Richard, I have read all the info in the links provided by you in the other thread. As a lighting enthusiast, I am worried, and driven by curiosity as to the future of HID.

1) Does the NHTSA believe it has enough facts and evidence to give validity to complaints in recent news reports on OEM HID, not retrofits or other kits.

2) Is there a possibility, based on these fact finding studies that the agency and others have conducted, that OEM HID will be banned as the news reports would want?

3) Has the agency considered that counter-petitions supporting HID probably go unnoticed unless discussed in these forums and probably outnumber the 7000+ complaining letters the agency has received?

I know this message was addressed specifically to an individual, but I couldn't resist.

I don't think a outright ban is possible. HIDs have been available as OEM options from Auto mfgs for almost 10 years now. Even with "grandfathering" existing HIDs and arbitrarily banning further installations as an OEM option, there are too many legal HIDs left on the road today to make such an effort to rid the alleged "glare" caused by them.

As I've stated earlier, I'm reminded of what my driving instructor beat into our heads 30 years ago:

IF SOMEONE APPROACHES YOU WITH THEIR "BRIGHTS" ON (producing an offending glare), DON'T LOOK AT THE LIGHTS. AFFIX YOUR EYES TO THE LANE STRIPES UNTIL THEY PASS.

You wrote: "Richard, I have read all the info in the links provided by you in the other thread. As a lighting enthusiast, I am worried, and driven by curiosity as to the future of HID.

"1) Does the NHTSA believe it has enough facts and evidence to give validity to complaints in recent news reports on OEM HID, not retrofits or other kits.

"2) Is there a possibility, based on these fact finding studies that the agency and others have conducted, that OEM HID will be banned as the news reports would want?

"3) Has the agency considered that counter-petitions supporting HID probably go unnoticed unless discussed in these forums and probably outnumber the 7000+ complaining letters the agency has received? "

1. Yes, NHTSA has stated so publicly many times in many venues.
2. OEM HID would appear to need additional performance requirements related to spectral energy density, beam pattern width, and intensity limits, that were never contemplated in any regulatory agencies' safety standards.
3. Counter petitions are just heresay. I have not seen anything that leads me to believe that there are any. NHTSA has received no such petitions. BTW, the number of responses to the docket are just over 5000, but in the last two years we have received other complaints that were not sent to the docket by the complainee. I estimate that there have been about 500 to 1000 of those. Essentially, those are all no different than the majority of complaints that are in the official docket.

Thank you for your reply Richard, I guess there will be more to come in the fight against HID, this time in the OEM front. I am very sorry, and hope that stiff action be taken against overwattage blue bulbs first.

Some people are fighting against HIDs, NHTSA is only trying to make sure that they don't do more harm than any other headlighting system. Its also quite possible, that headlighting performance has met a human physiology barrier that makes any higher performance publicly unacceptable. Only time and science will tell.

If you think that the public is concerned about HID, wait until we start having LED headlamps. Research so far infers that they will be perceived as even more glaring than HIDs.

that would be nice...LED headlamps that glare more...may help take the witchhunt off of HIDs and people might actually think the HIDs are better.

Heres another question Mr. 108.

Does NHTSA consider the fact that a generation gap exists, and the number of people complaining come from a generation whose eyes have been used to nothing but halogen lights for such a long time. Since political issues are mostly taken up by older people, and older people perceive glare more intensely, does NHTSA recognize this fact that complainers are older, glare receptive people?

Also, do you think that in time as the younger, more accepting crowd grows older, complaints will decrease?

Can you also comment on how the public took to the move from incandescent to halogen headlights?

Thanks!

If what you say is true about the generation gap (and it may well be) then it just shows how different things are in the US to Europe (specifically Germany) where some of the strongest supporters of HID are older people who's eyes are not what they used to be and find HID lighting on the cars they drive to be a lifesaver - sometimes literally.

Once again it looks like the US may once again lag far behind Europe in auto-lighting performance.

On the other hand, I wasn't around at the time but I believe that the backlash against HID happening now is similar to what happened when halogen lights first started appearing but everyone eventually got used to them.

The future of auto lighting is in increasingly accurate beam patterns and delivery mechanisms which will allow greater intensity to be used where it's needed whilst still avoiding the eyes of oncoming drivers. Also there will be infra-red and ultra-violet systems which, combined with a head-up display will far surpass anything you could do with conventional lighting.

HID in its current form may yet be relatively short lived.

Michael.

Ha!! complaints against halogens? what about all the hype about European cars with "square or rectangular" light fixtures that were not allowed in the U.S. until its own car manufacturers started making squared sealed beams?

"Ha!! complaints against halogens? what about all the hype about European cars with "square or rectangular" light fixtures that were not allowed in the U.S. until its own car manufacturers started making squared sealed beams?" That is pure BS. The reason is that they had no corrosion protection and their performance would begin to deteriorate upon delivery. It was not until all the manufacturers decided to solve that problem, that headlamps were allowed to be the unsealed, replaceable bulb design.

"The future of auto lighting is in increasingly accurate beam patterns and delivery mechanisms which will allow greater intensity to be used where it's needed whilst still avoiding the eyes of oncoming drivers." That cost money, and unless goverments madate it only the rich will have it. Also, try proving that it is legally necessary. Wish I could. If you had been working in the automotive lighting industry for the last two decades, you would know that what you want is not practical and will never happen. Yes, adaptive frontal-lighting systems might be able to do that, but what vehicle owner is going to pay the big bucks, Euros, or yen to save the other guys eyes? Ain't gonna happen unless its mandated, and no one can prove that it would make roads safer and give greater value to the public than it pays.

"Does NHTSA consider the fact that a generation gap exists, and the number of people complaining come from a generation whose eyes have been used to nothing but halogen lights for such a long time. Since political issues are mostly taken up by older people, and older people perceive glare more intensely, does NHTSA recognize this fact that complainers are older, glare receptive people?"

Yes, older drivers are becoming the majority on the road. Are you suggesting that they be neglected in the search for finding better lighting?

"Also, do you think that in time as the younger, more accepting crowd grows older, complaints will decrease?" No, it is their eyes that change to become more affected by glare, not their attitude.

"Can you also comment on how the public took to the move from incandescent to halogen headlights?" Only a decade, but in that situation, the light was only whiter. With HID and LED, you have grossly uneven spectral energy density plots, compared to incandescent or halogen incandescent. Unless that is resolved, glare complaints will never stop. Even you will complain as you get older and you eyes evolve to have clouding, floaters, less dynamic range, and etc.

Richard, I wonder if the public is educated enough to be able to tell the difference between overwattage blue bulbs and OEM HID. There is no comparison to a textured reflector housing with a standard halogen and a well adjusted OEM Xenon projector. Even the more efficient free form reflectors with standard halogens produce more glare than OEM HID projectors with standard halogens.
Of all the letters that the agency received, many specifically stated HID was glaring, but I wonder if the complainees are right or mistaken.

"Richard, I wonder if the public is educated enough to be able to tell the difference between overwattage blue bulbs and OEM HID. There is no comparison to a textured reflector housing with a standard halogen and a well adjusted OEM Xenon projector. Even the more efficient free form reflectors with standard halogens produce more glare than OEM HID projectors with standard halogens. Of all the letters that the agency received, many specifically stated HID was glaring, but I wonder if the complainees are right or mistaken." Who cares whether it is blue overwattage or HID, both problem should be resolved.

Richard answered:

"Who cares whether it is blue overwattage or HID, both problem should be resolved."

Wouldn't you say there is a big difference? one is fixed to an unadjusted reflector which per se produces more glare. OEM is professionaly fitted mostly in projectors by competent car manufacturers. Also, blue overwattage can be had for cheap and are probably more widely used and it is probably the number one cause of all the complaints that the NHTSA has received.

Mr. 108 wrote, "If you think that the public is concerned about HID, wait until we start having LED headlamps. Research so far infers that they will be perceived as even more glaring than HIDs."

Yeah, I can hardly wait for that, since I find the (illegal, of course) windshield wiper LEDs annoying NOW. When you get 50~100 of those things bouncing off of a reflector, I believe that all hell will break loose, with some people actually shooting the lights out of cars that have those things.

I actually disagree with your statement. LED's will yield less glare IMHO. You can make them extremely directional (5-10 degrees) as well as possibly designing a projector type housing for them.

Danny wrote, "I actually disagree with your statement. LED's will yield less glare IMHO. You can make them extremely directional (5-10 degrees) as well as possibly designing a projector type housing for them."

The directional aspect of LEDs is fine, but that's not the problem(s). The problem comes in when you try to produce the required "white light". Two ways to do this; white light LEDs, or an array of LEDs with different colors. Currently, white light emitting LEDs don't have enough punch (that could change) for an LED headlight to be cost-effective, since you would need an impractical quantity in each fixture to get acceptable light output. The multi-colored approach to produce the various parts of the visible spectrum will produce something that looks like white light, but isn't. Without some very clever optical work (I won't hold my breath on that), the light output will be stratified, with the same problem caused by HIDs, in that it affects the eyes of many people that are sensitive in the blue frequency range. When that stratified blue-frequency light hits the retina of the human eye, it will be absorbed up to 500 times faster than light of equal intensity longer wavelength (yellow, green, red) light. Even limited exposure to this stratified blue light will destroy some of the rhodopsin that's present in the eye's macula. The end result of this is that the "target eye" temporarily (hopefully) loses almost all night vision, effectively blinding the driver of the target vehicle. This night blinding will last anywhere from a few seconds to a minute or more depending on the target eye's ability to manufacture more rhodopsin to replace that which was destroyed by the blue frequency light absorption (older takes longer). Scientists know this, ophthalmologists know this, and I'm sure there's someone at the light makers and lighting regulators headquarters' that know this. The upshot of the whole thing is, if these LED based headlights aren't done correctly, people will start to become temporarily blinded by poor implementations of LED headlights, and nighttime car crashes with attached lighting causality will become more common than they already are.

"I actually disagree with your statement. LED's will yield less glare IMHO. You can make them extremely directional (5-10 degrees) as well as possibly designing a projector type housing for them."

See my response to Ed, below, about LED headlamps.

"Mr. 108 wrote, "If you think that the public is concerned about HID, wait until we start having LED headlamps. Research so far infers that they will be perceived as even more glaring than HIDs."

"Yeah, I can hardly wait for that, since I find the (illegal, of course) windshield wiper LEDs annoying NOW. When you get 50~100 of those things bouncing off of a reflector, I believe that all hell will break loose, with some people actually shooting the lights out of cars that have those things."

HEY (shouting), THIS JUST IN:

UMTRI-2003-39 November 2003 "LED Headlamps: Glare and Color Rendering" Sivak, M., Schoettle, B., and Flannagan, M.J., The University of Michigan Transportation Research Institute
2901 Baxter Road
Ann Arbor, Michigan 48109-2150 U.S.A. for the Industry Affiliation Program for
Human Factors in Transportation Safety.
Abstract:
Because of rapid improvements in the light output of light-emitting diodes (LEDs), serious
consideration is being given to using LEDs as light sources for headlamps. This study examined
the potential effects of LEDs on discomfort glare for oncoming drivers and on color rendering of
retroreflective traffic materials. In both cases, the effects of LED light sources were compared to
the changes in these properties that occurred when the traditional tungsten-halogen light sources
were replaced with high-intensity discharge (HID) light sources. Specifically, the effect on
discomfort glare was estimated by comparing the chromaticities of 7 LED light sources
(considered for use in headlamps) with the chromaticities of the light sources from 17 actual HID
headlamps. Analogously, the effects on color rendering were estimated by comparing the
chromaticities of 46 retroreflective materials when illuminated by the LED light sources with the
chromaticities of the same materials when illuminated by the HID light sources.
The main findings concerning the range of LEDs that are currently being considered for use
in headlamps are as follows: (1) Headlamps using LEDs with the chromaticities examined here
are predicted to lead to more discomfort glare than the current HID headlamps, and substantially
more discomfort than tungsten-halogen headlamps. Keeping the correlated color temperature as
low as practicable is likely to minimize the problem. However, the relationship between spectral
power distribution and discomfort glare is not fully understood, and further research on this issue
would be valuable."

Mr. 108, aka R. Van Iderstine, quoted an excerpt from an UMTRI study:
"(1) Headlamps using LEDs with the chromaticities examined here are predicted to lead to more discomfort glare than the current HID headlamps, and substantially more discomfort than tungsten-halogen headlamps. Keeping the correlated color temperature as low as practicable is likely to minimize the problem. However, the relationship between spectral power distribution and discomfort glare is not fully understood, and further research on this issue would be valuable."

I don't know that it's necessary to be "fully understood", since causality between certain types of Cancer and smoking is not "fully understood", yet the wise course of action is to stop smoking to improve the odds of NOT getting Cancer.

As far as the causality between spiked SPD and eye discomfort goes, it's easily demonstrated with simple lab equipment consisting of; a regulated power source, a few LEDs of various colors, an old headlight reflector, and a few observers. Give it a try; if I can do it on my budget, you should be able to manage it with yours! Also carefully re-read my response to Question 22 on Docket 8885-3960. When the stratified "blue" spikes hit the human eye (in some people), it's as if they were jabbed there with the proverbial "red-hot poker", causes temporary night blindness via destruction of rhodopsin, and triggers migraines in some more-susceptible observers. These effects are minimized with homogenous (halogen) light, since the pupils respond to the TOTAL visible light spectrum input based on actual brightness (glare, intensity, lumens, whatever) and adjust accordingly.

Sure, but does any of that cause crashes? If you can prove it, you should work here.

"Sure, but does any of that cause crashes? If you can prove it, you should work here."

If you have drivers being temporarily night-blinded while traveling at 88+ fps, don't you believe there's crash causality there? Work? Been there, done that!

ekooke,

where did you learn that this stratified blue light destroys rhodopsin and creates migrains in some people? Sounds like an interesting tid bit of knowledge. Id like to see its physiology since I just had a course in neurology.

I dont see most ligting as causing a washout in vision or lots of spots. Usually the light only last momentarily and it takes an amount of light with a duration taht overcomes the ability of the eye to constrict the pupils.

H1HID,
I've given you the Site for the rhodopsin thing before. See:
http://www.neuroscience.unizh.ch/e/groups/reme00.htm
The migraine headache evidence is the result of an analysis of headlight & other automotive lighting complaints that I've compiled over the last several years, from the NHTSA dockets & other sources.

Ekooke,

i dont believe that you have given me this link before. Its not in my bookmarks, and trust me I have tons of bookmarks. Plus this info im reading is all new to me. Knockout mice for the study rhodopsin is something new im hering. It is pretty cool that they can create these gene knockout mice and have actually identified that these guys lack rhodopsin.

"To induce light damage, photons have to be absorbed by rhodopsin leading to its activation. Using different lines of transgenic animals, we showed that at least two pathways of photoreceptor apoptosis might exist: Wheras one pathway activated by acute exposure to high photon dosis is not dependent on phototransduction, a second mechanism seem to depend on a functional phototransduction system. "

I see that some people respond to acute dosis of high photon absorption damamge. I wonder exactly they consider high dosage and is the dosage of blue wavelength in HIDs and LEDs significant enough to stimulate apoptosis. It really sucks for those that have phototransduction induced apoptosis. This means seeing blue every time(but they dont really go into detail here) causes apoptosis after the conversion of light energy into electrical stimulus.

you know what i just realized something. Rhodopsin is found in your rods. How does one visualize color and lose black and white photopigment. maybe it could be the eye responding to a dominant stimulus and eliminating functional proteins that do not aid in its visiualization. anyways, thanks for the link bc this really is the first time im reading this.

H1HID,
The germane paragraph to understanding the temporary night-blindness effect (via rhodopsin destruction) is here:
"A second approach towards the understanding of light-induced photoreceptor apoptosis investigates mechanisms of spectral dependence of light damage. Blue light (403nm) very efficiently induces apoptosis, whereas green light (550nm) does not. Although rhodopsin is being bleached by both blue and green light, rhodopsin exposed to blue light can absorb at least 500 times more photons per time than in green light."

thats kind of a jump Ekooke,

how are you so sure that apoptosis is that quick, as in situations like a cars headlights flashing in your eyes. Apoptosis from my understanding doesnt jsut cause your cells to instantly die. Its usually some sort cellular signal via a second messenger pathway. The lady never once talked about the correlation of temporary night blindness. I think thats ur inference. I clearly do not see that as the lady here is resarching AMD and Retinitis Pigmentosa, both of which lack acute symptoms and are exhibited chronically. I think you are taking her research to a different level and one that doesnt seemed to be based on her true impetus for research. She is researching ways to trigger the stabilization of the retinal cells through proteins like Erythropoetin whcih is the same chemical that is being fervently made in people who live in higher altitudes to prevent hypoxia. This release from the kidney is slow, as is the apoptosis of retinal cells. the reason that age related macular degeneration takes a long time to exhibit is because...well its age related. Doesnt occur instant thats for sure.

H1HID,
I wasn't implying that brief exposure to blue-frequency light leads to apoptosis (although long-term, it may), merely that light in that range is absorbed up to 500 times faster than longer wavelength light. It's my belief that when stratified SPD light in the 400-angstrom wavelength hits the human eye, the pupil doesn't have time to react or possibly even recognize the light as such. The result is that either the rhodopsin is temporarily neutralized (bleached) or the macula is just plain overloaded; in either case the optical receptors are temporarily shut down, i.e., blindness. If you're really interested in this phenomenon, I suggest that you try the experiment that I outlined on December 5 2003, 2:28 PM, this thread. Do it in a near-dark room, so the eyes are dark-adapted, then you may begin to understand my concern on this matter. Don't look at the blue LED too long.

ohhh,

it was odd b/c i read the paragraph with the wavelengths that you brought to my attention and it dealt mainly deals with apoptosis especially the first two lines. Furthermore, it talks about bleaching of rhodopsin from blue and green wavelengths with more polarity towards blue. However, with what intensity, with what duration? Theres really no experiemental details given, just a simple abstract. The research here is nothing to base anything on I suppose even if there is a 500x absorption rate. I dont think staring a blue LED will really demonstrate to me a correlation between headlights and temporary nightblindness (that is the topic right) since HIDs and im sure LED headlamps will be a much more homogenous than this. Also, duration and intensity seem to be key factor here. Im considering blue to be the noxious stimulant and like any "drug/stimulant" one must find the dosage at whcih it provides this noxious reaction. A solid blue LED is like me giving you 10,000mg of a drug so that we can figure out whether its bad for you or not. This is how pharmacology workd. Find the source of the problem, what dosage does it require to make it effect, how long does it need to be in system to make its effect, is there a threshold? Staring at one particular wavelength doesnt seem to quite correlate to night blindness. It does discover that yes blue can cause but at what dosage/intensity and for what duration.

I am also unaware of your eye being dilated while driving at night. Staring at any bright light (headlights on the ground) will mediate pupillary constriction more so than dilation.

All in all im having trouble correlating this ladies research abstract to anything pertinent with night time driving. I have no idea how long this lady tests 400nm on the eye, what intensity, etc. I mean if i simulate a car flashing you from a distance head on (the premise is that headlights arent glaring 100% while coming towards you...but in a periodic motion) would this cause the bleaching of the rhodopsin? I mean to say yes or no really isnt founded unless you have some other experimental data. Its a very interesting theory but i think it jumps too quickly from one theory to another b/c theres too many other physiological aspects that are undefined. When i have time ill break out my neurology book and they have about 100 pages dedicated to the eye. Im sure it may have some aspect that clears this matter up.

"Sure, but does any of that cause crashes? If you can prove it, you should work here."

Ed, you said: "If you have drivers being temporarily night-blinded while traveling at 88+ fps, don't you believe there's crash causality there?"

Sure, but I can't prove it. That's the rub. No proof, no amendment.

Then you said: "Work? Been there, done that!" Yea, I can retire; maybe I should. But I got a 15 y.o. daughter who wants to go to George Washington University next fall to be a physician. Then a son to follow at University of Maryland in five years. I quess I'll be at least 62. Then I can say that, too!

OT a bit: What do you guys think the long term effects of my interior lights will could? I don't notice any effect on my night vision, but they are not directed into my eyes per-se. They are backlit with Blue LEDs at 470nm. Their output is rated at 1500mcds, but only about 30-50% is comming through the button windows.

"OT a bit: What do you guys think the long term effects of my interior lights will could? I don't notice any
effect on my night vision, but they are not directed into my eyes per-se. They are backlit with Blue LEDs at
470nm. Their output is rated at 1500mcds, but only about 30-50% is comming through the button windows."

Not really OT. The blue is "cool looking" but you'd probably have just a bit better night vision with red backlighting (like a Mazda). I've already changed my blue high beam indicator light out with a red one, and I'll be doing my other vehicles the same way soon. I also drive at night with the instrument lighting turned way down, so I barely see the gauges; on a long night trip, it helps.

the blue wont bother you. Seriously, the modification of your interior lights to aid your night vision is starting to get a little crazy. I understand its purpose in military vehicles (red for reducing the chanign of your eyes from light to dark pupillar reaction, etc.) but I high doubt that a few blue lights will ever hinder anything in the long run. But thats my opinion.

Thanks for the response guys.

Wow....you guys are all getting so technical...especially dealing with LEDs, blue wavelengths, maculas, rhodopsin, etc...Should I chip in? What do you think, H1HID?