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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:

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:

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