Dear Assemblymember Chu:
I regret that I must write on behalf of the California Association of Bicycling Organizations (CABObike.org) in opposition to your bill, AB 28 unless modified to better enhance traffic safety.

We recommend modifying the proposed change to CVC 21201 to allow a steady as well as a flashing red rear light, to retain the red rear reflector requirement, and to remove the option for substituting reflective clothing for the required red light and reflector. We make these recommendations for several reasons.
1. A steady red rear light is standard for all vehicles, internationally the solid red light means a unit of traffic in front is moving in your direction. This is standard for bicycles in many states. While a flashing light can be said to draw attention, it is easier and more likely for people to accurately judge the distance away from a steady light rather than an intermittently flashing light.
2. A reflector does not rely on external power, battery or dynamo, and is therefore always available to reflect back.
3. The description “Reflective gear” to be worn by the bicyclists does not provide enough specificity to provide for sufficiently conspicuous reflectivity. Also reflective material such as jerseys, jackets, etc. are worn by regular bicycles above the level of headlights and when worn by people using recumbent bicycles are not in position to reflect back.

We recommend that AB 28 be amended to change CVC 21201 (d. 1 & 2) as shown below.
(d) A bicycle operated during darkness upon a highway, a sidewalk where bicycle operation is not prohibited by the local jurisdiction, or a bikeway, as defined in Section 890.4 of the Streets and Highways Code, shall be equipped with all of the following: (1) A lamp emitting a white light that, while the bicycle is in motion, illuminates the highway, sidewalk, or bikeway in front of the bicyclist and is visible from a distance of 300 feet in front and from the sides of the bicycle. (2) A flashing or steady red light visible from a distance of 300 feet in back of the bicycle, and a red reflector on the rear that shall be visible from a distance of 500 feet to the rear when directly in front of lawful upper beams of headlamps on a motor vehicle. The reflector may be an integral part of the light.

Thank you for considering our recommendations.
Sincerely,
Jim Baross
CABO President