“RonF” and I engaged in talk about smart lights over lunch yesterday. We agree that the fog light setup on the smart is in violation of our VA Admin Code because they don’t extinguish when the high beams are selected. In fact there could be six forward facing lights on because the lows stay on with the highs, another VAC violation. But one could try to argue that that the highs and lows are all in the same shell and thus are integrated lamps – you might win that one. As far as the fogs-on-highs deal goes, the argument that they are OEM and how the car was manufactured with a NHTSA certificate of compliance might not fly. Even the owners manual has an admonition about combining fogs with highs in some jurisdictions (pg. 106).
We also agreed that for us, the pulsing third brake light could be construed as illegal, though we both have it (19VAC30-70-190. Signal device (intention to stop or turn), hazard lights, stop lamp. ... “The high mount stop lamp must be steady burning and not wired to flash with turn signals or other wig-wag device). I have braked in front of police cars and have not had a problem. But, I do have my GoMiniGo Gen 2 pulser set to the short interval and then steady-on after that. A constant pulser might get you in a jamb, as well as annoy the hob out of following vehicles. To say that M-BUSA got a NHTSA exemption for pulsing brake lights for the “S-Class” in 2006 is apples and oranges. That exemption involves all three lights in a panic braking situation, and activation of the hazard lights once stopped. The smart has such a feature. But, if I read between the lines for the intent of the VAC I see a only denial of tying the third brake light into a directional circuit or wig-wag. In VA parlance, “wig-wag” means alternating left-right emergency vehicle head and/or tail lights.
Re DRLs: For us – probably not a problem, unless:
a. Any lamp, except headlamps, used as DRLs if not an approved type (SAE-Y2) and is not marked "DRL";
b. Fog lamps or parking lamps are used as DRLs;
d. A DRL is mounted higher than 34 inches measured to the center of the lamp;
e. The color is other than white to amber;
f. DRLs do not deactivate when the headlamps are in any "on" position.
Some VA stickiness could come in with “f.” if the smart DRLs are tied to the high beams in any way because we have the situation wherein the low beams could be on, and the DRL-ed high beams are also on. One would think that M-B would have it covered at the national level.
So, all that with a nice Reuben sandwich and a Guinness and some “sea stories” made an interesting afternoon.
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