Lighting

from Daniel Stern, DVN

Time’s up! Last Tuesday, 11 December, was the official end of the public comment period for NHTSA’s NPRM (Notice of Proposed Rulemaking) regarding ADB. In weeks past, we’ve scrutinised and analysed the proposal as well as some of the general public’s replies while we waited for automakers, suppliers, industry associations, and safety outfits to weigh in. The timeframe has been very compressed given the scope and magnitude of the contemplated changes; substantive responses from stakeholders had to be crafted and drafted with great deliberation in a very big hurry, and even so, most of them were submitted and posted to the docket on the last possible day.

In perusing major players’ comments, straight away we notice something very encouraging: the high level of consensus among them. Consensus, we say, and not unanimity; each of the respondents gave their own unique voice to their own particular perspectives and concerns. That’s probably to the good; it shows that this feedback to NHTSA is the product of thought and effort, not merely a flurry of reflexive me-tooing—which is also available in the docket, serving as an effective backdrop against which the substantive consensus looks even better, thanks to alarmed owners of movie theatres. Drive-in cinemas, specifically, which are reportedly increasing in popularity lately in accord with retro-trends. The owner of such a drive-in got word of the proposal to allow ADB, thoroughly misunderstood it as a proposal to take away any driver control and have all the car’s lights permanently lit, wrote in begging NHTSA not to ruin his business, and set about very effectively instigating a letter-writing campaign amongst his fellows, as it seems. Perhaps it goes to emphasise the need for effective consumer education about what ADB is (and what it is not).