R.A.C. Criticism of Lighting Regulations
Page 38
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FRANK criticisms of the draft Road Vehicles (Lighting) Regulations, 1935, are contained in a memorandum issued by the Royal Automobile Club. This is the third occasion on which draft regulations embodying proposals for the control of dazzle have been issued.
The Club maintains that the regulations are unnecessary, because most new vehicles have anti-dazzle devices. The proposal that the regulations should come into force in respect of all vehicles, new or old, in April, 1936, is referred to as being of " false urgency" and would involve owners of old motors in expense, in many cases, totally disproportionate to the value of the marlines. On the other hand, drivers could circumvent the regulations by not using their existing headlamps and might thus be •tempted to drive with insufficient light.
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The Club is not aware of fatal accident figures that justify the isstie of the regulations, and, in any case, the present proposals would not have the desired effect, because the regulations do not demand that one driver, when lueeting another, shall operate the prescribed dipping device. The R.A.C. maintains that it is useless to demand that a vehicle shall be equipped with an anti-dazzle device, unless its operation in appropriate circumstances be enforced, but it is practically impossible to define the proper occasions on which a device of this description should be used.
The provisions regarding dazzle introduce an undesirable principle, for they deal with the nature of the device. to be fitted and limit future development, removing all possibility of treat ing the subject of dazzle along lines other than the optical or mechanical dipping of the beam. The Club regards the term " dazzle " as not being sufficiently precise to be used in the regulations.
With regard to the proposed limitation of the wattage of lamp bulbs, the R.A.C. declares that responsibility for the accuracy of marking should be Oared upon the seller of the lamp, and not upon the driver. The Club believes that the limiting of the power of side lamps, especially in the cases of buses and large goods vehicles, would be beneficial to private-car drivers, but declares that such a regulation is desirable only so long as it can be enforced without hardship.
It is submitted that 3 ft. 6 ins, is a proper and reasonable maximum height for a rear lamp, and that the proposal to enlarge further the scope of the-use of a red reflector as an alternative to a rear lamp is disturbing.