2022 Hyundai Venue

I am writing to respectfully request that the National Highway Traffic Safety Administration (NHTSA) consider adopting a Federal Motor Vehicle Safety Standard requiring vehicles to provide a clear driver alert when headlights and tail lamps are not illuminated in low-light conditions. Although many vehicles offer automatic headlights, these systems can be disabled without the driver’s knowledge when the physical headlight switch is moved from “AUTO” to “OFF.” This may occur during routine servicing, inspections, car washes, or detailing, and the vehicle provides no notification that the automatic lighting has been disabled. As a result, even conscientious drivers can unknowingly operate a vehicle without proper illumination at night. A recent incident involving my daughter illustrates this concern. She always keeps her headlights set to “AUTO,” and she is aware of the importance of nighttime visibility. However, after a state vehicle inspection, the inspector had manually turned her headlights to the OFF position. She later drove at night with the expectation that her automatic lighting system was functioning and subsequently received a warning ticket from law enforcement for not having her headlights on. The vehicle provided no warning whatsoever that the headlights and tail lamps were not active. Additionally, modern dashboard lighting systems automatically illuminate when ambient lighting decreases and may dim in the evening, which strongly implies to the driver that the vehicle’s exterior lighting is active. At the same time, daytime running lights illuminate the front of the vehicle, while rear lights remain off. From the driver’s perspective, the road ahead appears lit, and the interior displays reinforce the assumption that lighting is fully engaged. This creates a false sense of proper lighting and is misleading from a human-factors standpoint.