DRL Petition Cover Letter

Lane Courtesy

August 26, 1997

Ricardo Martinez, Administrator
National Highway Traffic Safety Administration
400 Seventh Street SW
Washington DC 20590

Dear Mr. Martinez:

The attached petition for rule making is being submitted on behalf of the National Motorists Association, a national membership based and funded organization, representing the interests of motor vehicle operators and owners.

Over the past several years, there has been increased public and commercial promotion of daytime headlight use which has culminated in the manufacture and sale of vehicles with hard-wired Daytime Running Lights (DRLs). Touted as a "safety " measure, the widespread use of headlights during daylight hours, as well as the growing population of DRLs, has once again stimulated the law of unintended consequences.

It is worth noting that the reported increase in hostility between motorists ("road rage, aggressive driving, etc.") corresponds with the increasing use of daytime headlight and DRL use and the complaints we receive from members (who express irritation and aggravation related to glare and visual clutter). Other complaints related to DRLs and daytime headlight use include: the masking of directional lights, DRLs being used in place of headlights during hours of darkness and periods of low visibility (when tail lights should also be lighted), and distance perception confusion. Our petition outlines additional negative elements of daytime headlight use and hard-wired DRLs.

In reviewing the "studies" that supposedly justify the safety benefit of DRLs, there appears one consistent pattern, inconsistency. There is a remarkable absence of any serious consideration to the "novelty effect" of DRLs or their possible negative effect on other highway users.

We believe the continued and expanded use of DRLs is a wasteful and counterproductive practice that should be discouraged through vehicle equipment standards and public education programs. The novelty effect of DRLs may moderately reduce accident involvement, in the short term. However, when DRLs are commonplace, they will simply become part of the background visual clutter and quite possibly reduce the conspicuity of non-DRL-equipped vehicles and pedestrians.

An appropriate analogy is the effect of when one person is standing in a crowded theater, that person is readily seen by others in the theater. But, when almost everyone in the theater stands, no one stands out, and the people who remain seated are not visible at all.

The promotion of DRLs and their appearance on vehicles in the U.S. market is largely the result of certain manufacturers trying to harmonize their product lines in response to misguided public policies in non-U.S. markets. It is our position that the negatives, ranging from wasted fuel resources to motorist aggravation and increased accident risk for other highway users, argues against the proliferation of DRLs and their variants. We are not dismissing the utility of daytime use of headlights for very specific purposes and during periods of reduced visibility. However, we believe the advantages of headlight use during daylight hours will be undermined by the proliferation of hard-wired DRLs.

On behalf of the members of the National Motorists Association, I ask that you give our petition prompt attention and that you formulate proposed rules that implement our recommendations.

Sincerely,

James J. Baxter
President

On the same day, a copy was also sent to:

Rodney Slater, Secretary
U.S. Department of Transportation
400 Seventh Street SW
Washington DC 20590

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The NMA's Position

The NMA opposes the installation of "hard-wired" daytime running lights (DRLs). The operator of any vehicle should be able to activate or de-activate all exterior lights on that vehicle, including motorcycle headlights. The NMA also advocates education programs that encourage headlight use only when visibility is poor.