NYC-- forget only passive illumination, that is only a bonus. All that counts is combo of active/passive illumination.
Is your active strong enough?
Active Illumination questions?
[ ] -- amber front safety lights at 45 degree angles?
[ ] -- is your rear light at least equal to Cateye TL LD-1000?
[ ] -- is your headlight bright enough for drivers to see you? Don't ask can I see, ask a friend to look at your in your environment and ask "Do I stand out?"
Is your passive illumination enough?
[ ] -- reflective glove spots?
[ ] -- reflective leg accents/stripes?
[ ] -- reflective tape on rims or reflective sidewalls?
[ ] -- additional reflective surfaces on bike rear?
[ ] -- reflective tape outlining bike frame so drivers can instantly recognize this strange object as a bike?
Good luck.