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July 18, 2006
The Chief Counsel National Highway Traffic Safety Administration, NCC-01 400 7th Street, SW Washington, D.C. 20590
“REQUEST for LEGAL INTERPRETATIONS” on FMVSS #108 Subjects
Receiver Receipt Requested
“EFFECTIVE PROJECTED LUMINOUS LENS AREAS” … also needed for TAIL & RUNNING LIGHTS!
The 1966 Vehicle Safety Act sanctioned the formation of NHTSA and directed the founders to establish Vehicle Lighting specifications that would make all “Vehicles’ Presence” and their “Braking, Turning and Lane Changing Intentions”* conspicuous** to nearby drivers and pedestrians. *our words **NHTSA’s main verb
It was learned long ago from professionally executed NHTSA and SAE Testing, that Vehicle Lamps with small “Effective Projected Luminous Lens Areas” (EPLLA) … were not perceived the same by the human brain as Lamps with larger “effective light emitting surfaces” even though each size developed ≈identical Photometric (Candela) Test Pattern outputs. In fact, sometimes it was found that small EPLLA lamps were not at all recognized by the brain - and at best - reacted to more slowly than larger EPLLA Lamps.
To provide adequate Effective Projected Luminous Lens Areas for Brake, Turn and Tail Lamps that will assuredly be perceived by the brain as a large, contiguous area of Red or Amber Light … requires the use of many closely spaced Parabolic or Fresnel type Facets that are typically illuminated by a common #1157 or (the latest) #3157 type bulbs. Designers may also use many LEDs or Tiny Bulbs if they are located in close proximity to each other … thus providing adequate “Presence” conspicuity as well as adequate “Intentions” conspicuity mandated by FMVSS #108.
To better understand mandated EPLLA requirements in the U.S.A. as well as in “EU” and other safety concerned Countries … refer to the attached color page taken from Truck Lite’s® recent catalog showing their one and only? “ECE (EU) Approved” 50 LED Brake/ Turn and Tail combination lamp - that has a Retail Price of $120*. *probably 1/3rd of this for OEM use
“EU” and S.A.E. Safety Engineers are well aware of what’s needed in “Luminous Flux” (NHTSA term) to produce proper human response to Presence and Intention – and that’s why the “EU” and the U.S.A. and Canada mandate that all Brake, Turn Signals and Tail Lights* used on smaller vehicles (under 80”) must project at least 7-3/4in² of qualified EPLLA** while at the same time, projecting a more or less “Uniform Luminous Flux” from this minimal 7-3/4in² of area. *The U.S.A. currently doesn’t require any Luminous Lens Area for Tail Lights … but should! The “EU” and Canada? do require specified EPLLA for Tail Lights! **EPLLA mandate is 11-5/8in² for over 80” wide vehicles
Therefore, to acquire “ECE” Approval, a LED or Incandescent Lamp can not simply use a couple (or a few) Red or Amber “Dots” of light because Dots are not conspicuous enough to the human brain. For NHTSA or anyone else to disregard this proven human fact … represents a violation of the main objective of the 1966 Vehicle Safety Act as well as a violation of common sense.
1113 Greenville Road Livermore, California
94550 Tel: (925) 443-3140 Fax: (925) 443-0384 “EFFECTIVE PROJECTED LUMINOUS LENS AREAS” … also needed for TAIL & RUNNING LIGHTS!
Further, all Lamp Manufacturers must also see to it that the entire array of Reflective/Refractive Facets and all the LEDs, or Tiny Bulbs used … plus the other supporting components … simultaneously comply with all FMVSS #108 Photometric as well as all Physical Testing mandates so as to assure everyone that we have bright, effective and long lasting lighting on our roadways. I recently drove up “fast” (at night) on a slow moving Big Rig that had recently converted to LED Tail* and Running Lights that were, indeed, turned on; however … each Tail Lamp* was represented by only 2 (two) small Dots of Red Light*, which indeed, was all that was identifying the “presence” of this huge mass of steel … and THAT’S ALL! *Located ≈1 foot inboard from each outboard edge of the Trailer’s 102” width Furthermore, this Big Rig’s mandated Clearance Lights were “not at all seeable to me” because they were mounted on the sides of the Trailer instead of at the rear corners, which, of course, eliminated all rearward, inboard, visibility to any driver “trailing behind” or “closing fast” or “pulling out to pass” this Big Rig. Realize! … that a few years ago, NHTSA actually modified* FMVSS #108 S5.3.2.1 to eliminate the entire 45° inboard visibility** requirement for Clearance Lights, thereby starting the advent of “Blind Clearance Light Mountings”. “Why was the entire 45° Inboard Visibility eliminated?” … “to protect mandated Clearance Lamps from damage.” *because of a SAE request? **The 45° Outboard Visibility requirement remained Why the entire 45° inboard sight area was eliminated instead of just a portion, was never explained by NHTSA. By eliminating only 25° or 30° … would have still left a ≈10° or 15° sight angle to following traffic, which almost any large or small trailer could easily and economically accommodate, while still properly exposing the Clearance Lights to following, closing fast and passing drivers. Of course, referring to the “damage subject” brings up the question … eliminating seeable Clearance Lights to save them from damage … we must ask … “What about the damage to following and passing drivers and their vehicles that crash (or sideswipe) this virtually unidentified mass of steel during limited visibility conditions?” which leads us to ask NHTSA … “Was this anti-damage concept actually implemented to save a $3.00 Clearance Light in lieu of saving a human life?”
Further, realize … I also could not see the Big Rig’s three I.D. Lights because they were also simple “LED Dots” that were mounted about 12 feet above the pavement, and therefore, they were no where near my line of sight. Further, consider the fact that each official I.D. light was also only represented by one or two Red Dots of LED light that projected only more or less, straight out* … and therefore, these Dots were all but invisible to any nearby following traffic, including me. *10° Up and 10° Down and no more
As “dumb” and dangerous as
this situation was … these non effective Dots of red light did indeed
comply with NHTSA’s “as high as practical” and “zero allowed
EPLLA” requirements. Bottom Line: All I could
see … as I rapidly “closed” on this slow moving mass of steel … were
two tiny Red Dots for each Tail Lamp … each mounted a foot inboard of the Big
Rig’s 8-1/2 foot width … Had there been adverse
conditions such as “fog”, “downpour”, “snow storm”, “dust
storm” or “smoky conditions” – I WOULD HAVE NOT SEEN ANYTHING!
and very likely crashed into the REAR of this “Legally Lit” BIG RIG,
and most likely been seriously injured or killed … a situation you or
your loved ones could be put into … at anytime … anywhere … on any
roadway. “EFFECTIVE PROJECTED LUMINOUS LENS AREAS” … also needed for TAIL & RUNNING LIGHTS! These kinds of non sensible safety violations can’t be sanctioned by NHTSA any longer! Therefore, we must ask:
1. Does NHTSA recognize that “Presence Lamps”, which display virtually “Zero” Effective Projected Luminous Lens Area, will be poorly recognized … if not ignored … by the human brain?
2. Does NHTSA realize that currently FMVSS #108 requires no (zero) minimal Effective Projected Luminous Lens Area for Tail Lights – and that simply one or two (or a few) Red Dots of light is not sufficient to produce proper human recognition and reactions?
3. Does NHTSA realize that all Side Marker, Clearance and I.D. lights (the same as Tail Lamps) … also require no (zero) Effective Projected Luminous Lens Area and therefore, when only one, two or a few LEDs are used, they also will not be properly recognized nor acted upon by nearby drivers and pedestrians?
4. Does NHTSA realize they have virtually disabled the effectiveness of Clearance Lights on Big Rigs, etc. by eliminating the entire 45° Inboard Sight Area?
5. Does NHTSA realize that common LEDs only project seeable light at little more than 10° down so when LED Identification Lights (I.D. Lights) are mounted 12 feet above the pavement … for instance, on a Big Rig trailer … these LEDs will not be seen within ≈60 feet of the rear-end, and even if they are properly lensed so they are seeable – one or two or a few Red Dots (Zero EPLLA) have been proven to be virtually incomprehensible to the human brain.
I believe a rapid answer to these questions is
required by Federal Law.
Dennis G. Moore, President (Dry Launch Light Company)
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