Open letters to
and from Volvo Cars UK
|
Mr. Stuart Kerr
Managing Director |
e-mail: dadrl@btinternet.com |
|
Volvo Cars UK
Ltd. |
|
|
Globe Park |
|
|
Marlow |
|
|
Bucks SL7 1YQ |
02 October 2007 |
Dear Mr. Kerr,
Volvo Cars - a Danger at any Speed? Daytime Running
Lights (DRL)
We thank you
for your letter of 21 September, albeit
with a disappointing response, please may we respond with some facts
and figures.
Firstly, may we differentiate between headlight
DRL as used by Volvo and the low power non-glaring lamps proposed by
Hella and Philips in 1997.
As little as 6 watts of lamp power
(or LED equivalent) can be used
to produce an effective, wide-angle, long-distance, non-glaring DRL
that does not interfere with the vehicle's directional signals, does
not encourage improper use of the vehicle's primary lights after
dark, and has a long time between failures.
There is no objection to low power, non glaring
DRL switched on only when the light level falls below 100lux, the
effect upon fuel economy would be minimal and they would provide
potential gains in safety.
Secondly, may we make a number of other points:
1. Expecting DRL to compete with the power of
the sun or high ambient light levels of 40,000 to 50,000 lux (the
CIBSE recommendation for reading is 300 lux), will create a
‘visually aggressive environment' to other road users, including
other drivers, to the general aggravation of the difficulties of the
driving task, and to the general detriment of road safety.
2. It is the glare and distraction of headlight
based DRL that is the problem. Whilst they may be appropriate for
sparsely populated Scandinavian countries, in the densely occupied
UK (and most other European states) and at a time when Governments
are actively encouraging people to walk and cycle, headlight based
DRL mask vulnerable road users and cause increased accidents.
3. When Bulgarian officials expected a decrease
in accidents from daytime running lights, their 2006/07 experiment
tragically recorded increases (please see appendix 1).
4. The Austrian 2006/07 DRL experiment
(appendix 1) was associated with a 12.2% increase in accidents, the
overall toll was 24,850 injured (+11%) and 324 subjects died (+17%).
Significantly,
there was a disproportionate increase to vulnerable road users:
Children
+13%
Cyclists
2,814 accidents + 43 %
Motorcyclists
1,400 accidents + 46% fatalities + 51%
5. Whilst DRL may save a few crumpled car
bumpers for air bag cocooned occupants in a steel safety cage, I
think you must agree that the consequence of less visibility of
pedestrians, cyclists and motorcyclists to other drivers are
infinitely more serious.
6. Expert ophthalmic is forming solidly against
DRL, the recent publication of ophthalmic evidence by Professor Dr.
Peter Heilig University of Vienna includes topics on:-
Change blindness,
Inattentional Blindness, Sustained Inattentional Blindness, Motion
Induced Blindness (as demonstrated by Michal Bach's computer
simulation), Repetitive Blindness Overload, Disability Glare,
Capacitive problems of cognitive processes and Exceeding Critical
Intensities of Stimulation.
(please
see Appendix 2 for more details).
7. The current trend of manufacturers to focus
upon bigger and brighter headlamps in the name of driving safety is
folly. The HID metal halide lamps which emit a high proportion of
light at the eye damaging blue short wave end of the spectrum add
another undesired component.
8. Extremely bright blue-white light sources
cause prolonged retinal recovery times due to light 'stress' which
is increasingly longer with higher age traffic participants.
9. Authorities are now recognising the safety
benefits of removing street signs to reduce the clutter of visual
distractions a motorist has to deal with and so aid the perception
of real hazards. It is acting at cross-purposes at the same time to
continue the clutter of Volvo daytime running lights.'
10. The collective success of submissions by
our alliance to the EC DRL consultation last November has persuaded
Dr. Stefan Tostmann, European Commission, Head of Road Safety Unit,
DG TREN not to proceed with headlight based DRL. We understand
that the UNECE WP29 group are now working on a
solution with dedicated low power DRL plus an automatic switch
between dedicated headlights/dipped-beam headlights, however we will
be lobbying for switched low power DRL.
11. The academic research you rely upon has
been shown by our experts to use flawed methodology and has been
discredited – see
www.dadrl.org/studies. The actual real-world results verify
that the studies were too optimistic (please see Appendix 3 for
comments).
12. The motor industry has known since the
publication of HILDI 1997 bulletin 15 (appendix 1) that headlight
DRL are associated with increased accidents (3.7% average) which the
2007 Austrian and Bulgarian statistics plus expert medical opinion
verify. Those promulgating headlight DRL may be deemed inapposite.
13. Environmental pollution has not been
addressed: if the UK was made to adopt Volvo types of DRL they would
negate most of the carbon savings achieved by the 1,874 wind
turbines installed in the UK.
To conclude, surely you would agree that based
upon the Austrian and Bulgarian experience; the HILDI finding; and
the Japanese Government’s ban
it is morally wrong for a manufacturer to introduce a so called
“safety measure” which is associated with injuries and deaths to
vulnerable road users and is a violation of their public Obligation
of Protection, Equality Principle, and Human Rights.
In view of the real-world evidence about the
dangers of Daytime Running Lights, we would have hoped that an
environmentally conscious and socially caring company would be keen
of it’s own accord to stop using DRL and recall existing vehicles to
protect the UK’s vulnerable road users.
Due to the declination of Volvo (and ACEA),
we shall use our collective electoral power to lobby our
representatives and the media for a DRL ban similar to that achieved
in Japan and proposed by Austria.
Yours sincerely,
Roy Milnes
Campaign Co-ordinator DaDRL
In
Japan, DRLs (400 cd or more in central luminous intensity)
equivalent to the requirement of ECE R87 are prohibited.'
Ref: JASIC 2003
http://www.unece.org/trans/doc/2004/wp29gre/gtr5-6e.pdf
Working Paper No. GRE-gtr-5-6 (5th GRE-gtr informal
meeting, Ottawa, 7-11 June 2004)
[3] Association des
Constructeurs Européens d'Automobiles = Association of
European Automobile Manufacturers
21 September 2007
Dear Mr Milnes
Volvo file reference:
373751
Thank you for your
letter dated 12 September 2007. I can confirm that Lewis Booth has
received your e-mail and I am pleased to respond on his behalf. The
concerns you raise have been duly noted.
We believe that daytime
running lights are a valuable safety feature helping to improve
visibility for Volvo drivers but also making our cars more visible
to other road users and pedestrians. Notwithstanding this, a simple
software download is available for all of our current models, to
turn off this feature if the driver so desires.
We have an absolute
commitment to safety and our decision to offer daytime running
lights as standard is based on research which has shown this to be a
positive safety feature.
I can confirm that our
vehicles meet all current UK and European legislation. Should the
legislative position change, then I assure you that we would act
accordingly
Stuart Kerr
Managing Director.
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|
Mr. Stuart Kerr
Managing Director |
|
|
Volvo Cars UK
Ltd. |
|
|
Globe Park |
|
|
Marlow |
12 September 2007 |
|
Bucks SL7 1YQ |
|
Dear Mr. Kerr,
Volvo Cars - a Danger at any Speed? Daytime Running
Lights
Since 1998 (letters to G. Keaney
MD), DaDRL have requested Volvo not to use Daytime Running Lights
because they put vulnerable road users at risk. Yesterday, The
Times reported that road accidents to children had increased and the
Austrian press announced that the Austrian Government intend to ban
DRL.
We have widespread international support for
our anti-DRL campaign, this response is typical:
“So
do we have to equip school children with headlamps and car batteries
in their satchels? Roger Harrobin BBC R4”
The DRL experiments have
failed in Austria and Bulgaria - accidents increased when DRL
were introduced. (see
http://dadrl.hit.bg)
“EPIGUS” report complied by ophthalmological experts submitted to
Austria’s Federal Ministry of Transport, Innovation & Technology
http://www.bmvit.gv.at/verkehr/strasse/sicherheit/fahrenlicht.html
We believe DRL are a safety negative measure
promulgated by motor manufacturers as a gimmick to sell safety at
the expense of pedestrians, cyclists and motor-cyclists lives.
Reports using flawed methodology have been issued, but the EC (&
Volvo) are unable to provide real-world statistics that DRL increase
safety.
The human eye is a complex structure, the
effects of glare on a driver’s ability to depict hazards and causing
overload of their perceptive and cognition processes i.e. visual
short term memory is only just becoming recognised by the
authorities.
We believe for a manufacturer to introduce a so
called “safety measure” which causes injuries and deaths to
vulnerable road users is a violation of their Obligation of
Protection, Equality Principle, and Human Rights.
With support expressed from Tony Blair, Stephen
Ladyman plus members of our association against DRL, please may we
ask how much longer Volvo are going to unnecessarily pollute the
environment and put the lives of pedestrians, cyclists,
motor-cyclists and other drivers at risk ?
Yours sincerely,
Roy Milnes
Campaign Co-ordinator DaDRL
