I urge NHTSA to allow the replacement of vehicle side mirrors with camera systems. Any replacement should be made with the proviso that the camera system be evaluated and be considered as safe or safer than side mirrors.
There are at least a half dozen benefits to allowing the use of camera systems in place of side mirrors:
1) Increase safety:
a. As vehicles become increasingly autonomous with more compute hardware and sophisticated software present, camera systems may be capable of analyzing the scene around the vehicle (not just what the side mirrors would have seen) and providing active warning
b. Side mirrors provide a very limited view and perhaps not from the best point of view. Camera systems afford the possibility to provide a better and more complete view to the driver. This might be done by locating the cameras higher or lower on the side of a vehicle or by combining views from multiple cameras.
c. Any projection from the vehicle, such as the side mirrors, are potential hazards. For example, motor cycle riders and cyclists may be caught on them.
2) Decrease use of fossil fuels: Eliminating projecting side mirrors in favor of near-flush cameras reduces the aerodynamic drag on the vehicle thereby increasing its efficiency and reducing its fuel consumption. Fossil fuels are a drain on consumers’ and taxpayers’ purses as well as having other costs to our country.
3) Decrease carbon dioxide emissions: Increased vehicle efficiency reduces CO2 emissions. This is a baby step towards making the world safer from the risks of climate change.
4) Decrease noxious emissions: Increased vehicle efficiency reduces noxious emissions. Surprisingly many vehicle exhaust systems are tampered with resulting in increased public health risk (
Tampered Diesel Pickup Trucks: A Review of Aggregated Evidence from EPA Civil Enforcement Investigations | US EPA). Replacement of the mirrors is one way to decrease emissions in a way that is unlikely to be reversed in the field.
5) Decrease cost:
a. Cameras cost little today. Vehicles increasingly have large display screens and compute power with the cost already being born. Taking away the side mirrors will reduce cost for the manufacturer both for the materials in the mirror (including motors and electronics) and for the manufacture of the mirror. The consumer will potentially save money as well.
b. Side mirrors today are complex mechanical systems. Damage to them, which is not infrequent as they project, can lead to an expensive repair reaching above $1,000.
6) Assist automakers in the transition to battery electric vehicles (BEVs): Battery electric vehicles must be efficient (ideally ~100+ MPGe) to have acceptable range for consumers. The fuel efficiency of new traditional internal combustion engine vehicles in 2019 was 24.9 MPG according the US EPA (
Highlights of the Automotive Trends Report | US EPA). Allowing the replacement of side mirrors with camera systems will help, by virtue of reducing drag, legacy automakers bridge the large gap in efficiency and, thus, help enable them to make more compelling BEV’s.
Cars are being increasingly dependent on digital systems—adding one more is unlikely to make them much, if any less reliable.
Thank you in advance for you attention to my comment.
