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From:
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NTSB
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To:
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NHTSA
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Date:
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4/26/2021
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Response:
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We note your ongoing research regarding the effectiveness of cameras to deter stop-arm violations and the driver factors contributing to illegal passing. We believe these studies will provide unique insight into why motorists do not stop for school buses; however, we are concerned that the focus of your work is directed toward evaluating drivers’ knowledge of school bus passing laws and their enforcement, rather than toward the recommended technology evaluation. We urge you to consider a research project that addresses technology such as supplemental lighting systems, pedestrian conspicuity, improved vehicle headlight performance, and extended and predictive stop arms, as noted in our Rochester report. Pending such action, Safety Recommendation H-20-11 is classified OPEN-- UNACCEPTABLE RESPONSE.
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From:
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NTSB
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To:
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NHTSA
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Date:
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9/2/2020
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Response:
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The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) notice and request for comments regarding approval for the collection of new information titled “Reducing the Illegal Passing of School Buses” published in 85 Federal Register 43645 on July 17, 2020. NHTSA is seeking comments on two proposed studies to assess driver knowledge about the laws governing passing a school bus. Study 1 is described as a national internet-hosted survey to determine respondents’ knowledge of and attitudes toward these laws, as well as their opinions on the safest driving behaviors when encountering a school bus on the roadway. Study 2 is proposed to be a field study of the effectiveness of school bus camera enforcement combined with high-visibility police enforcement and public education in reducing school bus passing violations.
The NTSB supports NHTSA’s efforts and, based on our school bus-related investigations, offers the following comments relevant to the necessity and practical utility of the proposed collected information.
Recent NTSB Crash Investigations
The NTSB recently completed its crash investigation report Vehicle Collision With Student Pedestrians Crossing High-Speed Roadway to Board School Bus, Rochester, Indiana, October 30, 2018, NTSB/HAR-20/02. Report available here: NTSB/HAR-20/02. In this crash, a pickup truck illegally passed a school bus that was stopped with its warning lights activated and stop arm extended. The pickup truck struck four children who were crossing the 55-mph roadway to board the bus. Three children died and one child was seriously injured.
The NTSB investigated two other fatal pedestrian crashes in 2018 involving illegal passing of school buses. In all three crashes, the school bus route required students to cross high-speed roadways to board the bus. Additional information on these crash investigations can be found by accessing the Docket Management System and searching for NTSB case numbers HWY19IH004 and HW19IH005. Our investigations identified three safety issue areas, including: (1) deficiencies in establishing safe school bus routes and stop locations; (2) failure of other drivers to stop or otherwise respond safely when approaching a stopped school bus with its warning lights activated and stop arm extended; and (3) need for greater use of technologies to prevent collision with, and mitigate injuries of, student pedestrians, including vehicle-to-everything, pedestrian automated emergency braking, and school bus safety-enhancing technologies.
Additionally, the results of a 2019, 1-day observational survey indicated that an estimated 17 million vehicles illegally passed school buses in a 180-day school year. National Association of State Directors of Pupil Transportation Services. 2019. Annual NASDPTS Survey Highlights Danger of Passing School Buses. https://www.isbe.net/Documents/2019-NASDPTS-Release.pdf.In the Rochester crash investigation report, the NTSB concluded that, “Although it is illegal in all 50 states, National Association of State Directors of Pupil Transportation Services data show that the passing of stopped school buses by other vehicles remains a pervasive and continuing safety issue in the United States.” The NTSB issued several safety recommendations related to modifying driver behavior near school buses through enforcement and education, enhancing safety of school bus routes and stops, and using technology to prevent collisions with student pedestrians and to mitigate injuries. For more information, see Safety Recommendations H-20-10 to -21 and H-13-30 and -31 in our database.
Need for and Practical Utility of the Proposed Collected Information
The studies proposed by NHTSA are designed to gather information on driver knowledge about state laws as related to roadway configurations, yellow and red flashing lights on school buses, and activation of the school bus stop arm. The NTSB believes NHTSA’s proposed studies will provide data that are not currently available and will provide insight to guide future efforts for education, advocacy, and research. For example, if the studies find that drivers are informed about state laws, then research efforts can target other methods of assisting drivers, such as implementing and assessing the benefits of various school bus-related technologies. In the Rochester crash investigation report, the NTSB recommended that NHTSA evaluate the effectiveness of technologies designed to reduce the incidence of illegal school bus passings, and publish and disseminate the evaluation. See Safety Recommendation H-20-11.
Separately, NHTSA has indicated that it is finalizing a case study project examining the effectiveness of cameras as a deterrent to school bus stop arm violations. The NTSB hopes the proposed field study of camera enforcement effectiveness described in this notice will be substantially different from the ongoing study and will provide new and distinct findings.
In general, the NTSB is pleased that NHTSA is proposing to study the issue of motorists illegally passing a stopped school bus and supports the proposed studies. We anticipate that these studies, conducted properly, will provide unique insight as to why motorists do not stop for school buses despite activated warning lights and extended stop arms and will help identify countermeasures to address this problem.
The NTSB appreciates the opportunity to provide these comments and supports NHTSA’s efforts in providing national leadership to reduce the illegal passing of school buses and improve school bus safety.
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From:
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NHTSA
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To:
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NTSB
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Date:
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7/7/2020
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Response:
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-From James C. Owens, Deputy Administrator: NHTSA has conducted case studies investigating the effectiveness of cameras as a deterrent to school bus stop-arm violations. This project investigated the use of stop-arm camera programs by examining the prevalence of illegal school bus passing before and after a public information program and implementation of a camera enforcement program. This report is expected to be issued this year.
Illegal passing is a frequent occurrence that can result in severe injury or death to children boarding or disembarking from school buses. To better understand the factors that contribute to illegal passing, NHTSA is engaged in research to evaluate drivers’ knowledge of school bus passing laws and the effectiveness of camera-based enforcement systems, high-visibility enforcement, and targeted media and education efforts. This report is expected to be issued in 2024.
NHTSA requests that recommendation H-20-11 be classified as Open, Acceptable Response.
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From:
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NTSB
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To:
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NHTSA
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Date:
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4/21/2020
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Response:
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The attached letter from the NTSB Chairman provides information about the NTSB’s March 31, 2020, report Vehicle Collision With Student Pedestrians Crossing High Speed Roadway to Board School Bus, Rochester, Indiana, October 30, 2018, NTSB/HAR-20/02. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (for example, H-20-10 and -11). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response.
This letter provides information about the National Transportation Safety Board’s (NTSB) March 31, 2020, report Vehicle Collision With Student Pedestrians Crossing High Speed Roadway to Board School Bus, Rochester, Indiana, October 30, 2018, NTSB/HAR-20/02. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov.
As a result of this investigation, we identified the following safety issues:
• Deficiencies in establishing safe school bus routes and stop locations.
• Failure of other drivers to stop or otherwise respond safely when approaching a school bus that is stopped with its warning lights on and stop arm extended.
• Need for greater use of technologies to prevent collisions with, and mitigate injuries of, student pedestrians, including vehicle-to-everything (V2X), pedestrian automatic emergency braking, and school bus safety-enhancing technologies.
Accordingly, the NTSB makes the following safety recommendations to the National Highway Traffic Safety Administration. Additional information regarding these recommendations can be found in the noted sections of the report.
When evaluating safety self-assessment reports from entities testing automated driving systems on public roads, evaluate how effectively the entities include school bus operations in their plans. (H-20-10) (See section 2.5.1.)
Evaluate the effectiveness of technologies designed to reduce the incidence of illegal school bus passings, and publish and disseminate the evaluation results. (H 20-11) (See section 2.5.3.)
In addition, the NTSB reiterates the following recommendations to the National Highway Traffic Safety Administration.
Develop minimum performance standards for connected vehicle technology for all highway vehicles. (H-13-30) (See section 2.5.1.)
Once minimum performance standards for connected vehicle technology are developed, require this technology to be installed on all newly manufactured highway vehicles. (H-13-31) (See section 2.5.1.)
Incorporate pedestrian safety systems, including pedestrian collision avoidance systems and other more-passive safety systems, into the New Car Assessment Program. (H-18-43) (See section 2.5.2.)
The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendations by number (Safety Recommendations H-20-10 and -11 and Safety Recommendations H-13-30 and -31 and H-18-43). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, please e mail us at the same address for instructions. Please do not submit both an electronic copy and a hard copy of the same response.
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