NHTSA Complaint #11419800 — 2018 AUDI A5

On the dark evening of 23 January 2021 a deer from the side of the Ohio Turnpike came onto the edge of my lane of roadway, did a Uturn and kicked the front fascia of my car. I slowed but couldn’t avoid the collision because of NHTSA rule Federal Motor Vehicle Safety Standard (FMVSS) No. 108. I did not see the deer in time to slow further, which would have allowed emergency maneuvers. If I was driving this same car in Europe, or Canada or Japan, I would have Adaptive driving beams on my vehicle. There is often only seconds to act at night, at speed and the glare from oncoming drivers contributes to this lack of safety on American Roads. NHTSA has allowed Tesla to experiment with unproven technologies such as ‘AutoPilot’ on American retail vehicles, with LIDAR/RADAR, cameras, software and now the removal by TESLA of the LIDAR/RADAR functionality, which, allegedly, has resulted in deaths of drivers on US roads. However, NHTSA has been negligent by delaying passage of revisions to FMVSS 108 to allow ADBs on US Roads, a proven safety technology in the EU and around the world, requested by Toyota and MB and other manufacturers in 2013 and since. This is inexcusable on NHTSA part. This either represents incompetence or negligence on NHTSA part, since there has been insufficient regulatory revision in eight years! As a former Emergency Medicine Physician and now Radiologist who has traveled to Canada and the EU, and having cared for patients injured at night in vehicle crashes, as well as being involved in my own that could have been prevented, I can not understand the delay by NHTSA of eight years to complete this approval when the overwhelming evidence proves the technology of ADB not only safe and effective but enhancing safety of all concerned, including pedestrians. Here is a link to the most recent article supporting this proven technology: https://www.msn.com/en-us/autos/news/we-need-to-legalize-adaptive-driving-beams-already-for-safety-s-sake/ar-BB1gUAhR