Germany: Bicycle lighting in StVZO/TA, inconsistencies (December 2019)
In this section I will tell you a bit about the inconsistencies in StVZO which tells you a lot about society and the hierarchies in place accompanied by and partly constrained by the set of rules in place. In this case the person responsible for the new TA (= The technical rules used for the approval of any non-ECE vehicle lighting in Germany, such as for bicycles and for e-scooters via the ekfv law from June 2019), doesn't seem interested in making the rules as they should be where possible and from a comment he made I inferred that he is constrained in what he can do/change in some respects, namely by mentioning 'experts' (and I disagree with many so-called experts which I made clear).
In 2018 and 2019 I've been trying to get some more input into the process of the new rules of StVZO that were coming, which at time of writing in Dec. 2019 are still not finished. What I wanted to do is in particular for the rule makers to deal with point light sources, and the result of it all is that it is clear that the one writing the rules is limited in what he can or wants to change. He refers to and defers to 'experts' as one of his later responses made clear, and I presume some psychological studies or absence thereof are related to some of the issues he mentioned [ Btw., I am not really interested in any psychological studies, because psychologists are almost all incompetent, they are not able to analyse what-if scenario's and not able to understand the actual causes for various situations and various behaviour ]. Doing some more work for a company that wants to make a non-standard lighting system, I discussed some things with the person reponsible for that project in that company, and he made the remark "I fail to understand why there is a need to have so much regulation with very specific requirements for some solutions and others just do not matter.". Exactly, some things are regulated tightly, and others are not regulated at all even though they are important. What I see is inconsistencies, caused by people not looking at the total picture and not doing proper analyis (I will get to what is proper analysis somewhere else).
So what do we have:
- Pseudo DRL in bicycle lamps: In many bicycle lights we have pseudo-DRL (not separately approved DRL, these are effectively considered to be stray light from the lamp and thus it only lights up (and it may only light up) along with the cutoff beam), which is not regulated in colour (see the blue/purple LEDs in the B&M Cyo RT), and which can be (and are allowed to be) points sources of light, that may shine at night. Note that separately approved DRL as in cars but which can also be done with bicycles since mid 2017, is not allowed to be used at night! You might counter that the cd value is higher for DRL than for car headlamps, however, the brightness in cd is not the essential part of what causes glare, see the point about DRL below.
- Variation of light colour in the beam of headlamps is allowed: In headlamps in general, for cars and bicycles, there is no consideration for variations of the light colour within the beam as long as the total colour is more or less white. I remarked in 2012 on the Philips bike lighting day, that a beam they showed on the projection screen, wasn't white, but white + yellow blotches. The person making the presentation didn't go into this, perhaps he didn't realise the point I was making, but it turned out that such things are allowed in ECE and StVZO. See in car headlamps the blueish light of Xenon lamps, and even worse are lamps that use optics such that the colours change when they overtake you going from whitish to blue and purple (I noted this elsewhere on my site long ago), and what some makers did was to on purpose put out more blue light at the top of the beam. I think BMW was the main culprit in the latter case. From having experienced the issues blue light gives for focussing, and that it gives an impression that an emergency light of a police car or ambulance or fire truck might be what you see in the distance, the non-regulation of this is just silly at best and anyone who is an 'expert' working on any rules, be they StVZO or ECE, should know this and should do something about it, as they have done with disallowing flashing lamps.
- Not requiring a minimal emitting surface area for bicycle DRL: Separately shining DRL (without the cutoff main beam shining) are allowed since mid 2017, but of the standard they took (ECE R87) they only referred to the requirements in that standard for brightness in cd, and not the area, and thus they didn't set limits for the experienced brightness in cd/m^2! This means blinding point sources are allowed for DRL! I complained about this and was told that in the new TA there will likely not be a surface area requirement. WTF not? They regulate this for cars, why not for bicycles?
- Symbol projection is not allowed as it may be a distraction whereas as other distractions are allowed: I was told end of 2018 that lights with projection symbols are not allowed because it's not a given that they don't distract other traffic. Uh, hello McFly! What about blue and blue purple lights on some car headlamps and in some bicycle headlamps? What about blue light at the top of beams of BMW car headlamps? What about point sources in pseudo DRL in say the B&M Luxos? (those are some of the worst annoyances and thus distractions I've ever seen from a bicycle headlamp!) What about artefacts in the beam patterns of many bicycle lamps? What about point sources in taillamps? Point sources are similar to lasers, they impair your vision and are a distraction by taking away attention from everything else. If the distance of the projection symbol is say around 15m then any distraction it may cause is only a showing of a cyclist that may be coming behind you (or for pedestrians before them) , that might otherwise get overlooked even if their beam pattern can shine much farther.
- Different requirements for battery and dynamo powered taillamps: Dynamo powered taillamps must shine some of their light forward, battery powered taillamps don't need to do this. This is as I explained elsewhere similar to an interface inconsistency, it is wrong because it means you expect a person to expect different things in the same circumstances. I.e. he needs to keep in mind the system he is using, which for taillamps, which you only see from a distance (i.e. no clear display close to you that shows the battery status and whether the lamp is on/off), a bad idea. I was told that not making the forward cone a requirement was suggested by the bicycle industry, so some bicycle lighting makers thought this was a good idea. Going through a few possible scenarios I showed on my site and to the researcher that this was in fact a very bad idea, and that "it's not needed because you push the button so you know it's on" is not a valid argument to know it is actually on. A person using multiple different bicycles could, after riding a little while on a bicycle that is equipped with dynamo lights, think/assume after a while that he is riding with battery powered lights, and thus seeing no red cone shining backwards towards him he may assume that that is fine (as it is a battery powered taillamp) instead of a non-working dynamo taillamp. This can happen similar to anything that people do a lot, automatisms remove thinking, it is like locking a door. If you leave the house, are you really sure you locked it? So are you really sure you switched on the taillamp, and that it is actually a battery powered taillamp? Then there are issues such as batteries running down quickly in the cold. So a visible indicator that the taillamp is on and is working, as a reminder or confirmation, is simply needed.
Such things are simply inconsistencies in dealing with the total of what you encounter at night, and to a lesser extent during the day, why don't they do something about this?
[ Note regarding DRL: The limit of 4 - 12 lux at 10 m (400 - 1200 cd) for DRL via ECE R87 might seem to mean that it can and may blind more than the stray light of less than 2 lux above the horizon for bicycle headlamps, and thus also for pseudo-DRL, and ditto for car headlamps which are allowed to be 6.25 lux at 10 m (= 625 cd) above the horizon, but the point is that there is no size reference for the headlamps other than implicitly, i.e. the 6.25 lux and 2 lux are more or less equal due to the smaller size of bicycle headlamps which works more or less, but fails in some cases (as I experienced with some quite small headlamps that I saw in some fairly new buses). With DRL and pseudo-DRL there needs to be an explicit size to make sure DRL doesn't blind oncoming traffic because these lights purposely and completely (rather than only via stray light) shine into the eyes of oncoming traffic. The requirement that real DRL may not light at night only makes sense when assuming that the given values for headlamps and DRL are equivalent in how much they blind, which is not necessarily the case because the main thing in that respect is the cd/m^2 (I've explained this in my bicycle lighting standard WHS-2015, see sections 1.0 and 1.3). DRL using point sources is clearly a problem that needs to be taken care of and not doing so is inconsistent with other regulations that are supposed to regulate glare and distractions! ]
My conclusion is that they don't want to do anything, if they don't need to do it... I.e. if there is no external pressure they won't make changes even if those would be better, in having consistent and thus fair requirements for different types of lamps, and in people better handling various situations.
What should be done
Actually, everything I've suggested in my own bicycle lighting standard WHS-2015) and what else I commented in various places about light colour! (orangy light became an issue after I wrote that). Some of these points are:
- DRL: Prescribe light emitting area, and thus a maximum in cd/m^2
- Headlamps: Disallow (large) colour variations. Disallow any optics that have visible point light sources, except for those that are created without doing so on purpose, such as from certain spots on reflectors. Disallow cool white light.
- Taillamps: Disallow point sources. Disallow orangy light as that makes me and thus also others think even if it is just briefly "Is that a taillamp or a signal indicator?".
- Dealing with the problem of blinding low-lux headlamps that are aimed too high. As mentioned in my bicycle lighting standard, I feel that approvals should only be given for high output in lux and lumen headlamps with cutoff, and to be seen lights, which have to have a fairly large light emitting area and a fairly smooth light output with a not very high value in cd/m^2, for rides within cities. A high lux rating and a lot of light means people see far more easily whether their lamps are aimed correctly or too high.
Last modified: 2019-12-34