Writing to NHTSA is probably the most productive thing you can do. Tell them to amend their guidelines for ghosting.Hey, I'm all in on pointless effort! That's what message boards are about!
Are we sure that Tesla isn't using internal guidelines? (You know, like our windshields are Beta or something.)
I recall reading a TMC or TM forum user following through with Tesla about Ghosting (if memory serves, over a year ago) and that user provided a link to the government guidelines. There are just too many references to ghosting to be able to find it via the forum search tools. If you have time, try searching here and at TeslaMotors forum.