Tesla, Inc., Receipt of Petition for Decision of Inconsequential Noncompliance, 60682-60684 [2024-16481]
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Federal Register / Vol. 89, No. 144 / Friday, July 26, 2024 / Notices
preventing any risk of vehicle
overloading.
IAA believes that the subject
noncompliance does not cause any
increased safety risk to vehicle
occupants because the maximum
vehicle capacity weight is understated
rather than overstated. Consequently,
IAA argues, adhering to the maximum
vehicle capacity weight provided on the
vehicle placard would not lead to
vehicle overloading.
IAA says that the purpose of the
vehicle placard is to convey accurate
information for the vehicle to be
operated in a safe manner and to reduce
the potential for crashes due to
overloading. The vehicle placard
contains information that includes the
subject vehicle’s maximum weight
capacity that should not be exceeded.
IAA explains that the placard for the
subject vehicles lists the weight capacity
as 604 pounds or 274 kg which is lower
than the actual maximum weight
capacity of the subject vehicles.
According to IAA, the subject vehicles
are designed and engineered to carry a
maximum weight of 1,889 pounds (857
kg), which is more than three times the
maximum weight capacity listed on the
vehicle placard. Consequently, IAA
believes that the noncompliant placard
does not pose a risk of overloading the
subject vehicles, even if the consumers
do not reference any other sources of
information, like the owner’s manual.
IAA notes that if the vehicle operator
questions the maximum vehicle weight
capacity, they can refer to additional
sources for information. The Grenadier
owner’s manual provides additional
information on the vehicle’s weight
carrying capacity and explains how to
calculate it correctly, including an
example of how to perform the
calculation. The owner’s manual also
includes information on safe handling
when the subject vehicle is loaded with
occupants and cargo, such as where to
place the cargo within the vehicle and
instructions on properly securing cargo.
Further, IAA says that the vehicle’s
certification label, per 49 CFR part 567,
is permanently affixed on each vehicle’s
B-Pillar. This label contains the subject
vehicle’s Gross Vehicle Weight Rating
(GVWR) and Gross Axle Weight Rating
(GAWR). IAA explains that if a
consumer notices an unusually low
maximum weight capacity listed on the
vehicle placard required by FMVSS No.
110 label, it is reasonable for them to
consult the certification label, along
with the owner’s manual, to clarify the
vehicle weight capacity value. IAA
highlights a prior petition by MercedesBenz USA, LLC, that NHTSA granted
(82 FR 33547 July 12, 2017). In that
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case, the GVWR and GAWR values
listed on the certification label were
accurate and provided an additional
resource for consumers to reference
maximum vehicle weight capacity.
IAA cites other prior petitions
NHTSA granted involving
noncompliances where information on
the vehicle placard was inaccurate, but
the manufacturer demonstrated that
there was no risk of vehicle overloading:
• BMW of North America, LLC, a
Subsidiary of BMW AG, Grant of
Petition for Decision of Inconsequential
Noncompliance, 78 FR 38799, June 27,
2013 (The number of rear and maximum
vehicle occupants on the vehicle
placard was understated and found to
be inconsequential because there was
little to no risk of vehicle overloading.),
• BMW North America, LLC, Grant of
Petition for Decision of Inconsequential
Noncompliance, 88 FR 14245, March 7,
2023. (The noncompliant vehicle was
designed to withstand a larger capacity
weight than was stated on its tire
loading label and would not present a
consequential safety problem.),
• Grant of Petition to Mercedes-Benz
USA, LLC, 82 FR 33547 July 12, 2017,
(The maximum vehicle weight capacity
was overstated, but the vehicle’s tire
loading capacities were sufficient to
handle the additional weight.).
IAA highlights another petition that
NHTSA granted, submitted by FCA US
LLC (FCA), which IAA says has nearly
identical facts. In FCA’s petition, the
vehicle placard displayed a combined
occupant and cargo weight of 1,150 lbs.
rather than 1,240 lbs. and misstated the
maximum number of occupants that the
vehicle could carry. (See Grant of
Petition of FCA US, LLC, 88 FR 84393,
December 5, 2023). IAA contends that,
unlike in the FCA petition, all
information on the subject vehicles’ is
accurate except the maximum vehicle
capacity weight.
IAA states that it has corrected the
subject noncompliance in its
production, and all of the remaining
information on the vehicle placard is
accurate, including the maximum
number of vehicle passengers, tire size
and tire pressure.
IAA concludes by stating its belief
that the subject noncompliance is
inconsequential as it relates to motor
vehicle safety and its petition to be
exempted from providing notification of
the noncompliance, as required by 49
U.S.C. 30118, and a remedy for the
noncompliance, as required by 49
U.S.C. 30120, should be granted.
NHTSA notes that the statutory
provisions (49 U.S.C. 30118(d) and
30120(h)) that permit manufacturers to
file petitions for a determination of
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inconsequentiality allow NHTSA to
exempt manufacturers only from the
duties found in sections 30118 and
30120, respectively, to notify owners,
purchasers, and dealers of a defect or
noncompliance and to remedy the
defect or noncompliance. Therefore, any
decision on this petition only applies to
the subject vehicles that IAA no longer
controlled at the time it determined that
the noncompliance existed. However,
any decision on this petition does not
relieve vehicle distributors and dealers
of the prohibitions on the sale, offer for
sale, or introduction or delivery for
introduction into interstate commerce of
the noncompliant vehicles under their
control after IAA notified them that the
subject noncompliance existed.
(Authority: 49 U.S.C. 30118, 30120:
delegations of authority at 49 CFR 1.95 and
501.8)
Otto G. Matheke, III,
Director, Office of Vehicle Safety Compliance.
[FR Doc. 2024–16483 Filed 7–25–24; 8:45 am]
BILLING CODE 4910–59–P
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety
Administration
[Docket No. NHTSA–2024–0019; Notice 1]
Tesla, Inc., Receipt of Petition for
Decision of Inconsequential
Noncompliance
National Highway Traffic
Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Receipt of petition.
AGENCY:
Tesla, Inc. (Tesla) has
determined that certain model year
(MY) 2017–2023 Tesla Model and Tesla
Model Y motor vehicles do not fully
comply with Federal Motor Vehicle
Safety Standard (FMVSS) No. 108,
Lamps, Reflective Devices, And
Associated Equipment. Tesla filed a
noncompliance report dated March 15,
2024, and subsequently petitioned
NHTSA (the ‘‘Agency’’) on April 8,
2024, and amended its petition on May
3, 2024, for a decision that the subject
noncompliance is inconsequential as it
relates to motor vehicle safety. This
document announces receipt of Tesla’s
petition.
DATES: Send comments on or before
August 26, 2024.
ADDRESSES: Interested persons are
invited to submit written data, views,
and arguments on this petition.
Comments must refer to the docket and
notice number cited in the title of this
SUMMARY:
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notice and may be submitted by any of
the following methods:
• Mail: Send comments by mail
addressed to the U.S. Department of
Transportation, Docket Operations, M–
30, West Building Ground Floor, Room
W12–140, 1200 New Jersey Avenue SE,
Washington, DC 20590.
• Hand Delivery: Deliver comments
by hand to the U.S. Department of
Transportation, Docket Operations, M–
30, West Building Ground Floor, Room
W12–140, 1200 New Jersey Avenue SE,
Washington, DC 20590. The Docket
Section is open on weekdays from 10
a.m. to 5 p.m. except for Federal
Holidays.
• Electronically: Submit comments
electronically by logging onto the
Federal Docket Management System
(FDMS) website at https://
www.regulations.gov/. Follow the online
instructions for submitting comments.
• Comments may also be faxed to
(202) 493–2251.
Comments must be written in the
English language, and be no greater than
15 pages in length, although there is no
limit to the length of necessary
attachments to the comments. If
comments are submitted in hard copy
form, please ensure that two copies are
provided. If you wish to receive
confirmation that comments you have
submitted by mail were received, please
enclose a stamped, self-addressed
postcard with the comments. Note that
all comments received will be posted
without change to https://
www.regulations.gov, including any
personal information provided.
All comments and supporting
materials received before the close of
business on the closing date indicated
above will be filed in the docket and
will be considered. All comments and
supporting materials received after the
closing date will also be filed and will
be considered to the fullest extent
possible.
When the petition is granted or
denied, notice of the decision will also
be published in the Federal Register
pursuant to the authority indicated at
the end of this notice.
All comments, background
documentation, and supporting
materials submitted to the docket may
be viewed by anyone at the address and
times given above. The documents may
also be viewed on the internet at https://
www.regulations.gov by following the
online instructions for accessing the
dockets. The docket ID number for this
petition is shown in the heading of this
notice.
DOT’s complete Privacy Act
Statement is available for review in a
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Jkt 262001
Federal Register notice published on
April 11, 2000 (65 FR 19477–78).
FOR FURTHER INFORMATION CONTACT:
Leroy Angeles, General Engineer,
NHTSA, Office of Vehicle Safety
Compliance, (202) 366–5304.
SUPPLEMENTARY INFORMATION:
I. Overview: Tesla determined that
certain MY 2017–2023 Tesla Model 3
and MY 2020–2023 Tesla Model Y do
not fully comply with paragraph
S10.14.6 of FMVSS No. 108, Lamps,
Reflective Devices, And Associated
Equipment (49 CFR 571.108).
Tesla filed a noncompliance report
dated March 15, 2024, pursuant to 49
CFR part 573, Defect and
Noncompliance Responsibility and
Reports. Tesla petitioned NHTSA on
April 9, 2024, for an exemption from the
notification and remedy requirements of
49 U.S.C. chapter 301 on the basis that
this noncompliance is inconsequential
as it relates to motor vehicle safety,
pursuant to 49 U.S.C. 30118(d) and
30120(h) and 49 CFR part 556,
Exemption for Inconsequential Defect or
Noncompliance.
This notice of receipt of Tesla’s
petition is published under 49 U.S.C.
30118 and 30120 and does not represent
any agency decision or another exercise
of judgment concerning the merits of the
petition.
II. Vehicles Involved: Approximately
19,917 MY 2017–2023 Tesla Model 3
and MY 2020–2023 Tesla Model Y
motor vehicles, manufactured between
October 27, 2017, and December 24,
2023, were reported by the
manufacturer.
III. Rule Requirements: Paragraph
S10.14.6 of FMVSS No. 108 includes the
requirements relevant to this petition.
Specifically, when tested according to
the test procedure provided by
paragraph S14.2.5 of FMVSS No. 108,
each integral beam headlamp must be
designed to conform to the photometry
requirements of Table XIX of FMVSS
No. 108 for lower beam, as specified in
Table II–c for the specific headlamp unit
and aiming method. As it relates to this
petition, the maximum photometric
intensity in the 10°U to 90°U zone for
the lower beam is 125 cd.
IV. Noncompliance: Tesla explains
that the subject vehicles are equipped
with headlamps that have a low-beam
output that exceeds the maximum
photometric intensity stated in
paragraph S10.14.6 of FMVSS No. 108.
Specifically, the affected right and lefthand headlamp lower beams may
measure as much as 230.1 candela (cd)
in the 10°U to 90°U zone, which
exceeds the maximum photometric
intensity allowed by 105.1 cd.
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60683
V. Summary of Tesla’s Petition: The
following views and arguments
presented in this section, ‘‘V. Summary
of Tesla’s Petition,’’ are the views and
arguments provided by Tesla. They have
not been evaluated by the Agency and
do not reflect the views of the Agency.
Tesla describes the subject
noncompliance and contends that the
noncompliance is inconsequential as it
relates to motor vehicle safety.
Tesla’s headlamp supplier, Marelli
Automotive Lighting, tested 25 righthand and 25 left-hand lamps, and for
this sample, found the maximum
photometric intensity measured at the
10°U to 90°U zone was between 136.2
cd and 230.1 cd for the right-hand
lamps and between 117.5 cd and 160.3
cd for the left-hand lamps. According to
Tesla, these tests revealed that the
photometric intensity of the right-hand
and left-hand headlamp lower beam on
the subject vehicles may measure as
much as 230.1 cd in the 10°U to 90°U
zone, exceeding the maximum
photometric intensity by 105.1 cd.
Additionally, a left-hand lamp tested by
a Transport Canada recognized
laboratory measured a maximum of
171.27 cd in the 10°U to 90°U zone.
Despite these measurements exceeding
the photometric maximum, Tesla
believes that the subject noncompliance
is inconsequential to motor vehicle
safety.
Tesla argues that the noncompliant
illuminated area of the subject
headlamp in the 10°U to 90°U zone is
positioned off the roadway both
horizontally and vertically, keeping it
outside of the driver’s and other road
users’ natural line of vision. Therefore,
Tesla believes there is no increased risk
of glare for surrounding traffic or the
driver of the subject vehicle in any
driving conditions.
Tesla’s petition provides a plan view,
side and orthogonal view (Figure 1) of
the emitted light exceeding 125 cd
overlaid onto the 10°U to 90°U zone. For
a left-hand headlamp, the affected area
is in the 30° inboard and 20° upward
zone, and this is symmetrical for the
right-hand headlamp.
Figure 2 in Tesla’s petition shows the
subject noncompliance from the view of
the driver of the subject vehicle. Tesla
explains that it simulated the
illumination of the noncompliant 10°U
to 90°U zone to demonstrate how the
subject noncompliance affects the
roadway. The simulation in Figure 2
shows that the left-hand headlamp
exceeds the 125 cd maximum by 35.3 cd
(totaling 160.3 cd), while the right-hand
headlamp exceeds it by 105.1 cd
(totaling 230.1 cd). Tesla explains that
these figures represent the largest
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measurements from the 25 sets of
headlamps tested by Marelli
Automotive Lighting.
Tesla asserts that the area illuminated
by the noncompliant headlamps in the
10°U to 90°U zone does not affect the
driver of the subject vehicle because its
high and outboard position falls outside
the driver’s line of vision. Furthermore,
Tesla believes that this illuminated area
does not impact the field of vision of
oncoming drivers or other road users
due to its extreme location. The light
from the subject headlamp in this zone
is projected off and above the roadway.
Therefore, Tesla argues that subject
noncompliance is inconsequential as it
relates to motor vehicle safety.
On May 3, 2024, Tesla amended its
petition to provide details of the low
beam testing they conducted. Using the
Adaptive Driving Beam (ADB) protocol
test method provided in FMVSS No.
108, S14.9.3.12, Tesla conducted low
beam tests on a proving ground. Tesla
explains that the study aimed to
characterize and quantify the low beam
glare in the 10°U to 90°U zone on the
subject vehicles compared to the same
vehicles equipped with compliant
headlamps.
The test involved one Model 3 and
one Model Y vehicle, each equipped
with the noncompliant left-hand and
right-hand headlamps that exceeded the
FMVSS No. 108 maximum permissible
candela in the 10°U to 90°U zone. Tesla
followed the test procedure described in
Scenario #1 of FMVSS No. 108, Table
XXII, at 60 mph and opposite direction.
Tesla argues that meeting the low
beam maximum illuminance permitted
by FMVSS No. 108, despite having
noncompliant headlamps, makes the
noncompliance at issue inconsequential
to motor vehicle safety. This, according
to Tesla, ensures that drivers of vehicles
equipped with the subject headlamps
and other road users would not
experience glare or distraction from
them.
Tesla, in their amended petition, says
that the subject vehicles did not exceed
the permitted maximum illuminance
values required by FMVSS No. 108,
Table XXI. Tesla believes that these test
results demonstrate that the subject
noncompliance does not create glare for
the driver of the subject vehicle or other
road users. Therefore, Tesla contends
that the noncompliance is
inconsequential as it relates to motor
vehicle safety.
Tesla adds that they are not aware of
any complaints, accidents, or injuries
related to the subject noncompliance.
Tesla has not found any complaints or
reports of accidents or injuries related to
this noncompliance in its records or
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Jkt 262001
NHTSA Vehicle Owner Questionnaires.
While Tesla acknowledges that this fact
is not dispositive in the consideration of
a petition for inconsequential
noncompliance, it mentions this to
illustrate that customers have not
reported issues such as excessively
bright or glare, and no accidents or
injuries have been attributed to the
subject headlamps.1
Tesla references a 2022 denial of a
petition submitted by General Motors,
LLC, (GM) in which Tesla says GM
argued that certain noncompliant lower
beam headlamps exceeding the
photometry requirements of S10.15.6
and Table XIX of FMVSS No. 108 were
inconsequential to motor vehicles
safety.2 Tesla explains that GM could
not demonstrate that the noncompliant
headlamps, which measured 450–470
cd and exceeded the photometric
requirement by more than three times,
did not cause glare or were not
distracting to other road users. (Id.)
Tesla believes that the subject
noncompliance is distinguishable from
GM’s petition because the subject
headlamps measure 230.1 cd at most.
Tesla also uses the ADB testing it
conducted to distinguish its petition
from the GM petition by demonstrating
that it believes the subject
noncompliance does not create glare for
the driver and other road users.
Tesla concludes by stating its belief
that the subject noncompliance is
inconsequential as it relates to motor
vehicle safety and its petition to be
exempted from providing notification of
the noncompliance, as required by 49
U.S.C. 30118, and a remedy for the
noncompliance, as required by 49
U.S.C. 30120, should be granted.
NHTSA notes that the statutory
provisions (49 U.S.C. 30118(d) and
30120(h)) that permit manufacturers to
file petitions for a determination of
inconsequentiality allow NHTSA to
exempt manufacturers only from the
duties found in sections 30118 and
30120, respectively, to notify owners,
purchasers, and dealers of a defect or
noncompliance and to remedy the
defect or noncompliance. Therefore, any
decision on this petition only applies to
the subject vehicles that Tesla no longer
controlled at the time it determined that
the noncompliance existed. However,
any decision on this petition does not
relieve vehicle distributors and dealers
of the prohibitions on the sale, offer for
sale, or introduction or delivery for
1 See North American Subaru, Inc., Denial of
Petition for Decision of Inconsequential
Noncompliance; 87 FR 48764, August 10, 2022.
2 See General Motors, LLC, Denial of Petition for
Decision of Inconsequential Noncompliance; 87 FR
12546, March 4, 2022.
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introduction into interstate commerce of
the noncompliant vehicles under their
control after Tesla notified them that the
subject noncompliance existed.
(Authority: 49 U.S.C. 30118, 30120:
delegations of authority at 49 CFR 1.95 and
501.8)
Otto G. Matheke, III,
Director, Office of Vehicle Safety Compliance.
[FR Doc. 2024–16481 Filed 7–25–24; 8:45 am]
BILLING CODE 4910–59–P
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety
Administration
[Docket No. NHTSA–2024–0007; Notice 1]
FCA US LLC, Receipt of Petition for
Decision of Inconsequential
Noncompliance
National Highway Traffic
Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Receipt of petition.
AGENCY:
FCA US LLC (FCA) has
determined that the pedestrian alert rear
speakers and service parts (‘‘Quiet
Vehicle Protection Module’’ or
‘‘QVPM’’) for certain MY 2022–2024
Jeep Grand Cherokee motor vehicles do
not fully comply with Federal Motor
Vehicle Safety Standard (FMVSS) No.
141, Minimum Sound Requirements for
Hybrid and Electric Vehicles. FCA filed
two noncompliance reports dated
October 26, 2023, and subsequently
petitioned NHTSA (the ‘‘Agency’’) on
November 16, 2023, for a decision that
the subject noncompliance is
inconsequential as it relates to motor
vehicle safety. This document
announces receipt of FCA’s petition.
DATES: Send comments on or before
August 26, 2024.
ADDRESSES: Interested persons are
invited to submit written data, views,
and arguments on this petition.
Comments must refer to the docket and
notice number cited in the title of this
notice and may be submitted by any of
the following methods:
• Mail: Send comments by mail
addressed to the U.S. Department of
Transportation, Docket Operations, M–
30, West Building Ground Floor, Room
W12–140, 1200 New Jersey Avenue SE,
Washington, DC 20590.
• Hand Delivery: Deliver comments
by hand to the U.S. Department of
Transportation, Docket Operations, M–
30, West Building Ground Floor, Room
W12–140, 1200 New Jersey Avenue SE,
Washington, DC 20590. The Docket
Section is open on weekdays from 10
SUMMARY:
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Agencies
[Federal Register Volume 89, Number 144 (Friday, July 26, 2024)]
[Notices]
[Pages 60682-60684]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2024-16481]
-----------------------------------------------------------------------
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2024-0019; Notice 1]
Tesla, Inc., Receipt of Petition for Decision of Inconsequential
Noncompliance
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
ACTION: Receipt of petition.
-----------------------------------------------------------------------
SUMMARY: Tesla, Inc. (Tesla) has determined that certain model year
(MY) 2017-2023 Tesla Model and Tesla Model Y motor vehicles do not
fully comply with Federal Motor Vehicle Safety Standard (FMVSS) No.
108, Lamps, Reflective Devices, And Associated Equipment. Tesla filed a
noncompliance report dated March 15, 2024, and subsequently petitioned
NHTSA (the ``Agency'') on April 8, 2024, and amended its petition on
May 3, 2024, for a decision that the subject noncompliance is
inconsequential as it relates to motor vehicle safety. This document
announces receipt of Tesla's petition.
DATES: Send comments on or before August 26, 2024.
ADDRESSES: Interested persons are invited to submit written data,
views, and arguments on this petition. Comments must refer to the
docket and notice number cited in the title of this
[[Page 60683]]
notice and may be submitted by any of the following methods:
Mail: Send comments by mail addressed to the U.S.
Department of Transportation, Docket Operations, M-30, West Building
Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC
20590.
Hand Delivery: Deliver comments by hand to the U.S.
Department of Transportation, Docket Operations, M-30, West Building
Ground Floor, Room W12-140, 1200 New Jersey Avenue SE, Washington, DC
20590. The Docket Section is open on weekdays from 10 a.m. to 5 p.m.
except for Federal Holidays.
Electronically: Submit comments electronically by logging
onto the Federal Docket Management System (FDMS) website at https://www.regulations.gov/. Follow the online instructions for submitting
comments.
Comments may also be faxed to (202) 493-2251.
Comments must be written in the English language, and be no greater
than 15 pages in length, although there is no limit to the length of
necessary attachments to the comments. If comments are submitted in
hard copy form, please ensure that two copies are provided. If you wish
to receive confirmation that comments you have submitted by mail were
received, please enclose a stamped, self-addressed postcard with the
comments. Note that all comments received will be posted without change
to https://www.regulations.gov, including any personal information
provided.
All comments and supporting materials received before the close of
business on the closing date indicated above will be filed in the
docket and will be considered. All comments and supporting materials
received after the closing date will also be filed and will be
considered to the fullest extent possible.
When the petition is granted or denied, notice of the decision will
also be published in the Federal Register pursuant to the authority
indicated at the end of this notice.
All comments, background documentation, and supporting materials
submitted to the docket may be viewed by anyone at the address and
times given above. The documents may also be viewed on the internet at
https://www.regulations.gov by following the online instructions for
accessing the dockets. The docket ID number for this petition is shown
in the heading of this notice.
DOT's complete Privacy Act Statement is available for review in a
Federal Register notice published on April 11, 2000 (65 FR 19477-78).
FOR FURTHER INFORMATION CONTACT: Leroy Angeles, General Engineer,
NHTSA, Office of Vehicle Safety Compliance, (202) 366-5304.
SUPPLEMENTARY INFORMATION:
I. Overview: Tesla determined that certain MY 2017-2023 Tesla Model
3 and MY 2020-2023 Tesla Model Y do not fully comply with paragraph
S10.14.6 of FMVSS No. 108, Lamps, Reflective Devices, And Associated
Equipment (49 CFR 571.108).
Tesla filed a noncompliance report dated March 15, 2024, pursuant
to 49 CFR part 573, Defect and Noncompliance Responsibility and
Reports. Tesla petitioned NHTSA on April 9, 2024, for an exemption from
the notification and remedy requirements of 49 U.S.C. chapter 301 on
the basis that this noncompliance is inconsequential as it relates to
motor vehicle safety, pursuant to 49 U.S.C. 30118(d) and 30120(h) and
49 CFR part 556, Exemption for Inconsequential Defect or Noncompliance.
This notice of receipt of Tesla's petition is published under 49
U.S.C. 30118 and 30120 and does not represent any agency decision or
another exercise of judgment concerning the merits of the petition.
II. Vehicles Involved: Approximately 19,917 MY 2017-2023 Tesla
Model 3 and MY 2020-2023 Tesla Model Y motor vehicles, manufactured
between October 27, 2017, and December 24, 2023, were reported by the
manufacturer.
III. Rule Requirements: Paragraph S10.14.6 of FMVSS No. 108
includes the requirements relevant to this petition. Specifically, when
tested according to the test procedure provided by paragraph S14.2.5 of
FMVSS No. 108, each integral beam headlamp must be designed to conform
to the photometry requirements of Table XIX of FMVSS No. 108 for lower
beam, as specified in Table II-c for the specific headlamp unit and
aiming method. As it relates to this petition, the maximum photometric
intensity in the 10[deg]U to 90[deg]U zone for the lower beam is 125
cd.
IV. Noncompliance: Tesla explains that the subject vehicles are
equipped with headlamps that have a low-beam output that exceeds the
maximum photometric intensity stated in paragraph S10.14.6 of FMVSS No.
108. Specifically, the affected right and left-hand headlamp lower
beams may measure as much as 230.1 candela (cd) in the 10[deg]U to
90[deg]U zone, which exceeds the maximum photometric intensity allowed
by 105.1 cd.
V. Summary of Tesla's Petition: The following views and arguments
presented in this section, ``V. Summary of Tesla's Petition,'' are the
views and arguments provided by Tesla. They have not been evaluated by
the Agency and do not reflect the views of the Agency. Tesla describes
the subject noncompliance and contends that the noncompliance is
inconsequential as it relates to motor vehicle safety.
Tesla's headlamp supplier, Marelli Automotive Lighting, tested 25
right-hand and 25 left-hand lamps, and for this sample, found the
maximum photometric intensity measured at the 10[deg]U to 90[deg]U zone
was between 136.2 cd and 230.1 cd for the right-hand lamps and between
117.5 cd and 160.3 cd for the left-hand lamps. According to Tesla,
these tests revealed that the photometric intensity of the right-hand
and left-hand headlamp lower beam on the subject vehicles may measure
as much as 230.1 cd in the 10[deg]U to 90[deg]U zone, exceeding the
maximum photometric intensity by 105.1 cd. Additionally, a left-hand
lamp tested by a Transport Canada recognized laboratory measured a
maximum of 171.27 cd in the 10[deg]U to 90[deg]U zone. Despite these
measurements exceeding the photometric maximum, Tesla believes that the
subject noncompliance is inconsequential to motor vehicle safety.
Tesla argues that the noncompliant illuminated area of the subject
headlamp in the 10[deg]U to 90[deg]U zone is positioned off the roadway
both horizontally and vertically, keeping it outside of the driver's
and other road users' natural line of vision. Therefore, Tesla believes
there is no increased risk of glare for surrounding traffic or the
driver of the subject vehicle in any driving conditions.
Tesla's petition provides a plan view, side and orthogonal view
(Figure 1) of the emitted light exceeding 125 cd overlaid onto the
10[deg]U to 90[deg]U zone. For a left-hand headlamp, the affected area
is in the 30[deg] inboard and 20[deg] upward zone, and this is
symmetrical for the right-hand headlamp.
Figure 2 in Tesla's petition shows the subject noncompliance from
the view of the driver of the subject vehicle. Tesla explains that it
simulated the illumination of the noncompliant 10[deg]U to 90[deg]U
zone to demonstrate how the subject noncompliance affects the roadway.
The simulation in Figure 2 shows that the left-hand headlamp exceeds
the 125 cd maximum by 35.3 cd (totaling 160.3 cd), while the right-hand
headlamp exceeds it by 105.1 cd (totaling 230.1 cd). Tesla explains
that these figures represent the largest
[[Page 60684]]
measurements from the 25 sets of headlamps tested by Marelli Automotive
Lighting.
Tesla asserts that the area illuminated by the noncompliant
headlamps in the 10[deg]U to 90[deg]U zone does not affect the driver
of the subject vehicle because its high and outboard position falls
outside the driver's line of vision. Furthermore, Tesla believes that
this illuminated area does not impact the field of vision of oncoming
drivers or other road users due to its extreme location. The light from
the subject headlamp in this zone is projected off and above the
roadway. Therefore, Tesla argues that subject noncompliance is
inconsequential as it relates to motor vehicle safety.
On May 3, 2024, Tesla amended its petition to provide details of
the low beam testing they conducted. Using the Adaptive Driving Beam
(ADB) protocol test method provided in FMVSS No. 108, S14.9.3.12, Tesla
conducted low beam tests on a proving ground. Tesla explains that the
study aimed to characterize and quantify the low beam glare in the
10[deg]U to 90[deg]U zone on the subject vehicles compared to the same
vehicles equipped with compliant headlamps.
The test involved one Model 3 and one Model Y vehicle, each
equipped with the noncompliant left-hand and right-hand headlamps that
exceeded the FMVSS No. 108 maximum permissible candela in the 10[deg]U
to 90[deg]U zone. Tesla followed the test procedure described in
Scenario #1 of FMVSS No. 108, Table XXII, at 60 mph and opposite
direction.
Tesla argues that meeting the low beam maximum illuminance
permitted by FMVSS No. 108, despite having noncompliant headlamps,
makes the noncompliance at issue inconsequential to motor vehicle
safety. This, according to Tesla, ensures that drivers of vehicles
equipped with the subject headlamps and other road users would not
experience glare or distraction from them.
Tesla, in their amended petition, says that the subject vehicles
did not exceed the permitted maximum illuminance values required by
FMVSS No. 108, Table XXI. Tesla believes that these test results
demonstrate that the subject noncompliance does not create glare for
the driver of the subject vehicle or other road users. Therefore, Tesla
contends that the noncompliance is inconsequential as it relates to
motor vehicle safety.
Tesla adds that they are not aware of any complaints, accidents, or
injuries related to the subject noncompliance.
Tesla has not found any complaints or reports of accidents or
injuries related to this noncompliance in its records or NHTSA Vehicle
Owner Questionnaires. While Tesla acknowledges that this fact is not
dispositive in the consideration of a petition for inconsequential
noncompliance, it mentions this to illustrate that customers have not
reported issues such as excessively bright or glare, and no accidents
or injuries have been attributed to the subject headlamps.\1\
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\1\ See North American Subaru, Inc., Denial of Petition for
Decision of Inconsequential Noncompliance; 87 FR 48764, August 10,
2022.
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Tesla references a 2022 denial of a petition submitted by General
Motors, LLC, (GM) in which Tesla says GM argued that certain
noncompliant lower beam headlamps exceeding the photometry requirements
of S10.15.6 and Table XIX of FMVSS No. 108 were inconsequential to
motor vehicles safety.\2\ Tesla explains that GM could not demonstrate
that the noncompliant headlamps, which measured 450-470 cd and exceeded
the photometric requirement by more than three times, did not cause
glare or were not distracting to other road users. (Id.) Tesla believes
that the subject noncompliance is distinguishable from GM's petition
because the subject headlamps measure 230.1 cd at most. Tesla also uses
the ADB testing it conducted to distinguish its petition from the GM
petition by demonstrating that it believes the subject noncompliance
does not create glare for the driver and other road users.
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\2\ See General Motors, LLC, Denial of Petition for Decision of
Inconsequential Noncompliance; 87 FR 12546, March 4, 2022.
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Tesla concludes by stating its belief that the subject
noncompliance is inconsequential as it relates to motor vehicle safety
and its petition to be exempted from providing notification of the
noncompliance, as required by 49 U.S.C. 30118, and a remedy for the
noncompliance, as required by 49 U.S.C. 30120, should be granted.
NHTSA notes that the statutory provisions (49 U.S.C. 30118(d) and
30120(h)) that permit manufacturers to file petitions for a
determination of inconsequentiality allow NHTSA to exempt manufacturers
only from the duties found in sections 30118 and 30120, respectively,
to notify owners, purchasers, and dealers of a defect or noncompliance
and to remedy the defect or noncompliance. Therefore, any decision on
this petition only applies to the subject vehicles that Tesla no longer
controlled at the time it determined that the noncompliance existed.
However, any decision on this petition does not relieve vehicle
distributors and dealers of the prohibitions on the sale, offer for
sale, or introduction or delivery for introduction into interstate
commerce of the noncompliant vehicles under their control after Tesla
notified them that the subject noncompliance existed.
(Authority: 49 U.S.C. 30118, 30120: delegations of authority at 49
CFR 1.95 and 501.8)
Otto G. Matheke, III,
Director, Office of Vehicle Safety Compliance.
[FR Doc. 2024-16481 Filed 7-25-24; 8:45 am]
BILLING CODE 4910-59-P