Coffee Brake: The Amber Turn Signal

This is Coffee Brake, DT’s weekly black hole of somewhat automotive related nonsense.  Back in the day when government agencies asked for public comment, the result was to some extent a joke.  Sure, if you knew the right people, lived in the correct town, you might be able to show up at some hearing or submit a letter, (or better yet, if you were a lawyer you could do something) but for the most part business went along as usual.  The internet has changed all that, and now when a goverment agency asks for feedback, they will darn well get some.  Take, for example, when the National Highway Traffic Safety Administration (NHTSA) drafts its latest regulations, they put up a notice on regulations.gov for public comment.  You might will notice that it has gotten 20 comments, some of which are well written and persuasive, particularly a note written by a former Volvo engineer named Karl Donina.

Karl writes:

I am writing to provide perspective on the rear turn signal color. I was
with Volvo in the 1960s and -70s mainly with vehicle and equipment
specifications for the various regulations and market needs in North
America. Before the advent of Federal Motor Vehicle Safety Standards,
this meant specifying the vehicle configurations so they met all state
standards. At that time, many state standards specified red for rear
turn signals, but when FMVSS 108 came in for the 1968 model year and
superceded different state standards, yellow became an allowable color
nationwide. Volvo switched almost all US models immediately (the
exception was the 1800, which was switched to yellow when the new 1800ES
model came in 1972) because a yellow rear turn signal was more
conspicuous and less ambiguous, and Volvo was pursuing a safety-first
philosophy. This was not done as a cost-saving or parts-consolidation
measure. There still had to be US-specific rear lamp assemblies because
of different photometric requirements for SAE versus the European ECE
standards. The difference between the ’67 and ’68 models was just a
different color of plastic for the turn signal portion of the
multi-function rear lamp assemblies. There was no cost saving or
penalty. From 1968 until this year, Volvo used only yellow rear turn
signals in the US.

Now this year, the new XC-90 came out, with
red rear signals as described on https://tinyurl.com/hsw9ojk (see
attached). After I went and confirmed this is in fact the case —
despite a large rear lamp with ample room for a US-size yellow rear turn
signal, they have chosen to use red — I wrote to Volvo expressing my
dismay about it. As you can see (attached), they basically blew me off:
Get lost, buzz off, they’re winning awards with the XC-90. Look at their
claims that the XC-90 is “the best of what Volvo has to offer” (No, the
rear turn signals are not the best, and Volvo knows it) “the beautiful
design” (which apparently takes precedence over optimal crash avoidance
through yellow turn signals Volvo chose for safety reasons almost half a
century ago) and “exceptional safety features” (except for the
demonstrably inferior turn signals).

Clearly this is how makers
see it: red and yellow are equally as legal, so it’s an ornamental
feature like paint color or the wheel styling or the typeface on the
nameplates. Car buyers who know and care about the difference are left
out in the cold — the makers clearly don’t care because they don’t have
to, and the level of follow-the-herd benchmarking in today’s auto
industry is such that they all pretty much copy what each other is
doing. This is true even as the industry has come right out and said
yellow (amber) turn signals do a better job, as GM did 17 years ago on
the GMC Yukon (attached, a GM press release archived at
https://tinyurl.com/p752kzc ). then they changed the Yukon back to red
with the next design refresh!

I went to the NAIAS Auto Show in
Detroit this past week, and was disappointed to see a big proliferation
of red turn signals. All Audis, all Mercedes, all VW, all BMW except the
low-volume i3 and i8, all Porschss, all have red. The high-volume Honda
Fit has switched from yellow to red. The high-volume Chevy Cruze,
yellow up to now, has been changed to red except the hatchback. Numerous
models from GM, Ford, FCA, Nissan, Honda, Toyota, Hyundai, Kia, and
other makes use red. Many of them are package-protected so they COULD be
yellow with a snap decision and scant or zero extra expense…maybe
it’ll be next year’s “facelift”? Appropriate policy should not let
safety devices be treated as ornamental playtoys.

There is no
effective mechanism for the consumer to demand things like yellow turn
signals. So I am encouraged to see NHTSA considering adding such a
mechanism, though I am discouraged to see it is such a weak and partial
one. Yellow rear turn signals are clearly better than red ones. There is
a lot of high-quality research, going back decades, showing this to be
the case, for just two examples see https://tinyurl.com/hgtpxs2 (UMTRI)
and https://tinyurl.com/ztqc7pw (SAE). There’s the practical crash-data
study NHTSA did in 2009, validating that research. Every other civilized
country and most developing countries have required yellow for many
years. Really, NHTSA should sunset the allowance for red rear turn
signals, not with a tentative half-step like this NCAP proposal, but
decisively and finally, for all vehicles starting from whatever
effective date.

I don’t seem alone in these views; please see
https://tinyurl.com/gpaprb3 and https://tinyurl.com/jb9peta and
https://tinyurl.com/htw9qaq and (closer to NHTSA’s home) https://tinyurl.com/z6zgl6x and comments at https://tinyurl.com/goe2yq2 .

Thank you for the opportunity to provide my perspectives, for whatever they might be worth in NHTSA’s process.

The argument about aesthetics versus safety has been settled (no more pedestrian spearing hood ornaments) and amber turn signals probably make more sense, so you have to wonder if the NHTSA is really cowing to the demands of Detroit designers, or if basic incompetence is more likely.  Regardless, you have through Feb 16, 2016 to make a comment of your own on the regulations.gov website. Tip of the hat to DCCarGeek on Oppositelock for finding the above comment from Karl.