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Safety Recommendation Details

Safety Recommendation H-01-008
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: 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.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Alternate 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 - Acceptable Alternate Action)
Keyword(s): Adaptive Cruise Control,

Safety Recommendation History
From: NTSB
To: NHTSA
Date: 2/16/2016
Response: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) request for comments (RFC), “New Car Assessment Program,” published at 80 Federal Register 241 on December 16, 2015. NHTSA proposes to expand the New Car Assessment Program (NCAP) to include 5-star safety ratings for crashworthiness, crash avoidance technologies, and pedestrian protection systems. NHTSA believes that the proposed enhancements to NCAP will keep pace with technological advancements and provide consumers with thorough evaluation criteria for current safety technologies. The NTSB appreciates the merits of the intended changes to NCAP and supports NHTSA in this endeavor. The NTSB recognizes the importance of NCAP, both as a means of informing consumers and as a tool for providing incentives to vehicles manufacturers to produce safer vehicles. We applaud NHTSA’s efforts and, based on our experience in conducting crash investigations and tracking safety technologies, offer the following comments organized under five main topics: Crash Avoidance Technologies, Frontal Crashworthiness, Side Crashworthiness, Pedestrian Protection, and the Rating System. The NTSB first made a safety recommendation to NHTSA pertaining to collision warning systems in 1995, asking the agency to determine the potential of such systems to prevent crashes. Since then, NHTSA has conducted considerable research, as have researchers in industry and academia, demonstrating the significant safety benefits provided by this technology. As a result of such research, in 2001, the NTSB recommended that NHTSA develop performance standards for collision warning systems in passenger vehicles (Safety Recommendation H-01-8). The NTSB has classified this recommendation “Closed—Acceptable Alternate Action.”

From: NTSB
To: NHTSA
Date: 6/8/2015
Response: Safety Recommendation H-01-008 was classified CLOSED--ACCEPTABLE ALTERNATE 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) Testing of CWS and AEB in the United States has primarily been conducted in low- to medium-velocity conditions, leaving an information gap about how they would operate under high-velocity conditions. The IIHS testing protocols for the AEB component included only low-velocity scenarios, and NHTSA’s testing scenarios for a CWS are based on a single velocity of the test vehicle (45 mph). The predicted benefits research presented earlier in the report showed that forward CAS have the potential to save hundreds of lives each year. The NTSB believes that the ultimate goal of these systems should include the reduction of fatalities, necessitating testing of their effectiveness in conditions resembling highway crashes. Testing conducted by the ADAC shows that at least some systems are capable of mitigating high-velocity crashes. The crash in Elizabethtown, discussed in section 1, involved a striking vehicle traveling at a speed greater than 60 mph shortly before impacting a very slow-moving vehicle—velocity parameters that far exceed NHTSA’s current test scenarios for the assessment of CWS. These parameters would not be covered by ADAC’s test scenarios either. Although ADAC’s scenarios include a test vehicle traveling at highway velocities (for example, 62 mph), the velocity differential (difference in the velocity between the test and the lead vehicle) is only 25 mph.28 Although the velocity differential in NHTSA’s test protocols approaches the observed differences in the Elizabethtown crash, the velocity of the test vehicle does not. The available energy of a vehicle in a 65 mph test is twice that of the same vehicle in a 45 mph test, and the stopping distance is almost double.29 So, neither NHTSA’s nor ADAC’s testing scenarios would fully account for the conditions present in the Elizabethtown crash. The NTSB, therefore, concludes that NHTSA’s existing testing scenarios and protocols for the assessment of forward CAS in passenger vehicles do not adequately represent the wide range of velocity conditions seen in crashes, particularly high-speed crashes. Because of this deficiency, the NTSB recommends that NHTSA develop and apply testing protocols to assess the performance of forward CAS in passenger vehicles at various velocities, including high speed and high velocity-differential. This new recommendation necessitates a review of the recommendation the NTSB issued to NHTSA to develop performance standards for CWS in passenger vehicles (H-01-8). While NHTSA has developed these performance standards, they do not address adherence to human factors guidelines. However, NHTSA has funded and conducted considerable research into the development of human factors guidelines for forward CAS—the findings of which the auto manufacturers, in conjunction with their own research, now use to develop their systems. As such, the evaluation of the adherence to human factors guidelines has been addressed in an acceptable alternate manner. Therefore, Safety Recommendation H-01-8 is classified CLOSED--ACCEPTABLE ALTERNATE ACTION.

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: 7/5/2013
Response: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) notice of proposed rulemaking (NPRM), titled “New Car Assessment Program (NCAP),” which was published at 78 Federal Register 20597-20604 (April 5, 2013). The NTSB appreciates the opportunity to comment on NHTSA’s near-term enhancements to the NCAP and recognizes NHTSA’s commitment to providing improved vehicle safety information to consumers. The NTSB recognizes the importance the NCAP program plays in improving vehicle safety and based upon our accident investigations and our tracking of emerging technologies, the NTSB offers the following comments in the areas of crash avoidance, crashworthiness, and consumer information: Although the NTSB has not issued any recommendations specifically addressing BSD in passenger vehicles, the NTSB recognizes it as an element of a complete collision warning system. As a result of a 2001 Special Study, the NTSB issued the following safety recommendation to NHTSA: 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. Safety Recommendation H-01-8 is currently classified as “Open – Unacceptable Response.” The NTSB is pleased that NHTSA includes forward collision warning in its NCAP program. Similarly, incorporating BSD into NCAP will require performance standards for detection parameters and driver alerts. As NHTSA develops these standards and completes the rulemaking to satisfy H-01-8, the NTSB would anticipate that BSD systems would also be included.

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: 9/12/2012
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: NHTSA
To: NTSB
Date: 7/10/2012
Response: -From David L. Strickland, Administrator: As stated previously, NHTSA respectfully disagrees with the classification of ACC as a safety technology. As such, NHTSA will not be pursuing regulatory activity with respect to ACC. NHTSA recognizes the benefits of collision warning systems and other crash avoidance technologies. In a letter dated February 26, 2010, NHTSA discussed including FCW into the New Car Assessment Program (NCAP), a government safety rating program. The program includes test protocols for FCW that outlines minimum performance levels for detection distance and timing of alerts, as suggested in H-01-8. We currently do not address the human machine interface (HMI) with FCW, but we continue to conduct research on the human factors issues associated with FCW and other warning systems. NHTSA announced the inclusion of FCW and test protocols for the systems in 2008, as noted in the aforementioned letter. For model year (MY) 2010 vehicles, only 1 percent of the vehicle models in the fleet had a FCW system that was certified to the NCAP performance criteria. This increased to 4 percent for MY 2011 vehicles and then doubled to 8 percent for MY 2012 vehicles. It is also important to note that two-thirds of the FCW systems in the MY 2012 fleet were certified to the NCAP performance criteria compared to just one-tenth for MY 2010 vehicles. These figures illustrate the strong market force to equip motor vehicles with FCW and to ensure that the systems are certified to the programs performance criteria. Given the steady increase in the deployment and uniformity of FCW and the continued work into the HMI aspect of warning systems, we believe H-01-8 should be classified as "Open - Acceptable Response."

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 RESPONSE. The NTSB also reiterates Safety Recommendations H-01-6 and -7 to NHTSA.

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: NHTSA
To: NTSB
Date: 10/29/2009
Response: Letter Mail Controlled 11/4/2009 11:04:45 AM MC# 2090672 : - From Linda Lawson, Department of Transportation: DOT Regulatory Status: As part of DOT'S Intelligent Transportation System (ITS) Program, NHTSA, through a cooperative test program with General Motors and UMTRI as its industry partners, completed a Field Operational Test (FOT) of Forward Crash Warning (FCW) for passenger cars. The results of the FOT were further analyzed by the Volpe Center as an independent evaluator. These FOT results provided the agency witli valuable insight into the potential benefits of the tested technologies, especially for FCW systems. As such, we have moved forward with a consumer information program that will encourage consumers to purchase FCW systems which will generate market demand for manufacturers to install them. In July 2008, NHTSA announced final enhancements to its consumer information program that for the first time will provide information on selected crash avoidance teclmologies so that consumers can use the information in their purchasing decisions. The technologies that will be highlighted include electronic stability control and two collision warning systems: forward crash and lane departure. To gain credit for their systems, manufacturers must meet certain performance tests. The performance tests provide the pre-crash scenarios that the systems should detect, detection distance, and the timing of alerts. They were included in the filial decision notice and can be found in docket number 2006-26555 at www.regulations.gov. The agency continues to study the human factor issues associated with these and other warning systems to determine best practices for the type and mode of warning. As we develop a better understanding, we will incorporate the warning interfaces into the test protocols.

From: NTSB
To: NHTSA
Date: 4/6/2009
Response: NMC# 103252: The Safety Board notes that, in November 2005, the U.S. Department of Transportation 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 occur over an approximate 12-month time period and intends to publish the final plan in late February 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 is also working with the Federal Motor Carrier Safety Administration (FMCSA) to monitor the real-world benefits realized by early-adopter truck fleets of technologies including ACC, forward collision warning (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 Safety Board further notes that, in July 2008, NHTSA announced final enhancements to its Government safety ratings program for passenger vehicles. The 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 highlighted technologies include electronic stability control, two CWSs, and forward crash and lane departure. 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. In addition, NHTSA continues to study the human factor 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, appears to be working consistently, although slowly, on this important technological safety issue. The preliminary results of the testing on advanced safety systems are encouraging, but the Safety Board continues to believe that rulemaking is needed to ensure uniformity of such system performance standards as obstacle detection, timing of alerts, and human factors guidelines, regarding new passenger and commercial vehicles. Accordingly, Safety Recommendations H-01-6 and -8 remain classified OPEN -- ACCEPTABLE RESPONSE pending completion of action to develop performance standards for enhanced vehicle safety technology in new passenger and commercial vehicles. The Safety Board voted that these recommendations would remain on the Most Wanted List in the issue area Prevent Collisions by Using Enhanced Vehicle Safety Technology with a timeliness designation of yellow acceptable response, progressing slowly.

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, through a cooperative test program with General Motors and the University of Michigan Transportation Research Institute (UMTRI), completed a Field Operational Test (FOT) of Forward Crash Warning (FCW) for passenger cars. The results of the FOT were further analyzed by the Volpe Center as an independent evaluator. In July 2008, NHTSA announced final enhancements to its Government safety ratings program to include new crash tests, new dummies, and for the first time, provide information on selected crash avoidance technologies so consumers can use the information in their purchasing decisions. The technologies that will be highlighted include: electronic stability control; two collision warning systems; and forward crash and lane departure. Similarly, test protocols to assure minimum levels of performance were included in the final decision notice, which can be found in docket number 2006-26555 at www.reaulations.gov. The performance tests provide the pre-crash scenarios that the systems should detect, detection distance, and the timing of alerts. The agency continues to study the human factor issues associated with these and other warning systems to determine best practices for the type and mode of warning.

From: NTSB
To: NHTSA
Date: 2/29/2008
Response: The Safety Board is aware that, in 2001, the Department of Transportation (DOT) established an Intelligent Vehicle Initiative (IVI)"the goal of which was to improve significantly the safety and efficiency of motor vehicle operations by reducing the probability of motor vehicle crashes"as a major component of the Intelligent Transportation System program. 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, Automotive Collision Avoidance System Field Operational Test Final Program Report, showing potential to reduce rear-end crashes by 10 percent and reporting positive user reaction to the systems. The final report on the commercial vehicle field testing conducted for the DOT by Battelle and Volvo Trucks North America, Inc., was released in January 2007. The preliminary findings of the report indicate that a combination of CWS and ACC in a bundled safety system accounts for a statistically significant reduction in rear-end crashes through reduced exposure to safety-critical driving scenarios. In correspondence dated November 9, 2006, the Board requested information about NHTSA’s interpretation of the commercial vehicle testing or timeline for future actions to mandate use of this technology. To date, we have not yet received this information and would appreciate receiving an update regarding progress that has been made in this area. NHTSA, along with its cooperative partners, the Federal Highway Administration, the Federal Motor Carrier Safety Administration, and the Research and Innovative Technology Administration, appears to be working consistently, although slowly, on this important technological safety issue. The preliminary results of the testing on advanced safety systems are encouraging, but the Safety Board continues to believe that rulemaking is needed to ensure uniformity of such system performance standards as obstacle detection, timing of alerts, and human factors guidelines, regarding new passenger and commercial vehicles. Accordingly, Safety Recommendations H-01-6 and -8 remain classified OPEN -- ACCEPTABLE RESPONSE pending completion of action to develop performance standards for enhanced vehicle safety technology in new passenger and commercial vehicles. The Safety Board voted that these recommendations would be added to the Most Wanted List in the issue area "Prevent Collisions by Using Enhanced Vehicle Safety Technology."

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: 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 Treaffic 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: 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 IV1 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.

From: NTSB
To: NHTSA
Date:
Response: At the September 18, 2007 Board meeting addressing the NTSB’s Most Wanted List of Transportation Safety Improvements (MWL), the Board voted to place Safety Recommendations H-01-06 and H-01-08 on the Federal MWL under the issue category “Prevent Collisions by Using Enhanced Vehicle Safety Technology.”