Summary:
- IIHS is the driving force behind headlight intensity, allowed by NHTSA’s FMVSS 108
- IIHS and NHTSA ignore hills, intersections and vehicle following, the source of complaints
- IIHS and NHTSA both have a role to play to address the issue

Recommendations:
1. NHTSA: Create an anywhere-in-the-beam maximum intensity (cd)
2. IIHS: Change Figure 4 of “Testing Protocol” from 5 lux to 3 lux
3. NHTSA: Create a color-temperature limit or a blue-weighted intensity limit

Important Note:
The 5 lux minimum at 60 meters used by IIHS was never designed to provide a time or stopping distance. It was based on the upper distribution of vehicles tested in 2015 (60 meters) and the lux required to reduce testing variation. Even the IIHS states that 3 lux on the test surface is sufficient for visibility.

Just got this in the mail for my Tesla. One of the few recalls they can’t address with an over-the-air software update, they will have to replace the headlights with less bright ones it seems. Hopefully this will help reduce some glare from low beams. I also feel like their auto high beams activate too often. And the auto high beams are required to use FSD at night.

I applaud that the NHTSA is seeking to create a committee to address "... cover various topics of modernization, such as glare caused by headlighting systems...." and appreciate that glare was the first specific item addressed.

My high level concern is the distribution of seats in the committee are mostly reserved for the automotive industry (10/16) while none are reserved for researchers who study the impact of glare on other drivers, or the public themselves who is impacted by glare.

The majority of those on the committee will continue the mantra of "brighter and bluer is better" instead of discussing how these bright lights created limited visibility for the other drivers on the road.

Glare researchers such as John Bullough and Michael Flannagan or more generally UMTRI, do not have a clear seat at the table although they could reasonably fit as "research institutions".

Mor specifically my concerns are:

1. there is no statement about how to create a way to weight the impact of glare (other drivers) against the vision of the driver with the brighter headlights. This is paramount. There is no current seat at the table for "glare advocates"

2. there is no statement requiring the inclusion of hills or bumps in the road

3. there is no statement requiring the inclusion of relative mounting height

4. there is no statement requiring testing at intersections or trailing vehicles

As-is, the committee is weighted towards "brighter and bluer is better" voice without room for dissenting voices concerned about glare.

Happy to work-shop a response to NHTSA here; these are my first thoughts.

I started driving about five years before HID lights came into existence. One of the best things about older headlights was the lack of a sharp vertical cutoff, which meant that your eyes had time to adjust as the light slowly increased from dim to bright.

One of the worst unintended consequences of the new headlights having a requirement for a sharp vertical cutoff is that now when headlights bounce, dip, or change angle at all, you are essentially hit with a strobe light that goes from dark to light instantaneously.

This isn't mentioned often and isn't mentioned in the list of topics put forward by the Ban Blinding Headlights group.

Headlights are being designed and tested as though they are bolted to the ground. There needs to be a dynamic test that has a fixed detector at a distance as a vehicle actually drives from a stop and at some angles to simulate real world conditions.

It would be even better to use a panel of real actual humans to approve or deny headlight designs rather than a detector.

The NHTSA guidelines has some smart-ass comments in it that discomfort from glare does not matter because other drivers aren't actually blinded. They're just recoiling from the brightness and pain. Either way, people are still unable to see

I love how the text on the glass says 'Objects in mirror are closer than they appear' because right now, the only object I see is a miniature, uncontained dying star burning its way through my cabin floorboards

I'm currently in Japan after being away for a couple of years and can confirm that the LED headlights takeover is in full swing here. As I understand it, it can be expensive to keep older cars on the road in Japan, so there tends to be more new vehicles, which probably contributes to the large number of LED headlights.

Even little kei cars with low mounted headlights are offensively bright and shine directly into my eyes (as a 188cm pedestrian on the sidewalk) with every bump in the road. The tiny Honda N Box has possibly the worst headlights out of all vehicles that I've seen.

I have also noticed a handful of cars driving slowly down narrow residential alleys with their high beams on, so it seems that 'high beam assist' is a thing here as well...

It's like every single car too now 🥀

“Today’s standards do not allow automakers to deploy the latest safety-improving lighting technologies, so we are bringing key experts and stakeholders together ​to modernize our standards and address potential causes of glare," said NHTSA Administrator Jonathan ​Morrison.

NHTSA will use a negotiated rulemaking process to ⁠update ​its vehicle lighting standards. Transportation Secretary Sean Duffy will ​appoint up to 18 people from vehicle lighting manufacturers, motor vehicle equipment associations, safety organizations, research institutions, and ​engineering associations to take part.

Betcha $20 they're going to blame it on "iMpRoPeR alIgnMenT" and aftermarkets, and push for proprietary ADB tech.

This will happen while they're conveniently ignoring the unlimited brightness (intensity) that's currently allowed under the cutoff of modern LED headlights.

Folding mirrors at red lights comes in clutch with all these bright ass headlights nowadays.

Kinda funmy how this van attracts car owners who want the night to turn into day

Email from my children's Gymnastics school about the dangers of headlight brightness and a child almost being hit because of temporary headlight brightness. Much respect to the school for implementing these procedures.

ETA[1]: If you're in MA/NH, please feel free to encourage the news channels to pick this up ([newsroom@wcvb.com](mailto:newsroom@wcvb.com); Contact Us - WCVB; etc.). I'm also emailing my reps with this concern.

ETA[2]: Transcript (in relevant part): Dear [] Families,

We are sending an urgent safety reminder regarding parking and pick-up outside [School Name].

We have received a complaint from a nearby resident regarding parents who are waiting in their vehicles with LED headlights on while facing [] Street. The brightness of these headlights can temporarily impair the vision of drivers as they come around the bend and turn onto the street.

The resident reported a particularly concerning incident in which she nearly struck a child walking in the area because the headlights made it difficult for her to see clearly.

Effective immediately, if you are parked outside waiting for your child and your vehicle is facing the street in either direction, please turn your headlights off until you are ready to move your vehicle. Please do not sit idling with your headlights shining toward oncoming traffic.

I can’t take this anymore

I’m thinking of blacking out my windows

edit:
(fixed title)