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Go, Dan, go! Glad to hear you are taking this issue seriously and working in the system to make things better
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I just got done with a 3+ year stint as an administrative law judge and I know how glacially slow it is to get any kind of regulatory changes made.
I explained at some length in a keynote speech a few years ago how we wound up with NHTSA effectively unable to regulate car lights in the USA at more than a basic, lax level.Quote:
I am doing my part to reduce glare by running non-LED headlamps for as long as possible.
This right here is the nub of the problem: as we age, we need more light to see any given thing, and at the same time we grow more sensitive to glare. And "Hey, the headlamps on this model won't piss off other drivers as much as headlamps on other cars" is not an effective sales pitch. It is effectively impossible to point to a particular spot on the seeing light/glare light tradeoff and go "Right there! There's the perfect balance!". For decades, the European regulations (which are now the UN regs, which most of the world uses outside the North American regulatory island) have placed a much higher priority than the US regs on glare control. The EU/UN low beam specification allows less glare toward oncoming drivers (though it allows much more upward stray light --> backdazzle in bad weather) than the US specification. Periodic vehicle inspections are a fact of life in most of the rest of the world, during which headlamp aim is checked, and aim is routinely set lower than in the US/Canada. More vehicles in the rest of the world have automatic headlamp levelling systems to keep the beams down despite vehicle load. Etc.
But glare compliants are sharply rising not just on the American regulatory island, but even in countries with much more stringent glare regulations. That points at unregulated factors common around the world: smaller, brighter, bluer.
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Maybe they can tackle the obnoxiously bright LED taillights, too?
That's another problem. The same stylists and marketers who demand tiny, slim headlamps demand tiny rear lights, too, and what the stylists and marketers want, they get—no matter what the engineers and scientists say. The US/Canada regs require 50 square centimetres (=7.75 square inches) of lit area for each rear turn signal and each brake light. That rule was enacted specifically to avoid high luminance that would cause glare when you're stuck in traffic staring at the lights at close range. No such rule applies elsewhere in the world, but the intensity limits are lower for rear light functions, too, which helps with the glare. Here on the we're-right-and-the-stupid-rest-of-the-world-is-wrong American regulatory island, automakers started bending that rule awhile back: a tiny little ultra-bright brake light, but they'd also turn on the bigger taillight whenever the driver stepped on the brake, and claim the total lit area of [brake + tail] as their 50 cm2. That is a bad-faith move—it's not what the rule intended—but NHTSA never spanked any of them, so now they don't even bother with the taillight trick any more. Tesla Model 3 (maybe 7 cm2 if we're generous), Toyota RAV4 and Lexus NX (maybe 10 cm2, maybe), and a whole lot more. NHTSA stares at the sky and goes "Huh, looks like it might rain".