle will be driven within the right adjacent
lane and will not change lanes.
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[[Page 9948]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.010
BILLING CODE 4910-59-P
NHTSA acknowledges that it is common in real-world driving for
preceding vehicles to be located in the same lane or in the adjacent
right lane. However, the agency believes that simply testing with the
preceding fixture in the left adjacent lane will not result in a loss
of information about ADB system performance. The purpose of the testing
is to evaluate whether the ADB system is working in an integrated
fashion; this can be done on either side. While real-world situations
with a stimulus to the right side are common, it is reasonable to
expect that if a system functions on the left it will also function on
the right. Further, the final rule also has tests that include curves
to the right, where the detection system is exercised (limited to
oncoming and limited distances) on the right side of the field of view.
8. Test Scenarios \127\
---------------------------------------------------------------------------
\127\ The test scenario numbering used in the preamble and in
the final rule regulatory text (at Table XXII) differs somewhat from
the test scenario number in the ADB test report and repeatability
assessment docketed with this final rule.
---------------------------------------------------------------------------
a. Scenario 1: Oncoming Straight
The NPRM proposed testing for oncoming glare in a straight-path
test scenario at speeds from 60 mph to 70 mph at measurement distances
of 15 m to 220 m.
Comments
ALNA, Toyota, SAE, and the Alliance commented that the proposed
glare limits are at or well below those regularly occurring today from
lower beams, including, the commenters appeared to suggest, in a
straight-path scenario. SAE and the Alliance stated that the glare
limits are not reasonable if lower beams, including IIHS ``Good''-rated
lower beams, would fail to comply. SAE provided a graphical analysis
(based on IIHS data) of lower beam illuminance on a straight road (from
0 m to 125 m) for nine MY 2017 IIHS Top Safety Picks, all with FMVSS
108-compliant IIHS-rated ``Good'' headlamps. The graph shows that
almost all those headlamps complied with the proposed glare limits at
all proposed measurement distances.
Agency Response
NHTSA is finalizing the proposed specifications for this scenario,
including the proposal to evaluate illuminance from 15 m to 220 m. The
rule thus evaluates glare across a broader range of distances than SAE
J3069, which evaluates glare at 30 m, 60 m, 120 m, and 155 m,
respectively. The reasons for choosing this range are discussed in the
NPRM (83 FR at 51778-51781) and elsewhere in this preamble.
The available data indicate that current lower beams can comply
with the glare limits in this scenario. The IIHS data submitted by SAE
show that the lower beams for the 9 vehicles for which data was
provided were generally within the glare limits on a straight road for
all the distances for which the final rule regulates glare. NHTSA's
testing also shows that current lower beams would pass this scenario.
NHTSA tested the lower beams of a MY 2019 Ford Fusion and MY 2016 Volvo
XC90 in this scenario. The measured illuminance of the lower beams was
found to be within the glare limits by a considerable margin at all
distances. See Figure 11 and Figure 12.\128\
---------------------------------------------------------------------------
\128\ The illuminance measured from the higher-mounted
photometer representing the truck driver eye point, is, as expected,
lower than that measured from the lower-mounted photometer intended
to represent a passenger car driver's eye point. For that reason,
some of the test data included in this preamble may not report the
illuminance values measured from the higher-mounted illuminance
meter.
---------------------------------------------------------------------------
[[Page 9949]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.011
NHTSA's analysis and testing also indicate that current ADB systems
can reasonably be expected to comply with this scenario. As Figure 7
makes clear, the fixture is within the ADB camera's field of view at
the beginning of the measurement range, at less than 5 degrees left of
the center of the field of view. (As noted earlier, the field of view
of current ADB systems extends to about 25 degrees left and right.)
Accordingly, the ADB system should have sufficient time to detect and
react to the fixture stimulus lamps and adjust the beam. The agency's
ADB test data confirms this. For example, the ADB system we tested was
within the glare limits at all distances when tested with the oncoming
car/truck fixture. See Figure 13. Additionally, NHTSA's 2015 testing
showed that an older ADB system was able to pass this scenario even
when tested with stimulus vehicles, both moving and stationary.\129\
---------------------------------------------------------------------------
\129\ 2015 ADB Test Report at p. 103 (Table 23) (results for
Audi show adaptive beam within the glare limits at all distances on
the straight scenario, with both a static and dynamic stimulus
vehicle). Audi indicated that the shaded area of the adaptive beam
complied with the FMVSS No. 108 lower beam requirements.
---------------------------------------------------------------------------
The ADB system also passed the SAE scenario that is the closest
analog to this scenario (with the car/truck test fixture in Position
2), and NHTSA did not see a significant difference between performance
on the NHTSA and SAE test protocols here.\130\ See Figure 13.
---------------------------------------------------------------------------
\130\ Agency testing showed some anomalies when testing with the
motorcycle fixtures (both the final rule fixture and the SAE
fixture). For that reason, the results of that testing are discussed
separately. See Appendix C.
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[[Page 9950]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.012
b. Scenario 2: Oncoming Small Left Curve
The NPRM provided for testing oncoming glare on left curves with
radii of 98 m to 116 m, at speeds from 20 mph to 30 mph, for the full
range of 15 m to 220 m.
Comments
In addition to general comments from several manufacturers that the
proposal would require ADB systems to produce less glare than current
FMVSS No. 108-compliant lower beams, particularly on curves, SAE
provided a graphical analysis of IIHS data of illuminance from nine
``Good''-rated lower beams from 0 m to 125 m on a 150 m left curve. The
data show that almost all the lower beams were within the glare limits
in this entire range, except that one vehicle occasionally exceeded the
glare limits between 15 m and 60 m, one vehicle exceeded the glare
limits at 15 m, and a couple of vehicles exceeded the glare limits
between about 60 m and 90 m.
The Alliance, SAE, OICA, and SMMT commented that current ADB
systems would not comply with this scenario because it would
necessitate a camera field of view wider than provided on current ADB
systems. The Alliance stated that the camera visibility needed to
detect a stimulus vehicle on this curve is almost 45 degrees (with a
median) and 40 degrees (without a median). Both the Alliance and SAE
contended that, should this scenario be retained, camera visibility
would have to be extended, which would increase costs, potentially
diminish performance in the more critical central portion of the
visibility zone, and create dis-harmonization, limiting the
availability of ADB systems in the United States. SAE also stated that
upper beams at greater than 15 degrees left or right are not as bright
as lower beams straight ahead, and at an angle of 40 degrees the light
toward a stimulus vehicle driver is low. SAE stated that this is
supported by the fact that millions of semiautomatic beam systems on
the roads today are equipped with the same or similar forward vision
cameras and detection algorithms as ADB systems and have not resulted
in glare complaints. This suggests, SAE asserted, that wide angle
visibility (i.e., beyond 25 degrees) is unnecessary and precludes any
need to test on curves of these radii.
Honda commented that the proposed 0.1 s or 1 m allowance for
momentary spikes does not allow enough time for an ADB system to
respond to sudden changes in stimulus lighting, and that this
especially might be an issue on curves with a radius of 98 m-116 m, on
which an opposing vehicle will enter the ADB system's field of view
suddenly at a close distance.
Agency Response
The final rule retains this scenario but modifies the distances at
which illuminance from the ADB system is evaluated: The measurement
range now begins at 59.9 m \131\ instead of the proposed 220 m. The
reasons for this are explained below.
---------------------------------------------------------------------------
\131\ In the regulatory text this is specified as ``less than 60
m.'' Other distance specifications are stated similarly. The
preamble discussion simplifies this for ease of exposition.
---------------------------------------------------------------------------
First, the available data indicate that current, FMVSS 108-
compliant lower beams might not comply with the glare limits at
distances greater than 60 m but would generally comply at closer
distances. The IIHS data submitted by SAE show that almost all the
tested lower beams were almost fully within the glare limits in the
modified distance range (15 m-59.9 m), while some of the lower beams
exceeded the glare limits for distances greater than 60 m. NHTSA's
testing also shows that current lower beams would pass this modified
scenario. NHTSA tested two vehicles with lower beams activated on an 85
m left curve, and both vehicles performed well with considerable
margins. See Figure 14.
[[Page 9951]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.013
Next, NHTSA believes that this modified specification is within the
capabilities of most current ADB systems. On a curve with a 100 m
radius, at the highest vehicle speed specified for this scenario (30
mph), the fixture will enter the camera's field of view (25 degrees) at
77 m (see Figure 7). At the distance at which the final rule begins
evaluating the system's illuminance (59.9 m), the fixture is therefore
well within the camera's field of view (at about 21 degrees). The
fixture is not only within the camera's FOV, but has been within the
FOV for 1.24 s, which is a sufficient time for an ADB system to react.
NHTSA acknowledges that for shorter radii in the specified range, the
time elapsed between the fixture entering the system's field of view
and the test vehicle reaching the beginning of the evaluation range
(59.9 m), may not provide sufficient time for an ADB system to react
and switch from an area of unreduced intensity (i.e., upper beam) to an
area of reduced intensity. For example, on a curve with an 85 m radius
at 30 mph, the fixture will enter the camera's field of view at 63 m.
At 59.9 m, the fixture will have been within the system's FOV for 0.13
s. The agency does not, however, expect this to result in a
noncompliance because at that distance the headlamps are at a large
enough angle to the photometer that the upper beam should be within the
glare limits. (Agency testing generally showed that the upper beam was
within the glare limits at angles greater than 20 degrees. There are no
upper beam photometry requirements at angles wider than 12 degrees. At
12 degrees, Table XVIII specifies (depending on the type of upper beam)
a minimum of, at most, 1,500 cd (at horizontal) and 1,000 cd (at 2.5D).
NHTSA's ADB test data bear this out. When NHTSA tested an ADB
system at 29 mph on a curve at the upper bound of the range (115 m),
the ADB system detected and reacted to the fixture prior to the
measurement range. See Figure 15. On the other hand, when testing the
ADB system on a curve at the lower bound of the radius range (85 m),
the system did not react to the fixture and dim the beam until 41 m--
which is after the specified beginning of the measurement range (59.9
m). See Figure 16. However, the illuminance (the upper beam) at these
large angles was below the applicable glare limit, and the system was
able to react and adapt the beam before the geometry was such that the
narrower angle of the upper beam would exceed the glare limit.
[[Page 9952]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.014
NHTSA also tested the SAE scenario that is the closest analog to
this scenario (with the oncoming fixtures in Position 1) and observed
no glare limit exceedances. See Figure 17. However, the illuminance
was, for closer distances, significantly lower than the illuminance
measured during the corresponding final rule scenario. This is because,
as the test vehicle approaches the SAE fixture, the fixture moves more
and more off-angle from the test vehicle as the distance closes,
resulting in lower-than-expected illuminance.
[[Page 9953]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.015
NHTSA notes that this scenario, as modified, does not evaluate
illuminance from 60 m to 220 m, so it would not test whether the ADB
system switched from an upper beam to an adaptive beam in this range.
In the NPRM the agency tentatively concluded that it was important to
regulate illuminance in the full range of 15 m-220 m. However, as
explained above, NHTSA decided the full range is unnecessary because an
upper beam projected at angles larger than 20 degrees is not glaring at
distances beyond those at which we are evaluating illuminance in this
scenario.
c. Scenario 3: Oncoming Medium Left Curve
NHTSA proposed testing for oncoming glare on left curves with radii
of 223 m to 241 m, at speeds of 40-45 mph, for the full range of 15-220
m.
Comments
NHTSA received one comment specifically related to this scenario.
SAE provided a graphical analysis of IIHS illuminance data (out to 125
m) for nine lower beams on a 250 m left curve showing that all the
lower beams were within the glare limits, except for two headlamps that
had some exceedances between 60 m and 110 m. As noted earlier, some
commenters argued more generally that the proposed glare limits were so
stringent that even currently-compliant lower beams would exceed them.
Agency Response
The final rule modifies the measurement range, which now begins at
150 m instead of the proposed 220 m. The rationale for this is
analogous to the rationale for limiting the measurement distances for
the small left curve.
First, the available data indicate that compliant lower beams would
generally comply with these requirements. As explained earlier, this
(in conjunction with the requirement that areas of reduced intensity
meet the corresponding lower beam laboratory photometric requirements)
means that an area of reduced intensity, up to and including a full
lower beam, will meet the same level of safety (with respect to both
visibility and glare prevention) as current lower beams certified to
FMVSS No. 108. The IIHS data submitted by SAE shows that almost all the
tested lower beams complied with the glare limits for the distances for
which data was reported. NHTSA's testing also shows that current lower
beams would pass this modified scenario; both lower beams NHTSA tested
had illuminance values within the glare limits by a considerable
margin. See Figure 18.
[[Page 9954]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.016
Next, NHTSA's analysis also indicates that the modified
specifications are within the field-of-view and adaptation time
capabilities of most current ADB systems. For example, on a 230 m curve
at 45 mph, over two seconds elapse between the fixture entering the
field-of-view and the vehicle reaching the measurement range (150 m),
providing the ADB system sufficient time to react and adapt the beams.
As with the small left curve, however, for shorter radii in the
specified range, the time elapsed between the fixture entering the ADB
system's field of view and the vehicle reaching the beginning of the
measurement range may not provide sufficient time for the ADB system to
adapt and switch from an area of unreduced intensity to an area of
reduced intensity. For example, on a 210 m curve, only .57 seconds
elapse. However, as with the small left curve, at those distances the
headlamps are at a large enough angle to the photometers that the upper
beam should be within the applicable glare limit.
Again, NHTSA's ADB test data bears this out. NHTSA tested an ADB
system on a 210 m left curve at 44 mph. See Figure 19. The measured
illuminance values were within the glare limits except for two
exceedances lasting less than 0.1 s (which would not be considered a
noncompliance because they are within the allowance for momentary glare
exceedances). The ADB system reacted to the fixture at 120 m. Prior to
that (i.e., from 150 m to 121.9 m), the ADB system was projecting an
upper beam, but the upper beam was within the glare limits.
In comparison, when testing the most analogous SAE test scenario
(with the fixture in Position 1) there were no glare limit exceedances,
and, at closer distances, the SAE test scenario resulted in lower
illuminance values than were measured on the actual left curve.
[GRAPHIC] [TIFF OMITTED] TR22FE22.017
[[Page 9955]]
In addition, as noted earlier for the small left curve scenario,
although the final rule reduces the start of the measurement distance
in this scenario from 220 m to 150 m, this should not present a risk
that oncoming vehicles will experience glare outside of 150 m for the
reasons discussed earlier.
d. Scenario 4: Oncoming Large Left Curve
The NPRM specified testing for oncoming glare on left curves with
radii of 335-396 m, at speeds of 50-55 mph, from 15 m to 220 m.
Comments
NHTSA did not receive any comments that related specifically to
this curve. Commenters argued more generally that currently-compliant
lower beams would not always comply with the glare limits, especially
on curves, and that there might not be sufficient time for the ADB
system to react to the stimulus lighting.
Agency Response
The final rule adopts this scenario essentially as proposed (the
largest-specified radius of curvature has been rounded up). Both a
lower beam and an ADB system can reasonably be expected to comply with
the glare limits throughout this range.
The available data indicate that current FMVSS No. 108-compliant
lower beams can comply with the glare limits in the full measurement
range. The IIHS data submitted by SAE did not include a left curve with
a radius this large. However, the IIHS data did include lower beam
performance on a 250 m radius left curve and a straight road. As
explained in the preceding section for the medium left curve scenario,
all the IIHS-tested headlamps were essentially within the glare limits
at all distances for which data was reported (out to about 125 m) on
both the 250 m left curve and the straight road. Because the curve in
this scenario is essentially between a 250 m left curve and a straight
road, it is reasonable to extrapolate that the lower beams tested by
IIHS would also have complied on left curves with radii greater than
250 m. NHTSA's test data confirms this. Both the Fusion and the Volvo
lower beams were within the glare limits on this curve. See Figure 20.
[GRAPHIC] [TIFF OMITTED] TR22FE22.018
[[Page 9956]]
These specifications are also within the capabilities of current
ADB systems. On a curve with a 335 m radius at the highest speed
specified for this scenario (55 mph), the fixture will enter the
camera's field of view (25 degrees) at 283 m (see Figure 7). At the
distance at which we will begin evaluating the system's illuminance
(220 m), the fixture is therefore well within the camera's field of
view (at about 20 degrees), and has been within the FOV for 1.27 s,
which is sufficient time for an ADB system to react.
NHTSA's testing confirmed this. The ADB system tested was generally
able to respond and shade the fixture in this scenario. See Figure 21.
The system reacted at 185 m and performed well from a recognition
standpoint. The area of reduced intensity exceeded the limits in the
60-120 m range as well as the 30-60 m range. Because these exceedances
last longer than 0.1 s. and occur while the vehicle pitch is less than
0.3 degrees from the average pitch throughout the run, these
exceedances would be considered possible noncompliances. However, these
failures are relatively marginal, and the beam pattern could be
modified to fully comply with this scenario.
[GRAPHIC] [TIFF OMITTED] TR22FE22.019
As with the other oncoming left curve scenarios, the closest SAE
test analogue is with an oncoming fixture in Position 1. Again, NHTSA's
testing showed that, compared to NHTSA's test, the SAE test resulted in
much lower illuminance at close distances than on an actual curve. See
Figure 22. Thus, data indicate again that the two test methods can
yield different results, and that the actual curve test is preferable
because it would be more evaluative of real-world performance.
[GRAPHIC] [TIFF OMITTED] TR22FE22.020
BILLING CODE 4910-59-P
e. Scenario 5: Oncoming Medium Right Curve
The NPRM proposed regulating glare on right curves with a radius of
223 m to 241 m, at speeds of 40-45 mph, from 15 m to 220 m.
Comments
SAE provided a graphical analysis of illuminance data for nine IIHS
``Good''-rated lower beams on a 250 m radius right curve from 0 m to
125 m and
[[Page 9957]]
stated that it demonstrated none of those lower beams would meet the
proposed glare limits. Other commenters argued more generally that
current lower beams would exceed the proposed glare limits, especially
on curves. Intertek commented that NHTSA should limit the range for
right-hand curves to account for lower beam patterns at 3 degrees
right. Stanley ran simulations for a 232 m radius right curve and
commented that the proposed glare limits appeared to be inconsistent
with the current photometric requirement for lower beams at several
points (especially from 1R to 3R). It asked that the agency reconsider
the proposed glare limits and make them consistent with the current
regulatory requirements for lower beams.
Agency Response
The final rule retains this scenario but revises the measurement
range to begin at 50 m instead of the proposed 220 m.
NHTSA agrees with the commenters that current compliant lower
beams--especially ones that perform well on the IIHS test--would likely
not comply with the glare limits from 51 m-220 m. The IIHS data
submitted by SAE show that almost all the lower beams tested by IIHS
exceeded the glare limits at distances of 60 meters and greater on a
250 m right curve. NHTSA also examined IIHS lower beam data for a 2020
Toyota Camry with ``Good''-rated LED lower beams.\132\ IIHS measured
that vehicle on a 250-m radius curve to have a 5-lux line at 79.5 m
\133\ (70 m is the minimum without receiving demerits), which would
exceed the applicable glare limit at that distance (0.6 lux).
---------------------------------------------------------------------------
\132\ See www.iihs.org/ratings/vehicle/toyota/camry-4-door-sedan/2020#headlights (last accessed Dec. 18, 2020).
\133\ Corresponding to approximately 0.3D, 7R.
---------------------------------------------------------------------------
After considering the comments, NHTSA has determined that these
results should have been generally expected based on a comparison of
the oncoming glare limits and the longstanding Table XIX lower beam
photometry requirements that regulate lower beam design. The oncoming
glare limits were derived from the Table XIX left-side maxima (700 cd
at 1U, 1.5 L to L and 1,000 cd at 0.5 U, 1.5L to L).\134\ On a right
curve, however, the fixture enters the lower beam pattern from the
right side and traces a trajectory across the beam pattern from right
to left (See Figure 7). The Table XIX right-side maxima (1,400 cd at
1.5U, 1R to R and 2,700 cd at 0.5U, 1R to 3R) are higher than the left-
side maxima. In addition, unlike on the left side, the right-side
photometry is not limited at 0.5U extending indefinitely horizontally.
The left-side photometry is limited by the line 0.5U, 1.5L-L. The
right-side photometry is limited by 0.5U, 1R-3R. While right-side
photometry is ultimately limited at 1.5U, 1R-R, this line provides
considerably more flexibility to provide light down the right side.
Consequently, the Table XIX right-side maxima, on which current lower
beams are based, permit intensities that exceed the oncoming glare
limits, which were derived from the left-side maxima. Indeed, data show
that current compliant lower beams exceed the derived glare limits on
the right side at distances greater than 50 m. More specifically, based
on the IIHS data presented by SAE, exceedances at about 3R and greater
(corresponding to measurement distances of greater than about 50 m) are
found, and many fewer glare limits exceedances to the left of 3 degrees
right. Accordingly, the final rule revises this scenario so that the
measurement range does not start until 50 m.
---------------------------------------------------------------------------
\134\ Feasibility Study, p. 23.
---------------------------------------------------------------------------
The agency notes that even with this modification, the glare limits
in this final rule are still (as Stanley suggested) more stringent than
currently allowed by the Table XIX right-side maxima from 1R to
3R.\135\ However, this level of stringency is reasonable and provides a
manageable design range. The lower beam photometry was designed to
provide a generic beam to prevent glare regardless of the actual road
and traffic conditions; it was not customized to provide glare
protection to oncoming vehicles on a right curve. Because most
situations in which an oncoming vehicle can be glared will occur with
the oncoming vehicle to the left, the existing Table XIX lower beam
photometry requirements require shading the left side and permit more
light on the right side. However, the adaptive driving beam is not, and
need not be, an all-purpose beam like a conventional lower beam. It is
clear in the photometry tables that the appropriate glare limits for
oncoming situations are the left-side maxima in Table XIX, on which the
oncoming glare limits are based. These limits should, to the extent
possible, apply to oncoming glare, including from the right-side. In
any case, the agency believes that current lower beams would generally
comply with the glare limits as applied in this scenario with the
revised measurement distance range.
---------------------------------------------------------------------------
\135\ In Appendix A, we provide additional data and discussion
on this.
---------------------------------------------------------------------------
Indeed, both IIHS and NHTSA lower beam test data demonstrate that
compliant lower beams, including high-rated IIHS beams, would generally
be within the glare limits in this revised scenario. The IIHS data
submitted by SAE shows that for distances between 15 m and 60 m, most
of the lower beams were within the glare limits. Vehicles 1 and 7 seem
to take the most advantage of the flexibilities provided toward the
right side beyond 3 degrees in performing well in the IIHS right-curve
test, and the lower beams on both vehicles were below the glare limits
within 50 m. This demonstrates that a vehicle can both perform well on
the IIHS right-curve distance rating and stay within the glare limits
in this final rule's revised scenario.
NHTSA's testing also showed that current lower beams can pass this
revised scenario. NHTSA tested two lower beams on a 210 m right curve,
and both were within the glare limits at all distances within the
specified measurement range. See Figure 23. The agency also saw similar
results in our 2015 testing, which (among other things) evaluated lower
beam illuminance on a 231 m right curve, and found that the lower beams
exceeded the glare limits at 60 meters and greater, and was within the
glare limits from 15 m to 60 m.\136\
---------------------------------------------------------------------------
\136\ 2015 ADB Test Report, p. 193 (Fig. 85, Mercedes Trial 82
[lower beam]); p. 63 (Mercedes test vehicle modified by manufacturer
to produce a FMVSS No. 108 compliant beam pattern).
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[[Page 9958]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.021
NHTSA notes that these data from contemporary lower beams differ
somewhat from data on 1990s-era lower beams presented in the
Feasibility Study. Specifically, Figure 9 in the Feasibility Study,
which displayed a lower beam pattern typical of MY 1997 vehicles, seems
to indicate that lower beams would likely be within the oncoming glare
limits on the right side of the beam pattern illustrated in Figure 9.
However, as Auto Innovators pointed out in its comment, lower beam
design has changed since 1997. NHTSA believes it is reasonable to
assume that at least some manufacturers are supplying more light at or
just above the horizon for horizontal angles greater than 3 degrees
right (without violating the 1,400 cd maximum) than in the past in
order to perform well on the IIHS tests.\137\ Lower beams that are
designed to perform well on the IIHS test may thus be more likely to
fail the glare limits in the ADB track test, even if the system is
projecting an area of reduced intensity onto the fixture. This is
compounded by the effect of vehicle pitch: With higher intensity light
at larger vertical angles of the beam pattern, slight changes in pitch
can push the higher intensity portion of the lower beam upwards and
cause the oncoming glare limit to be exceeded. Further, at angles
beyond 3 degrees right, the glare limits begin to veer dramatically
from the flexibilities provided in the current Table XIX requirements
(specifically, the right-side maxima). Accordingly, the oncoming glare
limits, in conjunction with the revised measurement distances, are
consistent with the angular limits of the current lower beam
photometry. The track test continues the longstanding flexibilities for
lower beam design on the right side beyond 3 degrees.
---------------------------------------------------------------------------
\137\ Comment from Alliance for Automotive Innovation (July 31,
2020) (NHTSA-2018-0090-0219), p. 11 (Fig. 5, Low-Beam Headlight
Intensity Pattern from IIHS Headlight Rating.
---------------------------------------------------------------------------
The modified specifications for this scenario are also within the
capabilities of typical ADB systems. Because illuminance is evaluated
starting at 50 m from the fixture, there is more than enough time for
an ADB system to detect and react to the fixture (more than 7 seconds
on a 230 m radius curve).
The agency's ADB test data bear this out. When testing an ADB
system on a 210-meter radius right curve, the illuminance was within
the glare limits except for some limited exceedances, which can readily
be addressed by minor changes in the design of the area of reduced
intensity. See Figure 24. Similarly, the 2015 testing with actual
stimulus vehicles showed that even an older ADB system was able to pass
a right curve (231 m) oncoming scenario at 15 m to 50 m.\138\
---------------------------------------------------------------------------
\138\ 2015 ADB Test Report, p. 193 (Fig. 85, Mercedes Trial 83
[ADB]); p. 63 (Mercedes test vehicle modified by manufacturer to
produce a FMVSS No. 108 compliant beam pattern).
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[[Page 9959]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.022
The ADB system NHTSA tested had more exceedances when tested to the
most closely analogous SAE J3069 scenario (with the test fixture in
Position 3) compared to NHTSA's test. See Figure 25. This is because at
the measurement distances in this scenario, Fixture Position 3 is in
the bright (right-side) portion of the beam pattern, while the fixture
in NHTSA's test scenario is in the less-bright portion of the beam
pattern (center-right to center-left).
[GRAPHIC] [TIFF OMITTED] TR22FE22.023
NHTSA notes that this scenario does not evaluate the illuminance
from the ADB system from 50 m-220 m, so it would not test whether the
ADB system switched from an upper beam to an adaptive beam in this
range. NHTSA believes this is acceptable because the left curve
scenarios generally test the ability of the ADB system to react and it
is reasonable to expect similar reactions on the left and right side.
The right curve test simply confirms the right side is performing
similarly by applying the oncoming glare limits to narrow angles on the
right side and providing greater flexibility at broader angles on the
right side of the vehicle.
f. Scenario 6: Oncoming Large Right Curve
The NPRM proposed regulating glare on right curves with a radius of
335 m to 396 m at 50-55 mph from distances of 15 m to 220 m.
[[Page 9960]]
Comments
As explained above regarding the medium right curve scenario,
Stanley ran simulations for right curves with a radius of 366 m and
commented that the oncoming glare limits were effectively more
stringent than the current Table XIX photometry on the right side of
the beam pattern. In addition, as noted earlier, commenters argued more
generally that the proposed glare limits were so stringent that
compliant lower beams would exceed them, and that there might not be
sufficient time for the ADB system to react to the stimulus lighting.
Agency Response
This final rule modifies the proposal, similar to the modifications
for the medium right curve, in response to comments that current
compliant lower beams might not comply with the NPRM's glare limits at
all the proposed measurement distances. As explained earlier, this (in
conjunction with the requirement that areas of reduced intensity meet
the corresponding lower beam laboratory photometric requirements) means
that an area of reduced intensity, up to and including a full lower
beam, will meet the same level of safety (with respect to both
visibility and glare prevention) as current lower beams certified to
FMVSS No. 108. As NHTSA agrees with Stanley and other commenters that
the proposed scenario permitted less glare than presently required of a
lower beam on the right side of the beam pattern, NHTSA has narrowed
this angle not to go beyond 3 degrees right, to provide flexibility at
larger angles. The final rule therefore specifies testing on a right
curve with a radius of 335--400 m at distances of 15 m to 70 m, at the
proposed speeds of 50-55 mph.
NHTSA believes that a lower beam that is FMVSS No. 108-compliant
and performs well on the IIHS test would generally be able to comply
with the glare limits in this scenario. The reasons for this are
analogous to the reasons given earlier for revising the measurement
distance in the medium right curve scenario. None of the IIHS data
submitted by SAE was for a right curve of this diameter. NHTSA tested
two lower beams on this scenario. See Figure 26. The Fusion lower beam
was within the glare limits at all specified distances, while the Volvo
lower beam exceeded the glare limits at distances from 60 m--70 m. This
is likely because, as explained earlier, the Table XIX photometry
requirements and the IIHS test have prompted some manufacturers to
provide greater light on the right side. NHTSA believes such systems
can comply with the requirements with minor modifications. This is also
consistent with what Stanley points out in its comment.
[[Page 9961]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.024
The agency also believes that the finalized requirements are within
the capabilities of existing ADB systems, for reasons analogous to
those provided for the medium right curve scenario above. The ADB NHTSA
system tested was within the glare limits in this scenario except at
distances greater than 60 m. See Figure 27. This is similar to the
results for the Volvo lower beam and, we believe, can be addressed with
minor system modifications. Agency test data also confirm that the most
closely analogous SAE test scenario (Fixture Position 3) does not
accurately replicate an actual right curve; the measured illuminance on
this scenario was significantly higher than in the analogous SAE
scenario. Thus, the data indicate again that the two test methods can
yield different results, and that the actual curve test is preferable
because it would be more evaluative of real-world performance.
[[Page 9962]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.025
g. Scenario 7: Preceding Straight
The NPRM proposed testing for preceding glare in a variety of
vehicle maneuvers, on both straight and curved roadway. It proposed
scenarios in which a stimulus vehicle preceded the test vehicle in the
same lane and in which the test vehicle overtakes the stimulus vehicle,
and vice versa. We proposed evaluating glare out to 119.9 m.
Comments
SAE commented, with respect to NHTSA's statement in the NPRM that
the ECE ADB regulations require ADB cameras to be capable of sensing
vehicles out to 400 m, that this only applies to opposing vehicles
(headlamps), not preceding vehicles (rear lamps). For preceding
vehicles (i.e., tail/rear position lamps), the ECE requirement is
greater than 100 m. SAE also noted that ECE minimum photometric
requirements for a rear position lamp is 4 cd versus the 2 cd minimum
under FMVSS No. 108 for a taillamp. Thus, SAE stated, the ECE requires
a shorter detection distance (100 m in the ECE versus 120 m in the
NPRM) for a lamp whose absolute minimum intensity is two times that
required by FMVSS No. 108.
Auto Innovators found that there were very few test failures in
this scenario (5 failures out of 109 valid test runs in its testing)
and therefore suggested eliminating it because it would provide no
additional benefit.
Agency Response
The final rule scales back the proposal with respect to evaluating
preceding glare. The final rule does not include any passing or same-
lane scenarios because it utilizes stationary fixtures. The final rule
provides only for testing preceding glare with the fixture in the left
adjacent lane, on both a straight path (this ``preceding straight''
test scenario) and on a left curve path (Scenario 8).
The final rule also shortens the measurement distance to 100 m. As
SAE suggested in its comment, the detection distance for ADB systems
differs for oncoming versus preceding traffic. It is much more
difficult for an ADB system to detect taillamps than headlamps, and the
difficulty increases with greater forward distances. This is mainly
due, as SAE notes, to the fact that headlamps are much brighter than
taillamps. The NPRM stated that it is reasonable to expect ADB systems
to detect oncoming vehicles at 220 m but did not mean to imply that
this also applies to preceding vehicles. The final rule harmonizes with
the ECE requirements in this respect.
Agency test data indicate that current lower beams can comply with
this revised scenario. NHTSA tested two vehicle lower beams, both of
which performed well, with considerable margin. See Figures 28 and 29
below.
[[Page 9963]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.026
NHTSA's analysis also indicates that ADB systems can reasonably be
expected to comply with this scenario. As explained earlier for the
oncoming straight scenario, the preceding vehicle fixture--which is in
the same location as it is for the oncoming straight scenario--is
always within the ADB system's field of view, so that an ADB system
will have more than sufficient time to react to and shade the fixture.
NHTSA's test data bear this out. The Lexus ADB system performed well
with considerable margins in this scenario with all fixtures (passenger
car, truck, motorcycle). See Figure 30. On the SAE test run with the
preceding fixtures in Position 2 (the closest analog to this final rule
scenario), the ADB system passed with the car/truck fixtures, although
the margins were lower. See Figure 31.
[GRAPHIC] [TIFF OMITTED] TR22FE22.027
[[Page 9964]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.028
h. Scenario 8: Preceding Medium Left Curve
The NPRM included scenarios for testing preceding glare on short,
medium, and large right and left curves, in same-lane and passing
scenarios. It proposed evaluating glare from 15 m or 30 m (depending on
the scenario) out to 119.9 m. The agency did not receive any comments
specifically on the preceding curve scenarios.
The final rule retains only one preceding curve scenario of those
proposed. This scenario evaluates preceding glare on a medium left
curve (with a radius from 210 m to 250 m) from 15 m to 100 m with the
fixture in the left adjacent lane.
After considering the comments questioning the number and
complexity of the proposed test scenarios, NHTSA considered including
only a preceding vehicle straight path scenario, hypothesizing that it,
in addition to the full set of oncoming scenarios, would adequately
probe ADB system performance. NHTSA's testing, however, showed that ADB
systems encountered some difficulties preventing glare to preceding
vehicles on curves. The 2015 ADB Test Report concluded that left curve
same-direction maneuver scenarios in which the stimulus vehicle was
stationary were associated with high measured illuminance values.\139\
NHTSA's recent testing showed that the ADB system, while performing
adequately on oncoming left curve and preceding straight scenarios, had
trouble with a preceding left curve scenario for short and medium
curves, but handled the large curve well. See Figure 32.
---------------------------------------------------------------------------
\139\ 2015 ADB Test Report, p. 173. See also pp. 114-123.
---------------------------------------------------------------------------
[[Page 9965]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.029
[[Page 9966]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.030
BILLING CODE 4910-59-C
Accordingly, the final rule retains a preceding left curve scenario
to help ensure that ADB systems respond appropriately when encountering
preceding vehicles on curved roadways. NHTSA decided that one curve
test would suffice and has opted for the medium curve. The ADB system
we tested performed well on the large curve, and the short curvature
would be a difficult test for the manufacturers to meet. The final rule
does not add a right curve scenario for preceding vehicles because the
2015 study showed that ADB systems generally performed well on same-
direction right curve maneuvers.\140\ Further, because the final rule
truncates the measurement distances on right curves, preceding tests
for right curves would not test the system in any significant ways that
are not already covered by the other scenarios.\141\
---------------------------------------------------------------------------
\140\ 2015 ADB Test Report, p. 173.
\141\ For example, the Lexus has a late reaction (at 70 m) on
the preceding medium left curve. If the recognition system is
essentially symmetrical (i.e., the same for a right curve), the same
late recognition (70 m) on a preceding right curve would not result
in a failure, because the measurement distance for a right curve is
truncated to 50 m (Scenario 5). As is the case for the left curve,
the Lexus was under the right curve limits at distances less than 50
m.
---------------------------------------------------------------------------
The results from the SAE test fixture position most analogous to
this final rule scenario (with the SAE fixture in Position 1) show that
the ADB system passed the test with the car/truck fixture with wide
margins. See Figure 33. Again, this contrasts with the results from the
final rule test scenario and suggests that the SAE test does not
sufficiently replicate a preceding situation on an actual curve.
i. Decision Not To Include Oncoming Short Right Curve Scenario
The NPRM proposed evaluating illuminance on right curves with a
radius of 98 m to 116 m at distances of 15 m to 220 m.
Comments
SAE and Stanley commented--parallel to their arguments for the
medium right curve--that contemporary lower beams would likely not
comply with this scenario. SAE provided a graph of illuminance data for
IIHS ``Good''-rated lower beams from about 0 m to 125 m on a 150 m
radius right curve. SAE stated that these data show that many of those
lower beams would not comply with the proposed glare limits at
distances greater than 30 m. Other commenters stated more generally
that the proposed glare limits were so stringent that even currently-
compliant lower beams would exceed them. Similarly, Stanley ran
simulations for a right curve with a radius of 107 m and asserted that
the glare limits were more stringent than the right-side intensities
currently permitted by the standard.
As noted above under the small left curve scenario, several
commenters stated that curves of this size would require a camera field
of view beyond the capabilities of existing systems, and/or would not
allow a sufficient time for an ADB system to detect and react to the
stimulus.
SAE also commented that upper beams at greater than 15 degrees left
or right are not as bright as lower beams straight ahead, and at an
angle of 40 degrees the light toward a stimulus vehicle driver is low,
further suggesting that requiring a camera field of view beyond 25
degrees is unnecessary.
Agency Response
The final rule does not include a short right curve scenario
because NHTSA was persuaded by the comments.
The reasons for this decision are similar to the reasons for
modifying the measurement distances for the medium and large right
curve scenarios. As explained earlier, NHTSA concluded that
contemporary lower beams--especially beams that score well on the IIHS
test--would likely not comply with the oncoming glare limits at
distances corresponding to horizontal angles greater than 3 degrees--
that is, on a 100 m right curve, distances greater than 30 m (the
distance at which the fixture would cross 3 degrees). This is
consistent with the IIHS data submitted by SAE, which shows that none
of the lower beams tested were within the oncoming glare limits between
60 and approximately 120 m, and most of the lower beams tested were not
within the oncoming glare limits from 30 m to 60
[[Page 9967]]
m. (From 15 m to 30 m, almost all the lower beams tested by IIHS were
within the glare limits.) As such, the agency has confidence that
including a small radius right curve scenario would have no positive
impact on safety relative to that provided by current lower beams in
this situation.
Because, as explained above, the final rule specifies right curve
scenarios only for measurement distances corresponding to horizontal
angles to the left of 3R, this would leave only about 15 m of track
length (and 1 second of test time) for this scenario. NHTSA concluded
it was not useful to include such a short-duration scenario in the
final rule.
9. Other Test Parameters and Conditions
a. Radius of Curvature
NHTSA proposed testing using a curved path scenario (both left and
right curves) with a variety of radii of curvature. The NPRM proposed
testing on a ``small'' curve with radii of curvature from 98 m--116 m
(320-380 ft); a ``medium'' curve with radii of curvature of 223 m-241 m
(730-790 ft); and a ``large'' curve, 335 m-396 m (1100-1300 ft). The
NPRM proposed that the curve on which testing is conducted be of a
constant radius within the range listed in the test matrix.
Comments
Manufacturers requested clarification or modification of the
specifications and procedures related to the radius of curvature.
The Alliance, Ford, and Toyota commented on measuring the radius of
curvature. Ford requested clarification on how to measure the radius of
curvature and all three commenters recommended following the IIHS
protocol and measuring the radius of curvature from the center of the
test vehicle's travel lane.
Toyota suggested the final rule not specify a constant radius
because it is not practical and is rarely the case in real-world
situations.
Honda, Toyota, and Auto Innovators requested clarification of the
direction of curvature (left or right).
OICA, SAE, SMMT, and Auto Innovators commented that the proposed
road geometries do not exist at the proving grounds of many vehicle
manufacturers. Auto Innovators commented that its testing contractor
found that modifications to curvature radii were necessary to
accommodate performance of the specified test scenarios at its
facility, and that only the short-radius curve was within the NPRM
specification.
Agency Response
NHTSA has made a variety of changes in the final rule in response
to these comments. With respect to measuring the radius of curvature,
the final rule adopts regulatory text to specify that the curve is of a
constant radius, as measured to the centerline of the path on which the
test vehicle travels, within the range specified in the test matrix. In
its latest testing, NHTSA used an inertial navigation system to follow
a pre-programmed path for the centerline of the vehicle to follow. This
was executed using a steering controller that followed the predefined
path.
When conducting its compliance testing, the agency may choose any
radius within the range listed in the test matrix. The constant-radius
specification is intended to indicate that the agency does not intend
to test on compound curves (i.e., a curve with a non-constant radius of
curvature). Considering that the manufacturer must certify that the
vehicle will perform throughout the range of radii of curvature
specified in the test matrix, NHTSA does not expect dramatic
differences in results if the radius is not perfectly constant but
contains minor variations throughout the run. The final rule also
retains ranges for the radii of curvature, as opposed to a single
radius of curvature with a relatively narrow tolerance. NHTSA believes
the system should be able to function over at least these range of
radii because they are representative of real-world roadway geometry.
NHTSA agrees with Honda and Toyota about clearly specifying the
direction of curvature and has done so in the regulatory text.
With respect to the comment that the specified curves are not
available at testing facilities, NHTSA was able to test on the curves
specified in the final rule at the Transportation Research Center (TRC)
Vehicle Dynamics Area (VDA). This test facility is publicly available
to manufacturers.
The final rule slightly modifies the specifications for the radii
of curvature for all curves. NHTSA converted the center of the proposed
range units from feet to meters and rounded the meter units.
b. Test Vehicle Speed and Acceleration
The NPRM proposed, for each test scenario, a range of test vehicle
speeds that NHTSA could select. The values proposed for speed, radius
of curvature, and superelevation were consistent with a standard
formula used in road design specifying the relationship between these
parameters. The formula, referred to as the simplified curve formula,
is
[GRAPHIC] [TIFF OMITTED] TR22FE22.031
where f is the coefficient of friction, V is the vehicle speed, R is
the radius of curvature, and e is superelevation.\142\ The speeds
ranged from a high of 70 mph for the straight scenario to 25 mph for
the short-radius curve scenarios.
---------------------------------------------------------------------------
\142\ See A Policy on Geometric Design of Highways and Streets.
American Association of State Highway and Transportation Officials.
Washington, DC (2011) (AASHTO Green Book), pp. 3-19 to 3-20.
---------------------------------------------------------------------------
The NPRM proposed that for each test run, a speed conforming to the
ADB test matrix would be selected and that the test vehicle would
achieve this speed 0.45 m/s (1 mph) prior to reaching the
data measurement distance and maintain this speed with ``no sudden
acceleration or braking.''
Comments
SAE, Toyota, and Honda recommended that, to simplify the test and
reduce variability, the final rule specify a specific vehicle speed and
tolerance for each scenario. Auto Innovators recommended that the
maximum test speed be reduced from 70 mph to 55 mph because camera
detection does not depend on vehicle speed; the majority of fatal
nighttime crashes on curves occur at speeds of 55 mph or less; and
certain vehicles (such as large trucks) would have difficulty reaching
the specified test speeds given the lengths of courses available at
test facilities. Toyota suggested providing a more specific
specification for acceleration.
Agency Response
The final rule retains the speed ranges and tolerances proposed for
each scenario. The range of speeds reflects the real world (where
different drivers may take the same curve at different speeds) and
provides testing flexibility.
[[Page 9968]]
The speeds set out in the final rule are generally higher than
specified in SAE J3069, which states that ``[t]he speed of the vehicle
for the full length of the 155 m test shall be above the ADB activation
threshold of the vehicle as specified by the manufacturer.'' \143\
NHTSA believes that testing at speeds only marginally higher than the
activation speed would not be representative of real-world driving,
especially on the types of roads and situations (e.g., outdriving lower
beam) in which ADB is most useful. The ADB systems NHTSA tested had
activation speeds ranging from 19 to 43 mph.\144\ Safety concerns
regarding glare, like many safety concerns, are also magnified at
higher speeds.
---------------------------------------------------------------------------
\143\ 5.5.6.1.
\144\ 2015 ADB Test Report, p. 20.
---------------------------------------------------------------------------
NHTSA disagrees with the suggestion that test speed does not impact
ADB system performance, as the higher the test speed, the quicker the
system must identify and shade the fixture. The proposal did not
specify test speeds greater than 55 mph on curves; speeds above this
were only proposed for straight-path scenarios. Regarding the concern
that vehicles such as large trucks may have difficulty attaining test
speeds in the distances available at track test facilities, the final
rule specifies test fixtures and not stimulus vehicles, which should
facilitate testing at the higher speeds. Further, the agency was able
to achieve the maximum test speed of 70 mph on two different sections
of the TRC facility for the straight scenario, using a class 8 truck
tractor in the loaded and unloaded condition on the skid pad and the
vehicle dynamics area (this is the surface that was used for all of the
research testing). While complete lamp testing was not conducted using
the class 8 truck tractor, the pitch and speed parameters were recorded
along the path to demonstrate that a valid test was possible. Given the
superiority of full-vehicle testing of ADB, the difficulties that a few
vehicles may have in executing the test procedure do not appear
insurmountable for heavy vehicles.
Regarding Toyota's comment on the acceleration criteria, the
proposal did address acceleration beyond the specification that ``no
sudden acceleration or braking shall occur'' in that it also specified
a tolerance of +/- 0.45 m/s (1 mph) for the nominal test speed. This
tolerance is smaller than that used in the IIHS test procedure (3 km/h
(.83 m/s)). In NHTSA's testing, the test driver was able to
consistently maintain the speed within this tolerance. In addition, the
final rule includes a vehicle pitch allowance that constrains
acceleration in that if acceleration causes changes in vehicle pitch
exceeding 0.3 degrees compared to the average pitch, then the measured
illuminance at those points will not be considered in determining
compliance.
c. Headlamp Aim
The proposed test procedures specified several aspects of test
vehicle preparation. This included that the headlamps would be aimed
and the ADB system adjusted according to the manufacturer's
instructions.
FMVSS No. 108 requires that when a headlamp is installed on a motor
vehicle, it must be aimable.\145\ The standard specifies compliance
options for the aiming system. The principal options are vehicle
headlamp aiming devices (VHAD) and visual/optical aiming devices
(VOA).\146\
---------------------------------------------------------------------------
\145\ S10.18.
\146\ The standard specifies a third compliance option
(mechanical aim), which involves an externally-applied mechanical
device. This method is no longer in use and is not at issue in this
rulemaking.
---------------------------------------------------------------------------
A VHAD is an item of equipment installed on the vehicle and
headlamp which is used for aiming the headlamp mechanically, such as
with a bubble vial on the headlamp housing which has a closely
specified geometric relationship to the headlamp beam's vertical
location. A similar mechanical reference marking system is used for
correct horizontal aim, essentially aligning the optical axis of the
headlamp housing or reflector to the vehicle's longitudinal axis.
VOA involves either projecting the beam onto a vertical surface and
then adjusting the headlamp to an appropriate position as determined by
an observer (visual aim), or projecting the beam into an optical device
that is placed in front of the headlamp and then adjusting the headlamp
until the beam conforms to the appropriate parameters (optical aim).
VOA is used on most, if not all, vehicles currently sold in the U.S.
The standard requires a relatively sharp horizontal cutoff in the lower
beam pattern in order to aim the headlamps vertically. The standard
does not permit horizontal aiming on VOA headlamps unless the headlamp
is equipped with a horizontal VHAD.
Comments
IIHS expressed concern that the NPRM allowed vehicle manufacturers
to provide headlamp re-aiming procedures and ADB adjustments prior to
testing, because for the systems to be effective in real-world driving,
they need to function without adjustment when the consumer purchases
the vehicle. IIHS explained that its headlighting system evaluations
are conducted without changing the factory aim of the headlamps. They
found that there is often a wide range of aim values between
manufacturers, between some vehicles of the same make and model, and
even between the left and right headlamp of the same vehicle,
indicating that ADB effectiveness will be reduced if there is no
incentive in the regulation for precise aiming at the factory. IIHS
noted that this is even more important for ADB than for traditional
headlighting systems since both the headlamps and the camera system
require accurate alignment. IIHS further stated that just as NHTSA
would not allow manufacturers to modify an air bag deployment algorithm
prior to conducting FMVSS No. 208 compliance crash tests, the agency
should not allow the ADB system to be modified to a condition that may
not exist on any other production vehicle. IIHS provided data on
factory aim variation for seven new vehicle models with VOR headlamps
showing that most had aim values that would have a substantial effect
on the measured visibility distances in the IIHS evaluation. IIHS
stated that this indicates that conducting headlamp evaluations or
compliance testing with re-aimed lamps is likely to reduce the real-
world relevance of the tests.
Conversely, several commenters (Valeo, the Alliance, Volkswagen,
SAE, Koito, Global, Honda, Auto Innovators, and Ford) requested that
the final rule allow for horizontal aim adjustment on VOA ADB headlamps
without equipping them with a horizontal VHAD (as the standard
currently requires). The commenters highlighted the importance of
horizontal aiming for ADB systems and requested that the final rule
allow horizontal aim adjustment on VOA headlamps used in conjunction
with an ADB system. They stated that in order to maximize the
visibility benefits of ADB, the area of reduced intensity must be
minimized, which can only be accomplished using both horizontal and
vertical aiming. They commented that horizontal adjustment of the beam
is critical in placing the area of reduced intensity accurately over
the oncoming or preceding vehicles. If a horizontal aim access
allowance were not incorporated into the final rule, automakers would
be required to compensate for the expected horizontal vehicle variation
into the size of the area of reduced intensity, resulting in greatly
increasing this area, and lessening the additional light.
The commenters noted that the standard prohibits horizontal aim on
a
[[Page 9969]]
VOA headlamp unless a VHAD is provided, and stated that VHADs are
unreliable, ineffective, lack the accuracy necessary for use with ADB
systems, and are essentially obsolete. SAE suggested that NHTSA modify
the current regulatory text in S10.18 and S14.2.5 to allow headlamps
with adaptive driving beams to be adjusted according to the
manufacturer's instructions.\147\ Auto Innovators commented that the
method to horizontally aim ADB headlamps varies depending on the
specific execution of the ADB system. Each involves an ADB-specific aim
calibration mode to be activated either by a dealer or consumer when
the vehicle is parked. This mode illuminates a horizontal aim feature
utilizing one or more of the ADB-illuminated elements which have a
sufficient vertical gradient that can be used for horizontal aim, just
as one does today with vertical aim. The dealer or consumer would use
this vertical gradient to properly calibrate the horizontal aim
following instructions specified in the service manual or owner's
manual.
---------------------------------------------------------------------------
\147\ Ford noted that NHTSA has opined that horizontal aiming is
permitted with VOA headlamps provided it is disabled or made
inaccessible for consumers, but contended that this does not address
the potential need for re-adjustment should the ADB system need to
be aimed after sale to the consumer (for example, upon headlamp
replacement due to vehicle damage).
---------------------------------------------------------------------------
Several of these commenters pointed out that the ECE and Canadian
requirements provide for horizontal aim with VOA headlamps and that
effectively requiring horizontal VHADs would drive hardware
disharmonization. Ford pointed out that SAE J3069 recognized the
necessity of horizontal aiming for ADB systems, and that Canada, in
adopting SAE J3069, specifically permitted horizontal aim.
ALNA suggested applying tolerances for aiming the headlamps.
Agency Response
The final rule follows the proposal and specifies that the
headlamps will be aimed and the ADB system adjusted according to the
manufacturer's instructions. In addition, the final rule provides that
the test vehicle will be loaded within +/- 5 kg of the total vehicle
weight during track testing prior to aiming the ADB headlamps. This is
intended to indicate that NHTSA will not change the loading of the
vehicle by more than 5 kg compared to what it is when the headlamps are
aimed. This means that NHTSA will not aim the headlamps when the
vehicle is at a lower weight compared to when the vehicle is fully
instrumented and occupied by a test driver (which changes the pitch of
the vehicle, and thus, the aim of the headlamps).
NHTSA disagrees with IIHS and believes that manufacturers should be
permitted to specify aiming procedures prior to the compliance tests.
IIHS's suggestion is essentially that on-vehicle aim should be
regulated. Even if this approach may have merit, it is outside the
scope of this rulemaking, which extends the current requirements to ADB
systems. The proposed specification is also consistent with the
required laboratory testing, which involves aiming the headlamp prior
to testing. Conventional laboratory testing of headlamps has long
permitted aiming them prior to testing. This contributes to the
repeatability of the test and sets a consistent standard to which
headlamps must perform. This is important because the laboratory
photometric requirements are the basis for the current track-based test
procedure limits; if we were to consider practical limits that included
variations in aim introduced through the distribution chain, the limits
that are finalized might not be appropriate. In addition, as IIHS
notes, ADB systems rely on accurate alignment of the headlamps and
camera systems. Aiming the headlamps prior to the compliance test
limits aim variation and isolates ADB performance. This approach
ensures that the ADB compliance test will be performed with a
headlighting beam pattern that, as manufactured, at least meets a
minimum level of performance. The end customer or dealer can then aim
the headlamps to align the system appropriately.
The agency agrees that successful implementation of ADB using
current technology requires the regulation to provide flexibility to
permit headlamps to be aimed horizontally once installed on the vehicle
to align the vehicle, camera, and headlamps. As explained below, while
NHTSA agrees with the commenters that ADB systems should be exempt from
several of the current requirements for horizontal VHADs, NHTSA does
not agree that ADB-equipped VOA headlamps should be completely exempt
from all the VHAD requirements.
FMVSS No. 108 does not permit VOA headlamps to be visually aimed
with respect to horizontal aim. NHTSA explained the reason for this in
the 1997 final rule that permitted VOA aim headlamps.\148\ Because the
lower beam of a headlamp designed to conform to Standard No. 108 does
not have any visual cues for achieving correct horizontal aim when
aimed visually or optically, and because it is not possible to add such
visual features without damaging the beam pattern, horizontal aim
should be either fixed and nonadjustable, or have a horizontal VHAD.
The agency also noted that the negotiated rulemaking committee involved
in that 1997 negotiated rulemaking ``considered features for horizontal
visual/optical aiming but none were deemed sufficiently developed and
designed to be usable.'' \149\ Accordingly, that final rule did not
permit any horizontal movement of VOA headlamps, with the lamp
essentially being correctly aimed as installed, unless the headlamp was
equipped with a horizontal VHAD. The horizontal VHAD was included as a
compliance option (and required to be set to zero) as a means for
manufacturers to meet European requirements for both a horizontal and
vertical aim adjustment. For these reasons, in 1999 NHTSA denied a
petition for rulemaking to allow VOA headlamps to have a horizontal
adjuster system that does not have the required 2.5-degree horizontal
adjustment range or a VHAD indicator.\150\
---------------------------------------------------------------------------
\148\ 62 FR 10710 (Mar. 10, 1997).
\149\ Id., p. 10715.
\150\ 66 FR 42985 (Aug. 16, 2001) (denial of rulemaking petition
from Federal-Mogul Lighting Products).
---------------------------------------------------------------------------
Although VHADs are not widely (if ever) used, NHTSA is not
persuaded that a VHAD for horizontal aiming would not be feasible for
ADB-equipped headlamps. The commenters did not present any information
to show VHADs are necessarily incompatible with the aiming accuracy
necessary for ADB systems. While VHAD devices used prior to the
allowance of visual optical aiming in the U.S. may have been
inaccurate, these limitations are not driven by the requirements placed
on VHADs by the FMVSS.\151\ The minimum requirements in FMVSS No. 108
for horizontal VHADs provide a floor below which accuracy cannot drop,
but do not limit aiming accuracy.
---------------------------------------------------------------------------
\151\ See S10.18.8.
---------------------------------------------------------------------------
For example, the requirements in S10.18.8.1.2 that the VHAD include
references and scales relative to the longitudinal axis of the vehicle,
including a ``0'' mark and an equal number of graduations from the
``0'' mark, limit neither precision nor accuracy. The horizontal VHAD
need only be accurate enough to set at 0 in order to perform basic
photometry testing in the lab. Other measurement cues (including more
precise methods) may be used to more accurately aim the headlamps on
the vehicle for the purposes of ADB functionality. The
[[Page 9970]]
regulation does not restrict this but allows the flexibility to
customize such methods to accommodate any unique features present in
any beam.
Even if NHTSA were to agree with the commenters that VHADs were not
optimal for ADB systems, the agency does not currently have, and the
commenters did not provide, a workable alternative. For example, SAE's
suggested amendments to S10.18 and S14.2.5 simply stated that ``if the
headlamp is equipped with ADB, and has horizontal aim, it shall be
adjusted according to the manufacturer's instructions.'' If the
commenters sought allowance of horizontal VOA aim for ADB systems, they
did not provide information on how this would work in practice. Unlike
the lower beam pattern in Europe, where the lower beam pattern has a
vertical cutoff component and uses VOA for horizontal aim, the U.S.
lower beam pattern has no such required cutoff or other cues--meaning
horizontal VOA in FMVSS No. 108 is not currently feasible.\152\ If the
beam pattern were to include cues that could be used to visually aim
the headlamps horizontally, such a procedure could be workable. Such
procedures, however, have not been developed for the United States
market for visual/optical horizontal aim of the headlamps, and they
would need to include, among other things, a cut-off requirement
analogous to the current requirements for the horizontal cutoff for the
lower beam.\153\ In addition, such requirements would limit the
flexibility of beam pattern design currently permitted by the standard.
This could limit the potential for innovative safety solutions
generally afforded by this final rule. On the other hand, if the
commenters referred to non-VOA methods, they were not presented to the
agency.
---------------------------------------------------------------------------
\152\ The ECE horizontal aim test procedure is in R112 Annex 9.
This procedure is not suitable for headlamps in the U.S. because it
relies on features in the beam pattern, such as the kink, that are
not required to be present in a lower beam pattern by FMVSS No. 108.
\153\ See S10.18.9.1.
---------------------------------------------------------------------------
NHTSA agrees, however, that several of the requirements for
horizontal VHADs (in S10.18.8.1.2.1-4) are not necessary for ADB
systems. S10.18.8.1.2.1 requires that each graduation must represent a
change in the horizontal position of the mechanical axis not greater
than 0.38[deg] (2 in at 25 ft) to provide for variations in aim at
least 0.76[deg] (4 in at 25 ft) to the left and right of the
longitudinal axis of the vehicle, and must have an accuracy relative to
the zero mark of less than 0.1[deg]. As the commenters alluded to, this
minimum accuracy of graduation is likely not adequate for aligning the
camera and headlamps. NHTSA expects that a more accurate method will be
utilized to align the lamps and the camera and does not expect this
alignment procedure to be manually conducted by non-expert vehicle
owners. Similarly, S10.18.8.1.2.2-3 pertain to the readability of those
graduations. S10.18.8.1.2.4 specifies minimum horizontal indicator and
aiming ranges. Those limits are not relevant to ADB aim because they
are intended to align the lamp with the vehicle, whereas ADB systems
require the alignment of the lamp with the camera. NHTSA expects that
this alignment range will be determined by each manufacturer
appropriate for their camera installation and body tolerances.
Consequently, the final rule exempts ADB systems from these
requirements.
With respect to harmonization, the agency recognizes that VHADs add
some additional cost, but the option to use a horizontal VHAD was
actually intended to facilitate harmonization by giving manufacturers a
way to meet both the ECE requirements (which require both a horizontal
and vertical aim adjustment) and the U.S. requirements (which require
only vertical aimability). A VOA headlamp intended for sale in both the
European and U.S. markets would likely have a vertical aiming screw and
a horizontal VHAD, while one intended for use only in the U.S. market
need only provide for vertical adjustment.\154\ In practice,
manufacturers wishing to sell essentially the same headlamp design in
both markets, but not utilize a horizontal VHAD, would typically design
a lamp with both a vertical and horizontal aiming screw, and lock out
(or make inaccessible) the horizontal screw in the U.S.-market version.
---------------------------------------------------------------------------
\154\ 66 FR 42985, 42986 (Aug. 16, 2001).
---------------------------------------------------------------------------
d. Road Surface
The NPRM proposed several specifications related to the quality of
the test track surface, including that the tests would be conducted on
a dry, uniform, solid-paved surface; that the road surface have an
International Roughness Index (IRI) measurement of less than 1.5 m/km;
and that the test course surface be composed of concrete or asphalt.
The proposal also included an allowance for momentary glare exceedances
that might be related to, among other things, imperfections in the road
surface. SAE J3069 specifies an identical IRI value and that the test
course surface be uniform, straight, flat and represent a typical road
surface.
Comments
Intertek commented that the IRI is not simple to measure
quantitatively and that requiring a road surface quality of 1.5 m/km
will impose unnecessary restrictions on the test track. The commenter
recommend instead using the SAE J3069 value of 3 m/km.\155\ Auto
Innovators commented that, for its testing, longitudinal lane IRI
measurements were within the NPRM specification, averaging near 0.475
m/km, but that atypical IRI measurements across transverse lanes (east/
west) are unknown and may impact testing on curves.
---------------------------------------------------------------------------
\155\ SAE J3069 JUN2016 states, in section 7.1, that it is
recommended that the road have an IRI of less than 1.5 m/km, while
the text accompanying Figure 5 states that the IRI should be less
than 3. SAE J3069 MAR2021 corrects the text in Figure 5 to state
1.5.
---------------------------------------------------------------------------
ALNA commented that test ground conditions and variations should be
reflected in the requirements and suggested applying tolerances in
order to reflect variations such as ground unevenness. Toyota commented
that the NPRM did not sufficiently define the test track conditions and
that failure to do so would affect compliance test results.
Agency Response
The final rule deletes the IRI specification. The purpose of the
IRI specification was to limit angular changes between the vehicle and
the illuminance meters throughout the test run. This was anticipated to
provide a boundary limit for which a vehicle manufacturer could certify
performance of its vehicle. In other words, the ADB system was not
expected to perform to the limits specified in the NPRM on a bumpy or
wavy road. However, during NHTSA's most recent testing, it was found
that a more direct approach--pitch adjustment--could be used to limit
this orientation. IRI values are a general measurement of road
roughness, but, in the context of the track test in this rule, are
essentially a proxy for vehicle pitch: A test conducted on a test track
surface with a low IRI will generally have less pitch variation than a
test conducted on a surface with a high IRI. Directly measuring vehicle
pitch eliminates the need for the IRI parameter.
NHTSA believes that directly accounting for vehicle pitch addresses
Auto Innovators' concern that the transverse IRI may influence test
results (by influencing vehicle pitch, which in turn influences test
results) on curve scenarios. The area of the test facility that NHTSA
used for its most recent
[[Page 9971]]
testing had an IRI of 1.46 m/km in the EW direction and an IRI of 1.61
m/km in the NS direction. In conducting its testing, however, NHTSA
nested the straight, right, and left curves of each radius on the TRC
VDA large-area test facility. As such, those IRI measurements are not
direct measurements of the longitudinal or transverse paths taken
during ADB testing. While the final rule limits the number of
scenarios, it retains 6 different curved-path scenarios, including
various radii for right and left curves. These paths may have slight,
but potentially meaningful, differences in longitudinal IRI. While this
longitudinal test surface roughness measurement is possible along each
path, requiring a new IRI measurement any time the path is altered
would be unnecessarily burdensome, considering it is possible to
instead directly measure vehicle pitch. Additionally, the IRI can
change over time, especially considering large temperature changes; it
is possible that a path that in one season is under 1.5 m/km will
exceed that value in a different season. Replacing the IRI parameter
with a procedure for directly measuring and limiting the pitch
variation of the test vehicle eliminates these concerns.
With respect to the comments by ALNA and Toyota, the commenters did
not identify specific additional ways to specify the test conditions.
For the reasons given here and elsewhere in the preamble, NHTSA
believes the final rule sufficiently accounts for test surface
conditions to control for the major sources of testing variability--
including vehicle pitch--related to the test track.
e. Ambient and Reflected Light
The NPRM proposed to control for ambient and reflected light, which
can interfere with test results, in a few ways.\156\ Ambient
illumination recorded by the photometers must be at or below 0.2 lux;
testing must be conducted on dry pavement, and with no precipitation;
the test road must be free of retroreflective material; and the
pavement must not be bright white (to avoid intense reflections).
Notwithstanding such controls, some degree of ambient light is
unavoidable. Accordingly, in testing for compliance the agency proposed
to zero-calibrate the photometers. SAE J3069 similarly specifies that
the test track does not contain retroreflective material and that
testing be conducted during clear weather on dry pavement.
---------------------------------------------------------------------------
\156\ Ambient light refers to light emitted from a source other
than the ADB system. This may include moonlight, light pollution
from nearby buildings, or light coming from the test fixture itself.
Reflected light refers to light from the ADB vehicle's headlamps
reflected off the road or other surfaces (including rain or fog
droplets) onto the photometric receptors.
---------------------------------------------------------------------------
Comments
Intertek tentatively agreed with NHTSA's assessment of the impact
of stray and ambient light on the test. Some commenters, however,
stated that the proposal did not sufficiently control for ambient
light. The Alliance and Volkswagen commented that ambient light can
change throughout the data collection (e.g., due to clouds, the moon)
during a test, which could introduce uncontrolled variability and
difficulty in repeatability and reproducibility of test results. ALNA
suggested applying tolerances for variations in test course surface
conditions including ground reflectivity.
Volkswagen commented that the presence of reflectors in the
environment could cause test results to vary and that the NPRM did not
address environmental conditions such as fog, dust, or pollution which
exist in real-world testing and can introduce variability that will
present challenges for repeatability and reproducibility. Mobileye
commented that the track test requirements should specify that fog and
dust should not be present when performing testing. TSEI recommended
the agency clarify how ambient conditions should be treated.
Agency Response
The final rule adopts the proposed test procedures, but modifies
the photometer zero-adjustment procedure to reflect the fact that the
test uses fixtures, not stimulus vehicles. The meters will continue to
be zero-calibrated for each scenario tested.
With respect to the comment about ambient light changing throughout
the test, NHTSA found that the ambient light did not change
significantly during a test session. Further, NHTSA's testing method
accounted for ambient conditions by measuring ambient illuminance
either immediately before or after each test trial and subtracting that
value from the recorded test data. The repeatability analysis, which
included testing on different nights, showed that the night on which
testing occurred did not appear to be a significant source of
variation. The commenters did not recommend any alternative methods to
account for ambient or reflected light. SAE J3069 does not specify how
ambient conditions or reflected lighting are to be treated aside from
requiring that ``[n]o other vehicle lighting devices shall be activated
or any retro-reflective material present and care should be taken to
avoid other sources of light, reflected or otherwise.'' \157\ Although
the final rule does not specify a baffle, the regulatory text does not
prohibit it if it provides more accurate results for a particular
location. The agency did not study adding baffles in a systematic way
because testing did not show stray light to be a significant
contributor to variability.
---------------------------------------------------------------------------
\157\ 5.5.2.1 and 5.5.3.1.
---------------------------------------------------------------------------
With respect to reflectivity, as noted above, the proposal (and
final rule) specifies that the test road be free of retroreflective
material and that the pavement may not be bright white. With respect to
tolerances, although the agency does not expect reflectivity to affect
the illuminance measurements, the allowance for momentary exceedances
would be applied to spikes in illuminance caused by any such factors.
NHTSA is not aware of any standardized way of accounting for dust or
fog, and the commenters did not identify any such method. In any case,
the same test conducted on different nights did not lead to much
variation in results. Certainly, if ambient environmental conditions
were such that there was an unusual concentration of particulates--or
any other unusual conditions that would be likely to affect test
results--NHTSA would not attempt to conduct compliance testing. In
addition, NHTSA's testing showed that the ambient light did not appear
to fluctuate dramatically in the relatively short times it took to
perform a test run. And, as noted above, the recorded test data was
adjusted by subtracting the ambient illuminance. The agency therefore
believes that test outcomes will generally not be affected by changes
in ambient light.
f. Superelevation
Superelevation refers to the degree of banking of a road. The NPRM
specified that the test track have a superelevation of 0% to 2%. We
explained that it was desirable to minimize the degree of banking
because photometry design as well as the existing and derived glare
limits are based on flat surfaces.
Comments
Auto Innovators commented that it found that modifications to the
specified superelevation were necessary to accommodate the track
lengths at its test facility.
Agency Response
The VDA test pad, on which NHTSA's most recent testing was
conducted, has
[[Page 9972]]
a slope of 1% in the direction between the two loops. That means that
the largest superelevation that we tested was less than 1%. The
superelevation would be 1% had we tested across the width of the pad
and 0% had we tested along the length of the pad. All the recent NHTSA
tests were conducted somewhere between these two extremes. Accordingly,
every test scenario traversed had a superelevation of less than 1%
(based on the TRC site plan).\158\
---------------------------------------------------------------------------
\158\ See TRC site plan at www.trcpg.com/wp-content/uploads/2016/10/Vehicle-Dynamics-Area.pdf last accessed on February 16,
2021.
---------------------------------------------------------------------------
We recognize that superelevation could, conceivably, influence test
results.\159\ Depending on the details of the curve/fixture location, a
large superelevation can either increase or decrease the likelihood
that the measured illuminance will exceed the relevant glare limit.
Superelevation effectively rotates the beam pattern around the
centerline of the vehicle. If the rotation causes the pattern to rotate
down with respect to the sensor location, it is less likely that the
measured illuminance will exceed the glare limit; if, on the other
hand, the rotation causes the pattern to rotate up with respect to the
sensor location, the measured illuminance is more likely to exceed the
glare limit. More specifically, on a left curve a positive
superelevation will always make it less likely that the glare limit
will be exceeded because the fixture is always on the left side of the
beam pattern and the superelevation causes a rotation of the beam
pattern counterclockwise. For the portions of a right curve at which
the photometric receptors are to the left of the beam pattern, a
positive superelevation will increase the likelihood that the measured
illuminance will exceed the glare limit because the beam pattern is
rotated clockwise for a positive superelevation on a right curve.
Finally, for straight-path test scenarios, a large positive
superelevation will always be more stringent because the ``crown'' in
the road rotates the beam pattern clockwise and the fixture is always
to the left.
---------------------------------------------------------------------------
\159\ In addition, the wider the specified range of
superelevation, the more stringent the test, because the vehicle
must perform over a larger range of superelevation angles.
---------------------------------------------------------------------------
We do not expect superelevation to have a meaningful impact on the
test results, especially compared to the effect of vehicle pitch, which
can materially impact test results. For this reason, we concluded that
it was not necessary to include an adjustment for superelevation.
g. Lane Divisions
The NPRM specified that the test track lanes may have a median of
up to 6.1 m (20 ft) wide and should not have any barrier taller than
0.3 m (12 in.) less than the mounting height of the stimulus vehicle's
headlamps. SAE J3069 does not specify any lane divisions or medians but
does specify that the test track area be free from obstructions and
retroreflective markings.
Comments
Mobileye commented that roads with narrow curves do not typically
have such wide medians, and this will place the stimulus vehicle at a
very wide angle to the host vehicle. Intertek questioned the need to
consider medians or barriers and suggested that the median be limited
to a standard lane divider. SL Corporation commented that a traffic
barrier is not necessary and may make it difficult for ADB systems to
accurately detect oncoming traffic, recommending that final rule
provide a more detailed specification if retained. SAE questioned the
inclusion of a 20-ft median for a 320-ft curve because medians of that
size are typically found only on higher speed interstate roads which do
not contain curves of that sharpness.
Agency Response
NHTSA agrees with commenters that a median or barrier is not useful
for testing. These features are not included in the final rule.
h. Hills
The NPRM did not propose testing on sloped (dipped or hilly) roads,
explaining that even headlighting systems with compliant lower beam
photometry can glare oncoming or preceding vehicles on sloped roads
because the hill geometry may place that vehicle in the brighter
portion of the lower beam pattern. NHTSA's testing was consistent with
this, showing ADB headlighting systems and FMVSS-compliant lower beams
glared oncoming and preceding vehicles on roads with dips.\160\ NHTSA
tentatively concluded that to require this performance of ADB systems
would be neither practical nor consistent with the approach of this
rulemaking (extending the existing lower beam glare requirements to ADB
systems).
---------------------------------------------------------------------------
\160\ 2015 ADB Test Report, pp. 102, 108, 114.
---------------------------------------------------------------------------
Comments
AAA asserted that the track test should include scenarios with
undulating roadways and hills but seemed to suggest that this might be
limited to ADB systems with higher-intensity upper beams (i.e., at the
ECE maximum). AAA commented that ADB technology has the ability to
avoid glaring other drivers in these situations, and that including
this in the test will create pressure to more quickly and successfully
address this.
Agency Response
The final rule does not include testing on dips or hills for
several reasons. First, this approach would be more stringent than
current requirements. Current lower beams create glare for other
drivers on hills. The general approach of this rulemaking was to extend
the current headlamp requirements to ADB systems, not to increase the
stringency of existing requirements for ADB systems. Second, NHTSA's
testing indicated that current ADB systems did not perform well on hill
scenarios. Although including such scenarios in the track test could
help speed the development of ADB systems with these advanced
capabilities, it would likely make the systems more costly and slow
deployment. Finally, NHTSA has not developed test procedures for such
scenarios. This would take additional time and resources and would
require developing a complex test track that would be specific to ADB
testing. However, while it is outside the scope of the current
rulemaking to test ADB systems to ensure that they produce less glare
than current headlamps, NHTSA intends to monitor this issue and will
consider future action if warranted.
10. Data Acquisition and Measurement
a. Photometers
The proposed regulatory text specified that the photometer must be
capable of a minimum measurement unit of 0.01 lux.
Comments
Intertek suggested specifying that the photometric receiver have a
cosine response and be spectrally matched to the photonic response of
the human eye. It also suggested an accuracy limit of +/- 5% nominal
over the full range of illuminance from 0.01 lux to the upper limit
(about 100 lux).
Agency Response
NHTSA's testing utilized a Minolta T10A illuminance meter. The
manufacturer's specifications indicated that it has a spectral response
within 6% of the (CIE) human eye photopic vision [V([lgr])] and a
cosine correction characteristic within 3%. The photometers used in
agency research
[[Page 9973]]
were capable of measuring light within 3% of the ideal cosine response.
NHTSA agrees with Intertek's suggestion and has modified the regulatory
text to include photometer specifications drawn from S14.2.5.7.3 and to
specify a cosine response within 3%.
The agency also notes that the IIHS headlamp testing procedures
\161\ used baffles on the photometry equipment at 25 degrees to ensure
that the light captured was more directly attributable to the test
vehicle light source, and not to stray lighting that may be captured by
the photometer. This 25-degree angle is roughly equivalent to the
angles of incidence of light received from the light source when the
test vehicle is approaching the stimulus through a curve on the roadway
surface and equates to the angles at which ADB systems are typically
scanning for targets to shade. NHTSA finds the IIHS test method
specifications closely match our intent and has adopted similar
language to include a 25-degree angle of incidence.
---------------------------------------------------------------------------
\161\ See supra note 93.
---------------------------------------------------------------------------
b. Sampling Rate
The NPRM proposed to sample illuminance at a rate of at least 200
Hz. SAE J3069 specifies a sampling rate of 10 Hz, and IIHS test methods
sample illuminance at 200 Hz.
Comments
Volkswagen commented that sampling at 200 Hz would lead to a more
complex selection of measuring equipment and analysis for each
experiment and supported the SAE J3069 specification. Global requested
that NHTSA explain the appropriateness of this minimum sampling rate
and whether a maximum sampling rate should be specified.
Intertek commented that 200 Hz is near or exceeding the capability
of most high-grade light meters and recommended reducing the sampling
rate to 100 Hz in order to resolve illuminance in the ranges necessary
for this test. Intertek also stated that reducing the sampling time to
100 Hz is supported by the allowance of momentary exceedances up to 0.1
seconds in duration (100 Hz would include 10 measurements within that
0.1 seconds) and suggested determining acceptance based on a time-
averaged sampling rate at 10 Hz to account for very fast variances in
the illuminance level as well as the human eye response.
Agency Response
After considering the comments, the final rule adopts a sampling
rate of at least 100 Hz. NHTSA is balancing the need for precise data
collection with the cost and availability of equipment. NHTSA agrees
that 200 Hz is faster than the minimum needed to verify compliance,
particularly considering the 0.1 second allowance, but the SAE sampling
rate of 10 Hz simply provides too little data to ensure that ADB
performance is within the specified glare limits. While a 200 Hz
sampling rate matches that used by NHTSA in both its most recent
research and in the research reported in the 2015 ADB Test Report (as
well as that used by IIHS), and did not present any issues, NHTSA
agrees with Intertek that a sampling rate as low as 100 Hz would
provide adequate date collection to detect exceedances lasting near the
0.1 s allowance. As described by Intertek, a 100 Hz data collection
method collects 10 readings within 0.1 s. This is adequate to judge a
short exceedance, and an extra 10 readings provided by a 200 Hz rate
would not substantially change that ability. A sampling rate of 10 Hz
however would collect only a single reading over 0.1 s, making it
difficult to judge the actual time a short exceedance lasts. The agency
considered adding a maximum sampling rate but does not believe doing so
is necessary because the final rule specifies an allowance for
momentary glare exceedances (up to 0.1 s) as well as a low-pass filter
with a cutoff frequency of 35 Hz.
NHTSA is not incorporating time-averaged sampling due to concerns
that the delay associated with time-averaging would make it difficult
to properly synchronize illuminance and distance. This is particularly
important at higher vehicle speeds. Time-averaging (depending on the
parameters) could also collect illuminance levels from one location
over time and report that data at a moment while the vehicle is closer
to the fixture. This would have the result of shifting illuminance
levels down because all tests are arranged such that the vehicle
approaches the fixture, and never moves away from it.
c. Noise and Filtering
The NPRM did not specify any filters other than the 0.1 s or 1m
spike allowance, and the proposal did not explore this issue although
it sought comment on it. The IIHS test procedure does specify that
photometric sensor signals be filtered through a low-pass filter with a
cutoff frequency of 35 Hz. This allows for accurate measurement of all
existing types of headlamp light sources, including pulse width
modulated systems like LEDs. IIHS test methods sample illuminance at
200 Hz, and any ambient offset for the measurements is based on the
minimum ambient illumination from 1-5 seconds after the test vehicle
has passed the measurement location.
Comments
Global requested that the agency clarify which standards OEMs will
be permitted to use when removing test data noise from measured data,
and suggested incorporating any such standards in the final rule or the
formal compliance test procedure (NHTSA understands this to refer to
the laboratory test procedure, which is not part of the regulatory text
but is published separately by the Office of Vehicle Safety
Compliance). Intertek suggested that to ensure that all the energy is
accounted for, the minimum data acquisition rate should be 100 Hz, and
the data should be subject to averaging or boxcar smoothing to reduce
the effective sampling rate to a frequency of 10 Hz. Intertek
alternatively suggested an integrating photometer with a period of 100
ms. The final product would then be the filtered illuminance (with PWM,
pitch, and other sources of noise averaged out) reported with a
frequency of 10 Hz (or another frequency such as 25 or 33 Hz based on
the human eye response), or if boxcar averaging, it could be reported
at 100 Hz (with the understanding that each measurement carries 10 Hz
of averaging).
Agency Response
In response to Global's request, the final rule specifies that
NHTSA will use a low-pass filter with a 35 Hz cutoff frequency.\162\
---------------------------------------------------------------------------
\162\ As NHTSA has pointed out in the past, the FMVSS specify
the procedures NHTSA will use in compliance testing. While
manufacturers must exercise reasonable care in certifying that their
products meet applicable standards, they are not required to follow
the compliance test procedures set forth in a standard.
---------------------------------------------------------------------------
The low pass filter essentially reduces high-frequency noise by
adjusting each data point by comparing it to the average of the
neighboring data. Any individual points that are higher than the
immediately adjacent points are reduced, and any points lower than the
immediately adjacent points are increased. As long as the general data
trends in the underlying signal are true (low frequency--allowed to
pass), then the signal will not be distorted by smoothing. This filter
is suitable for the types of measurements collected as it
[[Page 9974]]
results in the most complete response to noise without detrimental
effects on the data. Because the noise effects are assumed to be evenly
distributed with a standard deviation (d), the noise remaining in the
measurements will be approximately d over the square root of the smooth
width (m) of 35 samples at the 100 Hz we are collecting data. At the
finalized low-pass filter rate, that reduces the noise to less than
0.03 of the standard deviation of the noise in the lux. Filtering will
not eliminate the measurement noise and will result in a slight
reduction of the peak lux values measured during the track test. The
agency does not expect this to affect test results, however, both
because the reduction in the peak value is limited by the higher
sampling rate (100 Hz versus 10 Hz for SAE) and because even at the
broad width of the smoothing filter, the filter only smooths values
over roughly a third of the ``sudden spike'' timing, allowing for
differentiation of a spike from a non-compliance.
The box-car averaging has the advantage of filtering out both
signal and test condition noise. Such data treatment is useful for
smoothing rapidly changing signal data, such as that type of data that
may result from vibratory effects as the test vehicle moves across the
track test bed. It is essentially equivalent to using a low pass
filter, as specified in the IIHS test procedure. The final rule is
therefore consistent with Intertek's comments.
d. Allowance for Momentary Glare Exceedances
The NPRM proposed an allowance for momentary glare exceedances (or
``spikes'') of not greater than 0.1 second in duration or spanning 1 m
of vehicle travel. This was intended to account for variations in
illumination due to uncontrolled testing variables, such as minor
imperfections in the road surface.\163\ Minor imperfections in the road
surface can cause glare exceedances by affecting vehicle pitch.
---------------------------------------------------------------------------
\163\ This is different from an allowance for an adaptation time
(referred to as ``reaction time'' in SAE J3069) which we understand
as referring to another possible reason for a testing allowance: To
account for the operation of the ADB system itself, because, as the
discussion in SAE J3069 points out, ``ADB cannot react
instantaneously.'' This is discussed in Section VIII.C.5 above.
---------------------------------------------------------------------------
Comments
Some commenters believed the proposed allowance was insufficient.
Toyota stated that the requirements to minimize glare go beyond the
levels currently specified in the standard and beyond what is needed to
meet a safety need and that, given the strict allowance for momentary
glare, additional test parameters would need to be defined; for
example, the vehicle pitch can vary (due to the condition of the road,
suspension, tires, and the vehicle's acceleration), potentially
affecting the compliance result. Similarly, SAE and Volkswagen
commented that a 0.1 second allowance is insufficient, would frequently
be exceeded even by compliant lower beams (for example, due to
momentary changes in vehicle pitch), and it would be unreasonable to
expect an ADB system to comply with the glare limits in the numerous
proposed test scenarios with only that allowance. Auto Innovators
proposed that NHTSA increase this allowance to 2.5 seconds, based on
the human response time to the sudden appearance of an opposing or
preceding vehicle. ALNA agreed that it is appropriate to apply
tolerances in order to cover on-road application and reflect variations
in test ground conditions.
SAE, Global, Ford, and the Alliance stated that in order to account
for otherwise uncontrolled-for test variability, NHTSA should follow
SAE J3069 such that the glare limits may be exceeded if the ADB
illuminance does not exceed 125% of the lower beam illuminance from the
vehicle measured under the same conditions. SAE, Global and Ford
commented that this better represents real-world conditions and
compensates for environmental factors such as dips and bumps in the
road, reflectivity of lane markers, ambient light, and vehicle pitch.
Global commented that the term ``spike'' is not defined and
recommended that it be defined relative to accommodating the natural
behavior of certain headlamp light sources to have a ``spike'' of light
intensity during the sequence of use.
Global also pointed out that in the proposed regulatory text (``no
longer that 1 meter'') ``that'' should be replace with ``than.''
Auto Innovators commented that the distance exceedance limit should
be eliminated because specifying both a time and distance specification
is duplicative, and timing is more relevant to real-world driving.
Agency Response
The final rule retains the 0.1 second component of the momentary
glare exceedance allowance and adds (as discussed in the next section)
an allowance for vehicle pitch.
The momentary glare exceedance allowance accounts for testing-
related variability caused by noise and uncontrolled test factors (such
as uncontrolled ambient illuminance).\164\ NHTSA believes that 2.5
seconds is an inordinately long time for a ``momentary'' exceedance,
for the reasons discussed earlier.\165\ The agency also declines to
follow SAE J3069 and allow ADB illuminance to exceed lower beam
illuminance by up to 25%. The reasons for this are discussed in Section
VIII.C.4, Maximum Illuminance Criteria (Glare Limits). NHTSA agrees
with Global that there was a typographic error in the proposed
S14.9.3.12.8.1 (now at S14.9.3.12.2), which has been corrected in the
final rule. The agency also agrees that even at the slowest test speed
of 25 mph the limiting factor is time, not distance, and has removed 1
m from the text as it serves no practical purpose.
---------------------------------------------------------------------------
\164\ NHTSA, in its testing, did not observe any test-related
variable other than pitch that led to a glare exceedance. While some
limited glare exceedances lasting less than 0.1 seconds were not
caused by pitch, these appeared to result from marginal performance
from the ADB system. The 0.1 second allowance means that such
exceedances would not be considered a noncompliance.
\165\ See Section VIII.C.5, ADB Adaptation Time.
---------------------------------------------------------------------------
NHTSA is removing the term ``spike'' and replacing it with a
clearer description of the adjustment: The agency will not consider, in
determining compliance, ``single illuminance values or consecutive
illuminance values occurring over a span of no more than 0.1 seconds
that exceed the applicable maximum illuminance[.]'' The momentary glare
exceedance duration may end in at least two ways. First, the
illuminance value can drop below the applicable glare limit. Second,
the glare limit itself might change (i.e., increase). This could happen
if the exceedance is experienced just before the glare limit changes.
In either case, if the glare limit is not exceeded for more than 0.1 s,
the exceedance will not be considered a noncompliance.
e. Vehicle Pitch
Pitch refers to rotation of a vehicle about its transverse axis
appearing as an opposing vertical motion of the front and rear ends of
a vehicle. When a vehicle's pitch increases, the vehicle's front end,
and therefore the angle of its headlamps, will raise in an upward
direction away from the road surface. Conversely, when pitch decreases,
the vehicle's front end will lower, and the headlamps light will be
cast downward towards the road surface.
The amount of glare perceived by other roadway users may be more
pronounced when the headlamp is pitched upward. Common causes of
changes in vehicle pitch angle include vehicle loading condition or
weight
[[Page 9975]]
distribution, tire inflation that deviates from specifications,
irregularities or pitting in the road surface, vehicle suspension
characteristics, and vehicle acceleration. As mentioned above, the NPRM
did not propose any adjustments to correct directly for or take vehicle
pitch into account as part of the compliance track testing, although it
specifically sought comment on this.
In the IIHS test method, pitch effects are corrected by measuring
road surface pitch changes through a self-leveling horizontal rotary
laser system every 5 m along the test track surface. The pitch angles
at each measured position are measured, and photometers placed at
different heights provide the illuminance data for each measurement
location. Once this illuminance data is collected, a pitch correction
factor is calculated that is used to offset any exceedance of glare
limits based on the roadway conditions.
Comments
As noted in the section above on allowances for momentary glare
exceedances, several commenters noted the potential effect of vehicle
pitch on test results. For this reason, Ford recommended NHTSA adopt
the IIHS pitch correction protocol. Ford commented that pitch
correction is essential to produce results that are independent of
differences in vehicle suspensions and are repeatable at different test
tracks and different locations on the test tracks themselves. Ford
noted that dynamic testing makes illuminance more difficult to measure
because throughout the driving event, the vehicle pitch changes and
effects from instrumentation inaccuracies increase proportionately. On
the other hand, Intertek claimed that pitch correction would not be
necessary unless there is a sustained change in pitch longer than 0.1
seconds.
Agency Response
After analyzing the comments and its own testing NHTSA has modified
the proposal by adding in an explicit allowance for pitch variation:
The agency will not consider any illuminance measurements recorded
while the vehicle pitch exceeds the average pitch recorded throughout
the entire measurement distance range specified for that scenario by
more than 0.3 degrees.
Although the NPRM did not propose any adjustments to directly take
vehicle pitch into account, the NPRM requested comment on this issue.
Further, the proposed test procedures controlled for the following
factors that could affect pitch:
Vehicle loading and suspension--the headlamps will be
aimed when the vehicle is loaded as it will be during testing, and the
gas tank (if the vehicle is equipped with one) is maintained at lease
three-quarters full. The tires will be within 1 psi of recommended cold
pressure.
Road surface--the road surface must have an IRI
measurement of less than 1.5 m/km.
Vehicle acceleration--the vehicle speed must be maintained
within 1 mph of the target test speed throughout the test run.
In addition to these procedures, as explained above, the proposal
also contained an allowance for momentary glare exceedances that was
intended to account for variations in illumination due to uncontrolled
testing variables, including minor imperfections in the road surface
that can cause glare exceedances by affecting vehicle pitch.
Despite these specifications, NHTSA's test data revealed two
situations in which vehicle pitch still impacted measured illuminance
and were not accounted for in the provisions listed above.
First, NHTSA repeatedly observed small cyclical pitch changes
related to road surface undulations, which affected illuminance
measurements. For one example, see Figure 34.
[GRAPHIC] [TIFF OMITTED] TR22FE22.032
Here, where the maximum pitch occurs (at about 85 m), there is a
peak in the illuminance reading. The highest illuminance value (at
about 31 m) also coincides with a positive spike in pitch. (In these
instances, the pitch did not exceed the average pitch by more than 0.3
degrees, so if this were a compliance test, these values would still be
considered when assessing compliance; in any case, in this instance,
all illuminance values are still within the glare limits).
To better understand the sources of the pitch oscillations
identified in testing, NHTSA collected pitch information both when the
test vehicle was moving, and when it was stationary at the same (or as
close as possible) location on the test surface. See Table 7. The pitch
measurements were similar, indicating that dynamic contributors were
generally small. Accordingly, although the testing did not show any
instances where pavement-related vehicle pitching led to a glare
exceedance that would be excused through the final pitch variation
allowance, the agency recognizes the possibility for this to occur and
has thus accounted for pitch in the regulatory text.
[[Page 9976]]
Table 7--Vehicle Pitch in Static and Dynamic States
------------------------------------------------------------------------
Pitch
Distance (deg.)
------------------------------------------------------------------------
Speed: 41 mph:
148.982.................................................. 0.3
119.254.................................................. 0.46
59.605................................................... 0.51
29.926................................................... 0.64
15.145................................................... 0.65
Speed: 0 mph (static):
149.058.................................................. 0.17
119.274.................................................. 0.51
59.650................................................... 0.46
29.939................................................... 0.63
15.152................................................... 0.63
------------------------------------------------------------------------
Second, NHTSA observed pitch changes related to acceleration. For
example, NHTSA tested the lower beams on the Fusion at 69 mph in a
straight-path scenario. See Figure 35. When the vehicle reached the
beginning of the illuminance measurement range (220 m) it had not yet
attained the target speed, so it was still accelerating and pitching
upward, resulting in an ``exceedance'' of the applicable glare limit.
The pitch of 1.1 degrees during the exceedance was greater than 0.3
degrees over the average pitch of 0.68 degrees. This shows that pitch
in excess of the proposed allowance could lead to an exceedance of the
glare limits.\166\
---------------------------------------------------------------------------
\166\ Because the target speed had not yet been attained, had
this been a compliance test, the measured illuminance value would
not be having been considered in determining compliance. We also
note that this glare exceedance lasted for more than 0.1 second, so
it would not have been addressed with the momentary glare allowance.
[GRAPHIC] [TIFF OMITTED] TR22FE22.033
Based on these instances of vehicle pitch fluctuations impacting
measured illuminance (due to either the road surface or acceleration),
the final rule includes an allowance for vehicle pitch variation.
NHTSA's testing demonstrated that it is generally possible to maintain
pitch within less than 0.3 degrees of the average pitch recorded
throughout the entire measurement distance. We believe that no
allowance for pitch, or a higher pitch variation allowance (e.g., ``by
no more than 0.4 degrees)--resulting in a more stringent test--could
lead manufacturers to design headlamps providing sub-optimal visibility
(because manufacturers might aim the headlamps down to minimize the
possible effects of pitch during a compliance test).
We believe this adjustment methodology is preferable to the IIHS
pitch correction procedure for the purposes of this rule. The IIHS test
procedure relies on interpolation, which introduces inaccuracy (without
knowing the linearity of the beam pattern). The final rule methodology
does not interpolate but instead measures pitch directly. By
controlling pitch to 0.3 degrees or less and regulating performance
only within that range, we are directly measuring the aspect of
performance that matters to safety. The IIHS procedure also requires
that the vehicle path be mapped with respect to pitch prior to running
the test. The final rule procedure does not require this, which
simplifies the test procedure.
11. Repeatability
The NPRM included an analysis of the repeatability of the test data
from the 2015 ADB Test report.\167\ That test data was based on the
proposed test procedures, which utilized dynamic stimulus vehicles.
---------------------------------------------------------------------------
\167\ NPRM, pp. 51789-51798.
---------------------------------------------------------------------------
Comments
NHTSA received a variety of comments on the repeatability of the
proposed test. One commenter, Intertek, agreed with NHTSA's
repeatability analysis. Other commenters expressed concerns that the
proposed test procedures were not repeatable based upon the complexity
of the proposed test procedures and a variety of test conditions that
might affect repeatability. Commenters identified several factors they
argued would adversely affect repeatability.\168\
---------------------------------------------------------------------------
\168\ A number of comments about repeatability were related to
the proposal to use stimulus vehicles. Because the final rule does
not use stimulus vehicles, we need not address those comments as the
issue is moot.
---------------------------------------------------------------------------
Auto Innovators, MEMA, the Alliance, TSEI, and Volkswagen commented
that the proposed track testing was overly complicated and expressed
concerns that it would not lead to repeatable results.
SAE commented generally that test results (both for tests conducted
on the same track and for tests conducted on different tracks) would be
sensitive to the environment because lighting measurements are affected
by small changes in conditions. Other commenters echoed this and
identified unspecified test conditions that they argued could introduce
uncontrolled variability, causing acceptable levels of repeatability
and reproducibility of the test scenarios to be extremely challenging
to achieve, particularly given the stringency of the requirements. The
Alliance and Volkswagen commented that, although the NPRM requires the
photometers to be zero-calibrated to the ambient light, the ambient
light can change throughout the data collection, introducing
uncontrollable variability. Volkswagen
[[Page 9977]]
also stated that the presence of reflectors in the environment may also
cause variances by redirecting part of the test vehicle lights into the
photometers. Volkswagen also commented that the NPRM only specified
that there be no precipitation and a dry road surface, but other
environmental conditions such as fog, dust, or pollution could affect
results. TSEI identified variation in road materials and reflectivity,
weather conditions, and road surface as other factors. Toyota
identified the test vehicle's suspension, tires, and acceleration/
deceleration during the test as affecting repeatability; it stated that
it is unclear whether any test track meets the ideal conditions
specified in the proposal, and, if so, whether such a test track can be
reasonably accessible to conduct compliance testing.
Auto Innovators commented that to evaluate testing variability, one
member company repeated a test series using a vehicle tested by FTTA
and cited in the NPRM. The full test series was repeated under the same
conditions using comparable measurement equipment. The commenter stated
that, despite careful attention to test setup and test conditions, the
results varied from those obtained by FTTA to the extent that the
variation altered the compliance status of the vehicle.
Agency Response
The final rule substantially reduces the complexity of the test,
especially by using test fixtures instead of stimulus vehicles and
streamlining the test scenarios. Further, while it is true that
lighting measurements can be sensitive to small changes in conditions,
NHTSA's testing has shown that measurement of headlamp illuminance
using the whole vehicle, rather than a component-level test, can be
accomplished in a repeatable manner.\169\ NHTSA has identified, and the
test parameters and conditions specified in the final rule control for,
the major sources of test-related variability, including vehicle pitch.
This final rule also includes a data filter, which will smooth out the
measured illuminance data, in addition to the proposed allowance for
momentary glare exceedances, which should address any otherwise
uncontrolled ambient illumination, among other things.
---------------------------------------------------------------------------
\169\ 2105 ADB Test Report, p. 172.
---------------------------------------------------------------------------
NHTSA conducted a series of tests to determine the level of
variability in the track test finalized today, as well as the SAE J3069
test method.\170\ To do this, NHTSA analyzed data from testing using
the original-equipment lower beams on a FMVSS-certified 2016 Volvo
XC90. Multiple runs of each test scenario were conducted to permit
different types of repeatability analyses, including: Same night
(gauge); different night (test procedure); and different headlamp
aiming technician (reproducibility). Data from these test trials were
analyzed for each measurement distance sub-range (interval),
calculating the mean, standard deviation, 95% confidence interval, and
95% prediction interval.\171\ Sample results of Test Number 1
(straight--oncoming) for the sub-range of 120 m to 220 m are shown
below in Tables 8 through 10. (Throughout this section, ``Test Number''
refers to the scenario test numbers as reported in the repeatability
report. Please see Table 1 (NHTSA Test Matrix) in that report. The test
scenarios in the repeatability report are the same as the test
scenarios specified in Table XXII of this final rule, but the numbering
of the test scenarios differs.) Data similar to this (i.e., 10 test
repetitions, 10 separate test days, and 3 headlamp aiming technicians)
were collected for every final rule scenario. Testing with the lower
beam headlamps activated (the test vehicle was not ADB-equipped)
allowed the agency to isolate variability to factors related to the
test and to be certain that ADB performance itself did not contribute
to variability. Oncoming and same direction data were collected during
the same run, using receptor heads (i.e., light sensors) placed in the
appropriate positions.
---------------------------------------------------------------------------
\170\ See Mazzae, E.N., Baldwin, G.H.S., Satterfield, K., &
Browning, D.A. 2021. Adaptive Driving Beam Headlamps Test
Repeatability Assessment. Washington, DC: National Highway Traffic
Safety Administration. The discussion here is a summary of that
report, which has been placed in the docket for this rulemaking.
\171\ NHTSA has used similar analyses before to assess the
reliability and repeatability of test methods developed for FMVSS.
As an example, refer to the test report ``Repeatability,
Reproducibility, and Sameness of Quiet Vehicle Test Data''
supporting the development of FMVSS No. 141, Minimum sound level for
hybrid and electric vehicles. See Docket number NHTSA-2016-0125-0006
at www.regulations.gov.
Table 8--NHTSA Test No. 1, 220 m-120 m, Gauge (Measurement System) Repeatability
----------------------------------------------------------------------------------------------------------------
Difference
between pitch
maximum (sub-
Repetition Car eye point Cycle eye Truck eye range) and pitch
Descriptive statistic (all in one (lux) point (lux) point (lux) average (entire
night) measurement
distance)
(degrees)
----------------------------------------------------------------------------------------------------------------
1 0.0688 0.0751 0.0652 0.0900
2 0.0666 0.0802 0.0602 0.1600
3 0.0751 0.0724 0.0618 0.1400
4 0.0665 0.0764 0.0560 0.1000
5 0.0686 0.0675 0.0561 0.1100
6 0.0711 0.0722 0.0599 0.1000
7 0.0709 0.0730 0.0542 0.1100
8 0.0830 0.0763 0.0590 0.1000
9 0.0693 0.0822 0.0574 0.0900
10 0.0736 0.0822 0.0625 0.1400
Mean......................... .............. 0.0714 0.0758 0.0592 .................
StdDev (S)................... .............. 0.0049 0.0048 0.0034 .................
Min.......................... .............. 0.0665 0.0675 0.0542 .................
Max.......................... .............. 0.0830 0.0822 0.0652 .................
95% C.I. Margin of Error (+/- .............. 0.0035 0.0034 0.0024 .................
)...........................
95% C.I. Upper Limit......... .............. 0.0749 0.0791 0.0617 .................
95% C.I. Lower Limit......... .............. 0.0678 0.0724 0.0568 .................
95% Prediction Interval .............. 0.0117 0.0113 0.0080 .................
Margin of Error (+/-).......
[[Page 9978]]
95% P.I. Upper Limit......... .............. 0.0831 0.0870 0.0673 .................
95% P.I. Lower Limit......... .............. 0.0596 0.0645 0.0512
----------------------------------------------------------------------------------------------------------------
Table 9--NHTSA Test No. 1, 220 m-120 m, Test Procedure Repeatability
----------------------------------------------------------------------------------------------------------------
Difference
between pitch
Repetition maximum (sub-
Descriptive statistic (one per Car eye point Cycle eye Truck eye range) and pitch
night) (lux) point (lux) point (lux) average (entire
test number
range) (degrees)
----------------------------------------------------------------------------------------------------------------
1 0.0839 0.0905 0.0774 0.1048
2 0.0847 0.0805 0.0564 0.1072
3 0.0796 0.0857 0.0662 0.1030
4 0.0713 0.0772 0.0522 0.1313
5 0.0745 0.0865 0.0634 0.1061
6 0.0777 0.0865 0.0614 0.1260
7 0.0717 0.0745 0.0554 0.1226
8 0.0794 0.0718 0.0559 0.1271
9 0.0817 0.0884 0.0679 0.1210
10 0.0815 0.0686 0.0581 0.0990
Mean......................... .............. 0.0786 0.0810 0.0614 .................
StdDev (S)................... .............. 0.0048 0.0076 0.0076 .................
Min.......................... .............. 0.0713 0.0686 0.0522 .................
Max.......................... .............. 0.0847 0.0905 0.0774 .................
95% C.I. Margin of Error (+/- .............. 0.0034 0.0055 0.0054 .................
)...........................
95% C.I. Upper Limit......... .............. 0.0820 0.0865 0.0668 .................
95% C.I. Lower Limit......... .............. 0.0752 0.0755 0.0560 .................
95% Prediction Interval .............. 0.0113 0.0181 0.0179 .................
Margin of Error (+/-).......
95% P.I. Upper Limit......... .............. 0.0899 0.0991 0.0794 .................
95% P.I. Lower Limit......... .............. 0.0673 0.0629 0.0435
----------------------------------------------------------------------------------------------------------------
Table 10--NHTSA Test No. 1, 220 m-120 m, Reproducibility
--------------------------------------------------------------------------------------------------------------------------------------------------------
Difference
between pitch
maximum (sub-
Descriptive statistic Aimer Repetition Car eye point Cycle eye Truck eye range) and pitch
(lux) point (lux) point (lux) average (entire
test number
range) (degrees)
--------------------------------------------------------------------------------------------------------------------------------------------------------
A 1 0.0545 0.0599 0.0578 0.1323
B 1 0.0673 0.0672 0.0581 0.1522
B 2 0.0658 0.0662 0.0556 0.0977
C 1 0.0632 0.0631 0.0545 0.0983
C 2 0.0676 0.0663 0.0540 0.1549
Mean........................................ ....................... .............. 0.0637 0.0645 0.0560 .................
StdDev (S).................................. ....................... .............. 0.0054 0.0030 0.0019 .................
--------------------------------------------------------------------------------------------------------------------------------------------------------
The standard deviation is a measurement of the variation within the
data set. The 95th percentile confidence interval is the estimate of
the upper and lower illuminance values in which there is a 95%
probability that the true mean falls within this interval. The
confidence interval is calculated using the equation
[GRAPHIC] [TIFF OMITTED] TR22FE22.034
[[Page 9979]]
Where the margin of error is calculated using t as the upper
critical value for the t distribution with n-1 degrees of freedom, S as
the standard deviation, n as sample size. The confidence interval is
then calculated by summing the mean (x) and the margin of error. The
95th percentile prediction interval is the estimate of the interval of
which there is a 95% probability that future measurements will be
within. The prediction interval is calculated using the equation:
[GRAPHIC] [TIFF OMITTED] TR22FE22.035
Where the margin of error is calculated using t as the upper
critical value for the t distribution with n-1 degrees of freedom, S as
the standard deviation, and n as the sample size. The prediction
interval is then calculated by summing the mean (x) and the margin of
error.
Note that CI95 and PI95 are
dependent on the number of values collected (t0.975 is large
for small sample sizes and decreases as more data are collected). That
is to say, the more data collected for a distribution, the more
confident we can be of where the true mean is located and where future
measurement values will fall. While a standard deviation can be
calculated for a very small sample size, CI and PI will be large for
small samples, even if the population standard deviation is small.
Taken together, the standard deviation and the prediction interval can
be used to quantify the repeatability of the test procedure. The
smaller the standard deviations and the tighter the prediction
interval, the smaller the range of values we will expect future values
to be within, indicating a tighter precision of measurement system.
The magnitude of the prediction intervals can be used to determine
how a vehicle with a similar headlighting system and beam pattern is
likely to perform with respect to the glare limits. The prediction
interval indicates the range within which a similar vehicle's measured
illuminance value is 95% likely to fall (5% chance of not falling
within the range). If the upper end value of the prediction interval is
less than the glare limit for a measurement distance sub-range, then a
similar vehicle's measured value is at least 95% likely to be less than
the glare limit when tested by NHTSA.\172\ Because the repeatability of
the measurement system and test procedure produced small standard
deviations, the variability of the illuminance values should not differ
substantially, even if the maximum illuminance value for other
headlighting systems is higher. This assumption holds true provided the
headlamp beam pattern under test demonstrates similar gradients in and
around the measurement locations.
---------------------------------------------------------------------------
\172\ For example, if this analysis produces a 95% prediction
interval of 0.180 lux and the limit is 1.8, a system with a true
performance of 1.62 or less will have a 95% or greater probability
of receiving a passing score if the agency were to do a compliance
test, using a single run.
---------------------------------------------------------------------------
Table 11 below pools the standard deviation for the oncoming
straight and left curve scenarios (Test Number 1,3,4,7--each of these
tests provide similar means), and the same direction straight and left
curve scenarios (Test Number 2,5), and lists the standard deviation
observed for the oncoming right medium curve (Test Number 6) and
oncoming-right large curve (Test Number 8) for each measurement
distance sub-range.
Table 11--Test Procedure: Standard Deviation Results
----------------------------------------------------------------------------------------------------------------
Same direction
Oncoming NHTSA NHTSA test Oncoming right Oncoming right
NHTSA test numbers 1, numbers 2, 5 NHTSA test NHTSA test
3, 4, 7 (lux) (lux) number 6 (lux) number 8 (lux)
----------------------------------------------------------------------------------------------------------------
Measurement Distance Sub-Range: All standard deviations were at or below:
---------------------------------------------------------------------------
220 m-120 m..................... 0.0076 ................. ................. .................
150 m-120 m..................... 0.0068 ................. ................. .................
119.9 m-60 m.................... 0.0156 ................. ................. .................
100 m-60 m...................... ................. 0.0153 ................. .................
70 m-60 m....................... ................. ................. ................. 0.5996
59.9 m-30 m..................... 0.0599 0.0494 ................. 0.5921
50 m-30 m....................... ................. ................. 0.9648 .................
29.9 m-15 m..................... 0.0713 0.1324 0.0651 0.0602
----------------------------------------------------------------------------------------------------------------
Table 12--Prediction Interval Margin of Error Values of the Test Procedure
[NHTSA Test]
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Glare
Measurement distance sub-range limit Test number 1 Test number 2 Test number 3 Test number 4 Test number 5 Test number 6 Test number 7 Test number 8
(lux)
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
95th Percentile Prediction Interval Car Eye Point/Passenger Side Mirror (Values in lux)
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
220 m-120 m................... 0.3 0.0113 (3.8%).... ................. ................. ................. ................. .................. 0.0128 (4.3%).... ..................
150 m-120 m................... 0.3 ................. ................. ................. 0.0145 (4.8%).... ................. .................. ................. ..................
119.9 m-60 m.................. 0.6 0.0357 (6.0%).... ................. ................. 0.0238 (4.0%).... ................. .................. 0.0171 (2.9%).... ..................
70 m-60 m..................... 0.6 ................. ................. ................. ................. ................. .................. ................. 1.4225 (237%) *
50 m-30 m..................... 1.8 ................. ................. ................. ................. ................. 2.2890 (127%) *... ................. ..................
59.9 m -30 m.................. 1.8 0.0741 (4.1%).... ................. 0.0690 (3.8%).... 0.0933 (5.2%).... ................. .................. 0.0812 (4.5%).... 1.4047 (78%) *
29.9 m-15 m................... 3.1 0.1436 (4.6%).... ................. 0.1672 (5.4%).... 0.1693 (5.5%).... ................. 0.1534 (4.9%)..... 0.1637 (5.3%).... 0.1427 (4.6%)
100 m-60 m.................... 4.0 ................. 0.0331 (0.8%).... ................. ................. 0.0189 (0.5%).... .................. ................. ..................
[[Page 9980]]
59.9 m-30 m................... 18.9 ................. 0.0963 (0.5%).... ................. ................. 0.1121 (0.6%).... .................. ................. ..................
29.9 m-15 m................... 18.9 ................. 0.2348 (1.2%).... ................. ................. 0.3141 (1.7%).... .................. ................. ..................
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
The prediction intervals shown in Table 12 are small compared to
the limits that are finalized for each measurement distance sub-range.
For instance, we found that within the sub-range of 120 m to 220 m Test
Number 1 resulted in a prediction interval of 0.0113 lux as compared to
the limit of 0.3 lux. This interval represents 3.8% of the limit.
Both measurement system (gauge) repeatability results and full test
repeatability results revealed NHTSA test scenarios involving right
curves (Test Numbers 6 and 8) to be less repeatable than the other test
scenarios (marked with * in the table). Unsurprisingly, these two
scenarios showed a pattern of higher standard deviations with respect
to the other NHTSA test scenarios. SAE Test Drive 3, in which the test
fixture was located to the right of the test vehicle also showed a
pattern of higher standard deviations as compared to the other
scenarios. As is the case with many U.S. vehicle lower beam headlamps,
the 2016 Volvo XC90 lamps produced beam patterns with a higher right-
side horizontal cutoff. The variability of measurements recorded on the
right side of the vehicle (right curve scenarios) is attributable to
the cutoff at the right portion of the headlamp pattern of this vehicle
projecting near the location of the lower-mounted light sensors. The
lower beam headlamps tested in this repeatability study exceeded the
glare limits for these two-measurement distance sub-ranges as well. An
ADB pattern designed to meet the requirements finalized today will need
to provide a greater angular distance between the cutoff and the light
sensors to meet the minimum glare requirements as described earlier in
the right curve discussion. With such a design, the agency anticipates
that similar repeatability will be obtained for right curves as was
demonstrated for the other scenarios.
Breaking down the 8 NHTSA test scenarios by measurement distance
sub-range and measurement points (light sensor locations) gives a total
of 99 data points. The finalized test method found the same pass/fail
results for 97 of the 99 data points in every one of the 10 test
procedure repetitions. For the vehicle's lower beam headlamps under
test, 94 of those data points, without fail, were under the glare limit
criteria and 3 of the data points consistently exceeded the glare
limits. The vehicle consistently failed to meet the glare criteria for
Test Number 6 (medium right curve) at the car eye point for the sub-
range 50 m-30 m. It also consistently failed to meet the glare
criterion for Test Number 8 (Large Right Curve) at the Car Eye and
Cycle Eye point for the sub-range 70 m-60 m. The 2 data points with
inconsistent results (sometimes the test reported that the vehicle met
the criteria and other times it reported a failure) were also found on
these two right curve tests. Test Number 6 had mixed results at the
cycle eye point for the sub-range 50 m-30 m and Test Number 8 had mixed
results at the car eye point for the sub-range 59.9 m-30 m. As
discussed above, we do not expect any mixed results for an ADB beam
pattern designed to meet the track test finalized today.
NHTSA also conducted testing to examine the possibility of
variability introduced by different technicians visually aiming the
headlamps. This reproducibility analysis examined the effects of three
different technicians performing headlamp aiming prior to running a
test set. This analysis found only small differences in illuminance
measurements between datasets associated with different headlamp aiming
operators. The pooled standard deviations for each orientation are
shown in Table 13 below.
Table 13--Reproducibility: Standard Deviation Results
------------------------------------------------------------------------
Oncoming NHTSA Same direction
test numbers 1, NHTSA test
3, 4, 6, 7, 8 numbers 2, 5
(lux) (lux)
------------------------------------------------------------------------
Measurement Distance Sub-Range: All standard deviations were below:
-------------------------------------
220 m-120 m................... 0.0055 .................
150 m-120 m................... 0.0069 .................
119.9 m-60 m.................. 0.0123 .................
100 m-60 m.................... N/A 0.0153
70 m-60 m..................... 0.0122 .................
59.9 m-30 m................... 0.0366 0.0521
50 m-30 m..................... 0.0355 .................
29.9 m-15 m................... 0.0933 0.1264
------------------------------------------------------------------------
NHTSA also assessed the repeatability of the SAE J3069 test (Table
14). We found that the SAE test resulted in similar variability of both
measured illuminance and test outcomes.
[[Page 9981]]
Table 14--Test Procedure: Standard Deviation Results
----------------------------------------------------------------------------------------------------------------
Same direction
Oncoming NHTSA NHTSA test Oncoming right Oncoming right
NHTSA test numbers 1, numbers 2, 5 NHTSA test NHTSA test
3, 4, 7 (lux) (lux) number 6 (lux) number 8 (lux)
----------------------------------------------------------------------------------------------------------------
Measurement Distance Sub-Range: All standard deviations were at or below:
---------------------------------------------------------------------------
220 m-120 m..................... 0.0076 ................. ................. .................
150 m-120 m..................... 0.0068 ................. ................. .................
119.9 m-60 m.................... 0.0156 ................. ................. .................
100 m-60 m...................... ................. 0.0153 ................. .................
70 m-60 m....................... ................. ................. ................. 0.5996
59.9 m-30 m..................... 0.0599 0.0494 ................. 0.5921
50 m-30 m....................... ................. ................. 0.9648 .................
29.9 m-15 m..................... 0.0713 0.1324 0.0651 0.0602
----------------------------------------------------------------------------------------------------------------
Oncoming SAE test Preceding SAE Preceding SAE
SAE drives 1, 2 test drives 10, Oncoming SAE test test drive 12
(lux) 11, 12 (lux) drive 3 (lux) (lux)
----------------------------------------------------------------------------------------------------------------
Measurement Distance: All standard deviations were at or below:
---------------------------------------------------------------------------
155............................. 0.0141 0.0228 0.1234 0.1436
120............................. 0.0132 0.0231 0.1489 0.1909
60.............................. 0.0219 0.0226 0.2464 0.3020
30.............................. 0.0380 0.0341 0.0413 0.3503
----------------------------------------------------------------------------------------------------------------
D. Laboratory (Component-Level) Testing
1. Need for Laboratory Testing
The NPRM proposed that an ADB system would also be subject to the
existing component-level laboratory-based upper and lower beam
photometry requirements. With respect to the adaptive beam, the NPRM
proposed that an area of reduced intensity meet the applicable Table
XIX lower beam photometry requirements (maxima and minima), and that an
area of unreduced intensity meet the applicable Table XVIII upper beam
photometry requirements. The NPRM proposed that when the ADB system is
producing a lower beam, that beam be subject to all the Table XIX lower
beam requirements, and when producing an upper beam, the beam be
subject to all the Table XVIII upper beam photometric requirements. The
NPRM proposed to require that the system provide only a lower beam when
the vehicle is travelling less than 25 mph (unless overridden by the
driver).\173\
---------------------------------------------------------------------------
\173\ For a general explanation of the laboratory photometry
requirements, see the NPRM at p. 51770.
---------------------------------------------------------------------------
This differed from SAE J3069 in some respects. SAE J3069 only
specifies that the lower beam maxima are not exceeded within the area
of reduced intensity, and that the lower beam minima be met in the area
of unreduced intensity. (These provisions reference the relevant SAE
photometric standards; the proposal instead appropriately referenced
the upper and lower beam photometric requirements in Tables XVIII and
XIX of the standard.)
Comments
Some commenters supported the inclusion of at least some laboratory
testing requirements. AAA and Intertek supported applying the existing
upper beam photometric requirements to the upper beam, Consumer Reports
supported requiring that the part of the adaptive beam that is cast
near other vehicles not exceed the current lower beam maxima, and the
part of the adaptive beam that is cast onto unoccupied roadway not
exceed the current upper beam maxima. Consumer Reports also supported
applying the lower beam minima to areas of reduced intensity and the
upper beam minima to areas of unreduced intensity. Zoox supported
applying the existing laboratory requirements to the upper and lower
beams.
In contrast, both SAE and Global disagreed that photometric
component testing is necessary in addition to vehicle testing. SAE
explained that, when SAE J3069 was published, component level testing
was included as an additional metric to aid in lamp manufacturers'
process controls and also because it is a familiar compliance method.
The SAE J3069 rationale accordingly explained that, if vehicle-level
testing of ADB systems were to be included in FMVSS No. 108, ``any need
for laboratory photometric requirements may be reconsidered for
removal.'' SAE therefore requested that the final rule not include
component testing.
Agency Response
The final rule retains the laboratory testing requirements because
the full-vehicle track test alone may not be sufficient to ensure that
an ADB system provides adequate visibility and does not glare other
vehicles, as discussed further below. Accordingly, the final rule
applies the existing laboratory testing requirements to any beam an ADB
system may provide (a lower beam, an upper beam, or an adaptive driving
beam). (The different types of beams classified in the final rule are
discussed in Section VIII.D.2.)
The full vehicle track test and the laboratory-based component test
are complementary. The full vehicle dynamic track test only evaluates
glare; it does not evaluate visibility. The final requirements include
laboratory testing requirements that ensure that the ADB system always
provides the driver with a minimum level of visibility.
The laboratory testing requirements generally assure adequate
visibility by specifying minimum levels of light at certain locations
(test points) that roughly correspond to different locations on the
road. As explained in Section VIII.D.2, we have modified the proposal
to give manufacturers greater flexibility in determining which areas of
the roadway receive an area of reduced intensity or an area of
unreduced intensity. For the former, the appropriate minimum visibility
is the applicable lower beam minima; for the
[[Page 9982]]
latter, the appropriate minimum visibility is the applicable upper beam
minima. Similarly, the lower beam minima indicate the appropriate
minimum visibility for the lower beam, and the upper beam minima for
the upper beam.
Laboratory testing will complement the track test to minimize glare
to other vehicles. The laboratory testing requirements minimize glare
by specifying photometric maxima at certain test points. The track test
evaluates whether an ADB system glares a test fixture in specific
scenarios. While the final track test requirements encompass many
common scenarios (e.g., a single oncoming vehicle in the adjacent
lane), they do not test every conceivable scenario. Laboratory testing
will therefore help serve as a backstop to the track test. Moreover,
the track test evaluates glare out to 220 meters. Extremely bright
upper beams (for example, an ECE-approved upper beam that exceeds the
current FMVSS No. 108 75,000 cd upper beam maximum) could create glare
further than this distance. The laboratory testing requirements will
therefore also ensure that upper beams are not exceedingly bright.
(Indeed, if the current upper beam maxima did not apply to the upper
beam of an ADB system, upper beam maximum intensity would effectively
be unregulated). Accordingly, the final rule specifies that the lower
beam and an area of reduced intensity must not exceed any applicable
Table XIX (lower beam) maxima, and the upper beam and areas of
unreduced intensity must not exceed any applicable Table XVIII (upper
beam) maxima.
2. Definitions of Areas of Reduced and Unreduced Intensity
The NPRM proposed (in S9.4.1.6.6-.7) that ``when the system is
producing a lower beam with an area of reduced light intensity designed
to be directed towards oncoming or preceding vehicles, and an area of
unreduced intensity in other directions,'' the system must meet the
Table XIX (lower beam) photometric requirements within the area of
reduced intensity and the Table XVIII (upper beam) photometric
requirements in the within the area of unreduced intensity. The
proposed rule did not otherwise define the areas of reduced and
unreduced intensity.
Comments
Several commenters suggested clarifications to the definitions or
references to the areas of reduced and unreduced intensity. ALNA, Zoox,
and Valeo commented that the definitions of the area of reduced
intensity and/or area or unreduced intensity were unclear. Mercedes
suggested expanding the definition of the area of reduced intensity to
include portions of the roadway other than those occupied by other
vehicles because sophisticated ADB systems are capable of dimming areas
of the beam pattern directed towards retroreflective signs or wet road
surfaces in order to minimize glare to the driver. Stanley requested
confirmation that the area of reduced intensity corresponds to the
windshield area of an oncoming vehicle and the area of unreduced
intensity refers to the area outside of the area of reduced intensity.
Ford suggested edits to clarify the regulatory text setting out the
dimmed and undimmed area requirements. It suggested that instead of
referring to the lower beam, the regulatory text refer to the
``adaptive driving beam,'' and suggested rearranging the regulatory
text. Valeo similarly commented that classifying the adaptive beam as a
lower beam is misleading because it is actually a modified driving or
upper beam and suggested including a definition of ``adaptive driving
beam.'' Intertek suggested requiring that the system emit a base lower
beam, which is only augmented by adding light to the portions of the
beam in which a preceding or oncoming vehicle is not detected, to the
limit that when there are no preceding or coming vehicles detected the
emitted beam is a compliant upper beam. This would, it contended,
ensure that the augmented lower beam is always compliant to the
applicable lower beam photometry requirements. Zoox commented that the
NPRM appeared to assume that the adaptive beam is a defined, static
beam pattern that is generated based on camera recognition of oncoming
or preceding traffic. It stated that the laboratory test requirements
should be technology neutral with respect to the manner and method of
controlling and producing an adaptive beam.
Some commenters requested that the agency establish more specific
laboratory test requirements. Zoox commented that the proposed
laboratory test requirements were not clear on how to determine which
portion of an adaptive beam is to be checked against the lower beam or
upper beam minima and maxima. For example, a system may progressively
dim an LED array across the headlamp width as vehicle distance closes
for oncoming traffic. The ADB pattern may also differ for oncoming
versus preceding traffic. Zoox requested clarification of which test
points would apply and how they would be evaluated. SL and Intertek
commented that specific test requirements need to be established
because it would be impracticable to test the hundreds of possible
adaptive beam patterns.
Agency Response
The final rule does not adopt the proposed regulatory text that
referred to an area of reduced intensity as being ``designed to be
directed towards oncoming or preceding vehicles,'' and to the area of
unreduced intensity as being directed ``in other directions.'' The
proposed text implied that an area of reduced intensity must be
directed towards oncoming or preceding vehicles and that an area of
unreduced intensity must be directed towards unoccupied portions of the
roadway. The final rule defines a new beam type, an ``adaptive driving
beam,'' and adopts the definition of this in SAE J3069 MAR2021 as ``a
long-range light beam for forward visibility, which automatically
modifies portions of the projected light to reduce glare to traffic
participants on an ongoing, dynamic basis.'' It requires that areas of
reduced intensity conform to the Table XIX test points, areas of
unreduced intensity conform to the Table XVIII test points and allows
for a 1-degree transition zone between areas of reduced and unreduced
intensity.
The final rule is intended to give manufacturers the flexibility to
design systems that provide an area of reduced intensity not only to
prevent glare to oncoming or preceding vehicles, but also in other
situations in which a dimmed beam would be beneficial (such as towards
retroreflective signs). Creating a new ``adaptive driving beam''
classification, distinct from the existing lower and upper beam
definitions, accomplished this.\174\ The intent behind these changes is
to essentially, as Intertek suggested, provide that the system emit a
lower beam, which is only augmented by adding light to the portions of
the beam in which a preceding or oncoming vehicle is not detected, to
the limit that when there are no preceding or coming vehicles \175\ the
emitted beam is an upper beam.
---------------------------------------------------------------------------
\174\ This is also related to comments that recommended not
specifying the upper beam minima in the area of unreduced intensity.
The final rule retains the specification of the upper beam minima in
the area of unreduced intensity, but now gives manufacturers the
flexibility to use an area of reduced intensity on roadway not
occupied by oncoming or preceding vehicles. This is discussed in
more detail in Section VIII.D.4.
\175\ Or other situations, such as the presence of
retroreflective signs, in which it would be appropriate or optimal
to provide less than a full upper beam.
---------------------------------------------------------------------------
[[Page 9983]]
Manufacturers will therefore have the flexibility to design the
system to produce areas of reduced intensity and areas of unreduced
intensity as they see fit, subject to several requirements or
constraints:
The adaptive driving beams must consist only of area(s) of
reduced intensity, area(s) of unreduced intensity, and transition
zone(s).
When the ADB system is operating in manual mode, the
system must provide only an upper beam or a lower beam. This was
implicit in the proposed regulatory text but is made explicit in the
final rule.
When the ADB system is operating in automatic mode, the
system must provide an adaptive driving beam. The adaptive driving beam
is subject to several requirements, including the following:
[ssquf] The adaptive driving beam must be designed to conform to
the track test requirements.
[ssquf] For speeds below 20 mph, the system must provide only lower
beams (unless manually overridden).
[ssquf] In an area of reduced intensity, the adaptive driving beam
must be designed to conform to the Table XIX (lower beam) photometry
requirements.
[ssquf] In an area of unreduced intensity, the adaptive driving
beam must be designed to conform to the Table XVIII (upper beam)
photometry requirements.
[ssquf] A 1-degree transition zone is permitted between any areas
of reduced and unreduced intensity.
These requirements are discussed in more detail in the following
sections (except for the track test requirements, which were discussed
in Section VIII.C).
In conducting its compliance testing, NHTSA will request
information from the manufacturer on how to power and control the
headlamp.\176\ The lower and upper beams will be aimed prior to
testing, and the aim will remain unchanged during testing. Testing of
the lower and upper beams will be the same as it is currently. To test
the adaptive driving beam, NHTSA will activate the headlamp in the
goniometer according to the manufacturer's instructions to produce an
adaptive driving beam pattern that is consistent with an ADB pattern
that would appear in the real world with areas of reduced intensity,
unreduced intensity, and/or transition zone(s). The ADB pattern
generated will result in light directed toward all the test points in
Tables XVIII and XIX. The issue then becomes which fixed test point
falls within an area of reduced intensity, an area of unreduced
intensity, or a transition zone. NHTSA will have manufacturers identify
the portion(s) of the adaptive beam which are areas of reduced
intensity and which are areas of unreduced intensity. The areas of
reduced intensity must conform to the requirements for the test points
in Table XIX, and the area of unreduced intensity must conform to the
requirements for the test points in Table XVIII. Procedures for
determining the transition for lower beams (similar to how the cutoff
is determined, i.e., a scan) can be used to determine whether the
transition zone exceeds 1 degree. Appendix B provides an example of how
this would work in practice.
---------------------------------------------------------------------------
\176\ This will include, as requested by Auto Innovators,
calibration of any sensors required for ADB system performance in
the laboratory prior to testing.
---------------------------------------------------------------------------
Although NHTSA will rely on manufacturers to inform it on how to
produce the beam--to some extent determining the precise contours of
the beam--this will still adequately ensure both visibility and glare
prevention. The adaptive driving beam may only consist of areas of
reduced intensity conforming to Table XIX, areas of unreduced intensity
conforming to Table XVIII, and/or transition zones between such areas.
With respect to visibility, the beam must meet either the lower beam
minima or the upper beam minima (other than in a transition zone). The
driver will at a minimum always have the visibility provided by a
traditional lower beam regardless of the size of the dimmed portion, up
to and including a situation where the entire beam is an area of
reduced intensity (i.e., a lower beam).
This approach should also help ensure adequate glare minimization.
First and most important, the system must be designed to conform to the
track test requirements, which evaluate the adaptive driving beam in
specific scenarios. Second, the laboratory testing requirements will
ensure that any areas of reduced intensity (up to and including a
pattern equivalent to a full lower beam) do not exceed the Table XIX
(lower beam) maxima, and any areas of unreduced intensity (up to and
including a pattern equivalent to a full upper beam), do not exceed the
Table XVIII (upper beam) maxima.\177\
---------------------------------------------------------------------------
\177\ We would expect manufacturers to design systems that avoid
glare even in scenarios not included in the track test. A system
that did not appropriately shade other vehicles, if not a non-
compliance, could potentially be a safety-related defect.
---------------------------------------------------------------------------
These modifications should address the concerns raised by
commenters about which Table XVIII or XIX test points apply to various
portions of the adaptive beam. The agency agreed with many of Ford's
suggested revisions to the proposed regulatory text and is
incorporating many of the suggestions into the final rule. The agency
does not believe that this presents too many cases to test or for a
manufacturer to certify. While it is true that an ADB system will be
capable of generating many different adaptive driving beam patterns, it
is reasonable to require that each beam pattern comply with the
applicable test points. As with all the FMVSSs, these requirements
would not require vehicle manufacturers to test every single case, or
to test at all; they may certify their vehicles using other means.
Manufacturers must use due care to ensure, however, that the system is
designed to conform with the FMVSS requirements when tested by NHTSA
when we use the test procedure specified in the FMVSS.
With respect to Zoox's comment regarding technological neutrality,
the agency intends the requirements to be technology-neutral, and
compatible with ADB systems that use bulbs and shutters, or LED arrays,
as well as any sensing technology. The requirements do not assume that
an adaptive beam is a static beam pattern. (As explained above, the ADB
pattern is dynamic; the laboratory testing will evaluate snapshots of
the dynamic ADB pattern while the dynamic aspects of ADB are tested
using the track test). Although the areas of reduced and unreduced
intensity will be subject to the longstanding lower and upper beam
laboratory photometric requirements, manufacturers will still have the
flexibility to design systems that provide a wide array of different
beam patterns to accommodate not only other cars on the road, but also
retroreflective signs among other things, and bicyclist and
pedestrians.
3. Requirements for Area of Reduced Intensity
The NPRM applied the Table XIX lower beam photometric requirements,
both minima and maxima, to areas of reduced intensity. This differed
from SAE J3069, which specifies only the lower beam maxima in this
area.
Comments
While Consumer Reports appeared to support requiring the lower beam
minima in this area, and Intertek supported requiring both the lower
beam maxima and minima, several commenters contended that if a
laboratory test was required for the area of reduced intensity, it
should specify the lower beam maxima (perhaps with some adjustments)
but not the lower beam minima. (Some commenters argued that the maxima
above 10
[[Page 9984]]
degrees should not apply. This is discussed in Section VIII.D.6.)
Volkswagen, SAE, SL, GM, Koito, Mercedes, the Alliance, IIHS, AAA,
Zoox, and Valeo commented that specifying the lower beam minima would
limit the ability of ADB systems to reduce glare below current lower
beam levels. The Alliance further commented that it would restrict
hardware design, entail separate development programs for different
markets, and add significant cost. IIHS commented that requiring the
lower beam minima would effectively create a lower beam ``cutoff''
within the area of reduced intensity and mean that drivers of other
vehicles below the horizontal axis of the ADB headlamps could
experience excessive glare. IIHS and AAA stated that current lower
beams produce high levels of glare in common situations such as
cresting hills, driving on bumpy roads, or the higher headlamp mounting
height of pickups and many SUVs, and that ADB systems have the ability
to reduce glare below these levels if the lower beam minima are not
specified.
Zoox suggested that market forces would ensure sufficient
visibility because, in order to avoid customer complaints of lack of
illumination, manufacturers are unlikely to provide ADB illumination
below the current lower beam minima. SL commented that the NPRM
disregarded the upper area of the cut-off line in this region.
Agency Response
The final rule adopts the proposed requirements for an area of
reduced intensity, including that it meet the Table XIX minima. NHTSA
believes requiring an area of reduced intensity to meet the lower beam
minima is justified because the rule does not include any ``false
positive'' tests, i.e., tests to ensure that an ADB system does not
mistakenly dim the beam in the absence of any oncoming or preceding
vehicles. The sensitivity of the system is largely left to the
manufacturer to design, provided it responds to the stimulus test
fixtures in the track test and passes the photometry tests. If a
manufacturer produces a very sensitive system that shades for things
that are not actually other vehicles, a beam pattern that provides less
visibility than a current lower beam would be less safe than the
current standard. Requiring the lower beam minima be met in the area of
reduced intensity ensures that the driver will always have a minimum
amount of light providing adequate visibility.
NHTSA does recognize that it would likely be possible to revise the
current lower-beam minima, as applied to ADB systems, to allow for
reductions in intensity below the currently-required limits without
risking safety. However, NHTSA does not have data, and no data were
supplied, that would allow it to establish the minimum size and roadway
scenario for an area of reduced intensity with less light below the
cutoff. Without such data, NHTSA does not have a clear basis on which
to revise or remove the current lower beam minima.
As some commenters pointed out, requiring the dimmed portion of the
ADB beam to meet the lower-beam minima means that an ADB system might
not be able to reduce glare below current levels in some situations.
This would likely occur in situations, as AAA alludes to, on undulating
roadways and hills where the ADB vehicle crests a hill and there is an
oncoming or preceding vehicle in front of it, in which case the lower
beam minima might coincide with that vehicle. In light of the concerns
noted above, NHTSA believes that accepting some level of glare in such
situations--which is already present with current lower beams--is a
reasonable trade-off to ensure adequate visibility for the driver. This
will result in disharmonization with the ECE regulations, which permit
the area of reduced intensity to project intensities below the lower
beam minima. However, this is justified for the reasons given above.
Specifying the lower beam minima will result in a situation that is
unchanged from present, in terms of both safety, costs, and
disharmonization.
NHTSA recognizes that market forces are more likely to ensure
adequate visibility than mitigate glare, thereby potentially obviating
the need to specify any minima. As noted in the NPRM, ``a vehicle
manufacturer's incentive, absent regulation, might be to provide
forward illumination at the expense of glare prevention because the
benefits of forward illumination are enjoyed by the vehicle owner.''
The agency believes such an argument has merit, and closely considered
the matter. As more experience is gained with these systems the agency
may consider modifying or eliminating this requirement. For now,
however, given the importance of visibility, the agency will err on the
side of caution and apply the lower beam minima to the dimmed portion
of the beam.
Potential issues of glare due to headlamp mounting height on
pickups and SUVs can be addressed with the on-vehicle aim of the
headlamps, much as it is currently addressed.\178\ Manufacturers might
also be able to further minimize glare if they use on-vehicle dynamic
aiming. In the past, NHTSA has explained that for headlamp systems
capable of dynamically re-aiming the headlamps (for example, based on
the steering angle), the laboratory photometry requirements ``must be
met in the nominal position of the lower beam headlamp (i.e.,
considering the location of the axis of reference to coincide with the
longitudinal axis of the vehicle).'' \179\ This means, for example,
that an ADB system that dynamically re-aimed the headlamps downward
when cresting a hill with an oncoming vehicle (which, in line with
AAA's comments, is the prime concern motivating the request to not
apply the lower beam minima) could effectively shift down the dimmed
area so as not to glare the oncoming vehicle.
---------------------------------------------------------------------------
\178\ See SAE J599 Lighting Inspection Code.
\179\ Letter from NHTSA to Kiminori Hyodo, Koito Manufacturing
Co., Ltd. (Feb. 10, 2006). See also 68 FR 7101 (Feb. 12, 2003)
(discussing application of laboratory photometry requirements to
adaptive frontal-lighting systems).
---------------------------------------------------------------------------
Although the final rule does not disregard the cut-off as suggested
by SL, the final rule modified the right curve scenarios to consider
the fact that the Table XIX (lower beam) photometry requirements permit
greater illuminance on the right side than on the left side.
4. Requirements for Area of Unreduced Intensity
The NPRM applied the current Table XVIII upper beam photometric
requirements (both the minima and the maxima) to the area of unreduced
intensity. This differed from SAE J3069, which specifies the lower beam
minima and does not specify any maxima.
Comments
Several commenters (GM, SL, ALNA, Koito, SAE, TSE, Auto Innovators,
and Texas Instruments) asserted that NHTSA should specify the lower
beam minima instead of the upper beam minima. SAE commented that SAE
J3069 intentionally replaced the upper beam minima with lower beam
minima to assure a performance comparable to the wider lower beam
versus the narrower upper beam. SAE also stated that specifying the
lower beam minima would harmonize with ADB systems already in use in
other regions. Texas Instruments commented that while it might be
appropriate to require mechanical shutter and low-resolution ADB
systems to meet the lower beam minima, the proposal would negatively
impact many of the potential safety
[[Page 9985]]
improvements enabled by high-resolution ABD systems, such as luminous
intensity optimization on retroreflective street signs and
differentially illuminating the face and body of a pedestrian. TSEI
similarly commented that specifying the lower beam minima would provide
a greater degree of design freedom, and also claimed that requiring the
system to meet the upper beam minima in the area of unreduced intensity
(in combination with the requirements for the area of reduced
intensity) would create potentially insurmountable technical challenges
because ADB systems require a transition zone between the area of
reduced intensity and the area of unreduced intensity.
A few commenters (SAE, GM, and Koito) supported the proposal to
specify the existing upper beam maxima in the area of unreduced
intensity.\180\ However, several commenters urged NHTSA to either not
specify any maxima or, alternatively, to adopt the higher maximum
allowed by the ECE. These commenters contended that adopting the higher
maximum would lead to greater safety benefits than the proposed
specification. Global commented that there are no safety reasons to
specify the upper beam maxima in the absence of other road users. The
Alliance commented that the safety benefits of ADB would be limited by
not allowing ADB systems to exceed the current upper beam maxima, and
recommended that, if NHTSA decides to specify a maximum, it should
harmonize with the ECE maximum of 430,000 cd (215,000 per headlamp). It
contended that, while glare is a concern, it is difficult to determine
glare as a direct cause to crashes or fatalities, referring to past
agency reports finding that evidence linking headlamp glare and crash
risk is difficult to obtain, and noting that the percentage of
accidents that could be at least partly related to headlamp glare is no
more than 1%. Notwithstanding the many consumer complaints regarding
glare noted by the agency, the Alliance stated that it was not aware of
any agency action to investigate issues related to headlamp glare. On
the other hand, the Alliance pointed out that in 2012, 70% of
pedestrian fatalities occurred at night, and by 2016 this had increased
to 75%. The Alliance also referred to the NPRM discussion that
referenced a study from the Insurance Institute for Highway Safety
finding that pedestrian deaths in dark conditions increased 56% from
2009 to 2016. Volkswagen supported the Alliance's comments and cited
studies it said showed headlamp intensities exceeding the current FMVSS
No. 108 upper beam maximum (last updated in 1978) would significantly
increase visibility and therefore safety. Mercedes also encouraged
NHTSA to adopt the ECE maximum because it could increase forward
visibility by 40% compared to the FMVSS No. 108 maximum.
---------------------------------------------------------------------------
\180\ SAE appears to suggest this approach if NHTSA does not
adopt a transition zone. As we discuss in Section VIII.D.5, the
final rule adopts a transition zone.
---------------------------------------------------------------------------
IIHS commented that, for properly-functioning ADB systems, an upper
beam maximum was either not necessary or that the higher ECE maximum
should apply. IIHS stated that the proposal would prevent ADB systems
from realizing their full visibility-enhancing potential. They stated
that if NHTSA is concerned that there are scenarios where ADB systems
may not properly detect and shadow other vehicles, it would be
preferable to include these in the set of dynamic tests rather than
limit ADB output to the same level as manually-controlled upper beams.
AAA commented that European specifications require camera recognition
and reaction at distances of 400 meters (1,312 feet), and that if ADB
systems are effective at this distance, the intensity limits could be
increased to the ECE maximum. It suggested that additional criteria for
raising the upper beam maximum should include proven ability to quickly
adapt to changes in vehicle elevation, as result from driving on
undulating roadways and hills.
Agency Response
The final rule follows the NPRM and specifies the existing upper
beam minima, not the lower beam minima. Because ADB systems can detect
other vehicles, the areas of the beam directed where other vehicles are
not present should be an upper beam. Because the track test evaluates
the ability of the ADB system to appropriately recognize and shade
other vehicles, requiring the upper beam minima should not result in
glare to other motorists.
However, NHTSA agrees with the comments about the possible safety-
enhancing effects of allowing manufacturers to shade areas of the
roadway in addition to those occupied by other vehicles (e.g.,
retroreflective signs). The final rule therefore gives manufacturers
the flexibility to design an ADB system that provides an area of
reduced intensity to any area of the roadway, not just areas occupied
by other vehicles (see Section VIII.D.2). This essentially gives
manufacturers the flexibility to meet the lower beam minima instead of
the upper beam minima for any part of the roadway it chooses, and more
closely harmonizes with SAE J3069. Because we have modified the
proposal to allow manufacturers the flexibility to provide an area of
reduced intensity on parts of the roadway that are not occupied by
other vehicles, they will have the ability to innovate and optimize
luminous intensity for objects such as retroreflective signs and other
roadway users. We also believe this will, in conjunction with the
transition zone allowance, address the transition zone issue (see
Section VIII.D.5). With respect to SAE's comment about the
preferability of a wider lower beam, nothing in the final rule prevents
this wider beam pattern in an area of unreduced intensity. The lower
beam pattern extends to test points at 20L and 20R, whereas the upper
beam test points only extend to 12L and 12R.
The final rule follows the NPRM in specifying the existing Table
XVIII upper beam maximum for the area of unreduced intensity. NHTSA has
decided not to adopt the higher ECE upper beam maximum. Table XVIII
specifies a maximum at H-V of 75,000 cd per headlamp, or 150,000 cd for
a headlighting system. The purpose of this maximum is to control glare
that would occur if the upper beam is improperly activated (i.e., when
other vehicles are within 500 ft) \181\ and to control glare to
vehicles that are more than 500 ft away, which is the distance outside
of which most States permit upper beam use.\182\
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\181\ 43 FR 32416, 32417 (July 27, 1978) (final rule increasing
upper beam headlamp intensity to 75,000 cd).
\182\ 61 FR 54981, 54982 (Oct. 23, 1996) (denial of rulemaking
petition to increase the upper beam maximum intensity to 140,000
cd). See also NPRM, p. 51779 n.75. Table XVIII also specifies an
upper beam maximum at 4D-V. This regulates foreground light that
affects a driver's ability to see objects far down the road. High
levels of foreground illumination tend to draw a driver's attention
away from the distant road scene to the foreground because the
foreground light appears brighter than the road scene further away.
In addition, high foreground intensities reduce the ability to see
dimly illuminated objects further down the road. See 62 FR 31008,
31010 (June 6, 1997) (denial of petition for reconsideration). The
magnitude of this maximum is based on the H-V maximum. Because we
are not adjusting the H-V maximum we do not need to consider the 4D-
V maximum.
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While NHTSA agrees with the commenters that brighter upper beams
would lead to safety benefits in the form of increased visibility in
the absence of other road users, NHTSA remains concerned about
potential glare from brighter upper beams in situations in which an ADB
system might not recognize and shade other vehicles. The final rule
includes a track test that evaluates an ADB system's ability to
recognize and shade other vehicles in a
[[Page 9986]]
variety of scenarios. The NPRM proposed an even greater variety of
scenarios that the agency could test, but many commenters argued that
the proposed testing was onerous and impracticable. Pursuant to these
comments, the final rule significantly streamlines the scenarios that
NHTSA may test. While the final rule includes a sufficient variety of
track test scenarios to reasonably ensure that an ADB system does not
glare other motorists, the track test does not include--nor could NHTSA
feasibly test--every scenario that an ADB system might encounter in the
real world. Maintaining the current upper beam maximum as a backstop to
the dynamic tests will help assure that if an ADB system fails to
properly detect and dim lighting towards another vehicle (whether due
to topography, sudden appearance, or any other situation that leads the
ADB system to fail to recognize and shade another vehicle), the system
will not produce glare beyond what a current FMVSS 108-compliant upper
beam would.
If the final rule were to adopt the higher ECE maximum, an
expansion of the track test scenarios might be warranted to ensure that
these brighter beam patterns do not glare other motorists. There are at
least two ways the agency might consider expanding the track test
scenarios. First, testing the ADB system for glare beyond the 220 m
proposed and included in this final rule. As explained in the NPRM,
testing out to 220 m is appropriate because at this distance, the glare
from an upper beam at the current implied system maximum of 150,000 cd
would be 3.1 lux, which is equivalent to the glare cutoff implied by
many State upper beam-use laws.\183\ Adopting the ECE system maximum of
430,000 cd could justify testing out to 372 m (the distance at which
430,000 cd equals 3.1 lx.). This is consistent with AAA's suggestion
that the upper beam maximum could be increased if NHTSA dynamically
tested headlamp illuminance at ranges of up to 400 meters. Second,
NHTSA might consider additional test scenarios related to other
concerns that might be associated with brighter beam patterns. For
example, as AAA suggested, expanding the track test scenarios might be
appropriate to ensure that the brighter upper beam does not glare other
road users, for example, by testing the ability of the system to
quickly adapt to changes in vehicle elevation.
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\183\ See NPRM n. 75 and accompanying text.
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NHTSA, however, is not currently prepared to expand the track test
scenarios in this way. In order to extend the distances at which we
evaluate glare in the track test, the agency would likely want to
consider, among other things, the appropriate glare limits at those
distances and whether the existing test procedures would need to be
modified to accommodate greater testing distances (for example, the
availability of test tracks with those distances).\184\ Further
research might also include the development of additional test
scenarios appropriate for higher-intensity headlamps.\185\ In short,
NHTSA is not currently prepared to make any further changes to the
proposal related to a brighter upper beam. The goal of this rulemaking
is to extend the existing photometry requirements to enable the safe
introduction of ADB systems, and to expeditiously finalize this rule to
enable deployment of ADB systems.
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\184\ The research on which the track test requirements are
based developed those requirements and test procedures only for
testing glare--commensurate with the current FMVSS No. 108-compliant
upper beams--out to 220 m, not at the greater distances that would
be necessary with ECE-approved upper beams.
\185\ NHTSA's earlier research did include some testing related
to ADB performance on hills. However, such scenarios were not
proposed because of relatively poor ADB system performance in those
trials. See 2105 ADB Test Report at p. 102.
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Because NHTSA is not prepared to extend the test requirements to
ensure that ADB systems with a higher maximum intensity would operate
safely, increasing the photometric maximum, without also adding such
additional test requirements, would result in a situation where glare
past 220 m was not regulated. Some commenters stated that there is
insufficient data to conclude that the disbenefits from glare at these
distances outweigh the benefits from greater visibility and pointed to
the increase in pedestrian fatalities. NHTSA agrees that evidence
linking headlamp glare and crash risk is difficult to obtain, that
there are benefits to increased visibility, and that there has been an
increase in pedestrian fatalities. However, we note that NHTSA has
previously declined to increase the upper beam maximum beyond 150,000
cd to the ECE maximum because of a lack of data on whether any
improvements would outweigh any associated disbenefits associated with
potential increases in glare.\186\ We are not aware of any compelling
new research on the issue, and the comments did not identify any such
research. Accordingly, we have no reason to revise our previous
conclusions that the current upper beam maximum appropriately balances
the benefits of visibility and the disbenefits of glare. In short,
NHTSA is presently unable to conclude that more than doubling the
maximum permitted intensity from 75,000 cd to 215,000 cd (per headlamp)
would provide a significant enough advantage to warrant risking the
potential negative externalities of glare.\187\ Nevertheless, ADB
systems will still provide increased visibility outside of the area of
reduced intensity, as well as increase upper beam use, which will help
prevent crashes.
---------------------------------------------------------------------------
\186\ Most recently, in 2009 NHTSA denied a petition for
rulemaking from The Groupe de Travail ``Bruxelles 1952'' and SAE to
amend FMVSS No. 108 to, among other things, increase the upper beam
maximum to 140,000 cd. 74 FR 42639 (Aug. 24, 2009). NHTSA declined
to increase the maximum because of a lack of data to allay the
concern that the benefits due to increased visibility might be
outweighed by the disbenefits from increased glare. Similarly, when
NHTSA increased the (implied) system-level upper beam maximum from
75,000 to 150,000 in 1978, it referred to contemporaneous research
``demonstrating that an increase in photometrics to a maximum of
150,000 cp will enhance seeing ability without any significant
increase in glare form properly aimed headlights, but that
photometric output exceeding 150,000 cp results in only a marginal
increase in visibility with an increase in glare.'' 43 FR 32416
(July 27, 1978). See also 61 FR 54981 (Oct. 23, 1996) (denial of
rulemaking petition to increase upper beam system-level maximum to
140,000 cd) (citing the 1978 rulemaking notice and stating that
``the agency has done no similar research work on upper beam
headlamps since then nor is it aware of other safety research in
this area'').
\187\ While we agree with the Alliance that adopting the ECE
maximum would enhance harmonization, we still believe that there is
a headlamp harmonization window. See 61 FR 54981.
---------------------------------------------------------------------------
5. Transition Zone
The NPRM applied the Table XIX lower beam photometric requirements
to areas of reduced intensity and the Table XVIII upper beam
photometric requirements to areas of unreduced intensity. The NPRM did
not provide for a transition zone between areas of reduced and
unreduced intensity.
Comments
Many commenters (SAE, ALNA, the Alliance, Global, Valeo, Honda, SL,
Stanley, Koito, Mercedes, Volkswagen, Toyota, and TSEI) pointed out
that the proposed photometric requirements could not be met without
allowing for a transition zone between the areas of reduced and
unreduced luminous intensity. Mercedes, Volkswagen, Toyota, Auto
Innovators, and TSEI specifically agreed with SAE's comments on this
issue.
SAE commented that a transition zone can only be minimized, not
eliminated, and because the transition between reduced and unreduced
areas does not comply with either upper or lower beam photometry it
must be eliminated in the photometric testing. Without a transition
zone, an ADB system would
[[Page 9987]]
be expected to modify its illumination from very low light levels to
above 40,000 cd over a zero angle, which is physically impossible. SAE
gave an example of an area of reduced intensity around the upper beam
minimum at 1U, 3L, with the edge of the area of reduced intensity to
the left of 3L, and the area of unreduced intensity at 3L. SAE pointed
out that in this example, the upper beam minimum of 5,000 cd and lower
beam maximum of 700 cd (at 1.5 U, 1.5 L to L) are impossible to
coincidentally satisfy, even with the 0.25 degree re-aim allowance in
FMVSS No. 108, because the transition from the unreduced intensity to
the reduced intensity is much larger than 0.25 degrees. To illustrate
this, SAE provided a horizontal scan through an ADB headlamp beam
pattern showing a transition zone of greater than 1 degree for the
minimum at (1U, 3L) to be met. SAE noted that similar issues will occur
in other parts of the beam pattern. Toyota similarly commented that the
absence of a transition zone leads to a distinctive vertical line
between the area of reduced intensity and the area of unreduced
intensity. It has been Toyota's experience that a sharp cutoff
distracts drivers and leads to customer complaints that the sharp
cutoff reduces visibility over bumps, dips, and twisty roads. Toyota
also noted that ADB systems it sells in other markets include a
transition zone and it has received positive consumer feedback.
There were a variety of comments related to how the agency might
account for a transition zone in the final rule. SAE suggested that the
transition zone be ``disregarded.'' SAE recommended several different
alternative modifications to the proposal if final rule were not to
disregard the transition zone. These included specifying only the lower
beam maximum values in the area of reduced intensity, and not minimum
values; excluding the boundaries of 10U to 90U from the lower beam
maxima requirements; specifying the lower beam minima instead of the
upper beam minima in the area of unreduced intensity; and modifying the
regulatory text by adding ``fully'' before the text describing the area
of reduced intensity. SAE also recommended reorganizing the regulatory
text of S9.4.1.6.6-.7.\188\ Some of SAE's suggestions were echoed by
other commenters. Global suggested that the final rule should allow for
a mid-beam independent of the lower or upper beam. SL suggested that
the manufacturer be permitted to set the boundary area or that the
final rule should specify light intensity criteria for the transition
zone.
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\188\ SAE stated that these recommendations are also intended to
address the veiling glare issue. See Section VIII.D.6, Veiling
Glare.
---------------------------------------------------------------------------
Agency Response
NHTSA agrees with commenters that the final rule should allow for a
transition zone between areas of reduced and unreduced intensity. The
final rule allows for a 1-degree transition zone between an area of
reduced intensity and an area of unreduced intensity, within which the
Table XVIII and XIX requirements will not apply, except that the
maximum at H-V in Table XVIII as specified in Table II for the specific
headlamp unit and aiming method may not be exceeded at any point in a
transition zone. Manufacturers essentially will be free to determine
the areas of reduced and unreduced intensity and, therefore, the
boundaries of the transition zone. In addition, the vehicle will still
need to pass the track test.
In considering how to account for a transition zone NHTSA consulted
photometric requirements specified in other technical standards and
comparable foreign regulations. Because SAE J3069 does not explicitly
define or identify a transition zone,\189\ the agency researched
references to aiming tolerances in other SAE-recommended practices for
headlamps. J2838 Full Adaptive Forward Lighting Systems specifies
aiming procedures for adaptive lighting systems. Section 6.5 includes
provisions for adjusting vertical and horizontal aim, including
expected aiming tolerances, and provides for a +/- 0.5 degree (or 1
full degree) vertical tolerance to transition between the lower beam
zones and the upper beam zones. The J2838 procedures, though not
specifically for a transition zone, suggest that a similar 1 degree
transition between areas of reduced and unreduced intensity in an
adaptive driving beam pattern would be appropriate.
---------------------------------------------------------------------------
\189\ SAE J3069 MAR2021 added a definition for the transition
zone (``The area in the ADB where the unreduced intensity
transitions to the non-glare zone''). It states that the prior
version assumed the existence of a transition zone and that this
definition was added for clarity. The transition zone allowed in
this final rule is similar in concept, but is more specific in order
to provide a more objective test procedure for the purposes of
compliance testing.
---------------------------------------------------------------------------
This is consistent with the ECE requirements for adaptive front
lighting systems. NHTSA could not find reference to a direct
specification of a transition zone in either ECE R.48 or R.123. Section
6.22.6.3 of R.48 does, however, specify a +/- 0.5 degree tolerance for
the cutoff of a lower beam. Similarly, Section 6.3.5 of R.123 specifies
a +/- 0.5 degree vertical and +/- 1 degree horizontal tolerance for
aiming of systems prior to testing to ensure photometric requirements
are met for ADB systems. Annex 8 of R.123 cites the same cutoff and
aiming provisions cited in SAE J2838 mentioned above.
A 1 degree transition should resolve the concerns of and be
consistent with the information presented by the commenters. SAE raised
the example of an adaptive driving beam pattern with an area of reduced
intensity with vertical cutoffs around 3L and 6L.\190\ As SAE pointed
out, there is an upper beam minimum of 5,000 cd at 1U 3L and a lower
beam maximum of 700 cd from 1U-1.5 L to L. As SAE also correctly
pointed out, it would impossible for an adaptive driving beam with an
area of reduced intensity with a vertical cutoff around 3L to
simultaneously satisfy both the upper beam minimum and the lower beam
maximum without a transition zone. A 1 degree transition zone resolves
this issue and gives the system room to gradually modify the intensity.
The data presented by SAE \191\ shows that a real-world ADB system
could comply with the final requirements: The upper beam minimum at 1U
3L would fall within the transition zone, and the area of reduced
intensity would comply with the lower beam maximum. SAE's example also
indicates that 1 degree is sufficient for a cutoff between an area of
unreduced intensity and an area of reduced intensity because it shows
that it takes the beam less than 1 degree to transition from
intensities characteristic of an upper beam (e.g., 5,000 cd) to
intensities characteristic of a lower beam (e.g., 700 cd). In addition
to the transition zone, the existing provision (in S14.2.5.5) for a
0.25 degree re-aim in any direction at any test point would also apply.
NHTSA believes that this specification for a transition zone, together
with allowing manufacturers the flexibility to project an area of
reduced intensity on areas of the roadway other than oncoming and
preceding vehicles, also resolves the other concerns raised by the
commenters.
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\190\ SAE comment (NHTSA-2018-0090-0167), p. 6 (Fig. 2).
\191\ Id.
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6. Veiling Glare
The NPRM extended the Table XIX lower beam photometric requirements
to areas of reduced intensity. These include a maximum of 125 cd in the
region of 10U to 90U and 90L to 90R.
[[Page 9988]]
The purpose of these test points controlling veiling glare is to limit
back-scatter in environmental conditions such as fog, mist, and snow.
Comments
Some commenters opposed applying the veiling glare limits to the
area of reduced intensity. ALNA commented that these maxima are not
necessary because the increased safety provided by an ADB system
justifies less strict self-glare (back-scatter) requirements. SAE
commented that if the final rule did not include a transition zone, the
area from 10U to 90 U should be excluded from photometric testing
because light from areas of unreduced intensity can fall into the area
of reduced intensity, exceeding the veiling glare requirement in the
10U to 90U zone. GM commented similarly.
Agency Response
The concerns the commenters expressed about the veiling glare
limits are addressed by two of the modifications to the proposal.
First, as explained in the preceding section, in response to the
comments the final rule added a transition zone between areas of
reduced and unreduced intensity. Second, the final rule modifies the
proposal to give manufacturers the flexibility, in designing the
adaptive beam, to illuminate portions of the roadway other than those
occupied by oncoming or preceding vehicles with either an area of
reduced intensity or area of unreduced intensity. An adaptive beam may
therefore provide an area of unreduced intensity that covers the
entirety of the 10U to 90U region, for which the Table XVIII upper beam
requirements do not contain any test points. NHTSA believes that these
modifications resolve the commenters' concerns about veiling glare
exceedances.\192\
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\192\ SAE J3069 MAR2021 excludes the boundaries of 10U to 90U
and 90L to 90R from the requirement in that practice that the non-
glare zone (area of reduced intensity) meet the lower beam maximum
values specified in SAE J1383. The modifications to the proposal are
consistent with this.
---------------------------------------------------------------------------
E. Minimum Activation Speed
The NPRM proposed that an ADB system must produce a lower beam
below 25 mph, explaining that since the primary purpose of ADB is to
provide additional light at relatively higher speeds, it may be likely
that the potential disbenefits from glare outweigh the potential
benefits from additional illumination at lower speeds.
Comments
One commenter, Consumer Reports, supported requiring the lower beam
as a default any time the vehicle is traveling at a speed below 25 mph
in order to limit glare in circumstances where upper beams are not
intended for use.
Other commenters, however, disagreed with the proposal. Toyota,
Honda, and Ford stated that there should be no speed restriction on ADB
activation. SAE, Koito, Valeo, Zoox, and Volkswagen asserted that ADB
operation should not be restricted to 25 mph and above. Texas
Instruments and Harley Davidson commented that ADB activation below 25
mph should be allowed in certain circumstances. The commenters made a
variety of arguments in support of these positions.
Some commenters suggested that the benefits of allowing ADB at
lower speeds outweighed any potential glare disbenefits. SAE stated
that the potential disbenefits from glare would be mitigated as ADB
systems become more advanced and able to recognize and respond
appropriately in low speed-environments. Honda commented that there is
a safety need for visibility at lower speeds and calculated that, based
on 2011 to 2016 GES data for pedestrian accidents, approximately 40% of
nighttime accidents occur when the vehicle speed is estimated to be
under 25 mph (when the vehicle speed can be estimated). Toyota
commented that there are not any data that show a safety need to
regulate the activation speed.
SAE commented that there is no single driving speed where the
benefits of ADB disappear to the point where automatic deactivation
should be required. They stated that changes in the driving environment
are not necessarily correlated with vehicle speed and it is the changes
in driving environment where the driver most benefits from an adaptive
driving beam. (Honda had a similar comment.) SAE asserted that sudden
deprivation of light based only on a specific speed threshold presents
potential safety risks and is contrary to the purpose of ADB. Toyota
stated that there was customer demand for ADB to be operable in urban
areas and in residential areas where visibility can be extremely low
and the speed limit is typically 25 mph, and believed it can provide
safety benefits, especially because there is a higher probability for
drivers to interact with pedestrians or cyclists in these areas. Honda
commented that ADB should provide active forward illumination under
certain environmental lighting conditions to address safety needs.
Valeo, Toyota, and Ford suggested that there should be no speed
limitation because FMVSS No. 108 contains no such speed restriction for
semiautomatic beam switching devices. SAE, Valeo, and Ford similarly
stated that FMVSS No. 108 does not contain a speed threshold for manual
switching between lower and upper beams. SAE commented that a
deactivation threshold speed of 25 mph may also encourage drivers to
exceed this speed where it is the posted limit or when road conditions
warrant lower speeds in order to maintain activation of the adaptive
driving beam. SAE also commented that if drivers want to override ADB
operation they can do so manually.
Zoox recommended that the agency consider reducing the minimum
speed to 20 mph so ADB use would be available for lower-speed city use,
especially to see pedestrians and cyclists on the roadway shoulder.
Texas Instruments commented that high-resolution ADB systems can change
this perceived disbenefit/benefit relationship, and that NHTSA should
exempt high-resolution systems to allow innovative uses of hazard
marking applications in urban settings.
Harley Davidson commented that activation of the adaptive beam
below 25 mph should be allowed on motorcycles because they lean during
cornering and use the upper beam for more than just additional light
down the road. They claim that the beam pattern projected from a
leaning motorcycle differs significantly from the beam pattern of a
four-wheel vehicle, and that this is particularly pronounced during
low-speed maneuvering where the vehicle dynamics required to maneuver
through a 90-degree intersection often results in a more severe lean of
the vehicle than required during higher speed turns with a larger turn
radius. They claimed that when traffic conditions allow, motorcycle
riders use the upper beam during these low-speed maneuvers to take
advantage of the enhanced illumination in the direction the rider is
looking. Harley Davidson further contended that motorcycle cornering
lighting systems have been developed to enhance the lower beam
illumination during vehicle leaning, and that ADB systems are
potentially an enhancement to current systems, which are can operate at
all speeds.
Agency Response
After considering the comments, NHTSA has decided to retain a
minimum activation speed, but has
[[Page 9989]]
lowered it to 20 mph to give greater flexibility to manufacturers
wishing to provide a hysteresis in the system design. (Hysteresis is
the difference in the activation or deactivation speed of the system
based on whether the vehicle is increasing or decreasing speed.)
NHTSA believes that lower beams generally provide adequate
visibility at speeds below 25 mph, given typical driver reaction time
and vehicle stopping distances. This is consistent with the information
that Toyota provided in its petition for rulemaking, which indicated
that lower beams provide sufficient illumination up to about 30 mph (or
about 160 ft).\193\ This is also consistent with many of the ADB
systems NHTSA tested, which had activation speeds between 20 mph and 40
mph and deactivation speeds from 15 mph to 25 mph.\194\ A more recent
model NHTSA tested (a MY 2018 Lexus NX built for the European market)
had three ADB modes, and the lowest activation speed was 9 mph (with a
deactivation speed of 7.5 mph).
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\193\ Toyota rulemaking petition, Appendix C. Consumer Reports,
in its comment, estimated a longer lower beam seeing distance (300
ft) but still supported the proposed minimum activation speed.
\194\ 2015 ADB Test Report, p. 91.
---------------------------------------------------------------------------
A 20 mph activation speed is also supported by research on glare
and driving performance. In 2008 NHTSA published a summary of this
research and found that in areas with high ambient light levels such as
city downtown areas, lower-beam headlamps provide sufficient visibility
because driving speeds are lower in urban areas (i.e., under 30-40 mph)
and because ambient light levels (from street lighting or other
sources) are usually higher; the study also noted that lower beam
intensities might even be able to be reduced in these areas to reduce
glare to other drivers without strongly affecting forward
visibility.\195\ This is also consistent with NHTSA's data on nighttime
crashes involving pedestrians and cyclists.
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\195\ DOT HS 811 043 (2008) at I-9 (citing and discussing
research).
---------------------------------------------------------------------------
Even if increased illumination at speeds under 20 mph were to
result in incremental benefits,\196\ omitting a minimum activation
speed could require expanding the dynamic track test scenarios to
evaluate ADB performance in the types of environments (e.g., urban) and
situations (e.g., intersections) associated with these lower speeds.
This is particularly important because the early ADB systems tested
were not able to pass low-speed scenarios such as intersection
scenarios.\197\ While it is likely true that the capabilities of ADB
systems have advanced since then--including but not limited to the
development of high-resolution systems--that does not obviate the need
for testing. However, the agency has not yet proposed or fully
developed the appropriate test scenarios to evaluate ADB performance in
these types of environments and speeds. To do so, NHTSA would have to
consider a number of factors, such as the relevant scenarios for
testing. Because such test scenarios have yet to be developed, the
agency is currently unable to test whether ADB systems would create
glare in those situations. Development of such test scenarios would
take additional time and resources. In the interests of facilitating
ADB deployment--especially in situations (i.e., at speeds over 20 mph)
at which it will provide the most benefit--NHTSA believes it is
expedient to finalize a rule with a minimum activation speed instead of
developing such additional test scenarios.
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\196\ See id., p. I-9 (``Modifications to low beam patterns have
been suggested and demonstrated to provide incremental benefits in
terms of visibility, but light levels comparable to those from
typical high beam headlamps appear to be desirable in terms of
forward lighting, particularly for faster driving speeds. Yet these
same light levels would almost certainly be undesirable by drivers
facing them in nighttime driving situations.'').
\197\ See 2015 ADB Test Report, p. 172 (``All of the ADB systems
produced considerably more glare in intersection scenarios than was
seen with lower beam mode.'').
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Because NHTSA is not extending the testing scenarios to include
typical low speed/urban environment scenarios, allowing ADB activation
at these lower speeds would allow glare in these situations to be
essentially unregulated. A few commenters suggested that the likely
benefits from enhanced visibility in these situations outweighed the
potential disbenefits from glare, or that ADB systems would be able to
mitigate any potential disbenefits from glare at lower speeds. However,
in light of the studies indicating that lower beams generally provide
adequate visibility at speeds under 25 mph and NHTSA's testing showing
that ADB systems may not yet reliably adapt to lower-speed scenarios,
the agency is not yet confident that any possible incremental benefits
to increased illumination (above present lower beam levels) below 20
mph would be likely to offset the possible disbenefits due to
glare.\198\
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\198\ While there are no speed limitations in the current
requirements for semiautomatic beam switching devices (which date to
the 1960s), we believe that a minimum speed is justified for ADB
systems for the reasons given above. Such a requirement may or may
not also be appropriate for conventional semiautomatic beam
switching devices, but such a requirement is out of the scope of
this rulemaking, which is focused on ADB systems. However, we also
note that ADB systems differ from conventional semiautomatic beam
switching devices because ADB systems provide more illumination than
a lower beam. We similarly note that the fact that there are no
current speed limitations on manual upper beam use is not relevant,
because ADB is automatic, not manual.
---------------------------------------------------------------------------
If a driver desires additional illumination at speeds under 20 mph,
the driver can manually switch to the upper beam mode. This balances
the concerns of glare and visibility better than (as suggested in the
comments) allowing activation of the adaptive beam below 20 mph and
relying on the driver to manually override the ADB and activate the
lower beam if that would be more appropriate (and the ADB system does
not automatically switch). This is both because such situations will be
relatively infrequent and because glare is a negative externality
\199\--that is, the driver has more incentive to switch to upper beam
mode to obtain more visibility in the relatively rare situations in
which it is needed at lower speeds than to override the adaptive beam
and switch to lower beam mode to avoid glaring others. Commenters did
not provide data supporting their contention that specifying a minimum
activation speed will encourage drivers to exceed the minimum
activation speed in order to maintain ADB operation; drivers that
recognize they lack adequate visibility can switch to upper beam mode.
The agency expects this to be more likely than a driver increasing
speed when they feel that the headlamps are not providing enough
visibility.
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\199\ A negative externality occurs when one party's actions
impose uncompensated costs on another party. Glare is a negative
externality because motorists exposed to glare are uncompensated for
the disability or discomfort they experience.
---------------------------------------------------------------------------
NHTSA has decided not to allow a lower activation speed for
motorcycles. Riders are provided a manual switch that activates the
upper beam in situations where the rider recognizes the need for
additional lighting. As such, the factors to consider for motorcycles
are the same as those for other motor vehicles discussed above.
F. Operator Controls, Indicators, Malfunction Detection, and Operating
Instructions
The NPRM included a variety of system requirements for ADB systems
that were either extensions of existing requirements for semiautomatic
beam switching devices or new requirements that would apply only to ADB
systems. These included requirements for controls, telltales, and
malfunction detection. Manufacturers would be free to devise
supplemental telltales as long
[[Page 9990]]
as they did not impair the required elements.
The NPRM proposed extending existing semiautomatic beam switching
device requirements for manual override, fail-safe operation,\200\ and
an automatic referred dimming indicator to apply both to conventional
semiautomatic beam switching devices (classified in the proposed
regulatory text as ``Option 1'' systems) and adaptive driving beam
systems (to as ``Option 2'' systems). With respect to the manual
override requirements, the proposal extended the current requirement
that a semiautomatic beam switching device include a convenient means
for the driver to switch beams. With respect to the automatic dimming
indicator requirement, the proposal followed the approach taken in SAE
J3069.\201\ The NPRM proposed requiring a telltale informing the driver
when the ADB system is activated.\202\ The agency tentatively decided
against following the approach of ECE Regulation 48, which requires the
upper beam telltale be used to indicate ADB activation, because the
NPRM did not classify the adaptive driving beam as an upper beam. The
NPRM also did not propose requiring a telltale indicating an enabled
ADB system is projecting an adaptive driving beam because providing the
driver with a visual indication of the type of beam an ADB system is
providing is not necessary for safe driving and could distract the
driver. For similar reasons, the NPRM also proposed revising the
existing upper beam indicator requirement in S9.5 to state that the
upper beam indicator need not activate when the ADB system is
activated.
---------------------------------------------------------------------------
\200\ The regulatory text in FMVSS No. 108 has long used the
unhyphenated ``fail safe.'' To maintain continuity, this final rule
maintains that spelling in the regulatory text.
\201\ SAE J3069 S6.8 and discussion at p. 2.
\202\ We note that the automatic dimming indicator (indicating
that the semiautomatic beam switching device is controlling the
headlamps automatically) is different than the upper beam indicator
(indicating that the upper beams are activated).
---------------------------------------------------------------------------
NHTSA also proposed adopting additional requirements with no
analogs in the current semiautomatic beam switching device
requirements. The NPRM proposed that the ADB system must be capable of
detecting system malfunctions (including but not limited to sensor
obstruction); notify the driver of a fault or malfunction; and disable
the system until the fault is corrected. Most of these are also
specified in SAE J3069.
NHTSA also identified and sought comment on a requirement in Table
I-a that might affect design choices for the headlamp and/or ADB
controls. This requirement states the ``wiring harness or connector
assembly of each headlighting system must be designed so that only
those light sources intended for meeting lower beam photometrics are
energized when the beam selector switch is in the lower beam position,
and that only those light sources intended for meeting upper beam
photometrics are energized when the beam selector switch is in the
upper beam position, except for certain systems listed in Table II.''
This could mean that the headlamp and ADB controls could not be
designed so the ADB system is activated when the beam selector switch
is in the lower beam position, because the adaptive driving beam might
utilize upper beam light sources, which would violate Table I-a because
upper beam light sources would be activated when the beam selector
switch is in the lower beam position.
Comments
NHTSA received several comments on the manual override
requirements. The United Drive-In Theatre Owners Association and a
number of drive-in theatre owner/operators asked that ADB systems be
required to provide manual deactivation. Many of these commenters
expressed concern that ADB systems could interfere with the enjoyment
of drive-in movies. Consumer Reports also recommended applying the
manual override requirement to ADB systems. One commenter (Victor Hunt)
suggested requiring a warning to the driver when the ADB system has
been manually overridden. Ford and Zoox suggested modifying the manual
override regulatory text. Both commenters noted that under the current
standard, when only lower beams and upper beams are provided, switching
to ``the opposite beam'' is clear since there are only two options.
However, when ADB is additionally provided it becomes less clear,
because ADB essentially introduces a third beam. To address this, Ford
recommended deleting the reference to the ``opposite'' beam in
S9.4.1.2. Zoox recommended that this requirement apply only to systems
certified to S9.4.1.5.The proposed fail-safe requirements (which
mirrored the current regulatory text) required simply that a failure of
the automatic control portion of the device must not result in the loss
of manual operation of both upper and lower beams. Consumer Reports
supported applying the existing requirements to ADB systems. Global and
Subaru recommended that the system should fail-safe to the upper beam
mode, while Zoox suggested requiring the system to default to a lower
beam until the fault is corrected.
Global and AAA commented on the wiring harness requirement. Global
stated that this might adversely affect design choices because it could
mean that the ADB system may not be activated when the beam selector
switch is in the lower beam position. To address this, Global
recommended adding an exception for ADB systems to Table I-a. Global
alternatively recommended that there could be three operational modes
that a driver could choose: Lower beam, upper beam, and adaptive
driving beam. AAA recommended amending Table I-a to account for
distributed control modules and recommended amending the regulatory
text so that the current language applies to distinct light sources,
which by design operate independently, and adding additional language
that the requirement is not applicable to headlamp beam systems that
are controlled at the headlamp component level.
Ford supported not requiring the upper beam indicator to be
activated when the ADB system is activated because Ford believed it
would be distracting for driver, is unnecessary because ADB is designed
not to glare, and harmonizes with SAE and Canada. Consumer Reports
agreed with extending the existing automatic dimming indicator
requirements to ADB systems and agreed that an indicator for the type
of beam ADB is providing or the upper beam indicator should not be
required. AAA also supported the proposed requirements for telltale
indicators and supported the focus on reducing driver distraction and
encouraged that additional indicators be designed so as not to
contribute to driver distraction.
Consumer Reports agreed with the additional operational
requirements in FMVSS No. 108 for ADB systems to detect system
malfunctions (including sensor obstruction), notify the driver of a
fault or malfunction, and automatically disable the system until any
detected fault is corrected. Subaru recommended that S9.4.1.6.2 be
amended to clarify that the ADB disablement requirement is only
applicable for non-mechanical failures because, if a mechanical portion
of the ADB system fails, the fault will not be able to be corrected
because the mechanism will be unable to function mechanically.
Zoox suggested edits to the regulatory text, commenting that
S9.4.1.3, S9.4.1.6.1 and S9.4.1.6.2 are very similar and may be
duplicative. It recommended that a system certified to
[[Page 9991]]
S9.4.1.5 must meet S9.4.1.3 for fail-safe operation, while a system
certified to S9.4.1.6 must meet S9.4.1.6.1 and .2 for fail-safe
operation. Further, instead of using ``shall work in manual mode'' in
S9.4.1.6.2, Zoox suggested the following alternatives to accommodate
both human and AI drivers: ``if a manual mode is provided, the lighting
system shall work in manual mode. . .'' or ``the lighting system shall
permit control of the beam(s) by the driver until the fault is
corrected.''
Brent Peterson commented that upper beam light often creates
detrimental back scatter under certain weather conditions (e.g., fog or
rain) and that the driver may not know how to respond.
Agency Response
NHTSA agrees that a manual override is necessary and, as proposed,
is extending the manual override requirements to ADB systems.
The final rule does not require a specific warning when the driver
chooses to switch the beam from the one provided by the ADB system.
Because switching from the beam provided is an action initiated by the
driver, a warning seems unnecessary because the driver would presumably
know the action was initialized and the required automatic dimming
indicator would indicate that the ADB system is no longer active. The
final rule does not prohibit such a warning, provided the warning does
not interfere with the functionality of the upper beam indicator.
NHTSA agrees with Ford and Zoox's suggested changes to the manual
override requirements. The regulatory text incorporates Ford's
recommended language (``The device must include a means convenient to
the driver for switching the beam from the one provided.'') The agency
believes this language provides sufficient flexibility for switch
design while ensuring that the driver is provided control over beam
switching for situations where the ADB system does not provide what the
driver needs for visibility and glare prevention. NHTSA is also
similarly amending the definition of ``semiautomatic beam switching
device'' to reflect the fact that the final rule adopts ``adaptive
driving beam'' as a third type of beam, and have amended that
definition to clarify that when a semiautomatic beam switching device--
whether or not an ADB system (i.e., certified to either Option 1 or
Option 2)--is in manual mode, the driver may obtain either the lower
beam or upper beam.\203\
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\203\ The term ``manual'' in this definition, as well as in
S9.4.1.2 and S9.4.1.3, has a general meaning that encompasses both
hand-operated and foot-operated controls. See S9.4 (``Each vehicle
must have a means of switching between lower and upper beams
designed and located so that it may be operated conveniently by a
simple movement of the driver's hand or foot.'').
---------------------------------------------------------------------------
The final rule does not adopt the commenters' suggested changes to
the fail-safe requirements but gives the manufacturer the flexibility
to determine whether the ADB system defaults to the lower or upper beam
in the event of an ADB system failure. Requiring an ADB system to
default to an upper beam would not ensure that other roadway users are
not glared; if, however, the ADB system were required to default to the
lower beam, visibility could be diminished. Because the appropriate
beam depends on a variety of situation-specific factors (e.g., presence
of other roadway users, the speed of the ADB vehicle, overall
visibility)--reflected in the conflicting comments on what the
appropriate fail-safe should be--NHTSA is giving manufacturers the
flexibility to determine the appropriate system response.
NHTSA has adopted Global's suggestion and added to Table I-a an
exception for ADB systems. The simultaneous activation of a full lower
beam and a full upper beam will continue to be prohibited for ADB
systems \204\ (except momentarily in certain situations and except for
certain systems listed in Table II \205\). The final rule does not
adopt AAA's suggestion to account for distributed control modules
because the current language is sufficiently clear to apply to both
traditional wiring as well as serial communication between the vehicle
and the headlamps. For example, with respect to powering the headlamp,
S14.2.5.4 specifies that headlamps are tested at 12.8 V-DC as measured
at the terminals of the lamp. This provision applies whether the
terminals of the lamp are also the terminals of the light sources or
the headlamp distributes this power to the appropriate light sources
(whether integral beam headlamp sources or replaceable light sources).
In essence, the wiring harness or connector assembly requirements
listed in Table I-a and Table I-c are the same whether they apply to
the basic vehicle wiring harness, or to the internal wiring within the
headlamp as instructed by the ADB system through a serial line.
---------------------------------------------------------------------------
\204\ For an ADB system in manual mode, for which the only beams
permitted are lower and upper beams, simultaneous activation of
lower and upper beams (subject to some limited exceptions) is
prohibited by the current language in S9.4, which requires that
``except as provided by S6.1.5.2, the lower and upper beams must not
be energized simultaneously except momentarily for temporary
signaling purposes or during switching between beams.'' However, to
make this clear, we have added a cross-reference to S9.4 in S4 in
the ADB requirements. For an ADB system in automatic mode, we have
also clarified that the system may only switch between lower, upper,
and adaptive driving beams and may not simultaneously activate any
of those beams.
\205\ See S6.1.5.2, S9.4, Table I-a, and Table II.
---------------------------------------------------------------------------
The final rule adopts the proposed telltale and malfunction
provisions. With respect to the telltale requirements, we have
clarified the proposal by requiring that the driver be provided with a
visible warning that an ADB system malfunction exists. With respect to
the malfunction provisions, the final rule does not adopt Subaru's
suggested changes to the malfunction requirements. If the ADB system is
not able to operate safely in automatic mode due to a malfunction, the
automatic mode should be deactivated, regardless of whether the
malfunction is mechanical. We have modified the proposed regulatory
text to make clear that the system is not required to be deactivated if
the malfunction does not prevent the system from operating in automatic
mode safely and in conformance with the requirements applicable to such
systems. The proposal would have required that, in the event of a
malfunction, the ADB system must be ``disabled.'' However, in order to
be less design restrictive, the final regulatory text simply requires
that the headlighting system must operate in manual mode in the event
of such a malfunction.
In response to Zoox's comment regarding editorial changes to
S9.4.1.3, S9.4.1.6.1, and S.9.4.1.6.2, the agency does not believe
these provisions are duplicative. The longstanding requirements for
semiautomatic beam switching devices at S9.4.1.3 requires that a
failure of the automatic control portion of the device must not result
in the loss of manual operation and control of both upper and lower
beams; neither S9.4.1.6.1 nor S9.4.1.6.2 clearly requires this. The
final rule also does not adopt Zoox's suggested edits regarding fully
autonomous vehicles. The appropriate fail-safe requirements in the
event that a fully automatic (with no manual controls) ADB system fails
raises a variety of issues that are outside the scope of this
rulemaking.
NHTSA agrees that upper beams may cause backscatter under certain
weather conditions but does not believe this merits regulatory
requirements for dealing with backscatter. The agency encourages
manufacturers to provide, as part of the required operating
instructions, information or instructions to the vehicle operator
explaining the conditions in which an upper beam or an adaptive beam
may or may not be optimal or appropriate.
[[Page 9992]]
G. Accommodation of Different Technologies
In the NPRM, we explained that our intent was to ensure that ADB
systems operate robustly, while not unduly restricting manufacturer
design flexibility.
Comments
NHTSA received a variety of comments regarding the appropriateness
of the requirements for high-resolution ADB systems. Infineon commented
that the final rule must allow for innovation (e.g., high-resolution
systems). Texas Instruments also highlighted the existence of high-
resolution pixelated ADB systems that make it possible to design more
flexible and precise beam patterns. It commented that the final rule
should exempt high-resolution ADB systems from the requirement that the
upper beam minima be met in areas of unreduced intensity and suggested
allowing variable light levels between the lower beam minima and the
upper beam maxima. It also asserted that the final rule should exempt
high-resolution systems from the 25-mph minimum activation speed
requirement to avoid blocking innovative uses of high-resolution
lighting in urban settings. Texas Instruments also commented that the
proposal did not consider advanced functions other than ADB (such as
symbol generation) and requested that NHTSA consider including guidance
in the regulations on how such systems could be deployed, possibly by
considering them supplemental lighting. Volkswagen requested that NHTSA
reconsider its past interpretation of the lower beam headlamp
requirements as applied to LEDs (namely, that an integral beam headlamp
that uses multiple LEDs would be compliant as long as the LEDs were
designed to operate or fail as though they are wired in series) to
accommodate high-definition ADB systems.
Zoox commented that the final rule should permit highly-automated
vehicles, those without manual controls for human drivers, to certify
to the ADB requirements. Zoox also suggested deleting or modifying (by
replacing ``must'' with ``may'') the operating instructions requirement
in S9.4.1.1 to accommodate highly automated vehicles.
Honda stated that manufacturers may employ multiple methods to
produce an ADB beam, such as an enhanced lower beam, an enhanced upper
beam, or a separate mid beam (essentially a partial upper beam in
addition to a lower beam). Honda requested clarification on how NHTSA
would interpret such ADB variations, and how this may impact technology
innovation in this area. Honda also stated that opportunities exist to
provide lighting patterns that are physically directed above lower beam
levels and below higher beam levels. The goal of such a mid-beam
lighting pattern would be to further balance the needs of visibility
and glare prevention and expand potential ADB operation speeds and
environments. They noted that since such a mid-beam would not solely be
able to comply with the existing lower beam requirements, this mid beam
would still require the lower beam to be activated. Honda requested
clarification on how NHTSA would interpret the standard with respect to
this.
Agency response
NHTSA believes the final rule is generally technology neutral, and
accommodates high-resolution technologies, provided they meet the
rule's performance criteria. The agency disagrees with Texas
Instruments' comment that the final rule should exempt high-resolution
systems from certain requirements because the final rule is intended to
be performance-based and technology neutral.
However, as explained earlier, we have modified the proposal in
response to the comments to provide more flexibility in beam design.
The final rule does not limit the number or shape of areas of reduced
or unreduced intensity, and permits localized dimming of the beam
within the photometric limits of the region of the beam in which it is
located (e.g., an area of reduced intensity may vary in intensity based
on the surrounding environment provided that intensity stays within the
corresponding maximum and minimum limits for the lower beam applicable
to the direction of light). The final rule also provides for a
transition zone. While the rule specifies the upper beam minima in the
area of unreduced intensity, the definitions of the areas of reduced
and unreduced intensity have been revised to give manufacturers more
flexibility in beam design.\206\ The minimum activation speed has also
been lowered to provide more flexibility to manufacturers.\207\
---------------------------------------------------------------------------
\206\ See Section VIII.D, Laboratory (Component-Level) Testing.
\207\ See Section VIII.E, Minimum Activation Speed.
---------------------------------------------------------------------------
We are not revising the rule in response to the comments by Texas
Instruments and Zoox regarding advanced functions such as on-road
symbols and highly autonomous vehicles because those issues are outside
the scope of this rulemaking. Volkswagen's comment regarding NHTSA's
interpretation of the requirements with respect to LED failures applies
to LED headlamps generally, not just ADB systems, and is also outside
the scope of this rulemaking.
With respect to Honda's comments, the final rule has two sets of
requirements for an adaptive driving beam: The laboratory requirements
and the track test requirements. Any ``mid-beam'' patterns would be
tested according to these requirements and test procedures. For
example, if Honda wishes to provide greater intensities than 1,400 at
the 1.5 U line as required for a lower beam, but less than the 5,000 cd
that is required at the upper beam test point 1U, 3R, the requirements
finalized today would prohibit this (unless if it were within a
transition zone, which may not exceed 1.0 degree in either the
horizontal or vertical direction). As explained previously, this
assures drivers that both glare protection and visibility of an ADB
lighting system will be equivalent to that of an upper and lower beam.
The reduced and unreduced intensity areas only need to meet the lower
and upper beam requirements, not the levels of intensity provided by
actual upper and lower beams installed on the vehicle. In the example
above, if that point is an area of unreduced intensity, 5,000 cd is all
that is required at 1U, 3R, even though many upper beams produce more
than 30,000 cd in that area. In this way, aspects of a middle beam are
permitted. For instance, if the upper beam installed on the vehicle
produces high levels of reflected light from a sign in the 1U, 3R
region, but a shaded area meeting the lower beam requirements are more
limiting than desired because, the upper beam may be reduced to as
little as 5,000 cd. The agency believes this provides flexibility to
customize a headlighting system to achieve the performance described by
Honda.
Accordingly, the final rule does not adopt Honda's suggested edits
of the NPRM's regulatory text. Nor does the rule adopt its suggestion
that the lower beam (or area of reduced intensity) need only comply
with the maximum photometric requirements of Table XIX \208\; as
explained earlier in this document (Section VIII.D, Laboratory
(Component-Level) Testing), the final rule retains the Table XIX
requirements (both minima and maxima) for areas of
[[Page 9993]]
reduced intensity (and does not alter the lower beam requirements).
However, the final rule does modify the regulatory text to clarify
which photometry requirements apply to areas of reduced and unreduced
intensities--for example, for an area of reduced intensity, the Table
XIX test points that correspond (with respect to angular location) to
that area of reduced intensity apply.
---------------------------------------------------------------------------
\208\ Honda's comment referred to ``Table XVIII'', but since
these are the upper beam requirements, and Honda's edit concerned
the lower beam, we assume Honda meant to refer to Table XIX, which
contains the lower beam photometric requirements.
---------------------------------------------------------------------------
H. Requirements for Semiautomatic Beam Switching Devices Other Than ADB
and Applicability of Compliance Options
The proposal retained the existing semiautomatic beam switching
requirements for standard systems (i.e., beam switching devices that
switch only between an upper beam and a single lower beam), explaining
that these requirements have been in the standard for several decades,
and while they might be updated, the focus of the rulemaking was on
amending the standard to allow the adoption of ADB systems. The
proposal classified these requirements as compliance Option 1, and the
requirements for ADB systems as compliance Option 2.
Comments
Valeo commented that ADB is essentially an advanced type of
semiautomatic headlamp beam switching device and suggested that it
could be certified to the existing requirements for these devices
(classified under Option 1 in the proposal), without any of the
proposed restrictions and vehicle level testing. Conversely, Global
commented that a standard semiautomatic beam switching feature should
be permitted to certify to the new ADB requirements (Option 2).
Bosch and Volkswagen requested that NHTSA update the semiautomatic
beam switching device requirements for conventional automatic ``hi-
beam'' systems (Option 1) to harmonize with SAE J656 (FEB 2010). Bosch
commented that the current semiautomatic beam switching requirements
(in S9.4.1 and 14.9.3.11 of the standard) are based on a 1969 SAE
standard (SAE J565), and beam switching technology has evolved
considerably since then. Bosch urged NHTSA to issue a supplemental
notice of proposed rulemaking or a separate rulemaking proceeding to
update the requirements to account for such advancements, including the
use of camera-based systems and advanced light sources. Volkswagen
pointed out that SAE J565 allows for a system without sensitivity
adjustment, which modern camera-based systems no longer use, and
modernized the luminous intensity minimum and maximum value
requirements.
Agency Response
The NPRM did not discuss, and, other than Valeo's comment, the
commenters did not raise, the issue of whether an ADB system could be
certified to the first option. NHTSA agrees that an ADB system is a
type of semiautomatic beam switching device, but not necessarily that
ADB systems were allowed by the standard prior to today's amendments.
As explained in the NPRM, NHTSA's understanding has been that most, if
not all, ADB systems would not have complied with at least some of the
requirements that apply to semiautomatic beam switching devices. Among
other things, most ADB systems would not comply with the semiautomatic
beam switching device requirements that existed prior to today's rule
(and are now classified as compliance Option 1) because they would not
always comply with the existing photometry requirements. Accordingly,
NHTSA expects that ADB systems will be certified to Option 2 and not
Option 1.
The NPRM also did not address whether standard semiautomatic beam
switching systems could be certified to Option 2. The proposed
regulatory text (along with the preamble) implied that semiautomatic
headlamp beam switching devices other than ADB systems could only be
certified to Option 1 and that ADB systems could only be certified to
Option 2. In light of the fact that the proposal did not squarely raise
this issue, and the fact that this approach maintains the status quo
with respect to conventional semiautomatic beam switching devices, the
final rule retains the proposed labels for the two compliance options.
The final regulatory text provides that standard semiautomatic beam
switching systems may only be certified to Option 1.
As Bosch suggested in its comment, updating the Option 1
semiautomatic beam switching requirements to account for advances in
technology is outside the scope of this rulemaking. NHTSA will consider
this idea as a suggestion for future rulemaking.
I. Physical Test Requirements
The NPRM explained that FMVSS No. 108 sets forth a variety of
performance requirements for semiautomatic beam switching devices (in
S14.9.3.11), including a series of physical tests (e.g., vibration
requirements). The NPRM did not propose to subject the switch
controlling the ADB system to any physical test requirements,
explaining that the existing physical test requirements date from the
1960s and do not appear to extend usefully to modern ADB technologies.
The NPRM also did not propose any new physical test requirements, based
upon a tentative belief that market forces would ensure an ADB system's
switching device will operate robustly. The proposal explained,
however, that other FMVSS No. 108 headlamp requirements would apply to
ADB systems, including the physical test requirements in S14.6 (e.g.,
an abrasion test and a chemical resistance test).
Comments
Global concurred that new physical test requirements were
unnecessary. Intertek agreed that ADB systems should be subject to all
existing physical test requirements for current headlamps.
Agency Response
The final rule follows the proposal and does not contain any
physical tests specific to ADB systems. ADB systems will be subject to
the physical test requirements applicable to all headlamp systems.
J. Other Requirements
Comments
A few commenters mentioned unique challenges presented by the
requirements for vertical headlamp arrangement for vehicles with high-
mounted headlamps. The Alliance and Ford commented that glare increases
as vehicle mounting heights increase and stated that this may result in
light trucks, utility and crossover vehicles not meeting NHTSA's glare
requirements. They asserted that this fact could either exclude a
significant portion of the new vehicle population from utilizing ADB
technology or increase vehicle cost and complexity by necessitating
additional hardware and components. To address this, they requested
making the vertical beam arrangement requirement in S6.1.3.5.1
optional. Toyota similarly stated that vehicles with headlamps mounted
higher than the height from which glare limits were derived (0.62 m)
would have difficulty meeting the proposed glare limits and could
prevent introduction of ADB on a significant number of trucks and SUVs.
Toyota stated that the 0.62 m height is based on the typical height of
a passenger vehicle, which is not representative of the current vehicle
fleet. Toyota stated that the shift in the fleet mix from the time this
limit was derived makes it difficult for OEMs to meet the requirements
at nominal or zero aim for these high-volume vehicles. Toyota suggested
that
[[Page 9994]]
the design would have to aim the lower beams downward on higher-mounted
headlamps in order to meet the glare limits for ADB, thereby
deteriorating the lower beam visibility provided to the driver. Toyota
claimed that this would reduce the safety benefits of ADB by either
sacrificing optimal lower beam performance or limiting the introduction
of ADB on a significant number of vehicles.
Related to this, Subaru commented specifically on the proposed
requirements for headlamp arrangement,\209\ stating that it seemed to
imply that a vehicle without parking lamps might somehow be permitted
by the rule. They requested that NHTSA clarify this provision and asked
whether it would simply mean a vehicle must illuminate the outermost
lamps when the ADB system is active.
---------------------------------------------------------------------------
\209\ See S9.4.1.6.8 in the proposed regulatory text. (``When
the ADB system is activated, the lower beam may be provided by any
combination of headlamps or light sources, provided there is a
parking lamp. If parking lamps meeting the requirements of this
standard are not installed, the ADB system may be provided using any
combination of headlamps but must include the outermost installed
headlamps to show the overall width of the vehicle.'') The NPRM
considered the adaptive driving beam to be a lower beam. As
explained earlier, under the final rule the adaptive driving beam is
defined as a new beam type and is accordingly not considered a lower
beam.
---------------------------------------------------------------------------
Agency Response
With respect to the comments about vehicles with high-mounted
headlamps, this issue is also present with respect to the lower beams
on those vehicles. As such, those vehicles already tend to have their
headlamps aimed downward, to avoid glaring oncoming or preceding
vehicles. While manufacturers might feel the need to aim the headlamps
somewhat lower to accommodate an adaptive driving beam, that would be
likely to have the greatest impact on areas of reduced intensity, not
areas of unreduced intensity (due to the characteristics of lower beam
and upper beam patterns), and would not likely have an outsized impact
on visibility.
Additionally, as suggested by the Alliance and Ford, manufacturers
might wish to alter the vertical arrangement of the headlamps and/or
light sources. However, the commenters who commented about high-mounted
headlamps appeared to overlook that the proposed rule permitted (in
S9.4.1.6.8) the adaptive driving beam to be provided by any combination
of headlamps. In light of the comments, the final rule retains the
proposed provision (now codified at S9.4.1.6.5) but modifies and
clarifies the regulatory text to reflect that the adaptive driving beam
is now considered a new beam type and not a lower beam as was initially
proposed.
Regarding Subaru's comment, the proposed S9.4.1.6.8 was not
intended to imply that parking lamp requirements were being eliminated.
The standard requires parking lamps on all passenger cars, and MPVs,
trucks, and buses less than 2032 mm in overall width. Today's final
rule does not alter this requirement. On vehicles for which parking
lamps are not required, the final rule requires that the adaptive
driving beam may be provided using any combination of headlamps but
must include the outermost installed headlamps to show the overall
width of the vehicle.
The final rule amends 10.14.1, 10.15.1 and 10.16.1 to require that
a headlamp system provide not more than two adaptive driving beams;
this parallels the same requirement for upper beams and lower beams.
The final rule does not amend 10.13.1 because ADB does not appear
feasible for sealed beam systems.
K. Information Reporting
The NPRM did not propose any reporting requirements related to ADB
system performance in the field.
Comment
Consumer Reports commented that NHTSA should require manufacturers
to submit detailed and timely information regarding the performance of
ADB systems and the consumer experience with them as they are
introduced. They suggested that this information be made available in
aggregate form publicly, at a minimum, and include crash reduction
estimates, near-miss statistics that are reasonably related to
lighting, and consumer satisfaction data, including documentation of
the technology's impact on glare experienced by other drivers.
Agency Response
NHTSA is not adopting the information collection requirement
suggested by Consumer Reports. If, after ADB systems have been
deployed, the agency sees a need to obtain detailed information on the
performance of ADB systems, it will address the matter at that time.
L. Aftermarket Compliance
Motor vehicle manufacturers are required to certify that their
vehicles comply with all applicable FMVSS, including FMVSS No.
108.\210\ FMVSS No. 108 also applies to replacement equipment (i.e.,
equipment sold on the aftermarket to replace original equipment
installed on the vehicle).\211\ Replacement equipment must be designed
to conform to meet any applicable requirements and include all
functions of the lamp it is designed to replace or be capable of
replacing.\212\ Each replacement lamp designed or recommended for
particular vehicle models must be designed so that it does not take the
vehicle out of compliance with the standard when the device is
installed on the vehicle.\213\ A manufacturer of replacement equipment
is responsible for certifying that equipment.\214\
---------------------------------------------------------------------------
\210\ 49 U.S.C. 30115.
\211\ S3.3 (the standard applies to ``[l]amps, reflective
devices, and associated equipment for replacement of like equipment
on vehicles to which this standard applies.'').
\212\ S6.7.1.1.
\213\ S6.7.1.2.
\214\ 49 U.S.C. 30115; Letter from NHTSA to George Van Straten,
Van Straten Heated Tail Light Co., Inc. (Aug. 11, 1989).
---------------------------------------------------------------------------
The NPRM stated that it may be the case that only the manufacturer
of the original equipment and/or vehicle would be able to make a good-
faith certification of ADB replacement equipment because requirements
are vehicle-level, not equipment level, and sought comment on this.
Comments
TSEI requested clarification of whether the rule permits
aftermarket ADB systems and stated that the benefits of ADB systems
would be the same for aftermarket systems as for original equipment.
Intertek supported allowing aftermarket parts, and believed that it is
entirely feasible in aftermarket certification to rent or purchase the
vehicle for which the ADB headlamp or switch is designed in order to
conduct vehicle-level testing, and that while technical challenges
could make aftermarket systems/parts cost-prohibitive, that will be
driven by market demand.
Agency Response
The final rule permits certification of aftermarket ADB systems and
parts. There would seem to be essentially two categories of aftermarket
ADB systems. The first is an aftermarket ADB system replacing an
original-equipment system; the second is an aftermarket ADB system
replacing a non-ADB headlamp. In either case, the aftermarket ADB
headlamp would be a ``replacement'' headlamp subject to FMVSS No. 108
because it would be ``replacing like equipment on vehicles to which the
standard applies.'' \215\ As such, the
[[Page 9995]]
aftermarket manufacturer will need to certify the headlamp to FMVSS No.
108; that is, the headlamp ``must be designed so that it does not take
the vehicle out of compliance with the standard when the individual
device is installed on the vehicle.'' This would include the ADB
requirements, as well as any other applicable requirements.
Accordingly, an aftermarket manufacturer could certify and sell ADB
headlamps, if the product complies and the manufacturer was able to
make a good-faith certification.\216\
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\215\ S3.3.
\216\ See also 70 FR 65972, 65974 (Nov. 1, 2005) (Notice of
Interpretation) (``To the extent the vehicle manufacturer could have
certified the vehicle using the replacement lamp, instead of the
lamp it actually used, we believe the replacement lamp should be
viewed as being designed to conform to FMVSS No. 108.'')
---------------------------------------------------------------------------
As noted in the NPRM, it might be difficult as a practical matter
for aftermarket manufacturers to make the necessary certification. For
example, if an aftermarket supplier wanted to develop an ADB system for
a vehicle not originally equipped with ADB, it would need to certify
that the aftermarket ADB system was designed to conform with this final
rule and that it would not otherwise take the vehicle out of compliance
with any other standards. Because the final rule requires specific
switching conditions, the aftermarket system may need to replace the
interior lighting control systems to allow for control of the ADB
system. On the other hand, the final rule significantly simplifies the
test procedures the agency will use to determine compliance, which
could ease the certification of aftermarket systems.
M. Exemption Petitions
In 2016, Volkswagen submitted a petition for a temporary exemption
(under 49 CFR part 555) from some of the requirements of FMVSS No. 108
to sell up to 2,500 exempted vehicles equipped with ADB systems during
each of the 12-month periods covered by the requested exemption. NHTSA
published a notice of receipt of this petition on September 11, 2017
and provided a 30-day comment period.\217\ BMW of North America, LLC
(BMW) submitted a similar petition, dated October 27, 2017. On March
22, 2018, NHTSA published a notice of receipt of the BMW petition and
requested additional information from both petitioners.\218\ Both
Volkswagen and BMW subsequently submitted additional information to the
docket. Prior to today, NHTSA had not made a decision on either
petition.
---------------------------------------------------------------------------
\217\ 82 FR 42720 (Docket No. NHTSA-2017-0018).
\218\ 83 FR 12650 (Docket No. NHTSA-2017-0018).
---------------------------------------------------------------------------
Comments
The Alliance, Volkswagen, and Auto Innovators requested NHTSA grant
these petitions to facilitate gathering of usage and performance data.
Agency Response
NHTSA believes that the publication of this final rule obviates the
need for the requested exemptions. NHTSA is today publishing a separate
notice of decision denying the petitions (Docket No. NHTSA-2017-0018).
N. Compliance Date
This final rule is effective on the date of publication in the
Federal Register. The Alliance requested that the final rule be
effective on publication. This final rule permits the certification of
vehicles equipped with ADB systems if a manufacturer chooses to equip a
vehicle with such a system. NHTSA believes there is good cause to
permit ADB systems meeting FMVSS No. 108 quickly as possible because
the systems produce increased illumination without increasing glare,
and have the potential to offer significant safety benefits in avoiding
collisions with pedestrians, cyclists, and roadside objects. Good cause
exists for these amendments to be made effective immediately pursuant
to 49 U.S.C. 30111(d), which allows an FMVSS to become effective sooner
than 180 days after publication of the standard if an earlier effective
date is in the public interest.
O. Regulatory Alternatives
In developing the final rule, NHTSA considered the ECE ADB
requirements and SAE J3069. As explained earlier, the ECE requirements
are not sufficiently objective to be incorporated into an FMVSS.
Accordingly, the main regulatory alternative NHTSA considered was SAE
J3069.
The proposal deviated from SAE J3069 in several ways; the NPRM
explained this in detail. In general, we explained that there were two
major differences.
First, the proposed vehicle-level track test was more realistic and
complex than the SAE J3069 track test. SAE J3069 specifies testing
using a straight-path scenario (and simulating curves with fixture
placement), and instead of using oncoming or preceding stimulus
vehicles, uses stationary test fixtures positioned at specified
locations adjacent to the test track. The proposed test permitted NHTSA
to test using scenarios having curved paths (with various radii of
curvature) using a broad range of FMVSS-certified vehicles as oncoming
or preceding vehicles.
Second, the proposal specified additional component-level
photometric requirements to regulate both glare and visibility that
were not included in the SAE document. We proposed to require that an
area of reduced intensity be designed to conform to the Table XIX lower
beam photometry requirements (both maxima and minima). This differed
from SAE J3069, which only specified the lower beam maxima for the area
of reduced intensity. We similarly proposed that an area of unreduced
intensity conform with the Table XVIII upper beam photometric maxima
and minima. SAE J3069 required only that the lower beam minima be met
in this area.
NHTSA tentatively concluded that the differences between the
proposal and SAE J3069 were needed to ensure the ADB systems meet the
dual safety needs of glare prevention and visibility.
Comments
Many commenters asserted that NHTSA should adopt either SAE J3069
or the ECE requirements. Concerns about the proposal not harmonizing
with either the SAE or ECE requirements were mainly focused on the
broad acceptance of existing systems in the world market and the
additional costs associated with development of systems that would
comply with the proposal. No data were presented to quantify any
additional development or system costs to comply with the proposed
rule.
As noted at various points earlier in this document, a few
commenters did support a variety of specific departures from SAE J3069.
More generally, Intertek agreed that the SAE J3069 approach may not be
sufficient to validate ADB performance over the full range of typical
real-world situations; it supported a more rigorous track test than
specified in SAE J3069, but also believed that the full set of proposed
test scenarios might not be necessary.
Many commenters, however, strongly supported harmonization with SAE
J3069 and/or the ECE requirements in order to align with requirements
or approaches in other markets. Honda, Global, GM, SAE, CEI, Toyota,
the Alliance, Mobileye, and OSRAM specifically supported SAE J3069.
MEMA, Infineo, Valeo, and NAFA supported either SAE J3069 or the ECE
requirements. Ford, Volkswagen, SMMT, Mobileye, OICA, NAFA, and Hella
supported global harmonization generally, and Seastrunk and Montgomery
supported harmonizing with the ECE requirements. Mobileye
[[Page 9996]]
supported making relatively minor changes to SAE J3069 (such as more
realistic lamps). Commenters made a variety of arguments related to
this.
A number of commenters (Global, MEMA, EMA, Intertek, CEI,
Volkswagen, SAE, Mobileye, the Alliance, Hella, OSRAM, SMMT, Ford, and
OICA) commented or supported the comments of others that the proposed
departures from the SAE and ECE standards would lead to additional
costs, both because the different requirements would require different
hardware, components, and/or software and because the proposed testing
was more complex. Global also commented that the lower costs would come
with no diminution in performance and an increase in visibility. SAE
commented that SAE J3069 was designed to harmonize with the ECE
requirements in order to allow common headlamps, controllers, and
sensors across markets; any aspects not harmonized could be
accommodated in headlamp aim or software calibration differences to
avoid hardware differences. OSRAM, SMMT, Volkswagen, Ford, MEMA, and
OICA agreed with or echoed SAE's comment. Hella commented that the NPRM
will demand completely different headlamp systems and additionally
different forward sensor designs compared to those already in use. This
means, that additional development is needed to establish an ADB system
in the US when compared to the rest of the world. EMA added that its
members have been developing ADB systems based on the ECE requirements
and have no experience with the proposed requirements; moreover, heavy-
duty vehicles are often engaged in cross-border operation that makes
harmonized requirements even more appropriate. Intertek estimated that
that the proposed track testing could cost as much as two to four times
more than testing to the SAE standard, which itself is around three
times costlier than current headlamp testing.
Several commenters (MEMA, the Alliance, Ford, Volkswagen, OICA,
Hella, GM, SAE, CEI, and SMMT) stated that the proposal would
disharmonize with Canada. MEMA noted that the Canadian regulations
accept either ECE R123 or SAE J3069, and stated that the proposal was
inconsistent with a Memorandum of Understanding between the U.S. and
Canada regarding regulatory cooperation.\219\ The Alliance commented
that while there have been longstanding differences with headlighting
requirements between the U.S. and Europe, differences between the U.S.
and Canada have been minimal. Ford commented that harmonization makes
sense given the close integration of the two markets.
---------------------------------------------------------------------------
\219\ The comment cited the Memorandum of Understanding Between
the Treasury Board of Canada Secretariat and OIRA Regarding the
Canada[hyphen]United States Regulatory Cooperation Council, June 4,
2018.
---------------------------------------------------------------------------
Infineon, EMA, Volkswagen, the Alliance, CEI, and NAFA commented
that the increased costs associated with the proposal would increase
the cost to consumers, hindering ADB adoption and the accompanying
safety benefits. CEI also contended that reduced consumer demand for
ADB systems could also reduce manufacturer investment in lighting
system research and development. NAFA highlighted the potential impact
on adoption by vehicle fleets for which cost is important.
Global, Volkswagen, and the Alliance suggested that the
disharmonized aspects of the proposal would not lead to safety benefits
or could decrease safety benefits. For example, Volkswagen stated that,
compared to the proposal, SAE J3069 would lead to ADB systems providing
better visibility. Volkswagen also stated that there is no evidence
that the ECE requirements are leading to excessive glare, and that it
has developed numerous ADB systems for other markets and tested to the
SAE standard, and has not received any complaints from customers or
regulatory authorities about glare. A few commenters (GM, Toyota, MEMA,
Global, Volkswagen) also stated that J3069 would provide a more
objective, practicable, and/or repeatable test procedure.
Agency Response
NHTSA agrees with the commenters that harmonization is an important
goal. Moreover, the National Technology Transfer and Advancement Act
directs Federal agencies to use voluntary consensus standards in lieu
of government-unique standards.\220\ This directive, however, is not
absolute. The NTTAA goes on to provide that an agency may decline to
use existing consensus standards if it determines that such standards
are inconsistent with applicable law or otherwise impractical.\221\
``Impractical'' includes circumstances in which the use of consensus
standards would fail to serve the agency's regulatory needs; be
inconsistent with a provision of law; or be less useful than the use of
another standard.\222\
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\220\ National Technology Transfer and Advancement Act of 1995,
Public Law 104-113, 12(d)(1), 110 Stat. 775 (1996).
\221\ Id. at Sec. 12(d)(3).
\222\ Office of Management and Budget, Circular No. A-119, ]
5(c)(ii), Federal Participation in the Development and Use of
Voluntary Consensus Standards and in Conformity Assessment
Activities (Jan. 26, 2016).
---------------------------------------------------------------------------
In light of these requirements, as well as the requirements of 49
U.S.C. 30111, and in response to the comments, NHTSA has modified the
proposal to more closely follow SAE J3069 where warranted, but to
deviate from that standard where necessary. The most important of these
changes were specifying stationary stimulus test fixtures instead of
dynamic stimulus vehicles and substantially simplifying the number and
complexity of the test scenarios. However, there are several aspects of
the final rule for which NHTSA ultimately concluded that deviation from
SAE J3069 is warranted because J3069 did not adequately address glare
or visibility. The major differences are summarized in Table 12. The
preceding sections of this document discuss in detail the ways in which
the final rule follows and differs from SAE J3069, and explains why we
believe these departures are justified.
Table 15--Summary of Major Differences Between the Final Rule and SAE
J3069
------------------------------------------------------------------------
Test elements Final rule SAE J3069
------------------------------------------------------------------------
Track test:
Glare limit applicability... Applies the glare Applies the glare
limits throughout limits only at 30
the measurement m, 60 m, 120 m,
range specified and 155 m.
for each scenario.
Fixture lighting............ Specifies actual Specifies lamp
vehicle lamp.. assemblies
intended to
simulate vehicle
lamps.
Test track geometry......... Specifies actual Specifies a
curves of various straight path and
sizes. uses fixture
placement to
simulate curves.
[[Page 9997]]
Compliance criteria......... Specifies Allows measured
allowances for illuminance to
momentary glare exceed an
and vehicle pitch applicable glare
fluctuations. limit if it does
not exceed 125%
of the lower beam
illuminance under
the same
conditions.
Specifications related to Specifies vehicle Recommends the
smoothness of road surface. pitch allowance. test track have
an International
Roughness Index
of less than 1.5
m/km.
Laboratory Test:
Area of reduced intensity... Specifies lower Specifies lower
beam (Table XIX) beam maxima.
minima and maxima.
Area of unreduced intensity. Specifies upper Specifies lower
beam (Table beam minima.
XVIII) minima and
maxima.
Physical tests.................. Not specified..... Specifies various
physical tests.
Minimum activation speed........ 20 mph............ Not specified.
------------------------------------------------------------------------
NHTSA recognizes that the final rule is more demanding than SAE
J3069 in several respects, and further recognizes that this will result
in some additional costs to develop and test these systems. The agency
believes these additional costs are justified because the departures
from the SAE test methods are warranted to properly address either
glare or visibility concerns. NHTSA is not persuaded that the test
procedures represent a significant cost burden over testing ADB systems
per the SAE J3069 test. Much of the development work the industry has
conducted on ADB systems for use in markets that permit certification
to the UNECE or SAE standards would directly apply to the performance
tests finalized today. As explained throughout this document, NHTSA has
adopted parameters similar to either the SAE standard or the UNECE
standard where appropriate.
For these same reasons, the agency believes that the resulting
disharmonization will not hinder ADB deployment. Similarly, NHTSA
concludes that the disharmonization with Canada is justified, and is
not inconsistent with the Memorandum of Understanding, which provides,
among other things, that the countries' respective regulations continue
to apply, and that closer alignment of regulations would be consistent
with their respective national laws and policies.
NHTSA also concludes the final rule is practicable. As explained in
previous sections in the preamble, ADB systems performed the same on
many of the final rule scenarios and the most closely analogous SAE
scenarios. As also explained above, there are likely certain test
scenarios (for example, right direction curves) with which some current
ADB systems may not comply; however, in these instances NHTSA believes
that manufacturers should be able to modify existing systems to meet
the requirements.
NHTSA has also concluded that the final rule is objective and
repeatable. The final rule sets out a rational test procedure that
yields a clear answer based upon readings obtained from measuring
instruments and is capable of producing identical results when test
conditions are exactly duplicated.\223\ Further, the final rule
establishes the specific scenarios the agency may test, including
ranges and values for key testing parameters, and specific numeric
limits for the maximum allowable illuminance at certain distances.
NHTSA believes that the final rule specifies the test parameters that
contribute to most of the test-related variability, and that there is
no ambiguity with respect to the parameter values (e.g., differing
radii of curvature) NHTSA may select in compliance testing. To further
evaluate the repeatability of the track test, NHTSA conducted a
repeatability analysis, which shows that the test is repeatable (see
Section VIII.C.11, Repeatability).
---------------------------------------------------------------------------
\223\ See Chrysler Corp. v. Dept. of Transp., 472 F.2d 659, 676
(6th Cir. 1972) (construing ``objective'').
---------------------------------------------------------------------------
P. Overview of Benefits and Costs
The NPRM considered the qualitative costs and benefits of the
proposal compared to both the current baseline in which ADB systems are
not deployed as well as the primary regulatory alternative (SAE
J3069).\224\ Based on this qualitative analysis, NHTSA tentatively
concluded that ADB systems should be permitted (because the proposal
would lead to higher net benefits compared to the status quo in which
ADB systems are not deployed) and that the proposed requirements and
test procedures would lead to higher net benefits than SAE J3069.\225\
---------------------------------------------------------------------------
\224\ NHTSA has not quantified the costs and benefits of the
proposal for the reasons discussed in the NPRM and below in Section
X, Rulemaking Analyses and Notices (in connection with the
discussion of Executive Order 12866).
\225\ For additional information, see the NPRM, pp. 51799-51801.
---------------------------------------------------------------------------
Comments
With regard to allowing the introduction of ADB systems, as noted
earlier, all the industry and public-interest commenters supported
amending the standard to allow the introduction of ADB technology. Many
of the drive-in theatre owner/operators indicated some level of support
for the rule (assuming it provides for manual control). The majority of
comments from individual members of the public supported the proposal,
frequently on the grounds that it would likely reduce glare or increase
safety. Some individual commenters, and some owner/operators of drive-
in movie theatres, opposed the proposal and/or expressed concern that
the introduction of ADB systems could lead to increased glare.
With respect to the proposed requirements and test procedures, most
industry commenters stated that the proposed requirements were too
stringent, and did not meet the need for safety because they
overemphasized glare prevention at the expense of visibility. \226\
Several commenters (Mobileye, the Alliance, IIHS, Auto Innovators,
Toyota, Volkswagen) contended that the proposal did not maximize
overall benefits because it prioritized glare prevention over enhanced
visibility and stated that the final rule should instead place greater
weight on the benefits from enhanced visibility. For example, Mobileye
commented that the proposal would not allow OEMs to tune an ADB system
to
[[Page 9998]]
provide optimal visibility to drivers. Mobileye contended that the
result would be that the benefit of providing a driver with higher
visibility will be diminished with negligible gain in preventing glare.
IIHS also argued that, in terms of safety, the glare problem appears
relatively small (glare was cited in only 1% of non-daylight crashes in
the National Motor Vehicle Crash Causation Survey). Auto Innovators
similarly commented that NHTSA's own research indicates that it is
difficult to determine glare as a direct cause of crashes or
fatalities.\227\ Auto Innovators noted that NHTSA's own research has
shown that while glare was a contributing factor in only about 0.3% of
nighttime fatal crashes \228\ over 70% of pedestrian fatalities occur
at night.\229\ Auto Innovators also pointed to IIHS research finding
that between 2009 and 2016, pedestrian deaths in dark conditions
increased 56%\230\ and a report from the Government Accountability
Office finding that the number of pedestrians killed annually in motor
vehicle crashes increased 43% between 2008 and 2018 and recommending
NHTSA take additional actions to address pedestrian safety.\231\ Toyota
also asserted that glare is predominantly an issue of inconvenience and
discomfort, and that the proposal was not justified by data showing
that glare is a safety concern that requires such stringency.
---------------------------------------------------------------------------
\226\ There were numerous comments as to why specific aspects of
the proposal were too stringent (for example, testing on small right
curves). These specific comments are addressed in the preceding
sections of the preamble. This section deals with more general
comments about the overall stringency of the requirements and the
relative benefits of visibility and glare prevention.
\227\ Comment from Alliance for Automotive Innovation (NHTSA-
2018-0090-0219), p. 8 (citing Nighttime Glare and Driving
Performance, Report to Congress, National Highway Traffic Safety
Administration, Department of Transportation (2007)).
\228\ Id. (citing National Highway Traffic Safety
Administration. 2014. Traffic Safety Facts 2012 Data: Pedestrians,
DOT HS 811 888. Washington, DC: National Highway Traffic Safety
Administration.).
\229\ Id. (citing National Highway Traffic Safety
Administration. 2018 (Revised). Traffic Safety Facts 2016 Data:
Pedestrians, DOT HS 812 493. Washington, DC: National Highway
Traffic Safety Administration.).
\230\ Id. (citing www.iihs.org/iihs/sr/statusreport/article/53/3/1.).
\231\ Id., pp. 8-9 (citing Government Accountability Office.
(2020, April). NHTSA Needs to Decide Whether to Include Pedestrian
Safety Tests in Its New Car Assessment Program. (Publication No.
GAO-20-419) (retrieved from www.gao.gov/assets/710/706348.pdf.).
---------------------------------------------------------------------------
Similarly, many commenters contended that the proposal,
particularly the track test, was costly, burdensome, and impracticable.
See Section VIII.C.1, Practicability of Proposed Test Scenarios. Honda
also stated more generally that the proposed dynamic track test
procedure did not strike the appropriate balance between effectiveness
and practicality. On the other hand, AAA recommended that the
requirements be technology-forcing with respect to improvements in both
glare prevention and visibility, and not simply adhere to established
minimums because absent such requirements such improvement may not be
made.
A few commenters commented that the final rule would better balance
visibility and glare if it exempted ADB systems from some or all the
laboratory photometric requirements. In this context, IIHS specifically
asserted that the Table XIX lower beam requirements should not apply to
ADB, the Alliance suggested that none of the laboratory requirements
should apply to ADB, and Volkswagen stated that the upper beam maximum
should not apply.
Mobileye and the Alliance argued that the proposal's emphasis on
glare was also unnecessary because market forces would sufficiently
incentivize glare prevention. Mobileye explained that OEMs are more
likely to hear from owners of ADB-equipped vehicles about problems with
glare than with visibility. The Alliance commented that manufacturers
are concerned with customer safety and satisfaction; for example,
automatic high beam systems are evaluated from both driver and other
motorist perspectives via intracompany test drive scenarios, some of
which include the presence of simulated ``other motorists.'' The
Alliance asserted that the deployment of ADB systems will result in a
decrease in the volume of glare complaints received by NHTSA.
As noted in the regulatory alternatives section, many commenters
recommended adopting SAE J3069. Some commenters (Global, Volkswagen,
the Alliance) suggested that the disharmonized aspects of the proposal
would not lead to safety benefits or could decrease safety benefits.
Commenters also claimed that the proposal would be more costly than SAE
J3069 and/or the ECE requirements because the disharmonization would
result in additional development and component costs.
Agency Response
With respect to the costs and benefits of the final rule compared
to the current baseline in which ADB systems are not deployed, NHTSA
has concluded that because the rulemaking expands the set of consumer
choices (compared to the status quo), it is an enabling regulation.
NHTSA also concludes that, because it expects positive benefits and
cost savings,\232\ this final rule will lead to higher net benefits
compared to the status quo in which ADB systems are not deployed.
---------------------------------------------------------------------------
\232\ As we explained in the NPRM, the estimated cost savings of
an enabling regulation include the full opportunity costs of the
previously foregone activities (i.e., the sum of consumer and
producer surplus, minus any fixed costs). NPRM at p. 51800.
---------------------------------------------------------------------------
With respect to the costs and benefits of the proposal compared to
SAE J3069, in the NPRM NHTSA tentatively concluded that although the
proposal was likely more costly than SAE J3069 (due to higher
compliance testing and equipment costs), these higher costs were likely
outweighed by the higher safety-related benefits (and lower glare
disbenefits). We therefore tentatively concluded that the likely net
benefits of the proposal were greater than if we adopted SAE J3069 in
every respect. As we explain below, however, after considering the
comments NHTSA has concluded that more closely following SAE J3069 in
certain respects would lead to higher net benefits than the proposal
through lower costs (testing and equipment) and higher benefits
(visibility) without meaningfully increasing disbenefits (glare). We
believe the final rule appropriately balances benefits and costs and
that the net benefits of the final rule are greater than if we adopted
SAE J3069 in every respect.
As an initial matter, NHTSA agrees with the commenters that it is
difficult to precisely determine the risk from glare; that pedestrian
fatalities are on the rise; and therefore that improved visibility
could help to address this trend. Nevertheless, in the absence of
empirical evidence to the contrary, the agency still believes that
glare poses a non-trivial safety risk that justifies some departures
from the SAE standard.
NHTSA agrees with the commenters that the proposed track test to
evaluate glare was too stringent in a couple of ways. First, the
proposed track test somewhat overemphasized glare at the expense of
visibility. This includes that lower beams that currently comply with
FMVSS No. 108 may not have complied with some of the proposed
scenarios. NHTSA also recognizes that the proposed requirements may
have led manufacturers to tune ADB systems to be overly conservative in
order to have acceptable compliance margins, potentially diminishing
the visibility benefits that ADB can provide. Second, the agency agrees
that the proposed track test procedure included redundant scenarios,
and that the final rule can more closely follow SAE J3069 without
sacrificing the evaluative power of the test.
The modifications we have made to the proposal address those issues
regarding stringency. The most important of the modifications are the
reduced number of test scenarios and the specification of stationary
test
[[Page 9999]]
fixtures instead of dynamic stimulus vehicles to follow SAE J3069 more
closely and reduce the complexity of testing. However, the final track
test procedure continues to depart from SAE J3069 in a few ways,
especially in that it retains the use of curved test path scenarios and
uses fixtures fitted with actual vehicle lamps. The agency believes
that the final test scenarios are efficient yet sufficient to determine
whether an ADB system prevents glare to other motorists, and that the
final rule strikes an appropriate balance between visibility and glare
prevention, and between safety and practicability. The reasons for the
agency's specific choices are explained earlier in the preamble.
NHTSA believes the final rule is neither cost-prohibitive nor
impracticable compared to the alternatives. As explained in Section
VIII.O (Regulatory Alternatives), design and development costs will not
significantly differ from those that would have been incurred by
compliance with the SAE or ECE standards. On the other hand, with
respect to AAA's comment that the final rule be technology-forcing,
NHTSA believes the final rule is somewhat technology forcing with
respect to glare: While the requirements are generally within the
capabilities of current ADB system, there are some respects in which
tested ADB performance fell short (for example, appropriately
responding to the motorcycle fixture). ADB systems may therefore need
to be improved or modified to certify to some aspects of the
requirements. With respect to visibility, the final rule does depart
from SAE J3069 in requiring the lower beam minima in an area of reduced
intensity and the upper beam minima in an area of unreduced intensity.
With respect to the comments about market incentives to mitigate
glare, NHTSA does not doubt that OEMs are attentive to owner concerns
but believes that vehicle owners are less likely to notify OEMs about
issues with glaring other motorists. Manufacturers pointed to the lack
of warranty claims or vehicle owner complaints about glare issues (and
Volkswagen noted that it has not received any owner complaints about
ADB systems causing glare). Of course, this could indicate that there
are no glare issues, but it also could indicate that glare issues go
unreported. In any case, the fact that glare is largely an externality
would seem to make glare mitigation less likely to be incentivized by
market signals.
NHTSA also believes that the final component-level laboratory
testing requirements strike an appropriate balance between visibility
and glare. In particular, the agency believes (and the comments did not
convince us otherwise) that specifying the lower beam photometric
minima for areas of reduced intensity and the upper beam minima in
areas of unreduced intensity are important for guaranteeing a minimum
level of visibility. Conversely, as discussed earlier in the preamble,
it is important to specify the current upper beam maximum for areas of
unreduced intensity.
IX. Appendix to FMVSS No. 108 (Table of Contents)
When NHTSA re-wrote FMVSS No. 108 (the final rule for which was
published in 2007), it added an appendix that contained a table of
contents for the standard.\233\ The Office of the Federal Register no
longer allows appendices to sections, and Sec. 571.108 is the only
section in Part 571 to have a table of contents. Because the appendix
may be a useful aid to users of the standard, rather than simply
deleting the appendix NHTSA is moving it to the end of subpart B of
Part 571.
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\233\ 72 FR 68234 (Dec. 4, 2007). This was an administrative
rewrite; it did not impose any new substantive requirements on
manufacturers.
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X. Rulemaking Analyses and Notices
Executive Order 12866, Executive Order 13563, and DOT Regulatory
Policies and Procedures
We have considered the potential impact of this final rule under
Executive Order 12866, Executive Order 13563, and DOT Order 2100.6A.
This final rule is not significant and so was not reviewed by OMB under
E.O. 12866 and is not of special note to the Department under DOT Order
2100.6A. Pursuant to E.O. 12866 and the Department's policies, we have
identified the problem this rule addresses, assessed the benefits and
costs, and considered alternatives. These analyses have been provided
in preceding sections of the preamble; benefits and costs are
summarized in Section VIII.P. As explained below, NHTSA has determined
that quantifying the benefits and costs is not practicable for this
rulemaking.
Quantifying the benefits of the rule--the decrease in deaths and
injuries due to the greater visibility made possible by ADB--is
difficult because of a variety of data limitations related to
accurately estimating the target population and the effectiveness of
ADB systems (as well as the potential penetration rate of ADB systems).
For example, headlamp state (on-off, upper-lower beam) is not reflected
in the data for many pedestrian crashes. Nevertheless, in the NPRM we
attempted to broadly estimate the magnitude of the target
population.\234\
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\234\ See Appendix A in the NPRM. Toyota's rulemaking petition
also includes a target population analysis using a different
methodology. Letter from Tom Stricker, Toyota Motor North America,
Inc. to NHTSA, Appendix D (Mar. 29, 2013).
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Quantification of costs is similarly not practicable. The only
currently-available ADB systems are in foreign markets such as Europe.
We believe, as explained in the discussion of regulatory alternatives
and elsewhere in the preamble, that an ECE-approved ADB system
(modified to have FMVSS 108-compliant photometry) would, with some
further modifications, be able to comply with the rule's requirements
(see the discussion of regulatory alternatives). For the reasons
explained in detail in the preamble, we believe that the final
requirements are generally within the capabilities of existing ADB
systems, although some adjustments might be necessary. We also note
that this final rule does not require manufacturers to equip their
vehicles with ADB systems. The requirements of this final rule specify
minimum performance requirements for the lighting systems that only
apply if manufacturers choose to equip vehicles with ADB systems.
Although NHTSA has concluded that quantification of costs and
benefits is not practicable, we have qualitatively assessed the
benefits and costs of the final rule. As we explain in Section VIII.P,
Overview of Benefits and Costs, we believe the final rule appropriately
balances benefits and costs and that the net benefits of the final rule
are greater compared to both the status quo in which ADB systems are
not deployed and if we adopted SAE J3069 in every respect.
Executive Order 13609: Promoting International Regulatory Cooperation
The policy statement in section 1 of Executive Order 13609 provides
that the regulatory approaches taken by foreign governments may differ
from those taken by the United States to address similar issues, and
that in some cases the differences between them might not be necessary
and might impair the ability of American businesses to export and
compete internationally. It further recognizes that in meeting shared
challenges involving health, safety, and other issues, international
regulatory cooperation can identify approaches that are at least as
protective as those that are or would be adopted in the absence of such
cooperation and can reduce, eliminate, or prevent
[[Page 10000]]
unnecessary differences in regulatory requirements.
This rule is different than comparable foreign regulations. For the
reasons described in this preamble, these differences are justified
because they have the potential to enhance safety.
Executive Order 13132 (Federalism)
NHTSA has examined this rule pursuant to Executive Order 13132 (64
FR 43255; Aug. 10, 1999) and concluded that no additional consultation
with States, local governments, or their representatives is mandated
beyond the rulemaking process. The agency has concluded that the rule
does not have sufficient federalism implications to warrant
consultation with State and local officials or the preparation of a
federalism summary impact statement. The rule does not have
``substantial direct effects on the States, on the relationship between
the national government and the States, or on the distribution of power
and responsibilities among the various levels of government.''
NHTSA rules can have preemptive effect in two ways. First, the
National Traffic and Motor Vehicle Safety Act contains an express
preemption provision: When a motor vehicle safety standard is in effect
under this chapter, a State or a political subdivision of a State may
prescribe or continue in effect a standard applicable to the same
aspect of performance of a motor vehicle or motor vehicle equipment
only if the standard is identical to the standard prescribed under this
chapter. 49 U.S.C. 30103(b)(1). It is this statutory command by
Congress that preempts any non-identical State legislative and
administrative law address the same aspect of performance.
The express preemption provision described above is subject to a
savings clause under which ``[c]compliance with a motor vehicle safety
standard prescribed under this chapter does not exempt a person from
liability at common law.'' 49 U.S.C. 30103(e). Pursuant to this
provision, State common law tort causes of action against motor vehicle
manufacturers that might otherwise be preempted by the express
preemption provision are generally preserved. However, the Supreme
Court has recognized the possibility, in some instances, of implied
preemption of State common law tort causes of action by virtue of
NHTSA's rules--even if not expressly preempted.
This second way that NHTSA rules can preempt is dependent upon the
existence of an actual conflict between an FMVSS and the higher
standard that would effectively be imposed on motor vehicle
manufacturers if someone obtained a State common law tort judgment
against the manufacturer--notwithstanding the manufacturer's compliance
with the NHTSA standard. Because most NHTSA standards established by an
FMVSS are minimum standards, a State common law tort cause of action
that seeks to impose a higher standard on motor vehicle manufacturers
will generally not be preempted. However, if and when such a conflict
does exist--for example, when the standard at issue is both a minimum
and a maximum standard--the State common law tort cause of action is
impliedly preempted. See Geier v. American Honda Motor Co., 529 U.S.
861 (2000).
Pursuant to Executive Order 13132, NHTSA has considered whether
this rule could or should preempt State common law causes of action.
The agency's ability to announce its conclusion regarding the
preemptive effect of one of its rules reduces the likelihood that
preemption will be an issue in any subsequent tort litigation.
To this end, the agency has examined the nature (e.g., the language
and structure of the regulatory text) and objectives of this rule and
does not foresee any potential State requirements that might conflict
with it. We note that many or most States have laws that regulate lower
and upper beam use. These laws require that a motorist use a lower beam
within a certain distance of an oncoming or preceding vehicle. We do
not believe that there is a conflict between the rule and these laws. A
vehicle equipped with a compliant and properly functioning ADB system
should not glare other vehicles. Moreover, the rule requires an ADB-
equipped vehicle to provide the driver with a means of manually
overriding the automatically provided beam. Therefore, if, for any
reason the driver determines that the automatically provided beam is
not appropriate, the driver can manually switch to the appropriate beam
(e.g., lower beam). NHTSA does not intend this rule to preempt State
tort law that would effectively impose a higher standard on motor
vehicle manufacturers than that established by this rule. Establishment
of a higher standard by means of State tort law would not conflict with
the standards in this final rule. Without any conflict, there could not
be any implied preemption of a State common law tort cause of action.
National Environmental Policy Act
The National Environmental Policy Act of 1969 (NEPA) (42 U.S.C.
4321-4347) requires Federal agencies to analyze the environmental
impacts of proposed major Federal actions significantly affecting the
quality of the human environment, as well as the impacts of
alternatives to the proposed action.\235\ When a Federal agency
prepares an environmental assessment, the Council on Environmental
Quality (CEQ) NEPA implementing regulations (40 CFR parts 1500-1508)
require it to (1) ``[b]briefly provide sufficient evidence and analysis
for determining whether to prepare an environmental impact statement or
a finding of no significant impact'' and (2) ``[b]briefly discuss the
purpose and need for the proposed action, alternatives . . ., and the
environmental impacts of the proposed action and alternatives, and
include a listing of agencies and persons consulted.'' 40 CFR
1501.5(c). This section serves as the Final Environmental Assessment
(Final EA).
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\235\ 42 U.S.C. 4332(2)(C).
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Purpose and Need
This notice sets forth the purpose of and need for this action. As
explained earlier in this preamble, ADB technology improves safety by
providing a variable, enhanced lower beam pattern that is sculpted to
traffic on the road, rather than just one static lower beam pattern,
thereby providing more illumination without glare to other motorists.
In addition, ADB technology will likely lead to increased upper beam
use, thereby improving driver visibility distance at higher speeds. In
the NPRM, NHTSA concluded that FMVSS No. 108 does not currently permit
ADB technology.
Alternatives
NHTSA considered a range of regulatory alternatives for the
proposed action. Under a ``no action alternative,'' NHTSA would not
issue a final rule amending FMVSS No. 108, and ADB technology would
continue to be prohibited. NHTSA has also considered the ECE
requirements and SAE J3069, which are described above in this preamble.
In the final rule, NHTSA incorporates elements from these standards,
but departs from them in significant ways, which are also described
above.
Environmental Impacts of the Proposed Action and Alternatives
This final rule is anticipated to result in increased upper beam
use as well as greater illumination provided by the adaptive driving
beams (in patterns designed to prevent glare to other motorists). As a
result, the primary
[[Page 10001]]
environmental impacts anticipated to result from this rulemaking are
associated with light pollution, including the potential disruption of
wildlife adjacent to roadways. The National Park Service (NPS) defines
``light pollution'' as the introduction of artificial light, either
directly or indirectly, into the natural environment.\236\ Forms of
light pollution include sky glow (the bright halo over urban areas at
nighttime), light trespass (unintended artificial lighting on areas
that would otherwise be dark), glare (light shining horizontally), and
over illumination (excess artificial lighting for a specific
activity).\237\ Light pollution caused by artificial light can have
various effects on flora and fauna, including disrupting seasonal
variations and circadian rhythms, disorientation and behavioral
disruption, sleep disorders, and hormonal imbalances.\238\
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\236\ National Park Service, Light Pollution. https://www.nps.gov/subjects/nightskies/lightpollution.htm (last accessed
Sept. 26, 2018).
\237\ Chepesiuk, R. 2009. Missing the Dark: Health Effects of
Light Pollution. Environmental Health Perspectives, 117(1), A20-A27.
\238\ Id.
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Although this rule is anticipated to result in increased levels of
illumination caused by automobiles at nighttime, NHTSA does not believe
these levels would contribute appreciably to light pollution in the
United States. First, the rule requires that the part of an ADB beam
that is cast near other vehicles not exceed the current lower beam
maxima and the part of an ADB beam that is cast onto unoccupied roadway
not exceed the current upper beam maxima. Although overall levels of
illumination are expected to increase from current levels due to
increased upper beam use and the sculpting of the adaptive driving
beams to traffic on the road, total potential brightness would not be
permitted to exceed the potential maxima that already exists on motor
vehicles today. These maxima not only reduce the potential for glare to
other drivers but also limit the potential impact of light pollution.
Second, we note that ADB systems remain optional. Because of the
added costs associated with the technology, NHTSA does not anticipate
that manufacturers would make these systems standard equipment in all
their vehicle models at this time. Thus, only a percentage of the on-
road fleet will feature ADB systems, while new vehicles without the
systems are anticipated to continue to have levels of illumination at
current rates.
Third, while ADB systems generally would increase horizontal
illumination, they likely would not contribute to ambient light
pollution to the same degree as other forms of illumination, such as
streetlights and building illumination, where light is intentionally
scattered to cover large areas or wasted due to inefficient design,
likely contributing more to the nighttime halo effect in populated
areas. According to NPS, the primary cause of light pollution is
outdoor lights that emit light upwards or sideways (but with an upwards
angle).\239\ As the light escapes upward, it scatters throughout the
atmosphere and brightens the night sky. Lighting that is directed
downward, however, contributes significantly less to light pollution.
Lower beams generally direct light away from oncoming traffic and
downward in order to illuminate the road and the environs close ahead
of the vehicle while minimizing glare to other road users. As a result,
any increases in lower beam illumination are not anticipated to
contribute meaningfully to light pollution. As discussed further in the
next paragraph, increases in upper beam illumination would be
anticipated largely in less populated areas, where oncoming traffic is
less frequent and small sources of artificial light (such as motor
vehicles) likely would not change ambient light levels at nighttime to
a meaningful degree.
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\239\ NPS, Light Pollution Sources. https://www.nps.gov/subjects/nightskies/sources.htm (last accessed Sept. 26, 2018).
---------------------------------------------------------------------------
Fourth, NHTSA believes that the areas that would see the greatest
relative increase in nighttime illumination are predominantly rural and
unlikely to experience widespread impacts. The rule requires ADB
systems to produce a lower beam at speeds below 20 mph. These slower
speeds are anticipated primarily in crowded, urban environments where
the current impacts of light pollution are likely the greatest. As a
result, such urban environments should not experience changes in light
levels produced from motor vehicles as a result of this rule. In
moderately crowded, urban environments, nighttime vehicles may travel
above 20 mph, thereby engaging the ADB system. However, in those cases,
upper beam use would likely be low, as the high level of other road
users would cause the ADB system to rely on lower beams for visibility
in order to reduce glare for other drivers. These areas may experience
small increases in light pollution as the upper beams occasionally
engage, as well as increased illumination associated with the adaptive
driving beam. In rural areas, where traffic levels are lower and
driving speeds may be higher, the use of ADB systems is anticipated to
result in increased upper beam use. However, the low traffic levels
would result in only moderate additional light output, and the low
quantity of artificial light sources in general would mean that light
pollution levels overall would be anticipated to remain low.
The final rule is anticipated to improve visibility without glare
to other drivers. In addition to the potential safety benefits
associated with reduced crashes, this rule could result in fewer
instances of collisions involving animals on roadways. Upper beams are
used primarily for distance illumination when not meeting or closely
following another vehicle. Increased upper beam use in poorly lit
environments, such as rural roadways, may allow drivers increased time
to identify roadway hazards (such as animals) and to stop, slow down,
or avoid a collision.
In addition, the impact of added artificial light on wildlife
located near roadways would depend on where and how long the additional
illumination occurs, whether wildlife is present within a distance to
detect the light, and the sensitivity of wildlife to the illumination
level of the added light. Wildlife species located near active roadways
have likely acclimated to the light produced by passing vehicles,
including light associated with upper beams (which would be the same
under the proposal in terms of brightness, directionality, and shape as
under current regulations). Any additional disruption caused by
increased use of upper beams is not feasible to quantify due to the
extensive number of variables associated with ADB use and wildlife.
NHTSA is unable to comparatively evaluate the potential light
pollution impacts of the rule compared to the other regulatory
alternatives (ECE requirements and SAE J3069). For example, the rule
requires that the area of unreduced intensity meet the upper beam
minima and the area of reduced intensity meet the lower beam minima.
The SAE standard only requires that the area of unreduced intensity
meet the lower beam minima. However, NHTSA also proposes that the area
of unreduced intensity may not exceed the upper beam maxima, whereas
the SAE standard does not specify any maxima for the undimmed portion.
Thus, while the final rule establishes requirements for minimum levels
of light, it also limits the maximum level of light in the area of
unreduced intensity; both differ from the SAE standard. This combined
with the wide variations still permitted under the final rule and the
SAE standard make it difficult to compare them with any level of
certainty.
[[Page 10002]]
However, to the degree to which ABD systems would function similarly
under each of those standards, the environmental impacts would be
anticipated to be similar.
Agencies and Persons Consulted
This preamble describes the various materials, persons, and
agencies consulted in the development of the proposal.
Finding of No Significant Impact
I have reviewed this EA. Based on the EA, I conclude that any of
the impacts anticipated to result from the alternatives under
consideration will not have a significant effect on the human
environment and that a ``finding of no significant impact'' is
appropriate. This statement constitutes the agency's ``finding of no
significant impact,'' and an environmental impact statement will not be
prepared. 40 CFR 1501.6(a).
Executive Order 12988 (Civil Justice Reform)
With respect to the review of the promulgation of a new regulation,
section 3(b) of Executive Order 12988, ``Civil Justice Reform'' (61 FR
4729, February 7, 1996) requires that Executive agencies make every
reasonable effort to ensure that the regulation: (1) Clearly specifies
the preemptive effect; (2) clearly specifies the effect on existing
Federal law or regulation; (3) provides a clear legal standard for
affected conduct, while promoting simplification and burden reduction;
(4) clearly specifies the retroactive effect, if any; (5) adequately
defines key terms; and (6) addresses other important issues affecting
clarity and general draftsmanship under any guidelines issued by the
Attorney General. This document is consistent with that requirement.
Pursuant to this Order, NHTSA notes as follows. The issue of
preemption is discussed above in connection with E.O. 13132. NHTSA
notes further that there is no requirement that individuals submit a
petition for reconsideration or pursue other administrative proceeding
before they may file suit in court.
Regulatory Flexibility Act
Pursuant to the Regulatory Flexibility Act (5 U.S.C. 601 et seq.,
as amended by the Small Business Regulatory Enforcement Fairness Act
(SBREFA) of 1996), whenever an agency is required to publish an NPRM or
final rule, it must prepare and make available for public comment a
regulatory flexibility analysis (RFA) that describes the effect of the
rule on small entities (i.e., small businesses, small organizations,
and small governmental jurisdictions). The Small Business
Administration's regulations at 13 CFR part 121 define a small
business, in part, as a business entity ``which operates primarily
within the United States.'' (13 CFR 121.105(a)). No regulatory
flexibility analysis is required if the head of an agency certifies
that the rule will not have a significant economic impact on a
substantial number of small entities. The SBREFA amended the Regulatory
Flexibility Act to require Federal agencies to provide a statement of
the factual basis for certifying that a rule will not have a
significant economic impact on a substantial number of small entities.
NHTSA has considered the effects of this final rule under the
Regulatory Flexibility Act. According to 13 CFR 121.201, the Small
Business Administration's size standards regulations used to define
small business concerns, manufacturers of the vehicles covered by this
final rule would fall under North American Industry Classification
System (NAICS) No. 336111, Automobile Manufacturing, which has a size
standard of 1,500 employees or fewer.
NHTSA estimates that there are six small light vehicle
manufacturers in the U.S. We estimate that there are eight headlamp
manufacturers that could be impacted by this rule. I certify that this
rule will not have a significant economic impact on a substantial
number of small entities. Most of the affected entities are not small
businesses. The rule will not establish a mandatory requirement on
regulated persons.
National Technology Transfer and Advancement Act and 1 CFR Part 51
Under the National Technology Transfer and Advancement Act of 1995
(NTTAA),\240\ ``all Federal agencies and departments shall use
technical standards that are developed or adopted by voluntary
consensus standards bodies, using such technical standards as a means
to carry out policy objectives or activities determined by the agencies
and departments.'' \241\ However, if the use of such technical
standards would be ``inconsistent with applicable law or otherwise
impractical, a Federal agency or department may elect to use technical
standards that are not developed or adopted by voluntary consensus
standards bodies[.]'' \242\ Voluntary consensus standards are technical
standards (e.g., materials specifications, test methods, sampling
procedures, and business practices) that are developed or adopted by
voluntary consensus standards bodies such as SAE. The NTTAA directs the
agency to provide Congress, through OMB, explanations when the agency
decides not to use available and applicable voluntary consensus
standards. Circular A-119 directs that evaluating whether to use a
voluntary consensus standard should be done on a case-by-case
basis.\243\ An agency should consider, where applicable, factors such
as the nature of the agency's statutory mandate and the consistency of
the standard with that mandate.\244\
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\240\ National Technology Transfer and Advancement Act of 1995,
Public Law 104-113, 110 Stat. 775 (1996).
\241\ Id. at Sec. 12(d)(1).
\242\ Id. at Sec. 12(d)(3).
\243\ Office of Management and Budget, Circular No. A-119, ]
5(a)(i), Federal Participation in the Development and Use of
Voluntary Consensus Standards and in Conformity Assessment
Activities (Jan. 26, 2016).
\244\ Id.
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SAE has published a voluntary consensus standard (SAE J3069
JUN2016) for ADB systems.\245\ The Competitive Enterprise Institute
(CEI), in its comments, specifically referenced the NTTAA, arguing that
the NPRM unnecessarily departed from SAE J3069.
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\245\ SAE has recently published a revised version, SAE J3069
MAR2021.
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NHTSA has modified the proposal to more closely follow SAE J3069
where warranted, but to deviate from that standard where necessary. The
most important of these changes were specifying stationary test
fixtures instead of dynamic stimulus vehicles and substantially
simplifying the number and complexity of the test scenarios. However,
there are several aspects of the final rule for which NHTSA ultimately
concluded that deviation from SAE J3069 is warranted because SAE J3069
did not adequately address glare or visibility. The major differences
are summarized in Section VIII.O, Regulatory Alternatives. The
preceding sections of this document discuss in detail the ways in which
the final rule follows and differs from SAE J3069, and explain why we
believe these departures are justified.
The CIE 1931 Chromaticity Diagram was previously approved for
incorporation by reference in the section where it appears as of
February 6, 2012.
Paperwork Reduction Act
Under the Paperwork Reduction Act of 1995 (PRA) (44 U.S.C. 3501, et
seq.), Federal agencies must obtain approval from the Office of
Management and Budget (OMB) for each collection of information they
conduct, sponsor, or require through regulations. This
[[Page 10003]]
rulemaking modifies two existing information collection requirements.
First, this rulemaking modifies the requirements for manufacturers to
provide instructions for operating semiautomatic headlamp switching
devices. Prior to this final rule, the standard required manufacturers
to provide instructions on how to operate the device correctly,
including: How to turn the automatic control on and off; how to adjust
the sensitivity control; and any other specific instructions applicable
to the device. This rule modifies the requirement by excluding ADB
systems from the requirement to provide instructions on how to adjust
the sensitivity control if they are not equipped with a sensitivity
control. The rule also modifies the requirements regarding providing
instructions for vehicle headlamp aiming devices (VHAD). Prior to this
rule, the standard required manufacturers to provide instructions
advising that the headlighting system is properly aimed if the
appropriate vertical plane (as defined by the vehicle manufacturer) is
perpendicular to both the longitudinal axis of the vehicle, and a
horizontal plane when the vehicle is on a horizontal surface, and the
VHAD is set at ``0'' vertical and ``0'' horizontal. The final rule
changes the standard to require manufacturers to provide instructions
advising the vehicle owner what to do if the headlighting system
requires aiming using the VHAD.
NHTSA is separately publishing a notice requesting comment on
NHTSA's intention to request approval for a modification to its
previously approved information collection request titled
``Consolidated Vehicle Owner's Manual Requirements for Motor Vehicles
and Motor Vehicle Equipment.'' The document (Docket Number: NHTSA-2021-
0059) will provide details about the burden associated with the
information collection and will provide a 60-day comment period.
Unfunded Mandates Reform Act
The Unfunded Mandates Reform Act of 1995 (Pub. L. 104-4) (UMRA)
requires agencies to prepare a written assessment of the costs,
benefits, and other effects of proposed or final rules that include a
Federal mandate likely to result in the expenditures by States, local
or tribal governments, in the aggregate, or by the private sector, of
more than $100 million annually (adjusted annually for inflation with
base year of 1995). Adjusting this amount by the implicit gross
domestic product price deflator for 2016 results in $148 million
(111.416/75.324 = 1.48). The assessment may be included in conjunction
with other assessments, as it is here.
This rule is not likely to result in expenditures by State, local
or tribal governments of more than $148 million annually.
UMRA requires the agency to select the ``least costly, most cost-
effective or least burdensome alternative that achieves the objectives
of the rule.'' As discussed above, the agency considered alternatives
to the final rule and has concluded that the requirements are the most
cost-effective alternatives that achieve the objectives of the rule.
Regulation Identifier Number (RIN) 2127-AL83
The Department of Transportation assigns a regulation identifier
number (RIN) to each regulatory action listed in the Unified Agenda of
Federal Regulations. The Regulatory Information Service Center
publishes the Unified Agenda in April and October of each year. You may
use the RIN contained in the heading at the beginning of this document
to find this action in the Unified Agenda.
Privacy Act
Anyone is able to search the electronic form of all documents
received into any of our dockets by the name of the individual
submitting the document (or signing it, if submitted on behalf of an
association, business, labor union, etc.). You may review DOT's
complete Privacy Act Statement in the Federal Register published on
April 11, 2000, (Volume 65, Number 70; Pages 19477-78) or you may visit
www.dot.gov/privacy.html.
Appendices to the Preamble
Appendix A. Comparison of Oncoming Glare Limits to Table XIX Right-Side
Photometric Maxima
To analyze the dynamic track test procedure requirements in the
narrow right-side region of the beam from 1R to 3R and compare it to
the current Table XIX requirements (particularly .5 U, 1R-3R, which has
a minimum of 500 cd and a maximum of 2,700 cd), the agency calculated
the horizontal angle for each headlamp (right and left) at each extreme
of each right curve. See Figure A.1. These calculations assume a
headlamp mounting height of 0.4 m below the oncoming photometer height
(1.1 m above ground), or a headlamp height of 0.7 m above the ground.
Additionally, they assume a headlamp separation distance of 1.1 m and a
lane width of 3.66 m.
BILLING CODE 4910-59-P
[[Page 10004]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.036
[[Page 10005]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.037
For the medium radius, right curve, the most stringent angle toward
the right side of the beam pattern will occur on the 210 m curve at
2.17 (right lamp) and 3.42 (left lamp) degrees right and 0.46U (close
to 0.5U). As Stanley pointed out, this is very close to the 0.5U, 1R-3R
line, for which Table XIX specifies a minimum of 500 cd and a maximum
of 2,700 cd. The per lamp maximum of 2,250 cd implied by the applicable
oncoming glare limit (1.8 lux) is slightly more stringent than 2,700
cd.
For the large radius right curve, the most stringent angle toward
the right side of the beam pattern will occur on the 335 m curve at
2.67 (right lamp) and 3.57 (left lamp) degrees right and 0.33U (below
the 0.5U line). This angle (which is dependent on the mounting height
of the lamps) is below the 0.5U, 1R-3R line. The implied maximum of
1,470 per lamp is more stringent than 2,700 cd.
Appendix B. Example of Laboratory Photometric Testing of Adaptive
Driving Beam
As explained in the preamble, in conducting its compliance testing,
NHTSA will request information from the manufacturer on how to power
and control the headlamps. To test the adaptive driving beam, we will
activate a headlamp in the goniometer according to the manufacturer's
instructions to produce an adaptive driving beam pattern that is
consistent with an ADB pattern that would appear in the real-world with
areas of reduced intensity, unreduced intensity, and/or transition
zone(s). Specific patterns will conform to any real-world scenario
determined by NHTSA. The ADB pattern generated will result in light
directed toward all the test points in Tables XVIII and XIX. The issue
then becomes which fixed test point falls within an area of reduced
intensity, an area of unreduced intensity, or a transition zone. NHTSA
will have manufacturers identify the portion(s) of the adaptive beam
are areas of reduced intensity and which are areas of unreduced
intensity. The areas of reduced intensity must conform to the
requirements for the test points in Table XIX that correspond to that
area of reduced intensity. The area of unreduced intensity must conform
to the requirements for the test points in Table XVIII that correspond
to that area of unreduced intensity. Procedures for determining the
transition for lower beams (similar to how the cutoff is determined,
i.e., a scan) can be used to determine whether the transition zone
exceeds 1 degree.
For example, NHTSA could request from the manufacturer information
on powering the headlamp and controlling it such that an area of
reduced intensity area is centered horizontally around 0.5U 1.2R. A
hypothetical isocandela pattern is provided in Table B.1. produced by
the headlamp (simplified to a resolution of 0.1 degree for ease of
visualization).
[[Page 10006]]
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[[Page 10007]]
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[[Page 10008]]
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[[Page 10009]]
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In this area of reduced intensity, NHTSA would check to ensure that
the applicable Table XIX minima and maxima are met. For this area of
the beam pattern, we would check the following lines within the lower
beam requirements.
1.5U 1R to 3R Min 200 cd
1.5U 1R to R Max 1,400 cd
0.5U 1R to 3R Max 2,700 cd
NHTSA would scan along 1.5 U to determine at what location the 1.5
U line begins to fail the lower beam photometric requirements. This
establishes the beginning of the transition zone. In the hypothetical
case shown above, the lower beam meets these requirements at 1.2R
[1,027] (where we asked for an area of reduced intensity) and continues
to comply at 1.3R [1,027] continuing right until 1.5U, 1.9R [4,020]
where it fails the Maximum 1,400 cd limit. So, for this case the
transition zone begins at 1.9 R. Similarly, the 0.5 U line complies
with the lower beam at 1.2 R [550 cd]. The 0.5 U line continues to
comply until, again, 1.9R. Considering this, the transition zone begins
at 1.9R and can continue for no more than 1 degree, or through the
location of 2.9R. As such, upper beam points extending past this
location must be met. As such, the beam pattern must meet the upper
beam test point 1U, 3R which requires a minimum of 5,000 cd for a UB2
lamp. In this case, the value is 31,000 and therefore compliant with
the area of unreduced intensity tested at that location. Additionally,
the upper beam point H, 3R minimum of 15,000 must be met along with all
the upper beam points at 6R, 9R, 12R and all points left of V. A 0.25
degree re-aim is permitted in S14.2.5.5.
Considering the left edge of the area of reduced intensity, we
would scan along the 1.5 U and 0.5 U right side lines and discover that
the transition zone begins at 0.4 degrees R (traveling to the left). As
such, the transition zone is permitted to extend 1 degree to the left
from the left edge, or through 0.5 degrees L. The ADB pattern is not
required to produce a compliant upper beam at the test point location
of H-V as that may still be within the transition zone. If, however, an
ADB beam pattern is produced with the left edge of the transition zone
beginning at an angle greater than 1 degree R, the upper beam H-V point
must be met for the area of unreduced intensity.
This example also demonstrates how, although no photometry
requirements apply to the transition zone, the photometry in the
transition zone is not unconstrained. In this example, the edge of the
area of reduced intensity is at 1.8R. That means that it must be at
least 200 cd but not more than 1400 cd. At the 3R point it must be at
least 5,000 cd. The transition zone will be between these two points.
With respect to potential concerns, illuminance above 1,400 cd is not
the concern, some exceedance is expected as the light transitions. It
might be a concern if the intensity drops below 200 cd, however, this
is very unlikely. As the commenters point out, it is difficult
physically, and not preferred by drivers to have such extreme cutoffs.
There is no reason for a manufacturer to allow the intensity to drop
below 200 cd through the transition zone.
Appendix C. ADB Performance With Motorcycle Test Fixture
Our testing showed consistently poor performance when the ADB
system was tested against the motorcycle fixture and lamps we are
finalizing.\246\ See Table C.1. The agency is concerned that if ADB
systems do not adequately react to motorcycles in the real world that
any safety benefits provided by ADB introduction could be negated by
additional glare related risk to motorcyclists. Many of the failures
listed below are not attributable to headlamp beam pattern design but
are fundamental failures of the ADB system to react to the motorcycle
lamps installed on the test fixture.
---------------------------------------------------------------------------
\246\ As mentioned earlier, in its recent revisions to SAE
J3069, SAE revised the specifications for the placement of the
illuminance meters (corresponding to two side-view mirrors) on the
same direction motorcycle fixture so that they are now 0.4 m from
the centerline of the rear position lamp as opposed to 0.2 m. This
change would not be expected to meaningfully impact our test results
because the vehicle we tested did not produce a particularly narrow
reduced area as a result of recognizing a motorcycle as compared to
a passenger car. As such, a 200 mm horizontal difference would have
no meaningful impact on the applicability of the research.
Table C.1--ADB Performance With Final Rule Motorcycle Fixture
--------------------------------------------------------------------------------------------------------------------------------------------------------
15.0-29.9 30.0-59.9 60.0-119.9 120.0-220.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Oncoming......................... Straight............ 61 PASS............... PASS............... PASS............... FAIL.
Same Direction................... Straight............ 61 PASS............... PASS............... PASS...............
Oncoming......................... 85-L................ 26 FAIL............... FAIL...............
Oncoming......................... 210-L............... 41 PASS............... FAIL............... FAIL............... PASS.
Same Direction................... 210-L............... 41 FAIL............... FAIL............... FAIL...............
Oncoming......................... 210-R............... 41 PASS............... FAIL...............
Oncoming......................... 335-L............... 51 PASS............... PASS............... FAIL............... FAIL.
Oncoming......................... 335-R............... 51 PASS............... FAIL............... FAIL...............
--------------------------------------------------------------------------------------------------------------------------------------------------------
The plots below (Figure C.1) are representative of the types of
failures we observed when testing. That is, the ADB system was often
late in reacting to the test fixture.
[[Page 10010]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.042
While we are confident in the realism of the finalized test
procedure, we did consider potential sources of variation within the
test to see if the safety need and practicality of the test could be
better optimized. As part of this investigation, we considered the
lamps that are installed on the fixture and compared the ADB systems
performance using the lamps specified in SAE J3069. See Table C.2 and
Figure C.1. The motorcycle lamps we have chosen are not the source of
the system's lack of performance as similar failures were observed when
using the SAE specified lamps.
Table C.2--ADB Performance With SAE J3069 Motorcycle Fixture
--------------------------------------------------------------------------------------------------------------------------------------------------------
15.0-29.9 30.0-59.9 60.0-119.9 120.0-220.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Oncoming......................... Straight............ 61 PASS............... PASS............... FAIL............... FAIL.
Same Direction................... Straight............ 61 PASS............... PASS............... PASS...............
Oncoming......................... 85-L................ 26 FAIL............... FAIL...............
Oncoming......................... 210-L............... 41 PASS............... PASS............... FAIL............... PASS.
Same Direction................... 210-L............... 41 FAIL............... FAIL............... FAIL...............
Oncoming......................... 210-R............... 41 PASS............... PASS...............
Oncoming......................... 335-L............... 51 PASS............... PASS............... FAIL............... FAIL.
Oncoming......................... 335-R............... 51 PASS............... PASS............... FAIL...............
--------------------------------------------------------------------------------------------------------------------------------------------------------
[GRAPHIC] [TIFF OMITTED] TR22FE22.043
We also considered if the fixture itself was a contributing factor
in the system's lack of performance when encountering motorcycles. This
does not seem to be the case based on the 2015 research, which exposed
those ADB systems, installed to a complete three-wheel motorcycle. Some
of those vehicles also demonstrated a lack of ability to react to the
motorcycle stimulus. That research observed that ``Motorcycle scenario
values . . . show, on average, the Audi headlighting system produced
substantially higher glare in the 30 to 120 m range, up to
approximately 9 times greater than that seen for lower beam mode
(quotient values ranging from 6.13 to 9.69) and ``preceding motorcycle
scenarios appeared to challenge ADB's ability to maintain glare within
derived lower beam limit values. In both the stationary and moving
preceding motorcycle scenarios, ADB mode for all four test vehicles
showed illuminance levels exceeding lower beam levels and exceeding
lower
[[Page 10011]]
beam glare limit values in at least one distance range.'' \247\
---------------------------------------------------------------------------
\247\ 2015 ADB Test Report, pp. 109, 114.
---------------------------------------------------------------------------
Although, as discussed previously, we do not believe that the SAE
test adequately replicates the real world, we also considered how well
the vehicle we tested performed on the SAE J3069 test. Overall, it
performed better against the SAE J3069 test then the finalized test,
however it did have dramatic failures on that test well. Figure C.3
depicts a sample of these failures.
BILLING CODE 4910-59-C
[GRAPHIC] [TIFF OMITTED] TR22FE22.044
In conclusion, the agency has determined that ADB systems must
protect motorcyclist against increases in glare in the same way as
other motor vehicle drivers. We have considered the ability of ADB
systems to achieve the finalized level of performance but are unwilling
to degrade overall safety. As such, we are finalizing today's rule to
include a fixture with a specified motorcycle headlamp and a taillamp
and testing ADB systems using the same real-world geometries for the
motorcycle fixture as for the car and truck fixture.
Appendix D. List of Comments Cited in Preamble
------------------------------------------------------------------------
Commenter Comment ID
------------------------------------------------------------------------
AAA.......................... NHTSA-2018-0090-0158.
Alliance for Automotive NHTSA-2018-0090-0219.
Innovation.
Alliance of Automobile NHTSA-2018-0090-0138.
Manufacturers.
Association of Global NHTSA-2018-0090-0182.
Automakers.
Automotive Lighting North NHTSA-2018-0090-0068.
America.
Competitive Enterprise NHTSA-2018-0090-0145.
Institute.
Consumer Reports............. NHTSA-2018-0090-0191.
Ford Motor Company........... NHTSA-2018-0090-0162.
General Motors............... NHTSA-2018-0090-0181.
GTB--The International NHTSA-2018-0090-0070.
Automotive Lighting and
Light Signalling Expert
Group.
Harley-Davidson Motor Company NHTSA-2018-0090-0148.
HELLA GmbH & Co. KGaA........ NHTSA-2018-0090-0085.
Honda (American Honda Motor NHTSA-2018-0090-0179.
Company).
Insurance Institute for NHTSA-2018-0090-0149.
Highway Safety.
International Organization of NHTSA-2018-0090-0089.
Motor Vehicle Manufacturers.
Intertek..................... NHTSA-2018-0090-0143.
Koito Manufacturing Company.. NHTSA-2018-0090-0173.
League of American Bicyclists NHTSA-2018-0090-0157.
Mercedes-Benz USA............ NHTSA-2018-0090-0147.
Mobileye, An Intel company... NHTSA-2018-0090-0140.
Montgomery, Bryan............ NHTSA-2018-0090-0069.
Motor & Equipment NHTSA-2018-0090-0175.
Manufacturers Association.
NAFA Fleet Management NHTSA-2018-0090-0067.
Association.
North American Lighting...... NHTSA-2018-0090-0163.
Osram Sylvania............... NHTSA-2018-0090-0177.
Peterson, Brent.............. NHTSA-2018-0090-0030.
Robert Bosch................. NHTSA-2018-0090-0159.
[[Page 10012]]
SAE International............ NHTSA-2018-0090-0167.
Seastrunk, Jay............... NHTSA-2018-0090-0200.
SL Corporation............... NHTSA-2018-0090-0183.
Society of Motor NHTSA-2018-0090-0156.
Manufacturers and Traders.
Stanley Electric Company..... NHTSA-2018-0090-0189.
Subaru....................... NHTSA-2018-0090-0217.
Texas Instruments............ NHTSA-2018-0090-0161.
Toyota Motor North America... NHTSA-2018-0090-0172.
Transportation Safety NHTSA-2018-0090-0193.
Equipment Institute.
Truck and Engine NHTSA-2018-0090-0165.
Manufacturers Association.
United Drive-In Theatre NHTSA-2018-0090-0153.
Owners Association.
Valeo Lighting Systems....... NHTSA-2018-0090-0142.
Victor Hunt.................. NHTSA-2018-0090-0028.
Volkswagen Group of America.. NHTSA-2018-0090-0154.
Zoox......................... NHTSA-2018-0090-0178.
------------------------------------------------------------------------
List of Subjects in 49 CFR Part 571
Imports, Motor vehicle safety, Motor vehicles, and Tires.
In consideration of the foregoing, NHTSA amends 49 CFR part 571 as
set forth below.
PART 571--FEDERAL MOTOR VEHICLE SAFETY STANDARDS
0
1. The authority citation for part 571 of title 49 continues to read as
follows:
Authority: 49 U.S.C. 322, 30111, 30115, 30117, 30166; delegation
of authority at 49 CFR 1.95.
0
2. Amend Sec. 571.108 by:
0
a. Adding, in alphabetical order, definitions of ``Adaptive driving
beam,'' ``Headlighting system midpoint'' and ``Transition zone'' to
paragraph S4;
0
b. Revising the definition of ``Semiautomatic headlamp beam switching
device'' in paragraph S4;
0
c. Revising paragraphs S9.4.1, S9.4.1.1, S9.4.1.2, S9.4.1.3, S9.4.1.4,
and S9.4.1.5;
0
d. Adding paragraphs S9.4.1.5.1 through S9.4.1.5.3 in numerical order;
0
e. Revising paragraph S9.4.1.6;
0
f. Adding paragraphs S9.4.1.6.1 through S9.4.1.6.5 in numerical order;
0
g. Removing S9.4.1.7;
0
h. Revising the introductory text of paragraph S9.5;
0
i. Revising paragraphs S10.14.1, S10.15.1, S10.16.1, S10.18.8.1.2, and
S10.18.8.2.1;
0
j. Adding paragraphs S14.9.3.12 through S14.9.3.12.6.3;
0
k. Revising the entries for ``Lower Beam Headlamps'' and ``Upper Beam
Headlamps'' in table I-a and table I-c;
0
l. Adding tables XXI and XXII, and figures 23 through 30 in numerical
order; and
0
m. Removing the appendix to the section.
The revisions and additions read as follows:
Sec. 571.108 Standard No. 108; Lamps, reflective devices, and
associated equipment.
* * * * *
S4 Definitions
Adaptive driving beam means a long-range light beam for forward
visibility, which automatically modifies portions of the projected
light to reduce glare to traffic participants on an ongoing, dynamic
basis.
* * * * *
Headlighting system midpoint means the intersection of a horizontal
plane through the test vehicle's headlamp light sources, a vertical
plane through the test vehicle's headlamp light sources and a vertical
plane through the test vehicle's centerline.
* * * * *
Semiautomatic headlamp beam switching device is one which provides
either automatic or manual control of beam switching at the option of
the driver. When the control is automatic the headlamp beams switch
automatically. When the control is manual, the driver may obtain either
the lower beam or the upper beam manually regardless of the conditions
ahead of the vehicle.
* * * * *
Transition zone means the portion of an adaptive driving beam that
occurs between an area of reduced intensity and an area of unreduced
intensity.
* * * * *
S9.4.1 Semiautomatic headlamp beam switching devices. As an
alternative to S9.4, a vehicle may also be equipped with a
semiautomatic means of switching beams that complies with 9.4.1.1
though S9.4.1.4 and either 9.4.1.5 (Option 1) or 9.4.1.6 (Option 2).
S9.4.1.1 Operating instructions. Each semiautomatic headlamp
switching device must include operating instructions to permit a driver
to operate the device correctly, including: How to turn the automatic
control on and off; how to adjust the sensitivity control (for Option 1
and if provided for Option 2); and any other specific instructions
applicable to the device.
S9.4.1.2 Manual override. The device must include a means
convenient to the driver for switching the beam from the one provided.
S9.4.1.3 Fail safe operation. A failure of the automatic control
portion of the device must not result in the loss of manual operation
and control of the upper and lower beams.
S9.4.1.4 Automatic dimming indicator. There must be a convenient
means of informing the driver when the device is controlling the
headlamps automatically. For headlighting systems certified to Option
1, the device shall not affect the function of the upper beam indicator
light.
S9.4.1.5--Option 1 (Semiautomatic headlamp beam switching devices
other than Adaptive Driving Beam systems).
S9.4.1.5.1 Lens accessibility. The device lens must be accessible
for cleaning while the device is installed on a vehicle.
S9.4.1.5.2 Mounting height. The center of the device lens must be
mounted no less than 24 inches above the road surface.
S9.4.1.5.3 Physical tests. Each semiautomatic headlamp beam
switching device must be designed to conform to all applicable
performance requirements of S14.9.3.11.
S9.4.1.6--Option 2 (Adaptive Driving Beam systems).
S9.4.1.6.1 The system must be capable of detecting system
malfunctions (including but not limited to sensor obstruction).
S9.4.1.6.2 If the system detects a malfunction that prevents the
system from operating in automatic mode safely and in conformance with
these requirements, the headlighting system must operate in manual mode
until the
[[Page 10013]]
malfunction is corrected and must provide the driver with a visible
warning that the malfunction exists.
S9.4.1.6.3 When operating in manual mode, the system must provide
only switching between lower and upper beams as provided in S9.4.
S9.4.1.6.4 When operating in automatic mode, the system must only
switch between lower, upper, and adaptive driving beams. The adaptive
driving beams must be designed to conform to the requirements of this
section.
S9.4.1.6.4.1 The adaptive driving beams must consist only of
area(s) of reduced intensity, area(s) of unreduced intensity, and
transition zone(s).
S9.4.1.6.4.2 The adaptive driving beams must be designed to conform
to the photometry requirements of Table XXI when tested according to
S14.9.3.12, and, for replaceable bulb headlighting systems, when using
any replaceable light source designated for use in the system.
S9.4.1.6.4.3 In an area of reduced intensity, the adaptive driving
beams must be designed to conform to the photometric intensity
requirements of Table XIX as specified in Table II for the specific
headlamp unit and aiming method, when tested according to the procedure
of S14.2.5, and, for replaceable bulb headlighting systems, when using
any replaceable light source designated for use in the system.
S9.4.1.6.4.4 In an area of unreduced intensity, the adaptive
driving beams must be designed to conform to the photometric intensity
requirements of Table XVIII as specified in Table II for the specific
headlamp unit and aiming method, when tested according to the procedure
of S14.2.5, and, for replaceable bulb headlighting systems, when using
any replaceable light source designated for use in the system.
S9.4.1.6.4.5 A transition zone not to exceed 1.0 degree in either
the horizontal or vertical direction is permitted between an area of
reduced intensity and an area of unreduced intensity. The Table XVIII
and Table XIX photometric intensity requirements do not apply in a
transition zone, except that the maximum at H-V in Table XVIII as
specified in Table II for the specific headlamp unit and aiming method
may not be exceeded at any point in a transition zone.
S9.4.1.6.4.6 For vehicle speeds below 32 kph (20 mph), the system
must provide only lower beams (unless manually overridden according to
S9.4.1.2).
S9.4.1.6.4.7 The adaptive driving beams must not be energized
simultaneously with the lower or upper beams except as provided in
Table II.
S9.4.1.6.5 The adaptive driving beams may be provided by any
combination of headlamps or light sources, provided parking lamps are
installed. If parking lamps meeting the requirements of this standard
are not required according to Table I and are not installed, the
adaptive driving beams may be provided using any combination of
headlamps but must include the outermost installed headlamps to show
the overall width of the vehicle.
* * * * *
S9.5 Upper beam headlamp indicator. Each vehicle must have a means
for indicating to the driver when the upper beams of the headlighting
system are activated. The upper beam headlamp indicator is not required
to be activated when an Adaptive Driving Beam system is operating in
automatic mode.
* * * * *
S10.14.1 Installation. An integral beam headlighting system must
consist of the correct number of designated headlamp units as specified
for the applicable system in Table II-c. The units must have their
upper and lower beams activated as specified in Table II-c, and their
adaptive driving beams (if so equipped) activated as specified in
S9.4.1.6.5. A system must provide in total not more than two upper
beams, two lower beams, and, optionally, two adaptive driving beams.
* * * * *
S10.15.1 Installation. A replaceable bulb headlighting system must
consist of either two or four headlamps as specified for the applicable
system in Table II-d. The headlamps must have their upper and lower
beams activated as specified in Table II-d, and their adaptive driving
beams (if so equipped) activated as specified in S9.4.1.6.5. A system
must provide in total not more than two upper beams, two lower beams,
and, optionally, two adaptive driving beams, and must incorporate not
more than two replaceable light sources in each headlamp.
* * * * *
S10.16.1 Installation. A combination headlighting system must
consist of the correct number of designated headlamp units as specified
for the applicable system in Table II-b. The units must have their
upper and lower beams activated as specified in Table II-b, and their
adaptive driving beams (if so equipped) activated as specified in
S9.4.1.6.5. A system must provide in total not more than two upper
beams, two lower beams, and, optionally, two adaptive driving beams.
When installed on a motor vehicle, the headlamps (or parts thereof)
that provide the lower beam must be of the same type and provide a
symmetrical effective projected luminous lens area when illuminated.
* * * * *
S10.18.8.1.2 Horizontal aim. The VHAD must include references and
scales relative to the longitudinal axis of the vehicle necessary to
assure correct horizontal aim for photometry and aiming purposes. A
``0'' mark must be used to indicate alignment of the headlamps relative
to the longitudinal axis of the vehicle. In addition, an equal number
of graduations from the ``0'' position representing equal angular
changes in the axis relative to the vehicle axis must be provided. If
the horizontal VHAD is part of an adaptive driving beam system,
S10.18.8.1.2.1 through S10.18.8.1.2.4 are not required.
* * * * *
S10.18.8.2.1 Instructions must be provided either on a label
permanently affixed to the vehicle adjacent to the VHAD, or in the
operator's manual, advising the vehicle owner what to do if the
headlighting system requires aiming using the VHAD.
* * * * *
S14.9.3.12 Test for compliance with adaptive driving beam
photometry requirements.
S14.9.3.12.1 Test scenarios.
S14.9.3.12.1.1 Any of the scenarios specified in Table XXII and
Figures 27, 28, 29, and 30 may be tested. Where a range of values is
specified, the vehicle shall be able to meet the requirements at all
values within the range.
S14.9.3.12.1.2 Any speed that conforms to the speeds specified for
that test scenario will be selected for the test vehicle. The vehicle
will achieve and maintain this speed 0.45 m/s (1 mph)
prior to reaching, and then throughout, the measurement distance range
specified for that scenario. Once the test speed is achieved and
maintained, no sudden steering inputs, acceleration, braking, or
anything that causes a change in vehicle pitch that affects the results
of the test shall occur.
S14.9.3.12.1.3 For test scenarios involving curves, any radius
within the allowable range specified for that test scenario may be
selected. The curve shall nominally consist of a constant radius path
and be referenced to the headlighting system midpoint. The actual path
of the test vehicle shall not deviate from the nominal path by more
than +/- 0.5 m throughout the measurement distance range.
[[Page 10014]]
S14.9.3.12.1.4 The test vehicle shall be driven within the lane and
will not change lanes.
S14.9.3.12.1.5 The measurement distance is the linear distance
measured from the headlighting system midpoint to the most forward
point of the relevant photometric receptor head mounted on the test
fixture.
S14.9.3.12.1.6 The illuminance values for each photometer, the
instantaneous pitch of the test vehicle, and the measurement distance
shall be recorded and synchronized throughout the measurement distance
range specified for that scenario.
S14.9.3.12.2 Compliance criteria. The maximum calculated
illuminance for each measurement distance interval specified in Table
XXI that is applicable to the scenario being tested, as determined
according to S14.9.3.12.2.1, shall not exceed the applicable maximum
illuminance listed in Table XXI.
S14.9.3.12.2.1 The maximum calculated illuminance for each
measurement distance interval specified in Table XXI that is applicable
to the scenario being tested will be the highest illuminance recorded
in that distance interval, excluding any illuminance value(s) that meet
any of the following conditions:
(a) A single illuminance value exceeding the applicable maximum
illuminance in Table XXI (i.e., the illuminance value is not
immediately preceded or followed by an illuminance value exceeding the
applicable maximum illuminance); or
(b) consecutive illuminance values occurring over a span of no more
than 0.1 seconds exceeding the applicable maximum illuminance in Table
XXI; or
(c) any illuminance values collected while the vehicle pitch
exceeds the average pitch recorded throughout the entire measurement
distance range specified for that scenario in Table XXII by more than
0.3 degrees.
S14.9.3.12.3 Stimulus test fixtures. Testing shall be conducted
using the stimulus test fixtures specified in this section and Figures
23 through 26.
S14.9.3.12.3.1 Headlamps. The headlamps specified in Fig. 23
(Opposite Direction Car/Truck) shall be a right- and left-hand 2018
Ford F-150 Halogen headlamp (part # KL3Z13008C KL3Z13008D) using any
replaceable light source designated for use in the system and,
separately, a right- and left-hand 2018 Toyota Camry LED headlamp (part
# 8111006C40/8115006C40). The headlamps specified in Fig. 25 (Opposite
Direction Motorcycle) shall be a 5.75-inch round headlamp kit from a
2018 Harley Davidson Sportster (part #68297-05B) using an HB2
replaceable light source. Each headlamp shall energize the lower beam
only, powered at 12.8 volts DC +/- 500 mV when measured at the lamp
terminals, and shall have been energized for a minimum of 5 minutes
before each test trial. The measurement locations specified in Figures
23 and 25 shall be measured to the optical axis marking of the
headlamps.
S14.9.3.12.3.2 Taillamps. The taillamps specified in Fig. 24 (Same
Direction Car/Truck) shall be a right and left-hand 2018 Ford F-150
incandescent rear combination lamp (part # JL3Z13405H/JL3Z13404H) and,
separately, a right and left-hand 2018 Toyota Camry rear combination
lamp (part # 81550-06730/81560-06730). The taillamps specified in Fig.
26 (Same Direction Motorcycle) shall be a 2018 Harley Davidson Roadster
layback LED taillamp assembly (part #67800355). The taillamps shall be
powered at 12.8 volts DC +/- 500 mV when measured at the lamp terminals
and shall have been energized for a minimum of 5 minutes before each
test trial. The measurement locations specified in Figures 24 and 26
shall be measured to the center of the taillamp.
S14.9.3.12.3.3 Photometers. Photometers must be capable of a
minimum measurement unit of 0.01 lux. The color response of the
photometer must be corrected to that of the 1931 CIE Standard Observer
(2-degree) Photopic Response Curve, as shown in the CIE 1931
Chromaticity Diagram (incorporated by reference, see Sec. 571.5), with
a cosine correction characteristic within 3%. The photometer lenses on
the test fixture shall be clean and free from dirt and debris, and the
photometers will be zero-calibrated for each test to account for
ambient light. The illuminance values from the photometers shall be
collected at a rate of at least 100 Hz and a maximum 25-degree angle of
incidence.
S14.9.3.12.3.4 The projection of the fixture lamp's optical axis
onto the road surface shall be parallel to a tangent of the road edge
at the location of the photometer.
S14.9.3.12.3.5 The test fixture shall be centered in the lane.
S14.9.3.12.4 Test vehicle preparation.
S14.9.3.12.4.1 Tires on the test vehicle shall be inflated to the
manufacturer's recommended cold inflation pressure 7 kPa
(1 psi). If more than one recommendation is provided, the tires are
inflated to the cold inflation pressure 7 kPa (1 psi) that
corresponds to the lowest loaded condition listed.
S14.9.3.12.4.2 Before initiating testing, if the test vehicle is
equipped with a fuel tank it shall be filled to approximately 100% of
capacity with the appropriate fuel and maintained to at least 75%
capacity throughout the testing.
S14.9.3.12.4.3 Headlamps on the test vehicle shall be aimed
according to the vehicle manufacturer's instructions. The test vehicle
shall be loaded within +/- 5 kg of the total vehicle weight during
track testing prior to aiming the adaptive driving beam headlamps.
S14.9.3.12.4.4 The adaptive driving beam system shall be adjusted
according to the manufacturer's instructions.
S14.9.3.12.4.5 To the extent practicable, adaptive driving beam
system sensors and the windshield on the test vehicle (if an adaptive
driving beam system sensor is behind the windshield) shall be clean and
free of dirt and debris.
S14.9.3.12.4.6 The headlamp lenses of the test vehicle shall be
clean and free from dirt and debris.
S14.9.3.12.4.7 The adaptive driving beam system shall be activated
according to the manufacturer's instructions and all other
independently controlled lamps, such as fog lamps, shall be turned off.
S14.9.3.12.5 Test road
S14.9.3.12.5.1 The test road shall have a longitudinal grade
(slope) that does not exceed 2%.
S14.9.3.12.5.2 The lane width shall be any width from 3.05 m (10
ft) to 3.66 m (12 ft).
S14.9.3.12.5.3 The lanes shall be adjacent to one another.
S14.9.3.12.5.4 The tests are conducted on a uniform, solid-paved
surface.
S14.9.3.12.5.5 The test road surface may be concrete or asphalt and
shall not be bright white.
S14.9.3.12.5.6 The test road surface may have pavement markings but
shall be free of retroreflective material or elements that affect the
outcome of the test.
S14.9.3.12.6 Other test parameters and conditions
S14.9.3.12.6.1 Testing shall be conducted on dry pavement and with
no precipitation.
S14.9.3.12.6.2 Testing shall be conducted when the ambient
illumination at the test road as recorded by the photometers is at or
below 0.2 lux.
S14.9.3.12.6.3 Photometer data signals shall be passed through a
low-pass filter with a cutoff frequency of 35 Hz.
* * * * *
[[Page 10015]]
Table I-a--Required Lamps and Reflective Devices
----------------------------------------------------------------------------------------------------------------
Lighting device Number and color Mounting location Mounting height Device activation
----------------------------------------------------------------------------------------------------------------
All Passenger Cars, Multipurpose Passenger Vehicles (MPV), Trucks, and Buses
----------------------------------------------------------------------------------------------------------------
Lower Beam Headlamps............ White, of a On the front, at Not less than 55.9 The wiring harness
headlighting the same height, cm nor more than or connector
system listed in symmetrically 137.2 cm. assembly of each
Table II. about the headlighting
vertical system must be
centerline, as designed so that
far apart as only those light
practicable. sources intended
for meeting lower
beam photometrics
are energized
when the beam
selector switch
is in the lower
beam position,
and that only
those light
sources intended
for meeting upper
beam photometrics
are energized
when the beam
selector switch
is in the upper
beam position,
except for
certain systems
listed in Table
II and
semiautomatic
headlamp beam
switching devices
certified to
S9.4.1.6.
Steady burning,
except that may
be flashed for
signaling
purposes or (for
semiautomatic
headlamp beam
switching devices
certified to
S9.4.1.6) vary in
intensity for
adaptive driving
beam
functionality.
Upper Beam Headlamps............ White, of a On the front, at Not less than 22
headlighting the same height, inches (55.9 cm)
system listed in symmetrically nor more than 54
Table II. about the inches (137.2 cm).
vertical
centerline, as
far apart as
practicable.
* * * * * * *
----------------------------------------------------------------------------------------------------------------
* * * * *
[[Page 10016]]
TABLE I-c--Required Lamps and Reflective Devices
----------------------------------------------------------------------------------------------------------------
Lighting device Number and color Mounting location Mounting height Device activation
----------------------------------------------------------------------------------------------------------------
All Motorcycles
----------------------------------------------------------------------------------------------------------------
Lower Beam Headlamps............ White, of a On the front, at Not less than 22 The wiring harness
headlighting the same height, inches (55.9 cm) or connector
system listed in symmetrically nor more than 54 assembly of each
S10.17. about the inches (137.2 cm). headlighting
vertical system must be
centerline, as designed so that
far apart as only those light
practicable. See sources intended
additional for meeting lower
requirements in beam photometrics
S10.17.1.1, are energized
S10.17.1.2, and when the beam
S10.17.1.3. selector switch
is in the lower
beam position,
and that only
those light
sources intended
for meeting upper
beam photometrics
are energized
when the beam
selector switch
is in the upper
beam position,
except for
certain systems
listed in Table
II and
semiautomatic
headlamp beam
switching devices
certified to
S9.4.1.6.
Steady burning,
except that may
be flashed for
signaling
purposes or (for
semiautomatic
headlamp beam
switching devices
certified to
S9.4.1.6) vary in
intensity for
adaptive driving
beam
functionality.
The upper beam or
the lower beam,
but not both, may
be wired to
modulate from a
higher intensity
to a lower
intensity in
accordance with
S10.17.5.
Upper Beam Headlamps............ White, of a On the front, at Not less than 55.9
headlighting the same height, cm nor more than
system listed in symmetrically 137.2 cm.
S10.17. about the
vertical
centerline, as
far apart as
practicable. See
additional
requirements in
S10.17.1.1,
S10.17.1.2, and
S10.17.1.3.
* * * * * * *
----------------------------------------------------------------------------------------------------------------
* * * * *
Table XXI--Adaptive Driving Beam Photometry Requirements (1)
------------------------------------------------------------------------
Maximum
illuminance Maximum
Measurement distance interval (m) Opposite illuminance
direction same direction
(lux) (lux)
------------------------------------------------------------------------
Greater than or equal to 15.0 and less 3.1 18.9
than 30.0..............................
Greater than or equal to 30.0 and less 1.8 18.9
than 60.0..............................
Greater than or equal to 60.0 and less 0.6 4.0
than 120.0.............................
Greater than or equal to 120.0 and less 0.3 N/A
than or equal to 220...................
------------------------------------------------------------------------
\(1)\ For purposes of determining conformance with these specifications,
an observed value or a calculated value shall be rounded to the
nearest 0.1 lux, in accordance with the rounding method of ASTM
Practice E29 Using Significant Digits in Test Data to Determine
Conformance with Specifications.
* * * * *
[[Page 10017]]
Table XXII--Adaptive Driving Beam System Test Matrix
--------------------------------------------------------------------------------------------------------------------------------------------------------
Test vehicle Radius of curve Superelevation Measurement distance
Scenario No. speed (kph) Orientation (m.) Curve direction (%) range (m)
--------------------------------------------------------------------------------------------------------------------------------------------------------
1............................... 96.6-112.7 [60-70 Opposite Direction. Straight N/A............... 0-2 Greater than or equal
mph] to 15 and less than or
equal to 220.
2............................... 40.2-48.3 [25-30 Opposite Direction. 85-115 Left.............. 0-2 Greater than or equal
mph] to 15 and less than
60.
3............................... 64.4-72.4 [40-45 Opposite Direction. 210-250 Left.............. 0-2 Greater than or equal
mph] to 15 and less than or
equal to 150.
4............................... 80.5-88.5 [50-55 Opposite Direction. 335-400 Left.............. 0-2 Greater than or equal
mph] to 15 and less than or
equal to 220.
5............................... 64.4-72.4 [40-45 Opposite Direction. 210-250 Right............. 0-2 Greater than or equal
mph] to 15 and less than or
equal to 50.
6............................... 80.5-88.5 [50-55 Opposite Direction. 335-400 Right............. 0-2 Greater than or equal
mph] to 15 and less than or
equal to 70.
7............................... 96.6-112.7 [60-70 Same Direction..... Straight N/A............... 0-2 Greater than or equal
mph] to 15 and less than or
equal to 100.
8............................... 64.4-72.4 [40-45 Same Direction..... 210-250 Left.............. 0-2 Greater than or equal
mph] to 15 and less than or
equal to 100.
--------------------------------------------------------------------------------------------------------------------------------------------------------
* * * * *
BILLING CODE 4910-59-P
[GRAPHIC] [TIFF OMITTED] TR22FE22.045
[[Page 10018]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.046
[GRAPHIC] [TIFF OMITTED] TR22FE22.047
[[Page 10019]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.048
[GRAPHIC] [TIFF OMITTED] TR22FE22.049
[[Page 10020]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.050
[GRAPHIC] [TIFF OMITTED] TR22FE22.051
[[Page 10021]]
[GRAPHIC] [TIFF OMITTED] TR22FE22.052
BILLING CODE 4910-59-C
* * * * *
0
3. Amend Subpart B by adding Appendix A to Sec. 571.108 to read as
follows:
Appendix A to Subpart B to Sec. 571.108 Table of Contents.
Sec.
571.108 Standard No. 108; Lamps, reflective devices, and associated
equipment.
S1 Scope.
S2 Purpose.
S3 Application.
S4 Definitions.
S5 References to SAE publications.
S6 Vehicle requirements.
S6.1 Required lamps, reflective devices, and associated equipment by
vehicle type.
S6.1.1 Quantity.
S6.1.1.1 Conspicuity systems.
S6.1.1.2 High-mounted stop lamps.
S6.1.1.3 Truck tractor rear turn signal lamps.
S6.1.1.4 Daytime running lamps.
S6.1.2 Color.
S6.1.3 Mounting location.
S6.1.3.3 License plate lamp.
S6.1.3.4 High-mounted stop lamps.
S6.1.3.4.1 Interior mounting.
S6.1.3.4.2 Accessibility.
S6.1.3.5 Headlamp beam mounting.
S6.1.3.5.1 Vertical headlamp arrangement.
S6.1.3.5.2 Horizontal headlamp arrangement.
S6.1.3.6 Auxiliary lamps mounted near identification lamps.
S6.1.4 Mounting height.
S6.1.4.1 High-mounted stop lamps.
S6.1.5 Activation.
S6.1.5.1 Hazard warning signal.
S6.1.5.2 Simultaneous beam activation.
S6.2 Impairment.
S6.2.3 Headlamp obstructions.
S6.3 Equipment combinations.
S6.4 Lens area, visibility and school bus signal lamp aiming.
[[Page 10022]]
S6.4.1 Effective projected luminous lens area requirements.
S6.4.2 Visibility.
S6.4.3 Visibility options.
S6.4.3(a) Lens area option.
S6.4.3(b) Luminous intensity option.
S6.4.4 Legacy visibility alternative.
S6.4.5 School bus signal lamp aiming.
S6.5 Marking.
S6.5.1 DOT marking.
S6.5.2 DRL marking.
S6.5.3 Headlamp markings.
S6.5.3.1 Trademark.
S6.5.3.2 Voltage and trade number.
S6.5.3.3 Sealed beam headlamp markings.
S6.5.3.4 Replaceable bulb headlamp markings.
S6.5.3.5 Additional headlamp markings.
S6.6 Associated equipment.
S6.6.3 License plate holder.
S6.7 Replacement equipment.
S6.7.1 General.
S6.7.2 Version of this standard.
S7 Signal lamp requirements.
S7.1 Turn signal lamps.
S7.1.1 Front turn signal lamps.
S7.1.1.1 Number.
S7.1.1.2 Color of light.
S7.1.1.3 Mounting location.
S7.1.1.4 Mounting height.
S7.1.1.5 Activation.
S7.1.1.6 Effective projected luminous lens area.
S7.1.1.7 Visibility.
S7.1.1.8 Indicator.
S7.1.1.9 Markings.
S7.1.1.10 Spacing to other lamps.
S7.1.1.10.2 Spacing measurement for non-reflector lamps.
S7.1.1.10.3 Spacing measurement for lamps with reflectors.
S7.1.1.10.4 Spacing based photometric multipliers.
S7.1.1.11 Multiple compartment lamps and multiple lamps.
S7.1.1.11.4 Lamps installed on vehicles 2032 mm or more in overall
width.
S7.1.1.12 Ratio to parking lamps and clearance lamps.
S7.1.1.13 Photometry.
S7.1.1.14 Physical tests.
S7.1.2 Rear turn signal lamps.
S7.1.2.1 Number.
S7.1.2.2 Color of light.
S7.1.2.3 Mounting location.
S7.1.2.4 Mounting height.
S7.1.2.5 Activation.
S7.1.2.6 Effective projected luminous lens area.
S7.1.2.7 Visibility.
S7.1.2.8 Indicator.
S7.1.2.9 Markings.
S7.1.2.10 Spacing to other lamps.
S7.1.2.11 Multiple compartments and multiple lamps.
S7.1.2.11.4 Lamps installed on vehicles 2032 mm or more in overall
width.
S7.1.2.12 Ratio to taillamps and clearance lamps.
S7.1.2.13 Photometry.
S7.1.2.14 Physical tests.
S7.1.3 Combined lamp bulb indexing.
S7.2 Taillamps.
S7.2.1 Number.
S7.2.2 Color of light.
S7.2.3 Mounting location.
S7.2.4 Mounting height.
S7.2.5 Activation.
S7.2.6 Effective projected luminous lens area.
S7.2.7 Visibility.
S7.2.8 Indicator.
S7.2.9 Markings.
S7.2.10 Spacing to other lamps.
S7.2.11 Multiple compartments and multiple lamps.
S7.2.11.4 Taillamps installed on vehicles 2032 mm or more in overall
width.
S7.2.12 Ratio.
S7.2.13 Photometry.
S7.2.14 Physical tests.
S7.3 Stop lamps.
S7.3.1 Number.
S7.3.2 Color of light.
S7.3.3 Mounting location.
S7.3.4 Mounting height.
S7.3.5 Activation.
S7.3.6 Effective projected luminous lens area.
S7.3.7 Visibility.
S7.3.8 Indicator.
S7.3.9 Markings.
S7.3.10 Spacing to other lamps.
S7.3.11 Multiple compartments and multiple lamps.
S7.3.11.4 Lamps installed on vehicles 2032 mm or more in overall
width.
S7.3.12 Ratio to taillamps.
S7.3.13 Photometry.
S7.3.14 Physical tests.
S7.3.15 Combined lamp bulb indexing.
S7.4 Side marker lamps.
S7.4.1 Number.
S7.4.2 Color of light.
S7.4.3 Mounting location.
S7.4.4 Mounting height.
S7.4.5 Activation.
S7.4.6 Effective projected luminous lens area.
S7.4.7 Visibility.
S7.4.8 Indicator.
S7.4.9 Markings.
S7.4.10 Spacing to other lamps.
S7.4.11 Multiple compartments and multiple lamps.
S7.4.12 Ratio.
S7.4.13 Photometry.
S7.4.13.2 Inboard photometry.
S7.4.14 Physical tests.
S7.5 Clearance and identification lamps.
S7.5.1 Number.
S7.5.2 Color of light.
S7.5.3 Mounting location.
S7.5.4 Mounting height.
S7.5.5 Activation.
S7.5.6 Effective projected luminous lens area.
S7.5.7 Visibility.
S7.5.8 Indicator.
S7.5.9 Markings.
S7.5.10 Spacing to other lamps.
S7.5.11 Multiple compartments and multiple lamps.
S7.5.12 Ratio.
S7.5.12.1 Clearance lamps.
S7.5.12.2 Identification lamps.
S7.5.13 Photometry.
S7.5.14 Physical tests.
S7.6 Backup lamps.
S7.6.1 Number.
S7.6.2 Color of light.
S7.6.3 Mounting location.
S7.6.4 Mounting height.
S7.6.5 Activation.
S7.6.6 Effective projected luminous lens area.
S7.6.7 Visibility.
S7.6.8 Indicator.
S7.6.9 Markings.
S7.6.10 Spacing to other lamps.
S7.6.11 Multiple compartments and multiple lamps.
S7.6.12 Ratio.
S7.6.13 Photometry.
S7.6.14 Physical tests.
S7.7 License plate lamps.
S7.7.1 Number.
S7.7.2 Color of light.
S7.7.3 Mounting location.
S7.7.4 Mounting height.
S7.7.5 Activation.
S7.7.6 Effective projected luminous lens area.
S7.7.7 Visibility.
S7.7.8 Indicator.
S7.7.9 Markings.
S7.7.10 Spacing to other lamps.
S7.7.11 Multiple compartments and multiple lamps.
S7.7.12 Ratio.
S7.7.13 Photometry.
S7.7.14 Physical tests.
S7.7.15 Installation.
S7.7.15.4 Incident light from single lamp.
S7.7.15.5 Incident light from multiple lamps.
S7.8 Parking lamps.
S7.8.1 Number.
S7.8.2 Color of light.
S7.8.3 Mounting location.
S7.8.4 Mounting height.
S7.8.5 Activation.
S7.8.6 Effective projected luminous lens area.
S7.8.7 Visibility.
S7.8.8 Indicator.
S7.8.9 Markings.
S7.8.10 Spacing to other lamps.
S7.8.11 Multiple compartments and multiple lamps.
S7.8.12 Ratio.
S7.8.13 Photometry.
S7.8.14 Physical tests.
S7.9 High-mounted stop lamps.
S7.9.1 Number.
S7.9.2 Color of light.
S7.9.3 Mounting location.
S7.9.4 Mounting height.
S7.9.5 Activation.
S7.9.6 Effective projected luminous lens area.
S7.9.7 Visibility.
S7.9.8 Indicator.
S7.9.9 Markings.
S7.9.10 Spacing to other lamps.
S7.9.11 Multiple compartments and multiple lamps.
S7.9.12 Ratio.
S7.9.13 Photometry.
S7.9.14 Physical tests.
S7.10 Daytime running lamps (DRLs).
S7.10.1 Number.
S7.10.2 Color of light.
S7.10.3 Mounting location.
S7.10.4 Mounting height.
S7.10.5 Activation.
S7.10.6 Effective projected luminous lens area.
[[Page 10023]]
S7.10.7 Visibility.
S7.10.8 Indicator.
S7.10.9 Markings.
S7.10.10 Spacing to other lamps.
S7.10.10.1 Spacing to turn signal lamps.
S7.10.11 Multiple compartments and multiple lamps.
S7.10.12 Ratio.
S7.10.13 Photometry.
S7.10.14 Physical tests.
S7.11 School bus signal lamps.
S7.11.1 Number.
S7.11.2 Color of light.
S7.11.3 Mounting location.
S7.11.4 Mounting height.
S7.11.5 Activation.
S7.11.6 Effective projected luminous lens area.
S7.11.7 Visibility.
S7.11.8 Indicator.
S7.11.9 Markings.
S7.11.10 Spacing to other lamps.
S7.11.11 Multiple compartments and multiple lamps.
S7.11.12 Ratio.
S7.11.13 Photometry.
S7.11.14 Physical tests.
S8 Reflective device requirements.
S8.1 Reflex reflectors.
S8.1.1 Number.
S8.1.2 Color.
S8.1.3 Mounting location.
S8.1.4 Mounting height.
S8.1.5 Activation.
S8.1.6 Effective projected luminous lens area.
S8.1.7 Visibility.
S8.1.8 Indicator.
S8.1.9 Markings.
S8.1.10 Spacing to other lamps or reflective devices.
S8.1.11 Photometry.
S8.1.12 Physical tests.
S8.1.13 Alternative side reflex reflector material.
S8.2 Conspicuity systems.
S8.2.1 Retroreflective sheeting.
S8.2.1.2 Retroreflective sheeting material.
S8.2.1.3 Certification marking.
S8.2.1.4 Application pattern.
S8.2.1.4.1 Alternating red and white materials.
S8.2.1.5 Application location.
S8.2.1.6 Application spacing.
S8.2.1.7 Photometry.
S8.2.2 Conspicuity reflex reflectors.
S8.2.2.1 Certification marking.
S8.2.2.2 Application pattern.
S8.2.2.2.1 Alternating red and white materials.
S8.2.2.2.2 White material.
S8.2.2.3 Photometry.
S8.2.3 Conspicuity system installation on trailers.
S8.2.3.1 Trailer rear.
S8.2.3.1.1 Element 1--alternating red and white materials.
S8.2.3.1.2 Element 2--white.
S8.2.3.1.3 Element 3--alternating red and white materials.
S8.2.3.2 Trailer side-alternating red and white materials.
S8.2.4 Conspicuity system installation on truck tractors.
S8.2.4.1 Element 1--alternating red and white materials.
S8.2.4.2 Element 2--white.
S9 Associated equipment requirements.
S9.1 Turn signal operating unit.
S9.1.2 Physical tests.
S9.2 Turn signal flasher.
S9.2.2 Physical tests.
S9.3 Turn signal pilot indicator.
S9.3.4 Indicator size and color.
S9.3.6 Turn signal lamp failure.
S9.4 Headlamp beam switching device.
S9.4.1 Semi-automatic headlamp beam switching device.
S9.4.1.1 Operating instructions.
S9.4.1.2 Manual override.
S9.4.1.3 Fail safe operation.
S9.4.1.4 Automatic dimming indicator.
S9.4.1.5 Option 1 (Semiautomatic Headlamp Beam Switching Devices
other than Adaptive Driving Beam systems).
S9.4.1.5.1 Lens accessibility.
S9.4.1.5.2 Mounting height.
S9.4.1.5.3 Physical tests.
S9.4.1.6 Option 2 (Adaptive Driving Beam systems).
S9.4.1.7 Physical tests.
S9.5 Upper beam headlamp indicator.
S9.5.1 Indicator size and location.
S9.6 Vehicular hazard warning signal operating unit.
S9.6.2 Operating unit switch.
S9.6.3 Physical tests.
S9.7 Vehicular hazard warning signal flasher.
S9.7.2 Physical tests.
S9.8 Vehicular hazard warning signal pilot indicator.
S9.8.4 Indicator size and color.
S10 Headlighting system requirements.
S10.1 Vehicle headlighting systems.
S10.2 [Reserved].
S10.3 Number.
S10.4 Color of light.
S10.5 Mounting location.
S10.6 Mounting height.
S10.7 Activation.
S10.8 Effective projected luminous lens area.
S10.9 Visibility.
S10.10 Indicator.
S10.11 Markings.
S10.12 Spacing to other lamps.
S10.13 Sealed beam headlighting systems.
S10.13.1 Installation.
S10.13.2 Simultaneous aim.
S10.13.3 Photometry.
S10.13.4 Physical tests.
S10.14 Integral beam headlighting systems.
S10.14.1 Installation.
S10.14.2 Aimability.
S10.14.3 Simultaneous aim.
S10.14.4 Markings.
S10.14.5 Additional light sources.
S10.14.6 Photometry.
S10.14.7 Physical tests.
S10.15 Replaceable bulb headlighting systems.
S10.15.1 Installation.
S10.15.2 Aiming restrictions.
S10.15.3 Replacement lens reflector units.
S10.15.4 Markings.
S10.15.5 Additional light sources.
S10.15.6 Photometry.
S10.15.7 Physical tests.
S10.16 Combination headlighting systems.
S10.16.1 Installation.
S10.16.2 Photometry.
S10.16.3 Physical tests.
S10.17 Motorcycle headlighting systems.
S10.17.1 Installation.
S10.17.1.1 Single headlamp.
S10.17.1.2 Two headlamps with both beams.
S10.17.1.3 Two headlamps, upper beam and lower beam.
S10.17.2 Motorcycle replaceable bulb headlamp marking.
S10.17.3 Photometry.
S10.17.4 Physical tests.
S10.17.5 Motorcycle headlamp modulation system.
S10.17.5.1 Modulation.
S10.17.5.2 Replacement modulators.
S10.17.5.2.1 Replacement performance.
S10.17.5.2.2 Replacement instructions.
S10.18 Headlamp aimability performance requirements (except
motorcycles).
S10.18.1 Headlamp mounting and aiming.
S10.18.2 Headlamp aiming systems.
S10.18.3 Aim adjustment interaction.
S10.18.4 Horizontal adjustment-visually aimed headlamp.
S10.18.5 Optical axis marking.
S10.18.5.1 Optical axis marking-vehicle.
S10.18.5.2 Optical axis marking-lamp.
S10.18.5.3 Optical axis marking-visual/optical aim headlamp.
S10.18.6 Moveable reflectors.
S10.18.7 External aiming.
S10.18.7.1 Headlamp aiming device locating plates.
S10.18.7.2 Nonadjustable headlamp aiming device locating plates.
S10.18.8 On-vehicle aiming.
S10.18.8.1 Aim.
S10.18.8.1.1 Vertical aim.
S10.18.8.1.2 Horizontal aim.
S10.18.8.2 Aiming instructions.
S10.18.8.3 Permanent calibration.
S10.18.8.4 Replacement units.
S10.18.8.5 Physical tests.
S10.18.9 Visual/optical aiming.
S10.18.9.1 Vertical aim, lower beam.
S10.18.9.1.1 Vertical position of the cutoff.
S10.18.9.1.2 Vertical gradient.
S10.18.9.1.3 Horizontal position of the cutoff.
S10.18.9.1.4 Maximum inclination of the cutoff.
S10.18.9.1.5 Measuring the cutoff parameter.
S10.18.9.2 Horizontal aim, lower beam.
S10.18.9.3 Vertical aim, upper beam.
S10.18.9.4 Horizontal aim, upper beam.
S10.18.9.5 Photometry.
S10.18.9.6 Visual/optical aiming identification marking.
S11 Replaceable light source requirements.
S11.1 Markings.
S11.2 Ballast markings.
S11.3 Gas discharge laboratory life.
S11.4 Physical tests.
S12 Headlamp concealment device requirements.
S12.7 Certification election.
S13 Replaceable headlamp lens requirements.
S14 Physical and photometry test procedures and performance
requirements.
S14.1 General test procedures and performance requirements.
S14.1.2 Plastic optical materials.
[[Page 10024]]
S14.1.4 Samples.
S14.1.5 Laboratory facilities.
S14.2 Photometric test procedures.
S14.2.1 Photometry measurements for all lamps except license lamps,
headlamps, and DRLs.
S14.2.1.1 Mounting.
S14.2.1.2 School bus signal lamp aiming.
S14.2.1.3 Measurement distance.
S14.2.1.4 Location of test points.
S14.2.1.5 Multiple compartment and multiple lamp photometry of turn
signal lamps, stop lamps, and taillamps.
S14.2.1.6 Bulbs.
S14.2.2 License plate lamp photometry.
S14.2.2.1 Illumination surface.
S14.2.2.2 Test stations.
S14.2.3 Reflex reflector and retroreflective sheeting photometry.
S14.2.3.1 Mounting.
S14.2.3.2 Illumination source.
S14.2.3.3 Measurement distance.
S14.2.3.4 Test setup.
S14.2.3.5 Photodetector.
S14.2.3.6 Photometry surface.
S14.2.3.7 Procedure.
S14.2.3.8 Measurements.
S14.2.3.8.1 Reflex reflectors.
S14.2.3.8.2 Retroreflective sheeting.
S14.2.3.8.3 Reflex reflector photometry measurement adjustments.
S14.2.4 Daytime running lamp (DRL) photometry measurements.
S14.2.5 Headlamp photometry measurements.
S14.2.5.1 Mounting.
S14.2.5.3 Measurement distance.
S14.2.5.4 Seasoning and test voltage.
S14.2.5.5 Aiming.
S14.2.5.5.1 Mechanically aimable headlamps using an external aimer.
S14.2.5.5.2 Mechanically aimable headlamps equipped with a VHAD.
S14.2.5.5.3 Visually aimable lower beam headlamps-vertical aim.
S14.2.5.5.4 Visually aimable lower beam headlamps-horizontal aim.
S14.2.5.5.5 Visually aimable upper beam headlamps-vertical aim.
S14.2.5.5.6 Visually aimable upper beam headlamps-horizontal aim.
S14.2.5.5.7 Simultaneous aim Type F sealed beam headlamps and beam
contributor integral beam headlamps.
S14.2.5.5.8 Motorcycle headlamp-upper beam headlamps designed to
comply with Table XX.
S14.2.5.5.9 Motorcycle headlamp-lower beam headlamps designed to
comply with Table XX.
S14.2.5.6 Positioner.
S14.2.5.7 Photometer.
S14.2.5.7.2 Sensor.
S14.2.5.8 Location of test points.
S14.2.5.9 Beam contributor photometry measurements.
S14.2.5.10 Moveable reflector aimed headlamp photometry
measurements.
S14.3 Motorcycle headlamp out of focus test procedure and
performance requirements.
S14.3.1 Procedure.
S14.3.2 Performance requirements.
S14.4 General test procedures and performance requirements.
S14.4.1 Color test.
S14.4.1.1 Samples.
S14.4.1.2 General procedure.
S14.4.1.3 Visual method.
S14.4.1.3.1 Visual method procedure.
S14.4.1.3.2 Visual method performance requirements.
S14.4.1.3.2.1 Red.
S14.4.1.3.2.2 Yellow (Amber).
S14.4.1.3.2.3 White.
S14.4.1.4 Tristimulus method.
S14.4.1.4.1 Tristimulus method procedure.
S14.4.1.4.2 Tristimulus method performance requirements.
S14.4.1.4.2.1 Red.
S14.4.1.4.2.2 Yellow (Amber).
S14.4.1.4.2.3 White (achromatic).
S14.4.1.4.2.4 Green.
S14.4.1.4.2.5 Restricted Blue.
S14.4.1.4.2.6 Signal Blue.
S14.4.2 Plastic optical materials tests.
S14.4.2.1 Samples.
S14.4.2.2 Outdoor exposure test.
S14.4.2.2.3 Procedure.
S14.4.2.2.4 Performance requirements.
S14.4.2.3 Heat test.
S14.4.2.3.1 Procedure.
S14.4.2.3.2 Performance requirements.
S14.5 Signal lamp and reflective device physical test procedures and
performance requirements.
S14.5.1 Vibration test.
S14.5.1.1 Procedure.
S14.5.1.2 Performance requirements.
S14.5.2 Moisture test.
S14.5.2.1 Procedure.
S14.5.2.2 Performance requirements.
S14.5.3 Dust test.
S14.5.3.1 Samples.
S14.5.3.2 Procedure.
S14.5.3.3 Performance requirements.
S14.5.4 Corrosion test.
S14.5.4.1 Procedure.
S14.5.4.2 Performance requirements.
S14.6 Headlamp physical test procedures and performance
requirements.
S14.6.1 Abrasion test.
S14.6.1.1 Procedure.
S14.6.1.1.1 Abrading pad.
S14.6.1.1.2 Abrading pad alignment.
S14.6.1.1.3 Abrasion test procedure.
S14.6.1.2 Performance requirements.
S14.6.2 Chemical resistance test.
S14.6.2.1 Procedure.
S14.6.2.1.1 Test fluids.
S14.6.2.1.2 Fluid application.
S14.6.2.1.3 Test duration.
S14.6.2.2 Performance requirements.
S14.6.3 Corrosion test.
S14.6.3.1 Procedure.
S14.6.3.2 Performance requirements.
S14.6.4 Corrosion-connector test.
S14.6.4.1 Procedure.
S14.6.4.2 Performance requirements.
S14.6.5 Dust test.
S14.6.5.1 Procedure.
S14.6.5.2 Performance requirements.
S14.6.6 Temperature cycle test and internal heat test.
S14.6.6.1 Samples.
S14.6.6.2 General procedure.
S14.6.6.3 Temperature cycle test.
S14.6.6.3.1 Procedure.
S14.6.6.3.2 Performance requirements.
S14.6.6.4 Internal heat test.
S14.6.6.4.1 Procedure.
S14.6.6.4.2 Performance requirements.
S14.6.7 Humidity test.
S14.6.7.1 Procedure.
S14.6.7.2 Performance requirements.
S14.6.8 Vibration test.
S14.6.8.1 Samples.
S14.6.8.2 Procedure.
S14.6.8.3 Performance requirements.
S14.6.9 Sealing test.
S14.6.9.1 Procedure.
S14.6.9.2 Performance requirements.
S14.6.10 Chemical resistance test of reflectors of replaceable lens
headlamps.
S14.6.10.1 Procedure.
S14.6.10.1.1 Test fluids.
S14.6.10.1.2 Fluid application.
S14.6.10.1.3 Test duration.
S14.6.10.2 Performance requirements.
S14.6.11 Corrosion resistance test of reflectors of replaceable lens
headlamps.
S14.6.11.1 Procedure.
S14.6.11.2 Performance requirements.
S14.6.12 Inward force test.
S14.6.12.1 Procedure.
S14.6.12.2 Performance requirements.
S14.6.13 Torque deflection test.
S14.6.13.1 Procedure.
S14.6.13.2 Performance requirements.
S14.6.14 Retaining ring test.
S14.6.14.1 Procedure.
S14.6.14.2 Performance requirements.
S14.6.15 Headlamp connector test.
S14.6.15.1 Procedure.
S14.6.15.2 Performance requirements.
S14.6.16 Headlamp wattage test.
S14.6.16.1 Procedure.
S14.6.16.2 Performance requirements.
S14.6.17 Aiming adjustment test-laboratory.
S14.6.17.1 Procedure.
S14.6.17.2 Performance requirements.
S14.6.18 Aiming adjustment test-on vehicle.
S14.6.18.1 Procedure.
S14.6.18.2 Performance requirements.
S14.7 Replaceable light source physical test procedures and
performance requirements.
S14.7.1 Deflection test for replaceable light sources.
S14.7.1.1 Procedure.
S14.7.1.2 Performance requirements.
S14.7.2 Pressure test for replaceable light sources.
S14.7.2.1 Procedure.
S14.7.2.2 Performance requirements.
S14.7.3 Replaceable light source power and flux measurement
procedure.
S14.7.3.1 Seasoning.
S14.7.3.1.1 Resistive filament source.
S14.7.3.1.2 Discharge source.
S14.7.3.2 Test voltage.
S14.7.3.3 Luminous flux measurement.
S14.7.3.3.1 Resistive filament light source setup.
S14.7.3.3.3.2 Discharge light source setup.
S14.8 Vehicle headlamp aiming devices (VHAD) physical test
procedures and performance requirements.
S14.8.1 Samples.
S14.8.2 Scale graduation test.
S14.8.2.1 Procedure.
S14.8.2.2 Performance requirements.
S14.8.3 Cold scale graduation test.
S14.8.3.1 Procedure.
S14.8.3.2 Performance requirements.
S14.8.4 Hot scale graduation test.
S14.8.4.1 Procedure.
S14.8.4.2 Performance requirements.
[[Page 10025]]
S14.8.5 Thermal cycle test.
S14.8.5.1 Procedure.
S14.8.5.2 Performance requirements.
S14.8.6 Corrosion test.
S14.8.6.1 Procedure.
S14.8.6.2 Performance requirements.
S14.8.7 Photometry test.
S14.8.7.1 Procedure.
S14.8.7.2 Performance requirements.
S14.9 Associated equipment physical test procedures and performance
requirements.
S14.9.1 Turn signal operating unit durability test.
S14.9.1.1 Power supply specifications.
S14.9.1.2 Procedure.
S14.9.1.3 Performance requirements.
S14.9.2 Vehicular hazard warning signal operating unit durability
test.
S14.9.2.1 Procedure.
S14.9.2.2 Performance requirements.
S14.9.3 Turn signal flasher and vehicular hazard warning flasher
tests.
S14.9.3.1 Standard test circuit.
S14.9.3.1.1 Test circuit setup.
S14.9.3.2 Power supply specifications.
S14.9.3.2.1 Starting time, voltage drop, and flash rate and percent
current ``on'' time tests.
S14.9.3.2.2 Durability tests.
S14.9.3.3 Turn signal flasher starting time test.
S14.9.3.3.1 Samples.
S14.9.3.3.2 Procedure.
S14.9.3.3.3 Performance requirements.
S14.9.3.4 Turn signal flasher voltage drop test.
S14.9.3.4.1 Samples.
S14.9.3.4.2 Procedure.
S14.9.3.4.3 Performance requirements.
S14.9.3.5 Turn signal flasher flash rate and percent current ``on''
time test.
S14.9.3.5.1 Samples.
S14.9.3.5.2 Procedure.
S14.9.3.5.3 Performance requirements.
S14.9.3.6 Turn signal flasher durability test.
S14.9.3.6.1 Samples.
S14.9.3.6.2 Procedure.
S14.9.3.6.3 Performance requirements.
S14.9.3.7 Vehicular hazard warning signal flasher starting time
test.
S14.9.3.7.1 Samples.
S14.9.3.7.2 Procedure.
S14.9.3.7.3 Performance requirements.
S14.9.3.8 Vehicular hazard warning signal flasher voltage drop test.
S14.9.3.8.1 Samples.
S14.9.3.8.2 Procedure.
S14.9.3.8.3 Performance requirements.
S14.9.3.9 Vehicular hazard warning signal flasher flash rate and
percent ``on'' time test.
S14.9.3.9.1 Samples.
S14.9.3.9.2 Procedure.
S14.9.3.9.3 Performance requirements.
S14.9.3.10 Vehicular hazard warning signal flasher durability test.
S14.9.3.10.1 Samples.
S14.9.3.10.2 Procedure.
S14.9.3.10.3 Performance requirements.
S14.9.3.11 Semiautomatic headlamp beam switching device tests.
S14.9.3.11.1 Test conditions.
S14.9.3.11.2 Sensitivity test.
S14.9.3.11.2.1 Samples.
S14.9.3.11.2.2 Procedure.
S14.9.3.11.2.3 Performance requirements.
S14.9.3.11.2.3.1 Operating limits.
S14.9.3.11.3 Voltage regulation test.
S14.9.3.11.3.1 Procedure.
S14.9.3.11.3.2 Performance requirements.
S14.9.3.11.4 Manual override test.
S14.9.3.11.4.1 Procedure.
S14.9.3.11.4.2 Performance requirements.
S14.9.3.11.5 Warmup test.
S14.9.3.11.5.1 Procedure.
S14.9.3.11.5.2 Performance requirements.
S14.9.3.11.6 Temperature test.
S14.9.3.11.6.1 Procedure.
S14.9.3.11.6.2 Performance requirements.
S14.9.3.11.7 Dust test.
S14.9.3.11.7.1 Procedure.
S14.9.3.11.7.2 Performance requirements.
S14.9.3.11.8 Corrosion test.
S14.9.3.11.8.1 Procedure.
S14.9.3.11.8.2 Performance requirements.
S14.9.3.11.9 Vibration test.
S14.9.3.11.9.1 Procedure.
S14.9.3.11.9.2 Performance requirements.
S14.9.3.11.10 Sunlight test.
S14.9.3.11.10.1 Procedure.
S14.9.3.11.10.2 Performance requirements.
S14.9.3.11.11 Durability test.
S14.9.3.11.11.1 Procedure.
S14.9.3.11.11.2 Performance requirements.
S14.9.3.11.12 Return to upper beam test.
S14.9.3.11.12.1 Procedure.
S14.9.3.11.12.2 Performance requirements.
S14.9.3.12 Test for compliance with adaptive driving beam photometry
requirements.
S14.9.3.12.1 Test Scenarios.
S14.9.3.12.2 Compliance Criteria.
S14.9.3.12.3 Stimulus test fixtures.
S14.9.3.12.4 Test vehicle preparation.
S14.9.3.12.5 Test road.
S14.9.3.12.6 Other test parameters and conditions.
Table I-a Required lamps and reflective devices All passenger cars,
multipurpose passenger vehicles (MPV), trucks, and buses
Table I-b Required lamps and reflective devices All trailers
Table I-c Required lamps and reflective devices All motorcycles
Table II-a Headlighting systems Sealed beams
Table II-b Headlighting systems Combination
Table II-c Headlighting systems Integral beams
Table II-d Headlighting systems Replaceable bulb
Table III Marking requirements location
Table IV-a Effective projected luminous lens area requirements
Table IV-b Effective projected luminous lens area requirements
Table IV-c Effective projected luminous lens area requirements
Table V-a Visibility requirements of installed lighting devices
Table V-b Visibility requirements of installed lighting devices Lens
area visibility option
Table V-c Visibility requirements of installed lighting devices
Luminous intensity visibility option
Table V-d Visibility requirements of installed lighting devices
(Legacy visibility alternative)
Table VI-a Front turn signal lamp photometry requirements
Table VI-b Front turn signal lamp photometry requirements
Table VII Rear turn signal lamp photometry requirements
Table VIII Taillamp photometry requirements
Table IX Stop lamp photometry requirements
Table X Side marker lamp photometry requirements
Table XI Clearance and identification lamps photometry requirements
Table XII Backup lamp photometry requirements
Table XIII-a Motorcycle turn signal lamp alternative photometry
requirements
Table XIII-b Motor driven cycle stop lamp alternative photometry
requirements
Table XIV Parking lamp photometry requirements
Table XV High-mounted stop lamp photometry requirements
Table XVI-a Reflex reflector photometry requirements
Table XVI-b Additional photometry requirements for conspicuity
reflex reflectors
Table XVI-c Retroreflective sheeting photometry requirements
Table XVII School bus signal lamp photometry requirements
Table XVIII Headlamp upper beam photometry requirements
Table XIX-a Headlamp lower beam photometry requirements
Table XIX-b Headlamp lower beam photometry requirements
Table XIX-c Headlamp lower beam photometry requirements
Table XX Motorcycle and motor driven cycle headlamp photometry
requirements
Table XXI Adaptive Driving Beam Photometry Requirements
Table XXII Adaptive Driving Beam Test Matrix
Figure 1 Chromaticity diagram
Figure 2 Flasher performance chart
Figure 3 Replaceable bulb headlamp aim pads
Figure 4 Headlamp connector test setup
Figure 5 Headlamp abrasion test fixture
Figure 6 Thermal cycle test profile
Figure 7 Dirt/Ambient test setup
Figure 8 Replaceable light source deflection test setup
Figure 9 Environmental test profile
Figure 10 Replaceable light source pressure test setup
Figure 11 Trailer conspicuity treatment examples
Figure 12-1 Trailer conspicuity detail I
Figure 12-2 Trailer conspicuity detail II
Figure 13 Tractor conspicuity treatment examples
Figure 14 92 x 150 Headlamp aim deflection test setup
Figure 15 Types G and H headlamp aim deflection test setup
Figure 16 Types A and E headlamp aim deflection test setup
Figure 17 Type B headlamp aim deflection test setup
Figure 18 Types C and D headlamp aim deflection test setup
[[Page 10026]]
Figure 19 License plate lamp target locations
Figure 20 License plate lamp measurement of incident light angle
Figure 21 Vibration test machine
Figure 22 Flasher standard test circuit
Figure 23 Car/Truck opposite direction stimulus test fixture
dimensions
Figure 24 Car/Truck same direction stimulus test fixture dimensions
Figure 25 Motorcycle opposite direction stimulus test fixture
dimensions
Figure 26 Motorcycle same direction stimulus test fixture dimensions
Figure 27 Opposite direction test scenarios
Figure 28 Same direction test scenarios
Figure 29 Left Curve Test Scenarios
Figure 30 Right Curve Test Scenarios
* * * * *
Issued under authority delegated in 49 CFR 1.95, 501.4, and
501.5.
Steven S. Cliff,
Deputy Administrator.
[FR Doc. 2022-02451 Filed 2-18-22; 8:45 am]
BILLING CODE 4910-59-P