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From:
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Consumer Electronics Association
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To:
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NTSB
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Date:
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5/8/2012
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Response:
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-From Gary Shapiro, President: The Consumer Electronics Association (CEA) is the preeminent trade association representing the consumer electronics industry. Our 2,200 member companies include the most innovative companies in the United States, such as large and small device manufacturers, service providers and retailers.
CEA has a long and storied past relating to the inclusion of technology in automobiles. In 1930, we were the Radio Manufacturers Association (RMA) and we faced calls from state regulators to ban the installation of radios in cars. Describing these radios as “distracting to the driver” since the “act of tuning would take attention from the driver” and the “radio would lull the driver to sleep,” the chairman of the RMA’s legislative committee, Clarence C. Colby, successfully made the case that car radios in fact have several safety benefits.
As Mr. Colby and the RMA did in the past, CEA continues to believe that technology in automobiles, whether it be installed in the dashboard or as a portable device should be viewed holistically and both safety and distracting elements considered.
Safety is paramount in a moving vehicle and a driver's highest priority must be attention to driving and control of the vehicle at all times. CEA publicly supports state legislation that imposes targeted limits on the use of in-vehicle electronics to ensure driver safety.
Naturalistic or “real world” driving studies, like that of the 100-Car Naturalistic Driving Study by the National Highway Traffic Safety Administration (NHTSA) and the Virginia Tech Transportation Institute (VTTI), have confirmed that manual texting while driving significantly increases the risk of a crash. CEA supports a ban on the use of handheld devices for manual texting while driving. Research has also shown that younger drivers typically do not have the skill set to perform secondary tasks while driving safely. Accordingly, CEA supports initiatives that restrict mobile phone use for novice drivers or drivers operating under a graduated drivers' license (GDL).
CEA strongly believes that any policy approaches in this area must be based on well-grounded science rather than on reflexive calls for regulation or outright bans. The naturalistic data referenced above allow policymakers and the public at large to understand the true impact of all distractions in the vehicle and its effects on driver performance. CEA must disagree with the NTSB’s overall recommendation calling for a ban on the nonemergency use of portable electronic devices (other than those designed to support the driving task) by all drivers. There is absolutely no real world evidence supporting such a blanket prohibition unless one would also ban fast food, make-up application and engaging with children in the car.
The U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA), which has clear regulatory jurisdiction over components installed in motor vehicles, recently issued draft voluntary guidelines for in-vehicle devices to minimize their potential for distraction. In its filing, NHTSA included the following graphic summarizing the risks associated with performing a variety of secondary tasks while driving both light and heavy vehicles based entirely on naturalistic studies:
NHTSA notes that a risk rating of 1.0 has the same risk as average or normal driving and a rating below it indicates a protective or safety-enhancing effect. As observed above, talking and listening on a hands-free phone produces such a positive effect, and talking and listening on a hand-held phone is not far behind. However, text messaging on a cell phone, with a risk rating of 23, increases the risk by 2,220% when compared with average driving. As such and as reflected in CEA’s safe driving principles, a text messaging prohibition is the clear policy solution whereas the NTSB’s recommendation of a blanket ban on all electronics use by a driver is unsupported by the data.
It should be noted in NHTSA’s Notice Of Proposed Federal Guidelines, the agency “has opted to pursue nonbinding, voluntary guidelines rather than a mandatory Federal Motor Vehicle Safety Standard (FMVSS) for three principal reasons. First, this is an area in which learning continues, and NHTSA believes that, at this time, continued research is both necessary and important. Second, technology is changing rapidly, and a static rule, put in place at this time, may face unforeseen problems and issues as new technologies are developed and introduced. Third, available data are not sufficient at this time to permit accurate estimation of the benefits and costs of a mandatory rule in this area.” CEA strongly concurs with the second point and believes that policies should be carefully calibrated so as not to inadvertently prohibit new technologies that could benefit drivers. The NTSB’s blanket prohibition, if adopted, would likewise forestall future innovation in the development of technologies that improve driver safety.
With regard to the specific recommendation made by the NTSB to CEA and CTIA, the private sector has responded to market demand with innovative products and applications that enhance driver safety. Some of these products and applications do indeed disable some functions of electronics devices for some period of time. For additional information, please see the attached list of products and applications compiled by the Federal Communications Commission (FCC) and displayed on their Distracted Driving Information Clearinghouse website. If drivers so choose to use these products and applications, then they are already available and often times at a low, nominal cost. While many consumers will undoubtedly find these technologies useful, CEA does not support mandating the installation of any of these products or applications into vehicles or personal electronics. Such measures, like the blanket prohibition, will inhibit innovation and will do little to improve safety.
CEA wishes to highlight two promising early-stage technological developments. First, automatic collision avoidance systems are developing quickly as are technologies which track driver behavior such as eye movements. Second, self-driving vehicle technology is advancing and is now in the road-test stage. These developments promise to create safer roadways and mitigate the effects of driver distraction.
Alongside its safe driving policy principles, CEA strongly believes that the issue of personal responsibility is a critically important but often ignored topic when discussing potential distraction in the automobile. If one were to apply the logic espoused in the NTSB’s blanket prohibition recommendation, it might seem reasonable in the name of safety to demand vehicle manufacturers stop producing cars that are able to drive up to and sometimes beyond 150 miles per hour and instead limit them to only 65 miles per hour, or ask that all vanity mirrors be outlawed, or cars be rendered inoperable if the driver is eating or drinking. CEA most certainly does not advocate any of these positions, but does stand firmly behind common sense. As every student in a drivers’ education class learns, driving is a privilege and the safe operation of a vehicle is the utmost responsibility of the operator. Driving without distraction is a critical component of this responsibility.
CEA stands ready to partner with the NTSB and any other organization to support and advocate for safe driving policies that are based on real world data, do not prevent innovation and embrace personal responsibility.
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