Interpretation ID: nht90-2.49

TYPE: Interpretation-NHTSA

DATE: May 22, 1990

FROM: Bob Abernethy -- Idea's Inc.

TO: Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-7-90 from P.J. Rice to B. Abernethy (A36; Std. 108)

TEXT:

I realize that a change or deviation from Standard # 108 is like changing the Constitution. However, some technical data could aid in your decision. This may be obtained from the Electrical Testing Laboratory.

I have written a proposed variance in your Standard # 108 in my letter to you dated 3/21/90. However I am not accustomed to a committee response.

Enclosed "REGULATION AT ITS BEST" from Automotive Engineering magazine stating the benefits of high mounted stoplamps. Please think further by changing this to an analog response.

If you need further assistance or information, feel free to write; or call me at my new number.

Enclosure

Editorial "Regulation At It's Best" Regular readers of this page will recall that, on occasion, I have criticized the Federal government's regulation of various aspects of the automobile and the automotive industry. So I think it's only fair to pay a compliment to the regulators in Washin gton when they produce a regulation with a clearly outstanding cost-benefit ratio. I refer to the FMVSS No. 108 amendment which requires new passenger cars to be equipped with a center high-mounted stoplamp beginning on September 1, 1985.

At the first of this summer's crop of long-lead press previews, I made it a point to follow as many cars as possible which were equipped with this center stoplamp. Even in bright sunlight I found it remarkably effective in getting a driver's immediate a ttention, alerting him to the braking of the car in front. Although I didn't get a chance to try it at night, I imagine it's all the more effective then. Some of its effectiveness may be due to the fact that it's brand-new, I admit, but even after the driving public has become accustomed to it there should be a significant net gain.

SAE Paper 851240 by Digges, Nicholson, and Rouse, titled "The Technical Basis for the Center High Mounted Stoplamp," says that "The long run costs of the center stoplamp are estimated at about $4 per car. The property damage reduction for a complete fle et equipped with these lamps is estimated at $434 million per year. Comparison of the long run costs and

the property damage savings produces a net benefit of almost $400 million per year."

The paper goes on to say that "Field tests have shown that the center high mounted stoplamp is about fifty percent effective in reducing relevant accidents. Based upon analysis, NHTSA estimates that on the order of 900,000 accidents per year would be av oided, and 40,000 injuries would be reduced."

Is this an example of Federal regulation at its best? It think it is, and I tip my hat to the people at NHTSA who produced it.

Larry Givens Editor "Automotive Engineering" July 85 Volume 93, Number 7