disagree concerning your assertion regarding choice of Matrix headlights for cosmetic difference only - is there any factual basis for your claim to the contrary? (I am well aware of Porche’s description of limited functionality of Matrix headlights in the US)

 

I’d say the fact that the configurator explicitly states that the lights are limited to functioning identically to non-matrix PDLS+ is a pretty strong basis... you’re paying for a (debatably) prettier headlamp assembly and that’s it. It’s very clear from the copy on the configurator.

Did I update my build to include the matrix lights on the hope that Porsche or some third party will eventually be able to activate normal matrix functionality? yep. But if it never happens I haven’t been scammed, I’m just a dumbass willing to risk $2k on it.

 

CMVSS allows cars adhering to the ECE standard to be homologated. Current FMVSS and the new rule doesn't as far as I know.

The final rule was only published this month. The published rules in 2018 were draft rules and had underwent revision (see the various comments and responses by NHTSA Section VIII of the final regulatory text).

There are no specific citations from Porsche, but Volkswagen and others mentioned in their filings with the NHTSA that differing requirements between the proposed rule (referred to as NPRM) and ECE/J3069 standards will require different hardware/components/software. Quoting from the final regulatory text:

The NHTSA disagrees, but admits that there will be additional costs:

We shall see how it shakes out, but I won't be surprised if some existing ADB systems are not compliant, since the NHTSA rule demands more stringent tests that may require better (wider view / higher resolution) cameras that current cars may not have.

 

I think this is the key part of Porsche’s disclaimer on the configurator:

”Individual LEDs are programmed to operate as a single light source to perform the functions listed above.”

“Programmed”.

Pretty obvious to me that the activation, to achieve full capabilities of the Matrix system, is a software fix. That said, Porsche can make it happen (even if they want to charge a fee), if they want to. Will they?

 

Activating matrix headlights to EU/Canada standards is a software fix. It remains to be seen whether the existing control program complies with the final rule.

 

that is SIMPLY NOT what the configurator or Porsche marketing literature EVER stated - see post #27 above.

 

the final rule was finalized and published in October 2018 - my assumption would have been that manufacturers would have built the physical characteristics of their lights and sensors to be capable of compliance with that rule, with only software/control to be programmed for final compliance if the rule as ultimately adopted differed from the final proposal.

Is there a different factual basis for your view?

 

There's a whole bunch of us that wondered about why BMW would bother having different spec hardware, but to no avail. It is however well documented, with pictures of the hardware differences to support: https://f80.bimmerpost.com/forums/sh....php?t=1553056

Disclaimer: this by no means implies that Porsche have different hardware between the US and the ROW. It is simply a reply to the post that specified BMW had common hardware across the different markets.

 

to repeat the question - what if any reason is there to think any of that BMW information is relevant in any way to Porsche vehicles?

 

You are wrong. A draft rule (Notice of Proposed Rule Making or NPRM) was published in October 2018. There was then a 2 month comment period where people/companies (everyone from individuals to drive-in theater owners to Volkswagen) can send in comments. You can see the comments here: https://www.regulations.gov/docket/N...-0090/comments

The NHTSA then goes back, reads the comments and redrafts/changes the rule. The final rule was published in the Federal Register on February 22nd 2022. That’s why you see a bunch of articles a few days ago about final approval happening.

Nothing is official until the final rule appears in the Federal Register, so automakers are loathe to build anything according to a draft rule which may change and set all their efforts to waste.

For what it’s worth, there are significant changes between the October 2018 rule and February 2022 final rule regarding glare allowances, measurements, and various tests to determine compliance.

For instance, the October 2018 draft rule had no allowance in transition between high beams and low beams, and automakers complained that it was impossible to achieve in practice in their comments. The final rule allowed for a certain amount of transition so the automakers and headlight manufacturers now know what to target.

 

I appreciate the link to the BMW site, but I’m not going to chase down the facts, by looking at all the comments on the BMW site.

I think the disclaimer, “programming”, on the Porsche’ configuator site is pretty clear. At least it is to me. Furthermore, if it was NOT possible to ever activate, one would think Porsche would, specifically state that. Put this under the heading of, “truth in advertising”.

 

You just said the keyword, "hopefully".

 

the final rule as published in 2022 conformed to the 2018 NPRM version, in any respect that would affect required physical characteristics, as far as I am aware.

care to cite any specific differences to the contrary?

 

To add on, Canadian / European standards are based on the UNECE standards, and the NHTSA has explicitly said in its final rule that the FMVSS standard differs. Even the NHTSA thinks that at least some ADB systems will not comply with its new rules:



It is unclear if the modifications are purely software or require hardware changes.

 

The largest one I can find when I skimmed is the glare/non-glare cutoff.

The 2018 rule does not have any allowance for a transition zone within the cut-off, so technically no headlight will conform to the 2018 rule. The 2022 rule allows for a 1 degree transition, but I don’t know if headlights meet that (they might well, but having a maximum allowed transition zone at all is not specified in either the SAE J3069 or UNECE standard, so manufacturers are unlikely to be targeting this when designing headlights).

There are also other things like the right-hand curve test that the NHTSA mentioned that may cause failures in the compliance test, but without trying to replicate the test setup, I don’t know if it is a hardware or software issue.