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Safety Recommendation Details

Safety Recommendation H-01-007
Details
Synopsis: In the past 2 years, the National Transportation Safety Board investigated nine rear-end collisions in which 20 people died and 181 were injured (three accidents involved buses and one accident involved 24 vehicles). Common to all nine accidents was the rear following vehicle driver's degraded perception of traffic conditions ahead. During its investigation of the rear-end collisions, the Safety Board examined the striking vehicles and did not find mechanical defects that would have contributed to the accidents. In each collision, the driver of the striking vehicle tested negative for alcohol or drugs. Some of these collisions occurred because atmospheric conditions, such as sun glare or fog and smoke, interfered with the driver's ability to detect slower moving or stopped traffic ahead. In other accidents, the driver did not notice that traffic had come to a halt due to congestion at work zones or to other accidents. Still others involved drivers who were distracted or fatigued. Regardless of the individual circumstances, the drivers in these accidents were unable to detect slowed or stopped traffic and to stop their vehicles in time to prevent a rear-end collision.
Recommendation: TO THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION: After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Unacceptable Action
Mode: Highway
Location: Washington, DC, United States
Is Reiterated: Yes
Is Hazmat: No
Is NPRM: No
Accident #: 80506
Accident Reports:
Report #: SIR-01-01
Accident Date: 5/25/2001
Issue Date: 5/25/2001
Date Closed: 6/8/2015
Addressee(s) and Addressee Status: NHTSA (Closed - Unacceptable Action)
Keyword(s): Collision Warning Systems,

Safety Recommendation History
From: NTSB
To: NHTSA
Date: 6/8/2015
Response: Safety Recommendation H-01-007 was classified CLOSED--UNACCEPTABLE ACTION in the NTSB's special investigative report "The Use of Forward Collision Avoidance Systems to Prevent and Mitigate Rear-End Crashes." (SIR-15-01, PB2015-104098, Notation 8638, adopted May 19, 2015, published June 8, 2015) The NTSB is disappointed with the lack of progress in the development of performance standards and assessment protocols for forward CAS in commercial vehicles. This lack of progress, however, should not preclude the use of such systems in these vehicle types. Currently available CWS and AEB provide clear benefits, meriting a consideration for their deployment, even without the existence of published performance standards. While the NTSB acknowledges the initial steps NHTSA has taken in the development of performance standards for AEB in heavy trucks, progress has been slow. Performance standards and assessment protocols would further advance these technologies, partly by allowing comparisons between systems. The NTSB, therefore, concludes that performance standards and protocols for the assessment of forward CAS in commercial vehicles would provide an impetus for the advancement of the systems and speed their deployment in commercial fleets. Because of the lack of finalized performance requirements, standards, and testing procedures, the NTSB recommends that NHTSA complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward CAS in commercial vehicles. Due to the insufficient progress on NTSB’s recommendations pertaining to the development of performance standards for CWS in commercial vehicles, and the new recommendations issued in this report instructing NHTSA to develop performance standards and assessment protocols for forward CAS, Safety Recommendation H-01-6 is classified “Closed—Unacceptable Action/Superseded” (superseded by new Safety Recommendation H-15-5). Furthermore, due to NHTSA’s lack of progress in requiring CWS on new commercial vehicles, Safety Recommendation H-01-7 is classified CLOSED--UNACCEPTABLE ACTION.

From: NTSB
To: NHTSA
Date: 3/30/2015
Response:

From: NHTSA
To: NTSB
Date: 12/3/2014
Response: -From David J. Friedman, Deputy Administrator: NHTSA's research program is in progress for Heavy Truck Forward Collision Warnings and Crash Imminent Braking. At this time, NHTSA is not researching Heavy Truck Adaptive Cruise Control. An agency decision on next steps towards developing performance standards for new commercial vehicles is planned for later this year.

From: NTSB
To: NHTSA
Date: 10/16/2014
Response: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration’s (NHTSA) advance notice of proposed rulemaking (ANPRM), entitled “Federal Motor Vehicle Safety Standards: Vehicle-to-Vehicle (V2V) Communications,” published at 79 Federal Register 161 on August 20, 2014. NHTSA proposes to create a new Federal Motor Vehicle Safety Standard (FMVSS), FMVSS No. 150 that would: (1) require V2V communications capability for new passenger vehicles and light trucks and (2) create minimum performance requirements for V2V devices and messages. NHTSA believes this standard would facilitate the development and introduction of advanced vehicle safety applications. While the NTSB appreciates the intent of the proposed rulemaking, we believe the standard should be expanded to include all highway vehicles. Additionally, NHTSA should do more to promote what the ANPRM refers to as “vehicle-resident” safety systems, which are best poised to facilitate future integration with V2V technology, and address the limitations of V2V technology in the initial stages of deployment. Vehicle-resident safety systems. NHTSA acknowledges the benefits of vehicle-resident safety systems in this ANPRM and seeks comments pertaining to their future role in traffic safety, particularly in connection with V2V technology. We have a long history of advocating vehicle-resident safety systems and have issued 12 safety recommendations requiring vehicle manufacturers and regulatory agencies to conduct more research related to their benefits, train drivers on their use, establish performance standards, and require these systems on all new vehicles. As a result of investigating several accidents in which dozens of people were killed and seriously injured, we issued the following safety recommendations to NHTSA: H-01-06 Complete rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. H-01-07 After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system. H-01-08 Complete rulemaking on adaptive cruise control and collision warning system performance standards for new passenger cars. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. H-08-15 Determine whether equipping commercial vehicles with collision warning systems with active braking and electronic stability control systems will reduce commercial vehicle accidents. If these technologies are determined to be effective in reducing accidents, require their use on commercial vehicles. These recommendations have remained open and have been reiterated multiple times in subsequent accident reports. NHTSA expressed several concerns in this ANPRM regarding different safety applications of V2V and vehicle-resident technologies, and the extent to which these technologies can coexist or hinder the other’s advancement. We do not view V2V as a safety technology that competes with vehicle-resident systems, but rather it is another method of providing safety critical information. Two points expressed in this ANPRM are particularly relevant to this issue: • The safety benefits of V2V are likely to be very different in the initial stages of V2V deployment when a small proportion of vehicles would be connected; it would take 15 20 years following the initial deployment before most vehicles on the road are connected. • Human factors research regarding warnings would be applicable, regardless whether the information source is V2V or a vehicle-resident safety system. NHTSA acknowledges that it could take two decades following the initial deployment before the extensive safety benefits of V2V technology would be attained. This leaves a considerable safety gap that should be addressed by current vehicle-resident technology. NHTSA also acknowledges the limited safety benefits of V2V in the initial stages of deployment; the most important limitation is that it would not detect nonconnected vehicles. Vehicle-resident safety systems would address both of these issues. Vehicle-resident safety systems would be invaluable during the early stages of V2V deployment when only a small proportion of vehicles would be connected. Until a level of market saturation is reached, drivers of V2V-equipped vehicles cannot rely on the technology to alert them to conflicts because these vehicles will only be able to connect to a small population of vehicles in use on the highways. A safety system that frequently fails to detect a conflict (even if such a limitation is by design) could easily become an unreliable system in the eyes of the driver. However, a vehicle equipped with both V2V and vehicle-resident safety systems would be able to alert drivers to a larger number of conflicts, even during the early stages of V2V deployment, increasing driver trust in the systems as a whole. In this regard, vehicle-resident safety systems would serve two functions: (1) they would fill the safety gap before the maturation of V2V technology, as these systems can prevent collisions and save lives today; and (2) they would serve as a platform onto which V2V technology would be added. The interface that is part of vehicle-resident systems that warn a driver or apply autonomous emergency braking could also be used by V2V technology. Because vehicle-resident safety systems would see immediate safety benefits and be poised to assume future integration with V2V technology, we believe that the safety benefits of V2V technology would be greater when installed on vehicles equipped with vehicle-resident safety systems and that NHTSA should do more to aid the promotion of vehicle-resident safety systems.

From: NTSB
To: NHTSA
Date: 2/13/2014
Response: CC# 201301266- ANPRM Response to Federal Transit Administration: ANPRM - The National Public Transportation Safety Plan, the Public Transportation Agency Safety Plan, and the Public Transportation Safety Certification Training Program; Transit Asset Management: Although the introduction of the ANPRM states that FTA “intends to focus its initial oversight and enforcement efforts on rail transit systems’ implementation of and compliance with these requirements,” the NTSB would like to provide some additional comments with regard to transit bus safety for FTA’s future planning purposes. As was noted in the ANPRM, the NTSB held an investigative hearing on transit bus safety in March 1998, investigated several transit bus accidents, and issued a Special Investigation Report titled Transit Bus Oversight. The report noted that FTA was unable to identify conditions on buses for the traveling public or resolve any unsafe conditions due to a lack of effective safety oversight and enforcement. In addition, the NTSB questioned the utility of the safety data that was being collected on transit bus safety. Finally, the NTSB was concerned that, at the time, a comprehensive bus safety program was not available to transit agencies outside of APTA’s membership program. Based on the findings of the investigation, the NTSB issued the following safety recommendations to the US Department of Transportation: Develop and implement an oversight program to assess and ensure the safety of transit bus operations that receive Federal funding. (H-98-43) Collect accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. (H-98-44) Evaluate the collected data, as part of the oversight program, to identify the underlying causes of transit bus accidents that could lead to the identification of safety deficiencies at transit agencies. (H-98-45) Develop, in cooperation with the American Public Transit Association, the Community Transportation Association of America, and the American Association of State Highway and Transportation Officials, a model comprehensive safety program(s) and provide it to all transit agencies. (H-98-46) In response, the FTA-sponsored outreach and research efforts to develop a model program for transit bus safety and security. Subsequently, the recommendations were closed with an acceptable response status by the NTSB. Moving forward, however, these recommendations must not be forgotten as data collection and evaluation is an integral component of any safety management program. It is vital that FTA continue to assess and monitor the safety of transit bus operations, including the collection of accurate, timely, and sufficient data so that thorough assessments can be made relating to transit bus safety. Likewise, it is essential that a program be maintained whereas transit bus accidents are thoroughly investigated to identify the underlying causes of crashes so that safety improvements can be implemented in a timely manner. While the NTSB is encouraged that FTA has developed a well-received bus safety program, we are concerned that the program remains completely voluntary and that FTA is unable to ensure that all bus transit agencies are positively affected. In 2013, the safety of bus operations was highlighted as a safety issue area of concern as part of the NTSB’s Most Wanted List. Over the years, the NTSB has made numerous recommendations to the motorcoach and school bus associations, manufacturers, and regulatory agencies such as the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA), which the NTSB believes should be considered when establishing a robust oversight program for bus transit operations. These recommendations address safety concerns such as driver distraction, driver fatigue, medical oversight, fire safety, event data recorders, and vehicle safety equipment. FTA should refer to the NTSB safety recommendations database for additional information. The following are examples of some of the NTSB recommendations which should be considered. Forward Collision Warning Systems To NHTSA: Complete rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. (H-01-6) After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system. (H-01-7)

From: NTSB
To: NHTSA
Date: 7/3/2013
Response: From the Safety Study: Crashes Involving Single-Unit Trucks that Resulted in Injuries and Death, NTSB/SS-13/01, PB13-106637, adopted June 17, 2013, published July 3, 2013: Vehicle-based collision avoidance technologies and advanced vehicle-to-vehicle connectivity, as well as vehicle-to-infrastructure communications, could reduce a variety of different types of crashes involving single-unit trucks. The technologies include lane departure warnings, adaptive cruise control, collision warning systems, and variable message signs to notify drivers of distant traffic congestion. Previous research has demonstrated the value of collision avoidance systems for large trucks (Jermakian 2012). An FMCSA-sponsored evaluation of forward collision warning systems designed to prevent large truck collisions with the rears of other vehicles concluded that motor carriers investing in this technology would experience cost savings within five years of purchasing it for their fleets; these benefits were applicable to both single-unit trucks and tractor-trailers (Murray et al. 2009). Field tests of forward crash, lateral drift, and lane-change/merge collision warning systems conducted by UMTRI “resulted in improvements in lane-keeping, fewer lane departures, and increased turn-signal use” for both tractor-trailers and passenger vehicles (Sayer et al. 2011). These results would also be applicable to single-unit trucks. Additionally, the case reviews conducted in this study pointed to some of these advanced technologies as being beneficial for specific crashes. This study also found that sideswipes posed a high risk of death and injury to passenger vehicle occupants, as did truck frontal impacts; these types of crashes can be mitigated by collision avoidance technologies, including lane departure warning and other warning systems. The NTSB concludes that collisions with the sides and fronts of large trucks could be prevented or mitigated by lane departure systems, adaptive cruise control, and collision warning systems installed on large trucks. Accordingly, the NTSB reiterates its prior recommendations to NHTSA to (1) develop standards for adaptive cruise control and collision warning system performance standards for new commercial vehicles, addressing obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning (Safety Recommendation H-01-6); (2) after promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system (Safety Recommendation H-01-7); and (3) require new commercial motor vehicles with a gross vehicle weight rating above 10,000 pounds to be equipped with lane departure warning systems (Safety Recommendation H-10-1).

From: NTSB
To: NHTSA
Date: 5/28/2013
Response: Notation 8491: The National Transportation Safety Board (NTSB) has reviewed the Federal Communications Commission (FCC) Notice of Proposed Rulemaking (NPRM), which was published at 78 Federal Register 21320 (April 10, 2013). The proposed rule would revise Part 15 of the Commission’s rules to permit operation of Unlicensed National Information Infrastructure (U-NII) devices within the 5 gigahertz (GHz) band. The 5 GHz band, specifically the frequency band between 5.850 and 5.925 GHz, serves as the platform for connected vehicle technologies essential to the advancement of transportation safety. Connected vehicle technologies that rely on Dedicated Short Range Communications Service (DSRCS) systems are operating in the Intelligent Transportation Service (ITS) allocation on the 5 GHz band. Careful attention to interference risk is essential when considering permitting spectrum sharing, as proposed in this NPRM. Since the mid-1990s, the NTSB has advocated intelligent vehicle technologies that rely on radar, vehicle-to-vehicle, or vehicle-to-infrastructure communications. Such technologies include collision warning and collision avoidance systems. The NTSB first addressed collision avoidance during its investigation of a 1995 multivehicle collision in Menifee, Arkansas,1 in which a commercial vehicle entered dense fog, slowed from 65 mph to between 35 and 40 mph, and was then struck from behind. Subsequent collisions occurred as vehicles drove into the wreckage. This accident, which involved eight loaded truck-tractor semitrailer combination units, resulted in five fatalities. Even then, before today’s wirelessly connected world existed, the need to establish dedicated communication airwaves for technologies that could prevent such collisions was recognized. As a result of the Menifee accident, the NTSB issued Safety Recommendation H-95-46 to the FCC, which states as follows: H-95-46 Expedite rulemaking action on the allocation of frequencies that would enhance the development possibilities of collision warning systems. The FCC successfully allocated spectrum for collision avoidance systems, and Safety Recommendation H-95-46 was classified “Closed—Acceptable Action” in 1999. The NTSB is concerned that the proposed rulemaking for spectrum sharing may compromise this necessary spectrum allocation for collision avoidance systems, by increasing the potential for dangerous interference. Since the closure of Safety Recommendation H-95-46, the NTSB has issued several additional safety recommendations concerning technologies that rely on wireless communication in the frequency band established by the FCC in response to Safety Recommendation H-95-46. These include recommendations to the National Highway Traffic Safety Administration (NHTSA) to research, establish performance standards for, and then require, advanced collision avoidance safety technologies on passenger and commercial vehicles. The NTSB issued the following recommendations as a result of investigations into accidents that killed or injured dozens of people. To the National Highway Traffic Safety Administration: H-01-6 Complete rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. H-01-7 After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system. 2 (a) National Transportation Safety Board, Vehicle- and Infrastructure-based Technology for the Prevention of Rear-End Collisions, SIR-01/01 (Washington, DC: National Transportation Safety Board, 2001). (b) National Transportation Safety Board, Truck-Tractor Semitrailer Rear-End Collision into Passenger Vehicles on Interstate 44, Near Miami, Oklahoma, June 26, 2009, HAR-10/02 (Washington, DC: National Transportation Safety Board, 2010). H-01-8 Complete rulemaking on adaptive cruise control and collision warning system performance standards for new passenger cars. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. H-08-15 Determine whether equipping commercial vehicles with collision warning systems with active braking and electronic stability control systems will reduce commercial vehicle accidents. If these technologies are determined to be effective in reducing accidents, require their use on commercial vehicles. These recommendations to NHTSA have been repeatedly reiterated as a result of more recent investigations in which we have seen fatalities and injuries as a consequence of the absence of such accident-prevention technology. These systems have advanced over the years since the NTSB began advocating their development, standardization, and inclusion in modern vehicles. The US Department of Transportation has sponsored voluntary standards, conducted cost-benefit analyses, and begun fleet operational testing. NHTSA analyses show that DSRCS-based connected vehicle technology could address approximately 80 percent of the crash scenarios involving non-impaired drivers.4 Given the progress that has been made by government and industry leaders in this area, such an outcome is a realistic possibility. The NTSB believes that all newly manufactured automobiles and commercial motor vehicles should be equipped with these crucial lifesaving technologies and has made “Mandate Motor Vehicle Collision Avoidance Technologies” a priority on our current Most Wanted List. The implementation of this technological opportunity to improve transportation safety so significantly must not be compromised by issues associated with interference on the 5 GHz band. The NTSB is not opposed to spectrum sharing in principle, but the security of preestablished communication frequencies related to transportation safety must first be ensured. Spectrum sharing could put the frequencies at risk of dangerous interference, and much is still unknown about frequency interference when it comes to vast numbers of connected vehicles in motion. A single incident like the case of interference encountered by the Federal Aviation Administration (FAA) with its Doppler radar could stall progress and cause concern within the industry—or even result in accidents, once these systems are deployed. The National Telecommunications and Information Administration (NTIA) is beginning its evaluation process to test the use of UNII devices on the 5 GHz band. The NTIA 5 GHz report, cited in the subject NPRM, identifies a number of risk elements associated with the likelihood of harmful interference from large numbers of U-NII devices and concludes that further analysis will be required to determine how the identified risk factors can be mitigated. Such analysis should be conducted before safety-sensitive frequencies are opened up to UNII devices. Yet, the need for such analysis will likely delay the widespread deployment of these much-needed safety systems. The NTSB appreciates the opportunity to provide these comments. Given our long history of advocating for collision avoidance technologies, the NTSB is very concerned that the development of these technologies—potentially saving thousands of lives each year—would be put at risk. Consequently, we urge the FCC to ensure that potential delays to the development of the collision avoidance development are considered before UNII devices are allowed to operate in the 5 GHz band and that the key elements of the transportation safety systems that communicate on the same frequency are adequately and reliably protected.

From: NTSB
To: NHTSA
Date: 2/4/2013
Response: We are pleased that NHTSA also believes that CWS has the potential for safety benefits in both commercial and passenger vehicle settings. We recognize the efforts that your agency has made to study the effectiveness of available systems and to develop New Car Assessment Program (NCAP) criteria for the passenger vehicle fleet. We are encouraged by the ever increasing percentage of passenger vehicles that are voluntarily equipped with CWS by industry. This is a positive trend that continues to improve safety on our nation’s highways and helps to educate consumers about the safety benefits of these systems. Despite this progress, we are disappointed that, 12 years after Safety Recommendations H 01-6 through -8 were issued, NHTSA has not yet promulgated the recommended rulemaking to require performance standards and the installation of CWS that meets those standards in all new vehicles. The intent of our recommendations was to establish and require a standard format for CWS, including consideration of ACC, which offers consistent usability for operators and takes into account human performance factors. This intent was expressed in one comprehensive recommendation for the passenger vehicle fleet and in two recommendations for the commercial fleet. In 2008, we recommended that NHTSA evaluate the additional benefit of ESC and active braking systems for those commercial vehicles already equipped with CWS. NHTSA has moved forward with proposed rulemaking on ESC and research on active braking. While the NTSB is encouraged that NHTSA is working on these technologies independently, we urge the agency to link them to the larger CWS issue and include these technologies when requiring the recommended CWS performance standards and implementation. The NTSB remains frustrated by the very slow progress NHTSA is making in its efforts to evaluate CWS and by the lack of rulemaking to require CWS for both the commercial and passenger vehicle fleets. In light of this very slow pace, pending action that addresses the intent of Safety Recommendations H-01-6 through 8, the recommendations remain classified OPEN—UNACCEPTABLE RESPONSE. We note that progress has been made toward the evaluation of the additional technologies recommended in Safety Recommendation H-08-15; accordingly, this recommendation is classified “Open?Acceptable Response.” As we have prioritized this issue by placinG it on our Most Wanted List, we urge NHTSA also to prioritize its work on CWS and move forward with the recommended requirements.

From: NTSB
To: NHTSA
Date: 8/31/2012
Response: Notation 8433: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration’s (NHTSA) notice requesting comments on its research concerning advanced braking technologies that rely on forward-looking sensors, which was published at 77 Federal Register 39561 on July 3, 2012. The NTSB agrees with NHTSA’s assessment that advanced braking technologies show promise for enhancing vehicle safety by helping drivers avoid or mitigate the severity of crashes. Since the mid-1990s, the NTSB has advocated this technology, and this letter summarizes our associated accident investigations, discusses open recommendations, and provides brief comments regarding the development of test protocols. To clarify the terminology being used in our comments, it should be noted that the NTSB’s open safety recommendations in this area use “collision warning systems,” “adaptive cruise control,” and “active braking,” as key technical terms. Technological developments have led to additional terms for describing collision avoidance systems, such as forward collision warning, dynamic brake support, and collision imminent braking. Regardless of their names, these safety systems all rely on forward-look-ahead technologies, enabling progressive warnings, and—in some systems—causing vehicle deceleration to avoid or mitigate a collision using the advanced braking technologies discussed in this request for comments. The NTSB first addressed collision warning technology as a major safety issue during its investigation of a 1995 multivehicle collision in Menifee, Arkansas, in which a commercial vehicle entered dense fog, slowed from 65 mph to between 35 and 40 mph, and was then struck from behind. Subsequent collisions occurred as vehicles drove into the wreckage. The accident, which involved eight loaded truck-tractor semitrailer combination units, resulted in five fatalities. In 2001, the NTSB conducted a special investigation of 9 rear-end accidents that killed 20 people and injured 181. In its investigation, the NTSB explored both vehicle- and infrastructure-based technologies for the prevention of rear-end collisions and discussed the challenges of implementation, consumer acceptance, public perception, and training associated with the deployment of such systems. As a result, the NTSB issued the following safety recommendations to NHTSA: H-01-6 Complete rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. H-01-7 After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system. H-01-8 Complete rulemaking on adaptive cruise control and collision warning system performance standards for new passenger cars. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. The NTSB reiterated Safety Recommendations H-01-6 and -7 to NHTSA, following a 2003 multivehicle collision that occurred on an approach to a toll plaza near Hampshire, Illinois, resulting in eight fatalities. The NTSB again reiterated these recommendations following its investigation of a 2005 accident involving the rollover of a truck-tractor semitrailer combination unit that came to rest blocking both lanes of a dark interstate near Osseo, Wisconsin. In the Osseo accident, the resting combination unit was subsequently struck by a motorcoach transporting a high school marching band, resulting in the deaths of the motorcoach driver and four motorcoach passengers. As a result of its investigation, the NTSB found that insufficient visual cues were present for the motorcoach driver to identify the truck wreckage in time to avoid the collision, concluding, “A collision warning system with active braking might have prevented, or at least lessened the severity of, the motorcoach’s impact with the overturned truck.” In addition, the NTSB also issued another safety recommendation to NHTSA regarding collision warning systems: H-08-15 Determine whether equipping commercial vehicles with collision warning systems with active braking and electronic stability control systems will reduce commercial vehicle accidents. If these technologies are determined to be effective in reducing accidents, require their use on commercial vehicles. The NTSB revisited collision avoidance systems in its investigation of a 2009 accident involving a truck-tractor semitrailer combination unit that rear-ended and overrode slow-moving and stopped passenger cars in a traffic queue, near Miami, Oklahoma. The truck collided with the passenger cars at a high rate of speed without braking, or taking any evasive maneuver, resulting in 10 passenger car occupant fatalities. The NTSB concluded as a result of its investigation that “A forward collision warning system with adaptive cruise control and active braking would have provided the driver with the best opportunity to prevent, or reduce the severity of, the truck-tractor semitrailer’s impact with the passenger vehicles in the traffic queue.” As a result of its investigation, the NTSB reiterated Safety Recommendation H-08-15 and reiterated and reclassified Safety Recommendations H 01 6 and -7 “Open—Unacceptable Response,” due to the lack of timely action to implement this recommendation. Safety Recommendations H-01-6 and -7 were once again reiterated, and Safety Recommendations H-01-8 and H-08-15 were reiterated and reclassified “Open—Unacceptable Response,” after the NTSB’s investigation of a 2010 multivehicle collision involving a commercial vehicle, a passenger vehicle, and two school buses in a traffic queue in Gray Summit, Missouri, that resulted in two fatalities. The reiteration of these recommendations was the result of our findings that forward collision warning systems on the two accident buses—and possibly on the passenger vehicle—could have prevented the accident, or at least mitigated its severity. During the 17 years since NTSB began advocating the use of collision avoidance technologies, these technologies have advanced, and although the U.S. Department of Transportation has sponsored voluntary standards, fleet operational testing, and cost-benefit analyses for collision warning systems and adaptive cruise control, with and without braking, there is still no requirement for these technologies. The manufacturers of these safety systems, which are now widely available on commercial and passenger vehicles, have begun to integrate forward-looking sensors, along with cameras, enabling them to intervene and slow a vehicle without driver input. The NTSB believes that it is long overdue for NHTSA to move forward on rulemaking that will mandate these important lifesaving technologies on all newly manufactured vehicles. The NTSB is aware that research is also being conducted on intelligent vehicle systems, such as vehicle to vehicle and vehicle-to-infrastructure technologies, which could accomplish similar goals to those addressed by collision avoidance technologies. However, since research into these areas has just advanced as far as the collision avoidance area, the NTSB hopes that the exploration of new technology does not hinder rulemaking on already established technologies. Your notice also sought comment regarding false positive brake applications, operational speeds, and system suppressions of advanced braking technologies. The NTSB believes that false positive, or unwarranted, activation of a vehicle’s brakes could not only be dangerous, but also undermine confidence in these systems. We are pleased to see that NHTSA is engaging manufacturers in a discussion of whether false positive activations should be included in the test protocol. The NTSB is also encouraged that NHTSA is exploring a variety of operational speeds and possible system suppression, or deactivation, scenarios; however, we would like to emphasize that it is important to include the largest possible operational speed range and least number of system suppressions in the development test protocol to achieve the greatest reduction in vehicle accidents. The NTSB hopes that accidents, such as those discussed in this letter, can one day be prevented for commercial and passenger vehicles alike. To accomplish this, advanced braking systems must be able to detect and activate under the variety of conditions seen by the NTSB in its accident investigations: inclement weather and fog (Menifee, Arkansas), stationary objects (Osseo, Wisconsin), and slow-moving and stopped traffic (Miami, Oklahoma; Hampshire, Illinois; and Gray Summit, Missouri). The NTSB appreciates the opportunity to provide these comments. Given our long history of advocating the study and implementation of collision warning and crash avoidance technologies, such as advanced braking, we are pleased to see that steps are finally being taken toward a well-thought-out rulemaking in this area.

From: NTSB
To: NHTSA
Date: 8/9/2012
Response: Notation 8429: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration's (NHTSA) Notice of Proposed Rulemaking to establish Federal Motor Vehicle Safety Standard (FMVSS) No. 136, Electronic Stability Control Systems for Heavy Vehicles, as published in Volume 77 of the Federal Register on May 23, 2012. The proposed rule would require truck tractors and certain buses with a gross vehicle weight rating (GVWR) over 26,000 pounds to be equipped with an electronic stability control (ESC) system meeting specified equipment and performance criteria. The NTSB has long advocated the study and implementation of crash avoidance technologies, such as ESC, to assist drivers in maintaining control of commercial motor vehicles. As a result of our investigation of a multivehicle collision in Slinger, Wisconsin, in February 1997, the NTSB recommended that NHTSA conduct research to evaluate the benefits of adding traction control devices to antilock brake systems (H-98-9). Based on NHTSA research for the current rulemaking effort, the NTSB classified this recommendation "Closed-Acceptable Action" in January 2012. In the investigation of a seven-fatal mid-size bus rollover accident in Dolan Springs, Arizona, in January 2009, the NTSB addressed the benefits of equipping buses with a GVWR greater than 10,000 pounds with stability control systems and issued Safety Recommendations H -10-5 and -6 to NHTSA: Develop stability control .system performance standard) applicahle to newly manufactured buses with a gross vehicle weight rating above 10, 000 pounds. (H-10-5) Once the performance standards from Safety Recommendation H-10-5 have been developed, require the installation of stability control systems in all newly manufactured buses in which this technology could have a safety benefit. (H-10-6) Upon completion of another commercial vehicle rollover accident investigation-in Indianapolis, Indiana, in October 2009, involving the rollover of a cargo tank trailer carrying liquefied petroleum gas and a subsequent fire3-the NTSB closed Safety Recommendations H-10-5 and -6 and issued superseding and broader Safety Recommendations H-11-7 and -8 to NHTSA: Develop stability control system performance standards for all commercial motor vehicles and buses with a gross vehicle weight rating greater than 10, 000 pounds, regardless of whether the vehicles are equipped with a hydraulic or a pneumatic brake system. (H-11-7) Once the performance standards from Safety Recommendation H-II-7 have been developed, require the installation of stability control systems on all newly manufactured commercial vehicles with a gross vehicle weight rating greater than 10, 000 pounds. (H-11-8) In the Indianapolis investigation, the NTSB also concluded that a retrofit for stability control systems would be advantageous given the long service life of cargo tank trailers and the potential safety risks posed by the hazardous materials they typically transport. And, because roll stability control (RSC) systems do not require the same integrated sensors and communication systems as ESC, making them more feasible to install as a retrofit, the NTSB issued Safety Recommendation H-11-3 to the Federal Motor Carrier Safety Administration: Require all in-use cargo tank trailers with a gross vehicle weight rating greater than 10, 000 pounds to be retrofitted with a rollover stability control system. (H-1l-3) The proposed rule has assessed the benefits of ESC versus RSC systems, acknowledging that RSC systems lack the ability to affect the directional control of a vehicle in situations of potential rollover. The NTSB agrees with NHTSA that there are additional benefits of ESC over RSC and applauds the research and testing that NHTSA conducted to come to this conclusion. Although NHTSA found that RSC on trailers would save fewer than 10 lives per year and would not be cost beneficial, the NTSB stands by Safety Recommendation H-1l-3 for cargo tank trailers to be retrofitted with RSC systems due to the high potential they hold for catastrophic damage and loss of life in the event of a hazardous materials release. The NTSB recognizes that FMVSS No.l26 requires ESC systems to be in place on light vehicles, and the proposed rulemaking extends the requirement for ESC systems to a large number of heavy vehicles. However, between the upper bounds of FMVSS No. 126, a GVWR of 10,000 pounds, and the lower bounds of the proposed FMVSS No.136, a GVWR of 26,000 pounds, there is a gap where stability control systems will not be required. A vehicle type within this gap that is of particular interest to the NTSB is mid-size buses. The Dolan Springs bus, a mid-size bus with a GVWR of 19,500 pounds, would not be covered in the proposed ESC rulemaking. During its Dolan Springs investigation, the NTSB estimated that the production volume of mid-size buses was 11,600 units per year, on average. Mid-size buses, which are used to transport groups of 16-40 people, should be held to the same--if not higher standards than vehicles used to transport cargo. Mid-size buses also have higher centers of gravity than many other passenger-carrying vehicles, making them more prone to rollover, and therefore more likely to benefit from rollover prevention technologies. The proposed rule also does not address ESC systems for other types of buses, and instead proposes exemptions for buses with fewer than 16 seating positions, buses with limited forward-facing seating configurations (such as limo-buses), urban transit buses, and school buses. We understand that certain exemptions to the rule may be required for slow-moving or specialty vehicles, but when it comes to vehicles that transport people, especially children, the NTSB encourages NHTSA to be as far-reaching as possible when implementing life-saving safety technologies such as ESC. The proposed rule also excludes medium-duty and single-unit trucks, which could benefit from stability control systems. As pointed out in the proposed rulemaking, a safety benefit study applicable to such commercial vehicles is underway, and ESC systems are still in development for medium-duty trucks and buses equipped with hydraulic brakes. The NTSB is pleased to see that steps are underway to equip the largest populations within the commercial vehicle fleet with stability control systems without waiting for their availability on all types of vehicles, but we will continue to advocate that this safety technology be universal. As recognized in the proposed rule, the NTSB has also issued safety recommendations on collision warning with active braking and adaptive cruise control systems, for which ESC systems are required as a baseline technology to enable vehicle braking without driver input. In 2001, the NTSB published a Special Investigation Report of nine rear-end accidents in which 20 people died and 181 were injured,5 and issued Safety Recommendations H-01-6 and -7 to NHTSA: Complete rule making on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. (H-01-6) After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system. (H-Ol-7) At the conclusion of the investigation of an October 2005 accident near Osseo, Wisconsin-involving the rollover of a truck-tractor semitrailer combination unit, which was subsequently struck by a motorcoach-in which 5 people died and 36 were injured,6 the NTSB reiterated Safety Recommendations H-0l-6 and -7 and issued Safety Recommendation H-08-15 to NHTSA: Determine whether equipping commercial vehicles with collision warning systems with active braking and electronic stability control systems will reduce commercial vehicle accidents. If these technologies are determined to be effective in reducing accidents, require their use on commercial vehicles. (H-08-15) We believe that the advancement of crash avoidance and mitigation technologies is dependent on equipping the entire commercial vehicle population with ESC. The NTSB understands that ESC alone cannot prevent all accidents and that conditions such as aggressive steering inputs, excessive speed, and shifting loads limit its effectiveness. For this reason, we encourage NHSTA to not only continue moving forward on accident prevention technologies, but also to develop rollover performance standards to ensure that the static rollover stability of commercial vehicles is considered and optimized in the design and manufacturing stages. The NTSB appreciates the opportunity to comment on this notice. Although we are encouraged by the proposed rulemaking and its effect on a large population of commercial motor vehicles, our open safety recommendations to NHTSA with regard to stability control systems include all commercial motor vehicles and buses with a GVWR greater than 10,000 pounds. Well-designed technology can improve driver performance and overall highway safety, and we will continue to support the development and requirement of such systems until a universal level of safety is realized.

From: NHTSA
To: NTSB
Date: 7/10/2012
Response: -From David L. Strickland, Administrator: NHTSA believes that collision warning systems, such as forward collision warning (FCW), have the potential for safety benefits in a commercial vehicle setting. NHTSA spent a number of years researching FCW to better understand the technology, the circumstances during which the technology best functions, the point at which the FCW intervenes, and the effectiveness of the systems. As such, since 2001, NHTSA and other Department of Transportation (DOT) agencies have completed three separate evaluations of FCW.' When the studies are evaluated in a comprehensive fashion, the work has yielded conflicting results. We believe there are several reasons for this, including insufficient data and system quality. As such, we continue to study and evaluate collision warning systems. Since our last correspondence with NTSB on this recommendation, NHTSA has begun new work with respect to collision warning systems on commercial motor vehicles. We anticipate this new work will address many of the shortcomings experienced with previous studies. We have also expanded our work to include those systems that incorporate active braking. We expect to complete this work by 2013 and will provide an update to NTSB at that time. This work includes the following activities for FCW and collision mitigation systems: • Determination of the applicable target crash population • Performance characterization of current generation • Development of objective test procedures • Development of a model to help predict the safety benefits • Evaluation of driver warning interface designs • The collection of performance, operational and customer acceptance data There are two aspects of H-01-6 and H-01-7 about which NHTSA respectfully disagrees with NTSB. The first involves the classification of Adaptive Cruise Control (ACC) as a safety technology or as a collision warning system.' In order for ACC to prevent a rear end collision, the vehicle must be operating in cruise control. The number of crashes that occur when a vehicle is operating in cruise control is not available in any national database, which makes it extremely difficult and resource-intensive for the agency to determine how widely available ACC is. Similarly, at the present time we cannot determine whether ACC can actually prevent crashes. This technology differs from FCW, in that FCW is always on (unless turned off by the driver) and FCW is intended to operate in a broader range of driving conditions than ACC. This provides a greater opportunity to link FCW performance with crash avoidance. Given these observations, NHTSA is not pursuing regulatory activity for ACC and continues to focus on FCW and crash mitigation systems to improve commercial vehicle safety. The technologies recommended in H-08-15, which will be explained later in this letter, surpass those included in H-01-6 and H-01-7. The former refers to collision warning systems with active braking. Recommendations for H-01-6 and H-01-7 include a specific type of collision warning system - thus a subset of H-08-IS recommended technologies. ACC is a system designed to maintain following distance and is only operable in limited circumstances, whereas the active braking recommended in H-08-15 is operable in a broad range of general driving circumstances. Thus the active braking in H-08-15 surpasses the ACC recommended in H-01-6 and H-01-7. Recommendations for H-08-1 5 include electronic stability control as an additional safety technology, which is not included in the earlier recommendations. Also, your September 9, 2010 letter to NHTSA discusses the Miami crash that prompted H-01-6 and H-01-7. NTSB states that the crash would have been minimized or prevented if the commercial vehicle had FCW and active braking (not just ACC). Thus, NTSB's own analyses of the technologies concludes the greater benefit of active braking over ACC. The second point upon which NHTSA disagrees with NTSB is that H-01-6 and H-01-7 are two unique recommendations. These two recommendations request that the agency pursue identical regulatory activity. Having both of these recommendations active is potentially confusing to the public and inconsistent with NHTSA's regulatory authority. The language in H-01-6, "Complete rulemaking ...." implies the full development and implementation of a Federal motor vehicle safety standard that would include performance requirements for applicable new vehicles to be equipped with the respective equipment. Thus the language in H-OI-07 "require that all new commercial vehicles be equipped ...." pertains to activity already covered by H-01-6. We request closure of H-01-7 given its duplicative nature with H-01-6 and that H-01-6 be classified as Closed - Alternate Action.

From: NTSB
To: NHTSA
Date: 4/24/2012
Response: Notation 8403: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) notice of proposed federal guidelines, "Visual-Manual NHTSA Driver Distraction Guidelines for In-Vehicle Electronic Devices" (proposed guidelines), which was published at 77 Federal Register 11200 (February 24, 2012). The nonbinding, voluntary guidelines represent one component of NHTSA's Driver Distraction Program, and are a useful step toward addressing the problem of driver distraction. Specifically, NHTSA is proposing a long-term, phased approach, through the issuance of guidelines to address the distraction potential of in-vehicle and portable electronic devices (PED). This initial proposal only addresses guidelines for the first of three planned phases and concerns the visual-manual interface of devices installed in vehicles as original equipment. The second phase will include PEDs and aftermarket devices, and the third phase will expand the guidelines to include auditory-vocal interfaces. The NTSB supports NHTSA's efforts to promote attentive driving but is concerned about the rapid migration of potentially distracting navigation, communications, and information and entertainment systems into vehicles. Issuing guidelines is one important step of many necessary to ensure appropriate safety oversight of the design and use of in-vehicle systems, aftermarket devices, and PEDs-which can distract drivers from the critical task of safely operating a motor vehicle. The following are suggestions for NHTSA to maximize the effectiveness of these guidelines. They discuss NHTSA's underemphasis of the cognitive component of operating in-vehicle information systems, the need to record data about in-vehicle communication system use in the event of crashes, the importance of moving quickly toward requiring collision avoidance technologies on all vehicles, and the need to evaluate in-vehicle technologies in large commercial vehicles. Background On March 27, 2012, the NTSB hosted a forum on Attentive Driving: Countermeasures for Distraction that examined countermeasures to mitigate distracted driving behaviors. Forum panelists discussed the findings of distracted driver research, distracted driving laws and enforcement, changing attitudes and behaviors through education and outreach, and technology and design countermeasures. The forum was the culmination of a decade of accident investigations involving distractions in all modes of transportation. The following paragraphs summarize NTSB highway investigations that have resulted in recommendations to reduce driver-distraction-related accidents and fatalities. On August 5, 2010, a highway accident occurred in Gray Summit, Missouri, I in which a pickup truck, whose driver was engaged in texting, rear-ended the back of a tractor and set off a series of collisions that killed two people. On December 13, 2011, as a result of its investigation of the accident, the NTSB called on the 50 states and the District of Columbia to ban the nonemergency use of PEDs while driving (other than those devices designed to support the driving task) for all drivers. The safety recommendation also urged the use of targeted education and enforcement campaigns to support these bans. Also in 2010, near Munfordville, Kentucky,2 a truck-tractor in combination with a 53-foot-Iong trailer left its lane, crossed the median, and collided with a IS-passenger van, resulting in 11 fatalities. The truck driver failed to maintain control of his vehicle because he was distracted by use of his cell phone. As a result of this and previous investigations, the NTSB issued a recommendation that all holders of commercial driver's licenses (CDL) be prohibited from using both hand-held and hands-free cell phones while operating a commercial vehicle, except in emergencies. In 2004, an experienced motorcoach driver failed to move to the center lane and struck the underside of an arched stone bridge on the George Washington Parkway in Alexandria, Virginia. Eleven of the 27 high school students on the bus were injured. The NTSB determined that the probable cause of this accident was the bus driver's failure to notice and respond to posted low-clearance warning signs and to the bridge itself due to cognitive distraction resulting from a hands-free cell phone conversation while driving. The NTSB issued a recommendation that the 50 states and the District of Columbia ban cell phone use by commercial drivers with school bus or passenger endorsements, except in emergencies. In 2002, a novice driver, distracted by a cell phone conversation, crossed the highway median near Largo, Maryland, flipped over, and landed on a minivan, killing five persons. As a result of this investigation, the NTSB issued a recommendation that the 50 states and the District of Columbia prohibit novice drivers from using interactive wireless communication devices while driving. Across all modes of transportation, the NTSB has issued 18 recommendations calling for the prohibition of PED use by aviators, railroaders, mariners, young drivers, and bus and truck drivers. Although the NTSB has not made any specific recommendations on driver distraction related to in-vehicle navigation, communications, or information and entertainment systems, the emergence of new in-vehicle technologies not related to the driving task is of significant concern and should be closely monitored to detect potential adverse effects upon driving performance. Maximizing the Effectiveness of Voluntary Guidelines NHTSA provides a detailed explanation of why it is proposing voluntary guidelines rather than mandatory Federal Motor Vehicle Safety Standards. The NTSB appreciates that the rapid pace of technology evolution cam10t be fully addressed with a static rule. One advantage of guidelines over safety standards is that they present the opportunity to set performance criteria above a minimum acceptable level and do so more quickly than standards would, given the time required for rulemaking. The proposed guidelines are somewhat stronger than current industry guidelines, but NHTSA should set the safety bar even higher. The NTSB urges NHTSA to go beyond its stated expectation of "interfaces that do not exceed a reasonable level of complexity for visual-manual secondary tasks" and strive for more than "discouraging the introduction of egregiously distracting non-driving tasks performed using integrated devices." Instead, NHTSA should be promoting integrated devices that provide a safety benefit, or that at least do not increase the risk in any measureable way. In the absence of a regulatory requirement for in-vehicle information system design, consumers need a method to determine whether a vehicle has a safe design, and manufacturers need incentives to demonstrate that they are meeting or exceeding the guidelines. One such mechanism would be to create a safety marketplace in which automakers compete to provide safer vehicles that meet or exceed the proposed guidelines, as NHTSA has been doing for more than three decades with its New Car Assessment Program (NCAP) five-star safety rating system. Beginning with model year 2011, NHTSA has provided more information about vehicles, indicating whether rated vehicles are equipped with electronic stability control, lane departure warning, and forward collision warning systems. As soon as the proposed Driver Distraction Guidelines are adopted, NHTSA should immediately add to its NCAP information a notice of whether a new car complies with the guidelines and also note those vehicles that do not comply. As NHTSA develops a better understanding of driver distraction and the means to evaluate the effects of in-vehicle systems on driving safety, it should consider developing a more refined rating system akin to NCAP's crashworthiness rating system that considers in-vehicle information systems. Furthermore, NHTSA's experience with evaluating in-vehicle information systems for the purpose of ratings will improve its ability to determine the effectiveness and sufficiency of the guidelines. Phased Approach to Driver Distraction Guidelines NHTSA intends to release the guidelines in three phases. The first phase will explore the visual-manual interfaces of devices installed in vehicles. The second phase will include portable and aftermarket devices, and the third phase will include auditory-vocal interfaces. Although it is understood that NHTSA intends to develop guidelines for aftermarket and PED interfaces immediately following completion of the first phase, it is essential to minimize the delay between phases to avoid (1) migration to systems that are not designed for the driving environment and (2) reliance on voice-based in-vehicle systems with flawed designs that may increase the cognitive distraction of drivers. Specifically, the NTSB is concerned that drivers may increase their use of PEDs due to the restrictions being placed on in-vehicle systems in phase one. Although general usability is a strong consideration in the design of some PEDs, the safety of their use as a secondary task to driving is not a factor in their design. Additionally, automotive and device manufacturers are adding greater connectivity for drivers, and in-vehicle information systems increasingly rely on voice activation. A release of guidelines in 2014 will not address nl0del year 2015 vehicles, further exacerbating the problem that first-generation auditory-vocal interfaces will be in widespread use in on-road vehicles without the benefit of design guidelines. Given the current deployment of in-vehicle computing with voice commands and synthetic speech, NHTSA needs to expedite the roll out of phases two and three. Underemphasis on Cognitive Distraction The NTSB is concerned that the NHTSA Driver Distraction Program is based on the assumption that the primary risk associated with in-vehicle PED use by drivers is visual-manual interaction. It is essential to understand the cognitive demands associated with secondary tasks, particularly auditory-vocal communication tasks, in the context of in-vehicle information and communication devices. As evidenced by the work of panelists attending the recent NTSB forum on countermeasures to distraction, numerous studies have shown that driver distraction occurs during both handheld and hands-free cell phone conversations. 8 NHTSA acknowledges that there is a large amount of research on the topic of driver distraction, yet the guidelines appear to focus on naturalistic driving studies. Particularly, this notice refers to naturalistic driving research that reports that engaging in hands-free phone conversations while driving is safe and provides a protective effect. This finding, from the commercial vehicle naturalistic study, is but one piece of an overall body of research and should be considered within the context of its limitations. Although naturalistic studies provide extremely strong evidence for distraction involving driver behaviors such as visual or manual activities, naturalistic studies, given their dependence on video data, cannot fully assess the cognitive demands associated with hands-free secondary tasks. The measurement of cognitive distraction that does not result in drivers taking their eyes off the road is essential. Both driver performance and brain activity should be assessed to better understand cognitive load. The NTSB findings from its investigation of the 2004 Alexandria, Virginia, motorcoach accident involving the driver's use of a hands-free cell phone are consistent with research showing that drivers conversing on a cell phone-whether handheld or hands-free-are cognitively distracted from the driving task. Need for Improved Event Data The NTSB agrees with NHTSA that efforts are needed to improve the validity and reliability of distracted driving data and believes that such data are necessary both to track the magnitude of distracted driving as a risk factor in accidents and to assess the efficacy of countermeasures. In its notice, NHTSA explains that identifying specific distracting activities and behaviors has presented challenges, partly because police reports may list "other distraction" or "distraction unknown" rather than identifying a specific distraction source, and partly because police may not have enough information to recognize the contribution of distraction to an accident. The NTSB supports NHTSA's ongoing modifications to the Model Minimal Uniform Crash Criteria (MMUCC), which may better capture and classify crashes related to distraction. The proposed 4th edition of the MMUCC currently does not have a specific code to distinguish in-vehicle electronics from PEDs. As integrated devices for navigation, communication, and information and entertainment continue to proliferate in the vehicle fleet, it is critical for NHTSA and others, such as the NTSB and law enforcement, to be able to determine whether drivers were using such systems immediately before or during a crash. Consequently, NHTSA should require manufacturers to include a recording capability in their in-vehicle and integrated systems, such as exists in some vehicles already on the market, to facilitate accident investigation and safety research. NHTSA recognized the value of recording vehicle data in its 2006 rulemaking on vehicle event data recorders (EDR) when it said, "EDR data can provide information to enhance our understanding of crash events and safety system performance, thereby potentially contributing to safer vehicle designs and more effective safety regulations. Crash Avoidance Technologies The proposed guidelines also cite the April 2010 "Overview of the National Highway Traffic Safety Administration's Driver Distraction Program," which summarized steps that NHTSA intends to take "to help eliminate crashes attributable to driver distraction." One of the four initiatives discussed in the program involves keeping drivers safe through the introduction of crash warning or crash avoidance technologies. The NTSB strongly agrees that such systems can prevent or mitigate accidents; and, for more than a decade, we have made recommendations advocating technological solutions to reduce or mitigate collisions for both passenger and commercial vehicles. A large body of evidence now shows that collision warning, lane departure warning, and automatic braking systems are effective, based on research sponsored by the U.S. Department of Transportation, automobile manufacturers, the Insurance Institute for Highway Safety, and other organizations. These systems address driver inattentiveness from all potential sources of distraction, including PEDs. Scope of Guidelines According to the notice, because NHTSA's research focus to date has been on light vehicles, the proposed guidelines are limited to passenger cars, multipurpose passenger vehicles, and trucks and buses with a gross vehicle weight rating of not more than 10,000 pounds. However, considering the significance of large commercial vehicles in overall crash and fatality rates, and given the increasing availability and use of electronic logs, global positioning system, and other potentially distracting systems in these vehicles, the NTSB encourages NHTSA, with the Federal Motor Carrier Safety Administration, to monitor the introduction of in-vehicle technology and aftermarket technology into medium trucks, heavy trucks, and buses, including motorcoaches, and to conduct research as appropriate. Conclusion The NTSB is pleased that NHTSA is moving forward with providing visual-manual guidance to manufacturers, but we view this phased approach as a limited effort, given the varied nature of driver distraction and new car market indications of future in-vehicle information system designs. The NTSB has concerns about the voluntary nature of the guidelines and believes that NHTSA's Distracted Driver Program underemphasizes the role of cognitive distraction. The NTSB also has made safety recommendations concerning crash avoidance technology. We are encouraged to see that NHTSA has included standards for these systems in the NCAP program that, in tum, provide an incentive for vehicle manufacturers to incorporate these technologies in new vehicles. We continue to believe that much could be gained by acquiring data on the use of in-vehicle systems prior to accidents, and we are interested in learning more about NHTSA's plans for evaluating the effects of in-vehicle, aftermarket, and portable systems in all vehicles. Thank you for this opportunity to comment on the proposed guidelines.

From: NTSB
To: NHTSA
Date: 2/8/2012
Response: From the greensheet issuing safety recommendations H-11-36 through H-11-38, which were issued as a result of the August 5, 2010 highway accident in Gray Summit, Missouri: For over a decade, the NTSB has advocated technological solutions to reduce the occurrence of rear-end collisions for both passenger and commercial vehicles. In 2001, the NTSB made the following recommendations to the DOT: Complete rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. (H-01-6) After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system. (H-01-7) Complete rulemaking on adaptive cruise control and collision warning system performance standards for new passenger cars. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. (H-01-8) Following its investigation of a 2005 multifatality accident involving a motorcoach and an overturned truck-tractor semitrailer combination unit on Interstate 94 near Osseo, Wisconsin, the NTSB issued a recommendation to NHTSA requiring FCW systems on commercial vehicles: Determine whether equipping commercial vehicles with collision warning systems with active braking and electronic stability control systems will reduce commercial vehicle accidents. If these technologies are determined to be effective in reducing accidents, require their use on commercial vehicles. (H-08-15) Following the investigation of a 10-fatality accident, when a truck-tractor semitrailer combination unit rear-ended and overrode several passenger vehicles on I-44 near Miami, Oklahoma, the NTSB reiterated Safety Recommendations H-01-6 and -7 to NHTSA and reclassified their status to “Open—Unacceptable Response.”12 The Miami report also reiterated Safety Recommendation H-08-15 to NHTSA, and its status is “Open—Acceptable Response.” Safety Recommendation H-01-8 is currently classified “Open—Acceptable Response.” The DOT has sponsored a variety of research into collision avoidance systems. Much of the passenger vehicle research has been conducted as part of the NHTSA crash avoidance research program in the area of integrated vehicle-based safety systems. Commercial vehicle research has found that 21 percent of rear-end crashes could be prevented with FCW systems alone, and 28 percent of rear-end crashes could be prevented with a combination of FCW and ACC. If all 1.8 million commercial trucks in the United States were equipped with FCW systems, the DOT estimates that 4,700 rear-end crashes, 2,500 injuries, and 96 fatalities could be prevented each year. NTSB investigators were unable to determine whether FCW and ACC could have prevented or mitigated the initial Gray Summit collision because of insufficient information about the actions of the GMC pickup driver. Had the pickup entered the right lane several hundred feet behind the Volvo tractor, an FCW system might have warned the driver in time for him to take evasive action and avoid the collision. Unfortunately, it is not possible to determine from the available evidence when the pickup entered the right lane and how soon after that the initial collision occurred. Had the lead school bus been equipped with an FCW system, it is possible that the driver would have been alerted far enough in advance to take action to avoid the GMC pickup–Volvo tractor collision. An FCW system would have alerted the bus driver to the accident 350 feet ahead. Although the ruptured brake line of the lead bus would not have allowed the driver to stop her vehicle in time, the FCW alert might have given her enough time to swerve to avoid a frontal collision, or at least to mitigate the severity of the impact. Moreover, the activation of brake lights on the rear of the lead bus would have given the driver of the following school bus a readily recognizable cue to initiate braking, and more time and distance to decelerate her vehicle. Had the following bus also been equipped with an FCW system, the bus driver would have been alerted to the slowing or stopped vehicles ahead. The braking cues of the lead bus and the FCW alerts might have allowed her to avoid the collisions ahead, regardless of the involvement of the lead bus. The NTSB concluded that FCW systems on the two accident buses—and possibly on the GMC pickup—could have prevented the accident or at least mitigated its severity. Because NHTSA has not yet completed rulemaking requiring FCW systems on private and commercial vehicles, and because the NTSB continues to investigate serious accidents that could have been prevented or mitigated with FCW systems, the NTSB reiterates Safety Recommendations H-01-8 and H-08-15 to NHTSA and reclassifies each recommendation "Open--Unacceptable Respone." The NTSB also reiterates Safety Recommendations H-01-6 and -7 to NHTSA.

From: NTSB
To: NHTSA
Date: 9/28/2010
Response: Written in the Miami, Oklahoma Accident Report (NTSB/HAR-10/02 PB2010-916202) In its 2001 special report on technology for the prevention of rear-end crashes,187 the NTSB reported that, in 1999, the DOT had begun operational testing of ACC systems and FCWSs for cars and trucks. The NTSB also reported that rear-end collisions accounted for 1.8 million crashes in 1999, including 1,923 fatal crashes. Of the fatal crashes, 770 involved commercial vehicles (trucks weighing more than 10,000 pounds and motorcoaches). Thus, CMVs were involved in 40 percent of the fatal rear-end crashes, even though they accounted for only 3 percent of vehicles and 7 percent of miles traveled. Although the NTSB has acknowledged that an FCWS is not intended to replace driver vigilance, such a system can aid drivers when they are distracted or fatigued, or when their attention is concentrated on something other than the road ahead. The NTSB concluded that accident statistics and the investigation findings indicate that accident consequences are more severe when commercial vehicles are involved in rear-end collisions and that the public can benefit from technology designed to help prevent such collisions. As a result, in its special report, the NTSB asked the DOT to implement Safety Recommendations H-01-06 and -07. Safety Recommendation H-01-6 is on the NTSB Most Wanted List of Transportation Safety Improvements in the issue area “Prevent Collisions by Using Enhanced Vehicle Safety Technology.” Deployment of vehicle collision avoidance technology has been on the Most Wanted List since November 2007. In the Miami accident, an FCWS alert could have drawn the accident driver’s attention to the hazard ahead, which was the slowing traffic. The truck-tractor semitrailer was traveling about 103 feet per second. With the maximum available warning detection distance of 350 feet provided by an FCWS, the Miami accident driver would have received a warning from the system about 3.40 seconds before striking the rear of the slowly moving traffic queue. Within this 3.40-second warning period, the driver would have to have (1) been effectively alerted; (2) comprehended the severity of the alert and the situation ahead; and (3) mechanically executed a reaction, including moving his foot from its rest location (the cruise control was engaged) and placing it on the brake and applying maximum (emergency) braking immediately. If any time (and distance) had remained from the 3.40 seconds after (1) through (3) above, it could have gone toward slowing the vehicle or enabling the driver to take an evasive action to mitigate the impact force of the tractor semitrailer upon the passenger vehicles.189 It should be noted that, for an alert driver,190 the average projected reaction time to an unexpected situation can range from 0.75 second to about 2.50 seconds for a 90th percentile driver.191,192 Research supports that, in the middle of this range, drivers have a perception reaction time to a common but unexpected stimulus (such as the unanticipated brake lights of a car ahead) of about 1.25 seconds.193 Given a reasonably clear and straightforward situation, most drivers will respond within 1.50 seconds of the first appearance of an object or condition of concern;194 they will react to a surprise event (such as an object moving unexpectedly into the vehicle’s path) in 1.50 to 1.75 seconds.195 Some FCWSs are equipped with ACC,196 which uses the same detection technology as the FCWS to adjust or disengage the conventional cruise control when it is in use. An active braking system that can automatically apply the foundation brakes197 of the vehicle is also an available technology. If a collision is deemed imminent, an FCWS with active braking does not wait for the driver to react; in such a critical situation, braking is applied automatically to reduce the severity of the impending collision. Once active braking is initiated to mitigate the accident (not when initiated to slow the vehicle to maintain following distance, such as with the ACC), it also may be referred to as “collision mitigation braking” or CMB. When these technologies are bundled together, they are often referred to as “collision mitigation systems.” If the Miami accident truck had been equipped with an FCWS that included an active braking system, the driver’s reaction time would not have been a factor—only the brake lag time would have contributed to the distance traveled before maximum braking was achieved. An FCWS alone or bundled with ACC and active braking could have significantly affected the outcome of the Miami accident, depending on a number of factors, including the point at which the system detected the Land Rover ahead of it. The unloaded truck-tractor semitrailer had a gross weight of 40,400 pounds (a loaded truck-tractor semitrailer can weigh up to 80,000 pounds). Most cars weigh less than 4,000 pounds. Thus, when a commercial truck strikes a passenger car in the rear, the large difference in mass between the vehicles means that this impact most likely will not bring the heavy truck to a stop or even slow it appreciably; consequently, the impact itself does relatively little to keep the truck from continuing to move and to involve more vehicles.198 An FCWS can reduce the risk of these rear-end crashes by identifying fast-closing speed situations and providing the driver with additional time to react. It should be noted that ACC systems are designed to maintain a predetermined199 following interval behind another vehicle, thereby providing more time to resolve driving conflicts to reduce the probability of a rear-end collision.200 An FCWS with active braking can begin to decelerate a vehicle automatically, having the added benefit either of reducing the speed of the vehicle if the driver does not intervene or of supplementing deceleration before the driver applies braking. Active braking systems, such as the Bendix Wingman ACB (active braking with cruise control) and the Meritor WABCO OnGuard, do not apply the foundation brakes at the full emergency brake application level that a driver can. FCWS Scenarios To illustrate some possible scenarios for this accident under different circumstances, the NTSB worked with several FCWS manufacturers201 and developed some potential outcomes had the accident truck been equipped with an FCWS alone or bundled with ACC and/or active braking. Three of the possible outcomes are presented below. NTSB investigators were unable to determine the speed of the Land Rover just prior to its being struck by the Volvo; therefore, the first two of the following scenarios are based on witness interviews indicating either that the struck vehicles were stopped in traffic or that the Land Rover was moving slowly (just over 10 mph). The third instance is the “best case” scenario, in which the Land Rover was just beginning to decelerate from the posted speed limit of 75 mph when the Volvo FCWS detected it at 70 mph, with the Volvo 350 feet or more behind it. All calculations in the scenarios and tables below considered a roadway coefficient of 0.65 g deceleration for the Volvo and an initial truck speed of about 70 mph. They also assumed the postaccident inspection condition of the brakes, which were within adjustment limits, on the truck-tractor semitrailer. An air brake lag time of 0.50 second was used, in addition to the driver perception reaction times of 2.50, 1.50, and 0.75 seconds. The term “distance to decelerate” used in the tables below is the distance between the accident truck-tractor and the Land Rover when the truck driver receives the first FCWS alert. The “warning time” is the time the truck driver would have between the first FCWS alert and the estimated impact. Scenario 1—FCWS and Land Rover Stopped. Had the Land Rover, the first vehicle struck by the Volvo truck, been stopped (stationary) in the traffic queue, an FCWS on the Volvo could have detected it at either 308 or 350 feet,202 calculated the closing distance, and sounded an audible alert. Table 7 shows the reductions in impact speeds possible, had the Volvo truck driver perceived the meaning of the alert and reacted, given the 0.75- to 2.50-second range of driver perception reaction time to the FCWS warning. This table shows the possible outcomes using FCWS alone, without the added benefit of ACC or active bra The Volvo driver, although he was fatigued, was not incapacitated, and had he received an alert warning from an FCWS, he might have reacted with emergency braking. The accident truck could not have slowed down tremendously, given the assumption of a 2.50-second perception reaction time and the stopped traffic ahead. Under such circumstances, it can be estimated that the impact speed range would be 70 to 64 mph. If the FCWS alert had immediately redirected the driver’s attention to the traffic ahead, and the driver had reacted very quickly, faster reaction times of 1.50 and 0.75 second would have reduced the impact speed to a range of 56 to 39 mph. Although 56- and 39-mph impacts are significant, they are less severe than a 70-mph impact. In addition, at the lower speeds, the Volvo driver might even have been able to take evasive steering action to avoid or mitigate the accident. The driver could have attempted an evasive maneuver, such as steering to the right, onto the roadway’s paved shoulder, or even off the road and onto the grassy right-hand right-of-way, to prevent striking the passenger vehicles. Scenario 2—FCWS and Land Rover Moving Slowly. Had the Land Rover been moving slowly in traffic at 10 mph, the truck-tractor combination unit would have gained an additional 44 to 50 feet of distance over which to decelerate in this scenario, depending on the warning and perception reaction times used. The radar-based FCWSs would have detected the Land Rover at a range of 350 feet: one system would have emitted the audible alert at 350 feet, while another would have calculated the closing distance and sounded an audible alert at approximately 318 feet in closing distance. The camera-based system would have detected the slowly moving Land Rover at a following distance period of 3.00 seconds, which equates to 308 feet, and would have emitted an alert at this distance. Table 8 shows that, had the traffic ahead been moving slowly, affording the Volvo truck a longer time and greater distance over which to decelerate, the impact speed of the truck could have been reduced to 38 mph under the most conservative reaction and warning time assumptions. Assuming a quicker driver reaction time of 1.50 seconds, the Volvo’s impact speed could have been reduced to a range of between 24 and 14 mph. Given a driver reaction time of 0.75 second, the impact speed might have been reduced to as low as 9 mph, or the impact might even have been avoided. One manufacturer indicated that with a bundled system on the Volvo truck, consisting of an FCWS with ACC and active braking, the driver could have brought the vehicle to a stop if he had applied 0.60 g emergency braking approximately 2.00 seconds after the active braking system engaged. In this scenario, the active braking itself might have alerted the driver to the impending hazard and caused him to initiate an appropriate response. According to the manufacturer, even if the driver had not initiated any emergency braking but the Volvo had been so equipped, this system might have been able to initiate CMB and slow the Volvo to an impact speed range of 48 to 53 mph without any driver action. Scenario 3—FCWS With Bundled System and Land Rover Beginning to Decelerate From 75 mph When the FCWS Detects it at 70 mph. Both of the scenarios described above assume that the Volvo truck-tractor was 350 feet behind the Land Rover (or any other vehicle) when the FCWS detected it as stopped or slow-moving traffic. If, instead, both vehicles were traveling about 70 mph when the truck’s FCWS detected the Land Rover—with at least 350 feet of separation distance—and the FCWS had been tracking the Land Rover when it began to slow in response to the traffic queue, this could have affected the accident outcome significantly. In this case, if the Volvo truck had been equipped with an FCWS with ACC and active braking, the system would have automatically slowed the Volvo to a preset safe following distance (one manufacturer’s default setting is 3.60 seconds) without driver input. Further, once the system detected that the vehicle ahead was continuing to slow, the Volvo with the FCWS, ACC, and active braking would have maintained the 3.60-second following distance by continuously slowing. When the Land Rover reached 0 mph, the Volvo truck-tractor semitrailer would also have slowed to 0 mph at a distance of 32 feet behind the Land Rover, thus entirely preventing the accident. The above “best case” scenario illustrates what might have been possible in the Miami accident with a vehicle equipped with an FCWS with active braking; under these very specific circumstances, such a system could have prevented an accident without any driver input.203 As discussed earlier, the Volvo’s impact speed generated tremendous kinetic energy, which was dissipated when it collided with the slower moving passenger vehicles, causing them catastrophic damage. Kinetic energy is the mathematical expression of the truck’s maximum ability to do damage.204,205 Because kinetic energy is proportional to the square of the vehicle speed, the energy of the impacting vehicle and its ability to do damage decline quickly as speed is reduced. Table 9 below shows the amount of kinetic energy that the accident Volvo had at about 70 mph, when it struck the passenger vehicles, as well as the amount it would have had with the incremental reduction in speed provided either by an FCWS alone or by an FCWS with a bundled system, as described above. A reduction in speed from about 70 to 50 mph would have cut the kinetic energy of the impacting heavy commercial vehicle in half. Further reducing the impact speed to 39 mph would have caused an energy reduction of nearly 70 percent. The scenario of the FCWS system bundled with ACC and active braking, without any input from the driver, could have resulted in a reduction in speed from about 70 to 39 mph at impact. (See table 9.) Depending on variables (such as the speed and distance of the vehicles ahead of the Volvo truck), even a bundled system might not have provided the fatigued Volvo driver sufficient time to react to the warning, brake the vehicle, and prevent the accident. However, it could have provided enough time for him to react, brake, and mitigate the severity of the accident or perhaps to avoid the collision through steering inputs. It might not have been possible to bring the heavy Volvo truck-tractor semitrailer to a complete stop with FCWS and related technologies before any collision occurred. However, as can be seen in table 9, the slower the truck had been traveling at impact, the lower the kinetic energy involved in the accident and the less severe the damage to the struck passenger vehicles would have been. This scenario most likely would have resulted in less severe injuries to the occupants of those vehicles. In fact, if the Volvo truck-tractor had been equipped with an FCWS bundled with ACC and active braking, assuming that scenario 3 circumstances had existed in the seconds before the accident, it is possible that the system could have entirely prevented the accident. Therefore, the NTSB concludes that an FCWS with ACC and active braking would have provided the driver with the best opportunity to prevent, or reduce the severity of, the truck-tractor semitrailer’s impact with the passenger vehicles in the traffic queue. The NTSB considers that installing new technologies in CMVs—such as FCWSs, ACC, active braking, and ESC—has the potential to reduce accidents substantially. Following the investigation of an October 2005 accident in which five people were killed when a motorcoach collided with an overturned truck-tractor semitrailer combination unit on Interstate 94 near Osseo, Wisconsin,206 the NTSB issued Safety Recommendation H-08-15 to NHTSA. Since February 26, 2010, Safety Recommendation H-08-15 has been “Open—Acceptable Response.” Also in the Osseo report, the NTSB reiterated Safety Recommendations H-01-6 and -7 to NHTSA. In a letter dated June 4, 2009, NHTSA responded to these NTSB recommendations by providing an update on its current projects evaluating the application of various technologies for commercial trucks and motorcoaches. NHTSA is conducting a test track evaluation of commercially available CMB systems and has indicated that an initial evaluation of their performance capabilities will be completed in 2010. A NHTSA project to evaluate the potential safety benefits of active braking systems is expected to be completed in 2011. Based on these reports of progress from NHTSA, Safety Recommendations H-01-6 and -7 were classified “Open—Acceptable Response.” Due to their high mileage exposure207 and the severity of crashes involving them, combination-unit trucks have the highest crash cost per vehicle over the operational life of the vehicle; therefore, FCWSs may provide a relatively higher safety benefit for this class of trucks.208 However, government and industry entities are still conducting operational testing and encouraging voluntary implementation of FCWSs. Although the work being done by private industry and the government is encouraging, the slow pace of testing and standards development and the limited deployment of FCWSs in commercial vehicles are cause for concern, given the large number of rear-end collisions and the high rate of fatalities that result when commercial vehicles are involved. For years, the NTSB has been advocating the implementation of in-vehicle systems that enhance the safety of heavy vehicles, both by mitigating accident severity and preventing accidents altogether. Safety benefits are often not the result of one system on its own; more often, it is the synergy of systems working together that can prevent and mitigate a larger percentage of accidents, resulting in the greatest reduction of highway injuries and fatalities. Although FCWS use within a heavy vehicle is crucial to provide warning of an impending collision, integrating this safety system with related technologies would provide even greater opportunity for preventing accidents, as well as for reducing the severity and frequency of rear-end accidents. The NTSB considers that FCWSs have great promise and that the added feature of active braking increases their potential for preventing accidents. However, the pace of NHTSA’s progress in this vital area has been too slow. Because NHTSA is still evaluating these systems and is not yet near rulemaking that would require them to be used in commercial vehicles, the NTSB reiterates Safety Recommendations H-01-6 and -7 and H-08-15. Further, although the NTSB acknowledges that NHTSA has made some progress in conducting research in this area, due to the lack of timely completion of the recommended actions, Safety Recommendations H-01-6 and -7 are reclassified OPEN – UNACCEPTABLE RESPONSE. The status of Safety Recommendation H-08-15 remains “Open – Acceptable Response.”

From: NTSB
To: NHTSA
Date: 2/26/2010
Response: As of 2001, the DOT had established an Intelligent Vehicle Initiative (IVI) as a major component of the Intelligent Transportation System program. The goal of this initiative was to improve significantly the safety and efficiency of motor vehicle operations by reducing the probability of motor vehicle crashes. As part of the IVI, NHTSA evaluated the performance of CWS and ACC by participating in field operational tests of vehicles equipped with advanced safety systems. In May 2005, NHTSA released the results of its passenger vehicle testing in its Automotive Collision Avoidance System Field Operational Test Final Program Report, which showed the potential for reducing rear-end crashes by 10 percent and reported positive user reaction to the systems. The final report on the commercial vehicle field testing, Evaluation of the Volvo Intelligent Vehicle Initiative Field Operational Test, conducted for the DOT by Battelle and Volvo Trucks North America, Inc., was released in January 2007 and indicated that a combined CWS and ACC bundled safety system would account for a statistically significant reduction in rear-end crashes through reduced exposure to safety-critical driving scenarios. In November 2005, the DOT entered into a cooperative research agreement with a private consortium led by the University of Michigan Transportation Research Institute to build and field test an integrated vehicle-based safety system (IVBSS) designed to prevent rear-end, lane-change, and run-off-the-road crashes. From November 2005 to April 2008 (the first phase of the IVBSS program), activities focused on system specification and the design, development, and construction of prototype vehicles. The next phase of the program included a field operational test (FOT) using 16 passenger cars and 10 commercial trucks equipped with a prototype integrated crash avoidance system that includes forward crash, lateral drift, and lane-change/merge warnings. Testing is expected to be completed in 2010. The purpose of the FOT is to evaluate the suitability of a state-of-the-art integrated CWS for widespread deployment in the U.S. passenger car and commercial-truck fleet. In 2006, the Federal Motor Carrier Safety Administration (FMCSA), in cooperation with the American Trucking Associations’ Technology and Maintenance Council, completed functional specifications and recommended practices for ACC and forward collision warning (FCW) systems. The specifications provide driver-vehicle interface requirements and guidance on the following: pre-crash scenarios an FCW system should detect, detection distance, human factors, and operational use by drivers and fleets. The FMCSA initiated research to evaluate the use of FCW, lane departure warning (LDW), and electronic stability control (ESC) in truck fleets in 2009. The study is scheduled for completion in 2011. In July 2008, NHTSA announced final enhancements to its government safety ratings program for passenger vehicles (commonly known as NCAP); these enhancements include providing information for the first time on selected crash avoidance technologies so that consumers can use the information in their purchasing decisions. The technologies that will be highlighted include the following: ESC, two CWSs, FCW, and LDW. Test protocols to ensure minimum levels of performance such as the pre-crash scenarios that the systems should detect, detection distance, and the timing of alerts were included in the final decision notice. NHTSA continues to study the human factors issues associated with these and other warning systems to determine best practices for the type and mode of warning. NHTSA, along with its cooperative partners the Federal Highway Administration, the FMCSA, and the Research and Innovative Technology Administration, continues to make steady progress toward addressing this important technological safety issue and satisfying the intent of Safety Recommendations H-01-6 through -8. Although the preliminary results of the testing on advanced safety systems are encouraging, the NTSB continues to believe that rulemaking is needed to ensure uniformity of system performance standards (such as obstacle detection, timing of alerts, and human factors guidelines) on new passenger and commercial vehicles. As much of the technology available today did not exist when these safety recommendations were issued, Safety Recommendations H-01-6 through -8 remain classified OPEN -- ACCEPTABLE RESPONSE pending the completion of such rulemaking.

From: NTSB
To: NHTSA
Date: 7/17/2009
Response: NMC# 103304: The NTSB notes that NHTSA has results showing an overall safety benefit for CWS gathered from (1) a field test of adaptive cruise control (ACC) and forward crash warning (FCW) systems as part of the U.S. Department of Transportation’s (DOT) Intelligent Transportation System (ITS) Program, in cooperation with the Federal Highway Administration, the Federal Motor Carrier Safety Administration (FMCSA), Volvo Trucks, and U.S. Express, using the Battelle Institute as an independent evaluator, and (2) a study conducted in conjunction with the Virginia Tech Transportation Institute (VTTI) using vehicle proximity sensing data collected during a previous heavy-truck/drowsy-driver study. The ITS field test showed that the benefit was derived from a reduction in driver exposure to safety-critical events and not from preventing crashes once a vehicle was actually involved in a rear-end, pre-crash scenario. The VTTI study, however, showed the opposite: that the source of benefit is prevention of crashes during a safety-critical event. Because the source of the benefit differed between the ITS field test and the VTTI study, NHTSA does not believe that it has sufficient certainty of the safety benefits at the current time to justify rulemaking and is conducting additional work before taking this step. The NTSB is aware that, in November 2005, the DOT entered into a cooperative research agreement with a private consortium led by the University of Michigan Transportation Research Institute to build and field test an integrated vehicle-based safety system (IVBSS) designed to prevent rear-end, lane-change, and run-off-the-road crashes. During the first phase of the IVBSS program, from November 2005 to April 2008, activities focused on system specification and the design, development, and construction of prototype vehicles. The next phase of the program includes plans for a field operational test using 16 passenger cars and 10 commercial trucks equipped with a prototype integrated crash avoidance system that includes forward crash, lateral drift, and lane-change/merge warnings. NHTSA anticipates that the testing should be completed in 2009. The purpose of the testing is to evaluate the suitability of a state-of-the-art integrated CWS for widespread deployment in the U.S. passenger car and commercial-truck fleet. NHTSA also is working with the FMCSA to monitor the real-world benefits realized by early-adopter truck fleets of technologies including ACC, FCW, and lane departure warning systems. In 2006, the FMCSA, in cooperation with the American Trucking Associations’ Technology and Maintenance Council, completed functional specifications and recommended practices for ACC and FCW systems. The specifications provide driver-vehicle interface requirements and guidance on the following: pre-crash scenarios an FCW system should detect, detection distance, human factors, and operational use by drivers and fleets. The NTSB is also aware that NHTSA continues to study the human factors issues associated with these and other warning systems to determine best practices for the type and mode of warning. Although NHTSA appears to be working consistently, albeit slowly, on this important technological safety issue and preliminary testing results are encouraging, the NTSB continues to believe that rulemaking is needed to ensure uniformity of such advanced safety system performance standards as obstacle detection, timing of alerts, and human factors guidelines as these standards relate to new commercial vehicles. Accordingly, pending completion of rulemaking to require that all new commercial vehicles be equipped with a CWS, Safety Recommendation H-01-7 remains classified OPEN -- ACCEPTABLE RESPONSE. We would appreciate receiving periodic updates on NHTSA’s progress in addressing this recommendation.

From: NHTSA
To: NTSB
Date: 6/9/2009
Response: Letter Mail Controlled 6/9/2009 4:15:57 PM MC# 2090360: - From Ronald L. Medford, Acting Deputy Administrator: Thank you for your February 2 letter regarding the National Transportation Safety Board’s (NTSB) Safety Recommendation H-08- 15 and reiterations of H-0 1-06 and H-01-07. Safety Recommendation H-08-15 requested that the National Highway Traffic Safety Administration (NHTSA) determine whether equipping commercial vehicles with collision warning systems that incorporate active braking and electronic stability control systems will reduce commercial vehicle crashes. NTSB recommends that the agency require their use on commercial vehicles. Safety Recommendation H-01-06 asks the agency to initiate rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, you believe that these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. Safety Recommendation H-0 1-07 states that after promulgating performance standards for collision warning systems for commercial vehicles, the agency should require that all new commercial vehicles be equipped with a collision warning system. NHTSA shares NTSB’s desire to improve commercial vehicle safety and the promise that advanced technologies such as stability control, forward collision warning, and crash mitigation technologies hold in doing so. We have several projects underway that are not only evaluating the application of these different technologies for commercial trucks but also for motorcoaches and similar high passenger carrying vehicles where a single crash has the potential to result in multiple injuries .and fatalities. I am pleased to provide you with an update on these activities. Directly related to H-01-06 and H-01-07, are NHTSA’s activities in the Department’s Intelligent Transportation System (ITS) Program. As you stated, NHTSA, in cooperation with the Federal Highway Administration (FHWA) and the Federal Motor Carrier Safety Administration (FMCSA), have completed a Field Operational Test (FOT) on a system that comprised Adaptive Cruise Control (ACC), Forward Crash Warning (FCW), and air disc brakes. While the results did provide some insight, unfortunately they were not conclusive. Furthermore, because it relies on the driver to activate the cruise control to receive any safety benefit, we believe that ACC in its current form is a driver convenience system and not a safety system. Additional research has been initiated by FMCSA this year to monitor and evaluate the realworld experience of truck fleets that are using FCW, lane departure warning, and electronic stability control (ESC) systems. The study is due to be completed in 2011. Regarding H-08- 15, NHTSA recently initiated research on collision warning systems that incorporate active braking, and we are continuing our work on stability control systems. NHTSA has accelerated its work on stability control systems for commercial vehicles with research completing in late 2009 on truck tractors, and 2010 for single unit trucks and buses. Collision warning systems that incorporate active braking, also known as Collision Mitigation Braking (CMB) systems, not only provide the functionality of FCW, but also initiate braking prior to a reaction from the driver. NHTSA is currently conducting a test track evaluation of commercially available CMB systems and an initial evaluation of their performance capabilities will be completed in 2010. In addition, a project to evaluate the potential safety benefits of CMB systems is expected to be completed in 20 1 1. While NHTSA understands the basis for H-01-06 and H-0 1-07 and fully appreciates that H-01 -06 is on the Most Wanted List, we believe that recommendation H-08-15 is largely duplicative of those and appears to supersede those previous recommendations, based upon more recent information. Based on our efforts to date, NHTSA’s research and regulatory decision activities are focused on what we believe to be the most promising safety technologies for commercial vehicles. These include stability control systems, and systems that combine FCW capability with active braking (e.g. CMB systems). Given the above updates, NHTSA respectfully suggests that the board change the status of H-01 -06 and H-0 1-07 to Open Acceptable Alternative Action and the status of H-08- 15 to Open Acceptable Action.

From: NHTSA
To: NTSB
Date: 6/4/2009
Response: Letter Mail Controlled 6/9/2009 4:15:57 PM MC# 2090360: See MC 2080627]: - From Ronald L. Medford, Acting Deputy Administrator: As part of DOT’S Intelligent Transportation System (ITS) Program, NHTSA, in cooperation with the Federal Highway Administration and the Federal Motor Carrier Safety Administration (FMCSA) completed a Field Operational Test (FOT) of Adaptive Cruise Control (ACC) and Forward Crash Warning (FCW). The industry partners were Volvo Trucks and U.S. Express. The results of the FOT were analyzed by the Battelle Institute as an independent evaluator. In addition, NHTSA recently completed a study with the Virginia Tech Transportation Institute (VTTI), which used the vehicle proximity sensing data (measured by the sensing portion of a commercial forward crash warning system) collected during a heavy truck drowsy driver study to augment the benefit estimates. The results, showed an overall safety benefit, however, the source of the benefit differed from the initial ITS FOT. The Volvo FOT showed that the benefit was due to a reduction in driver exposure to safety critical events and not in preventing crashes once a vehicle was actually involved in a rear end pre-crash scenario. The VTTI study showed the opposite, that the source of benefit is prevention of crashes during a safety critical event. Given the differing findings of the research to date and the large statistical confidence bounds, NHTSA does not believe that it has sufficient certainty of the safety benefits at the current time to justify rulemaking and is conducting additional work. NHTSA has an ITS-sponsored field operational test underway aimed at evaluating the benefits of an integrated vehicle based safety system. This integrated system includes an FCW component. This FOT should be completed in 2009 and provide the additional safety benefits data that is needed before making a regulatory decision. NHTSA is also working with FMCSA to monitor the real-world benefits accruing to early adopter truck fleets of technologies including ACC, FCW, and Lane Departure Warning systems. FMCSA plans to initiate further crash reduction benefit studies in 2009. With respect to developing requirements for ACC/FCW systems, FMCSA worked with the American Trucking Associations’ Technology and Maintenance Council to develop functional specifications and recommended practices for these systems. Functional specifications were completed in 2006 and are available on FMCSA’s website http://www.fmcsa.dot.gov/. The specifications provide guidance on the pre-crash scenarios an FCW system should detect, detection distance, and human factors information and guidelines pertaining to operational use by drivers and fleets, as well as driver-vehicle interface requirements.

From: NTSB
To: NHTSA
Date: 2/2/2009
Response: The Safety Board reiterated Safety Recommendations H-01-6 and -7 to NHTSA as a result of its investigation of a 2003 multivehicle collision at a toll plaza near Hampshire, Illinois.7 The Board determined that the probable cause was a truck driver who was driving too fast for conditions and failed to slow for traffic. The Board concluded that the driver did not detect the slowing traffic ahead of his vehicle and that, had his vehicle been equipped with a CWS, the accident might have been prevented. In its responses to the Safety Board concerning these recommendations, NHTSA reported that the USDOT had established the intelligent vehicle initiative and was undertaking studies to collect the field operational test data needed to establish performance standards. These studies have been completed.8 Further, in 2005, the Federal Motor Carrier Safety Administration (FMCSA) published voluntary performance standards for CWSs for commercial vehicles, which address functional, data, hardware and software, driver vehicle interface, and maintenance and support requirements. The Safety Board added the prevention of rear-end collisions through the use of CWSs and ACC to its Most Wanted List of Transportation Safety Improvements in November 2007. NHTSA has been working consistently, though slowly, on this issue. It has recently published its report on the field operational test conducted by Battelle and Volvo Trucks North America, showing a reduction in rear-end crashes. The Safety Board has not received any information on NHTSA’s interpretation of the commercial vehicle testing or a timeline for future NHTSA actions to mandate use of this technology. Rulemaking as requested in Safety Recommendation H-01-6 is needed to ensure uniformity of system performance standards, such as obstacle detection, timing of alerts, and human factors guidelines on commercial vehicles. Safety Recommendations H-01-6 and -7 are currently classified OPEN -- ACCEPTABLE RESPONSE. A CWS with active braking might have prevented or lessened the severity of the impacts in the Osseo and Lake Butler accidents. In both cases, even if the driver had not reacted to the CWS, either because he was asleep or driving while impaired from fatigue (Lake Butler) or because he did not see the object in the roadway (Osseo), a system with active braking could have stopped or slowed the vehicle before it collided with the stationary vehicle in its path. If a collision is deemed imminent, an active braking CWS does not wait for the driver to react. Braking is applied automatically in this critical situation to reduce the severity of the impending collision. It should be noted that the Safety Board is aware of some limitations of CWS with active braking. For instance, a radar system can detect the speed differential between two moving vehicles, but it has more difficulty distinguishing a stopped object, such as debris in the road or a stalled vehicle. Industry representatives have indicated that they are cautiously moving ahead in this area of technology. CWSs alert the driver to hazardous situations and often require the driver to take evasive action, such as hard braking or rapid steering. In the case of a CWS with active braking, application of maximum braking occurs when a collision is imminent. When evasive actions are taken either by the driver or the system (such as through active braking), the stability of the vehicle is critical, especially for commercial vehicles, because they are typically large and heavy, and have relatively high centers of gravity. Such vehicles may become unstable when hard braking is applied in slippery conditions or if the driver steers rapidly to avoid a collision. Actions taken to avoid a rear-impact collision or a collision with a fixed object may result in a directional loss of control of the vehicle or in a rollover, which could be even more hazardous than the collision the driver is attempting to avoid. Therefore, the Safety Board concludes that because commercial vehicles, which typically have high centers of gravity, are prone to become unstable when they are hard-braked or steered suddenly to avoid a collision, CWS-equipped commercial vehicles should also be equipped with an electronic stability control (ESC) system addressing both roll and directional stability. Both active braking and ESC technologies represent opportunities for significant enhancement of CWSs’ capabilities to prevent (or mitigate) commercial vehicle accidents. Therefore, the Safety Board recommends that NHTSA determine whether equipping commercial vehicles with CWSs with active braking and ESC systems will reduce commercial vehicle accidents. If these technologies are determined to be effective in reducing accidents, NHTSA should require their use on commercial vehicles. In addition, the Safety Board reiterates Safety Recommendations H-01-6 and -7 to NHTSA, which recommend that NHTSA complete rulemaking on ACC and CWS performance standards for new commercial vehicles (H-01-6), and once the CWS standards have been developed, that NHTSA require that all new commercial vehicles be equipped with a CWS (H-01-7).

From: NHTSA
To: NTSB
Date: 10/8/2008
Response: Letter Mail Controlled 10/15/2008 2:36:30 PM MC# 2080627: - From David Kelly, Acting Administrator: DOT Regulatory Status: As part of DOT’S Intelligent Transportation System (ITS) Program, NHTSA, in cooperation with the Federal Highway Administration and the Federal Motor Carrier Safety Administration (FMCSA) completed a Field Operational Test (FOT) of Adaptive Cruise Control (ACC) and Forward Crash Warning (FCW). The industry partners were Volvo Trucks and U.S. Express. The results of the FOT were analyzed by the Battelle Institute as an independent evaluator. In addition, NHTSA recently completed a study with the Virginia Tech Transportation Institute (VTTI), which used the vehicle proximity sensing data (measured by the sensing portion of a commercial forward crash warning system) collected during a heavy truck drowsy driver study to augment the benefit estimates. The results, showed an overall safety benefit, however, the source of the benefit differed from the initial ITS FOT. The Volvo FOT showed that the benefit was due to a reduction in driver exposure to safety critical events and not in preventing crashes once a vehicle was actually involved in a rear end pre-crash scenario. The VTTI study showed the opposite, that the source of benefit is prevention of crashes during a safety critical event. Given the differingfindings of the research to date and the large statistical confidence bounds, NHTSA does not believe that it has sufficient certainty of the safety benefits at the current time to justify rulemaking and is conducting additional work. NHTSA has an ITS- sponsored field operational test underway aimed at evaluating the benefits of an integrated vehicle based safety system. This integrated system includes an FCW component. This FOT should be completed in 2009 and provide the additional safety benefits data that is needed before making a regulatory decision. NHTSA is also working with FMCSA to monitor the real-world benefits accruing to early adopter truck fleets of technologies including ACC, FCW, and Lane Departure Warning systems. FMCSA plans to initiate further crash reduction benefit studies in 2009. With respect to developing requirements for ACC/FCW systems, FMCSA worked with the American Trucking Associations’ Technology and Maintenance Council to develop functional specifications and recommended practices for these systems. Functional specifications were completed in 2006 and are available on FMCSA’s website http://www.fincsa.dot.gov/. The specifications provide guidance on the pre-crash scenarios an FCW system should detect, detection distance, and human factors information and guidelines pertaining to operational use by drivers and fleets, as well as driver-vehicle interface requirements.

From: NTSB
To: NHTSA
Date: 9/16/2008
Response: From the accident report of a truck-tractor semitrailer rollover and motorcoach collision with overturned truck interstate highway 94 near Osseo, Wisconsin (report adopted 9/16/2008): The Safety Board published a special investigation report concerning CWSs in 2001. In it, the Safety Board asked the USDOT to H-01-6 Complete rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. H-01-7 After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system. Although the recommendations were originally issued to the USDOT, further communication with the USDOT indicated that NHTSA was the most appropriate agency to implement the recommendations. The Safety Board reiterated Safety Recommendations H-01-6 and -7 to NHTSA as a result of its investigation of a 2003 multivehicle collision at a toll plaza near Hampshire, Illinois.138 The Board determined that the probable cause was a truck driver who was driving too fast for conditions and failed to slow for traffic. The Board concluded that the driver did not detect the slowing traffic ahead of his vehicle and that, had his vehicle been equipped with a CWS, the accident might have been prevented. In its responses to the Safety Board concerning these recommendations, NHTSA reported that the USDOT had established the intelligent vehicle initiative and was undertaking studies to collect the field operational test data needed to establish performance standards. These studies have been completed. Further, in 2005, the FMCSA published voluntary performance standards for CWSs for commercial vehicles, which address functional, data, hardware and software, driver vehicle interface, and maintenance and support requirements. The Safety Board added the prevention of rear-end collisions through the use of CWSs and ACC to its Most Wanted List of Transportation Safety Improvements in November 2007. NHTSA has been working consistently, though slowly, on this issue. It has recently published its report on the field operational test conducted by Battelle and Volvo Trucks North America, showing a reduction in rear-end crashes. The Safety Board has not received any information on NHTSA’s interpretation of the commercial vehicle testing or a timeline for future NHTSA actions to mandate use of this technology. Rulemaking as requested in Safety Recommendation H-01-6 is needed to ensure uniformity of system performance standards, such as obstacle detection, timing of alerts, and human factors guidelines on commercial vehicles. Safety Recommendations H-01-6 and -7 are currently classified “Open—Acceptable Response.” A CWS with active braking might have prevented or lessened the severity of the impacts in the Osseo and Lake Butler accidents. In both cases, even if the driver had not reacted to the CWS, either because he was asleep or driving while impaired from fatigue (Lake Butler) or because he did not see the object in the roadway (Osseo), a system with active braking could have stopped or slowed the vehicle before it collided with the stationary vehicle in its path. If a collision is deemed imminent, an active braking CWS does not wait for the driver to react. Braking is applied automatically in this critical situation to reduce the severity of the impending collision. It should be noted that the Safety Board is aware of some limitations of CWS with active braking. For instance, a radar system can detect the speed differential between two moving vehicles, but it has more difficulty distinguishing a stopped object, such as debris in the road or a stalled vehicle. Industry representatives have indicated that they are cautiously moving ahead in this area of technology. CWSs alert the driver to hazardous situations and often require the driver to take evasive action, such as hard braking or rapid steering. In the case of a CWS with active braking, application of maximum braking occurs when a collision is imminent. When evasive actions are taken either by the driver or the system (such as through active braking), the stability of the vehicle is critical, especially for commercial vehicles, because they are typically large and heavy, and have relatively high centers of gravity. Such vehicles may become unstable when hard braking is applied in slippery conditions or if the driver steers rapidly to avoid a collision. Actions taken to avoid a rear-impact collision or a collision with a fixed object may result in a directional loss of control of the vehicle or in a rollover, which could be even more hazardous than the collision the driver is attempting to avoid. Therefore, the Safety Board concludes that because commercial vehicles, which typically have high centers of gravity, are prone to become unstable when they are hard-braked or steered suddenly to avoid a collision, CWS-equipped commercial vehicles should also be equipped with an ESC system addressing both roll and directional stability. Both active braking and ESC technologies represent opportunities for significant enhancement of CWS capabilities to prevent (or mitigate) commercial vehicle accidents. Therefore, the Safety Board recommends that NHTSA determine whether equipping commercial vehicles with CWSs with active braking and ESC systems will reduce commercial vehicle accidents. If these technologies are determined to be effective in reducing accidents, NHTSA should require their use on commercial vehicles. In addition, the Safety Board reiterates Safety Recommendations H-01-6 and -7 to NHTSA, which recommend that NHTSA complete rulemaking on adaptive cruise control and CWS performance standards for new commercial vehicles (H-01-6), and once the CWS standards have been developed, that NHTSA require that all new commercial vehicles be equipped with a CWS (H-01-7).

From: NTSB
To: NHTSA
Date: 11/9/2006
Response: The Safety Board notes that NHTSA is participating in a cooperative partnership with the Research and Innovative Technology Administration, the Federal Highway Administration, the Federal Motor Carrier Safety Administration, and industry partners (a group known as the Intelligent Transportation System [ITS] Program) to evaluate the performance, commercialization, and voluntary deployment of advanced safety system technologies. The Board further notes that two field operational tests (FOTs), conducted to collect the data needed to assess the viability of establishing performance standards for both passenger and commercial vehicles related to ACC and CWS systems, have been completed. NHTSA has indicated (1) that the results of its passenger vehicle testing, released in May 2005, titled Automotive Collision Avoidance System Field Operational Test Final Program Report, show the potential of the technology to reduce rear-end crashes by 10 percent and (2) that users had a positive reaction to the systems. The Board understands that the final report on the passenger vehicle FOT results is now available on NHTSA's Web site and that further research continues to refine system performance. The Board also notes that the final report and NHTSA's interpretation of the commercial vehicle FOT is expected to be released in February 2007; we would appreciate receiving copies when they become available. The Safety Board is encouraged by the preliminary results of the testing on advanced safety systems and encourages NHTSA and the ITS Program partners to continue working on this important technological safety issue. Accordingly, pending development of rulemaking on standards and equipment and requirement of the technology in commercial vehicles, Safety Recommendations H-01-6 through -8 remain classified OPEN -- ACCEPTABLE RESPONSE.

From: NTSB
To: NHTSA
Date: 5/8/2006
Response: The National Transportation Safety Board reiterated this recommendation as follows in its Highway Accident Report: Multivehicle Collision on Interstate 90, Hampshire-Marengo Toll Plaza, Near Hampshire, Illinois, October 1, 2003 (HAR-06-03): On July 6, 2005, NHTSA responded to the Safety Board that the DOT had established an intelligent vehicle initiative (IVI) as a major component of the ITS program and was evaluating the performance of ACC and CWS. The goal of the IVI is to improve the safety and efficiency of motor vehicle operations by reducing accidents through the use of advanced driver assistance systems, such as ACC and CWS. To achieve this objective, NHTSA-along with the Federal Highway Administration and the Federal Motor Carrier Safety Administration-completed field operational tests to evaluate the performance of advanced safety systems under normal fleet conditions and released the results report in August 2005. According to NHTSA, it is evaluating the results data to determine how to improve commercial vehicle safety, which will allow it to further address the Safety Board's recommendations; a final report was expected to be published in fall 2005. The Safety Board replied to NHTSA on October 31, 2005, informing it that the status of the recommendations will remain OPEN -- ACCEPTABLE RESPONSE pending publication of the final report on the field operational tests, application of test results to improve commercial and passenger vehicle safety through the use of ACC and CWS, and development of IVI performance standards. As of April 1, 2006, the Safety Board is still awaiting the final report from NHTSA. Although NHTSA has finished field operational tests and awarded grant funds for further research, it has been 5 years since the Safety Board issued the recommendations pertaining to collision warning technology. According to NHTSA's program milestones, full evaluation of the safety benefits of vehicles equipped with safety systems to address multiple crash types will not be completed until 2009-10 years after the Safety Board held its public hearing on existing ITS technology that could help prevent rear-end accidents. Accidents such as the Hampshire rear-end collision, with high loss of life, underscore the need for NHTSA to move forward more expeditiously. The National Transportation Safety Board therefore reiterates Safety Recommendations H-01-6 and -7 to the National Highway Traffic Safety Administration. As a result of this accident investigation, the Safety Board issued new safety recommendations to the U.S. Department of Energy, the U.S. Department of Transportation, the Federal Motor Carrier Safety Administration, the Federal Highway Administration, the American Association of State Highway and Transportation Officials, and the International Bridge, Tunnel and Turnpike Association.

From: NHTSA
To: NTSB
Date: 4/13/2006
Response: Letter Mail Controlled 4/20/2006 10:55:50 AM MC# 2060209: - From Jacqueline Glassman, National Highway Traffic Safety Administration: Thank you for your correspondence of October 31, 2005, addressing three recommendations to the National Highway Traffic Safety Administration (NHTSA) relating to adaptive cruise control (ACC) and collision warning systems (CWS). I am pleased to respond and to present recent NHTSA activities related to the below-referenced National Transportation Safety Board (NTSB) recommendations. During the May 2005 Safety With A Team (SWAT) meeting, and subsequent July 2005 correspondence, NHTSA advised the NTSB that our efforts in achieving the goals of these recommendations are predicated on the research sponsored by Department of Transportation's Intelligent Transportation System (ITS) Program. The ITS program is a cooperative partnership among Research and Innovative Technology Administration, NHTSA, the Federal Highway Administration and the Federal Motor Carrier Safety Administration, with industry partners. With respect to Adaptive Cruise Control and Collision Warning Systems, the partnership is focusing its efforts in three particular areas, including: 1)Evaluating the performance of several advanced safety systems, including ACC and CWS, through Field Operational Test (FOT) programs; 2)Accelerating the commercialization and voluntary deployment of advanced safety system technologies; and 3)Forming mutually beneficial commercial partnerships to advance the safety of motor vehicles NHTSA has completed two FOT programs that specifically seek to collect some of the empirical and behavioral research data necessary to assist us in assessing the viability of establishing performance standards related to ACC and CWS systems. The first program involves testing of a passenger vehicle safety system, while the second FOT tests a commercial vehicle safety system. Commercial Vehicle Safety System FOT The heavy vehicle FOT has been completed, but the results have not yet been published. The Final Report is under agency review and is expected to be published by July 2006. We will share this report with you when it is completed, along with our interpretation of any potential issues or implications from the preliminary data analysis. Based on that information, NHTSA will then decide on the appropriate next steps and will keep the NTSB apprised accordingly. Based on the agency's recent and anticipated research in the areas of ACC and CWS, we request the retention of the current "Open, Acceptable Response" status for these three recommendations. I hope this information is helpful. If you have any questions regarding the agency's programs on ACC and CWS, please have your staff contact me or Ronald L. Medford, Senior Associate Administrator for Vehicle Safety, at (202) 366-1810.

From: NTSB
To: NHTSA
Date: 10/31/2005
Response: At the SWAT meeting, NHTSA updated Safety Board staff on the status of its research on ACC and CWS. NHTSA staff explained that Active Safety Technology is its focus for the future, and its fiscal year 2006 budget includes funding for advanced, more objective test procedures. Although cost is currently a major constraint to widespread installation of advanced safety systems, certain technologies, such as ACC and CWS, are already available in high-end vehicle models and on commercial vehicles; research shows that ACC and CWS reduce the number of commercial vehicle drivers involved in critical situations. Safety Board staff suggested that NHTSA also send a written update on the progress made on these recommendations. In its July 6, 2005, letter, NHTSA indicated that, as part of the U.S. Department of Transportation's Intelligent Vehicle Initiative (IVI), the agency has participated with the Federal Highway Administration and the Federal Motor Carrier Safety Administration in field operational tests, which involved commercial vehicles equipped with advanced safety systems, including ACC and CWS. NHTSA reported that the test program has been completed, and that it expects the final report to be published in fall 2005. NHTSA is currently evaluating the test data to determine how to use its findings to improve commercial vehicle safety, which will allow the agency to further address Safety Recommendations H-01-6 through -8. The Safety Board encourages NHTSA to include the development of performance standards for IVI technologies in its evaluation of the test program results. Accordingly, pending publication of the final report on the field operational test, application of the test results to improve commercial and passenger vehicle safety through the use of ACC and CWS, and development of IVI performance standards, Safety Recommendations H-01-6 through -8 remain classified OPEN -- ACCEPTABLE RESPONSE. The Safety Board looks forward to additional updates from NHTSA regarding continued progress on IVI research.

From: NHTSA
To: NTSB
Date: 7/6/2005
Response: Letter Mail Controlled 7/12/2005 3:33:41 PM MC# 2050315: - From Jeffrey W. Runge, M.D., Administrator: Thank you for your correspondence of April 27, 2005, addressing three recommendations to the National Highway Traffic Safety Administration (NHTSA) relating to adaptive cruise control (ACC) and collision warning systems (CWS). I am pleased to respond and present recent NHTSA activities related to the referenced National Transportation Safety Board recommendations. H-01-6: Complete rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. H-01-7: After promulgating performance standards for collision warning systems for commercial vehicles, require that all new commercial vehicles be equipped with a collision warning system. H-01-8: Complete rulemaking on adaptive cruise control and collision warning system performance standards for new passenger cars. At a minimum, these standards should address obstacle detection distance, timing of alerts, and human factors guidelines, such as the mode and type of warning. The U.S. Department of Transportation has established an Intelligent Vehicle Initiative (IVI) as a major component of the Intelligent Transportation System (ITS) program. The agency, in cooperation with Federal Highway Administration (FHWA) and Federal Motor Carrier Safety Administration (FMCSA), is evaluating the performance of ACC and CWS as part of IVI. The goal of IVI is to improve the safety and efficiency of motor vehicle operations by reducing crashes through the use of advanced driver assistance systems, such as ACC and CWS. To achieve this objective, NHTSA has participated with FHWA and FMCSA in Field Operational Tests, which involve vehicles equipped with advanced safety systems, including ACC and CWS. The primary objectives of the Field Operational Tests were: 1) to evaluate the performance of advanced safety systems, including ACC and CWS, under normal fleet operational conditions; 2) to accelerate commercialization of advanced safety system technologies by showing positive cost/benefit relationship in commercial vehicle revenue generating operations; and 3) to form mutually beneficial partnerships to advance the operating safety, efficiency, and productivity of commercial trucking. The Field Operational Test program has been completed, and the agency expects the final report to be published in fall 2005. The agency is presently evaluating the data to determine how to utilize its findings to improve commercial vehicle safety, which will allow us to further address these recommendations. NHTSA recommends that Safety Recommendations H-01-6 through -8 remain classified as "open acceptable response".

From: NTSB
To: NHTSA
Date: 4/27/2005
Response: Safety Recommendations H-01-6 through -8 were originally issued to the DOT on May 25, 2001, and were subsequently transferred to the Federal Motor Carrier Safety Administration (FMCSA) for action. Although an initial response was received from the National Highway Traffic Safety Administration (NHTSA) on August 15, 2001, no response has been received from the FMCSA. As part of the Safety Board's effort to follow up on these recommendations, Board staff contacted staff in the DOT Office of Transportation Policy, who indicated that NHTSA is the most appropriate DOT modal office to respond to these recommendations and concurred that the recommendations should be reassigned to NHTSA. Accordingly, Safety Recommendations H-01-6 through -8 have been reassigned to NHTSA; they remain in an OPEN -- ACCEPTABLE RESPONSE status. The Safety Board looks forward to hearing from NHTSA regarding the progress that has been made on adaptive cruise control and collision warning system performance standards for both commercial vehicles and new passenger cars since NHTSA's initial response to this recommendation.

From: NTSB
To: NHTSA
Date: 11/26/2001
Response: The Safety Board notes that the goal of the Intelligent Vehicle Initiative (IVI) established by the DOT is to reduce motor vehicle crashes through the use of advanced driver assistance systems, such as collision warning systems (CWS) and adaptive cruise control (ACC). Your letter indicates that in order to accomplish this objective, NHTSA is participating in field operational tests, which involve vehicles equipped with advanced safety systems, including CWS and ACC, to (1) evaluate the performance of these advanced safety systems, (2) accelerate commercialization of advanced system safety technologies, and (3) form partnerships to advance the operating safety, efficiency, and productivity of commercial trucking. We would appreciate periodic updates on the field operational test program, which is scheduled to be completed in 2003. The Safety Board understands that the results of the field operational tests are critical to the development of performance standards, some of which are critical to reducing operator confusion. The Safety Board expressed its concern in our May 25, 2001, recommendation letter that relying on the industry to require that its trucks be equipped with these advanced systems is an ineffective strategy; we note, however, that the emphasis in your letter is on that very strategy. We encourage you to reconsider this approach upon completion and review of the field operational tests. Responses from many automobile and truck manufacturers regarding H-01-9 indicate enthusiasm about working with you in the future to inform drivers of the benefits, use, and effectiveness of these systems. Given the ongoing activities related to ACC and CWS, Safety Recommendations H-01-6 through -9 are classified OPEN -- ACCEPTABLE RESPONSE, pending receipt of a further response to the Safety Board.

From: NHTSA
To: NTSB
Date: 8/15/2001
Response: (This recommendation was originally issued to the FMCSA; after consultation with the DOT, the recommendation was transferred to NHTSA as the most appropriate DOT agency to implement the recommendation - MC 2010675) - From L. Robert Shelton, Executive Director: The Department of Transportation has established an Intelligent Vehicle Initiative (IVI) as a major component of the Intelligent Transportation System (ITS) program. The agency, in cooperation with Federal Highway Administration, Federal Motor Carrier Safety Administration, and Federal Transit Administration, is evaluating the performance of CWS and ACC as a part of the IVI. The goal of the IV1 is to reduce motor vehicle crashes through the use of advanced driver assistance systems, such as CWS and ACC. The intent of the IVI is to improve significantly the safety and efficiency of motor vehicle operations by reducing the probability of motor vehicle crashes. To accomplish this objective, NHTSA is participating in field operational tests, which involve vehicles equipped with advanced safety systems, including ACC and CWS. The primary objectives of the field operational tests are: 1) To evaluate the performance of advanced braking, collision warning, ACC, and diagnostic/prognostic advanced safety systems under normal fleet operational conditions. 2) To accelerate commercialization of advanced safety system technologies by showing positive cost/benefit relationship in commercial vehicle revenue generating operations, 3) To form mutually beneficial partnerships to advance the operating safety, efficiency, and productivity of commercial trucking. The field operational test program has been initiated and is scheduled to be completed by 2003. These field operational tests will quantify the benefits and effectiveness of these systems. When the information from the field operational tests becomes available, the agency will evaluate the data to determine how to develop a program to inform the public and commercial drivers on the benefits, use, and effectiveness of CWS and ACC, and evaluate the need for rulemaking, if warranted.