Safety Recommendation H-15-006
Details
Synopsis: In 2012 alone, more than 1.7 million rear-end crashes occurred on our nation’s highways, resulting in more than 1,700 fatalities and 500,000 injured people. Many of these crashes could have been mitigated, or possibly even prevented, had rear-end collision avoidance technologies been in place. However, slow and insufficient action on the part of the National Highway Traffic Safety Administration (NHTSA) to develop performance standards for these technologies and require them in passenger and commercial vehicles, as well as a lack of incentives for manufacturers, has contributed to the ongoing and unacceptable frequency of rear-end crashes. The National Transportation Safety Board (NTSB) has an extensive history of investigating rear-end crashes and has encouraged technological countermeasures since 1995. To date, the NTSB has issued 12 recommendations pertaining to this safety issue. In 2001, the NTSB released a Special Investigation Report on rear-end crashes that focused on technology as a potential countermeasure and made several recommendations to federal agencies and vehicle manufacturers (NTSB 2001). Due to a lack of progress in the implementation of NTSB recommendations intended to mitigate or prevent rear-end crashes, the recent technological advancements in collision avoidance technologies, and the continued prevalence of rear-end crashes, the NTSB is revisiting the topic of rear-end crash prevention.
Recommendation: TO THE NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION: Expand the New Car Assessment Program 5-star rating system to include a scale that rates the performance of forward collision avoidance systems.
Original recommendation transmittal letter: PDF
Overall Status: Open - Unacceptable Response
Mode: Highway
Location: United States
Is Reiterated: Yes
Is Hazmat: No
Is NPRM: No
Accident #: DCA14SS001
Accident Reports:
Report #: SIR-15-01
Accident Date: 11/20/2013
Issue Date: 6/8/2015
Date Closed:
Addressee(s) and Addressee Status: NHTSA (Open - Unacceptable Response)
Keyword(s):

Safety Recommendation History
From: NTSB
To: NHTSA
Date: 4/26/2021
Response: We learned that you recently pulled back the Federal Register notice seeking public comment on planned upgrades to the NCAP, which you had previously planned to release in 2020. We are concerned that, despite your publication of multiple requests for comments regarding which safety systems to include in an NCAP upgrade, and the latest postponed publication of yet another request for comments, we have yet to see the actual upgrade notice. We believe that you have collected sufficient information to make the needed revisions to the NCAP, and we urge you to move forward with the upgrade. NCAPs around the world have had ratings for collision-avoidance, pedestrian safety, and bicycle safety technologies for many years, yet the US NCAP still does not address the performance of these safety systems. Until such action is taken, Safety Recommendations H-15-6 and -7, H-18 43, and H-19-36 are classified OPEN-- UNACCEPTABLE RESPONSE.

From: NTSB
To: NHTSA
Date: 2/1/2021
Response: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) advance notice of proposed rulemaking (ANPRM) titled “Framework for Automated Driving System Safety,” published at 85 Federal Register 78058 on December 3, 2020. In its notice, NHTSA requests comments on the development of a framework for automated driving system (ADS) safety. ADS, as defined by SAE International and as used in the ANPRM, refers to driving automation levels 3, 4, and 5. An ADS is the hardware and software that are, collectively, capable of performing the entire dynamic driving task on a sustained basis, regardless of whether it is limited to a specific operational design domain. Specifically, the agency seeks input on its role in facilitating ADS risk management through guidance, regulation, or both. NHTSA also requests guidance on how it should select and design the structure of a safety framework and the appropriate administrative mechanisms for improving safety, mitigating risk, and enabling the development and introduction of innovative safety technology. Collision Avoidance Technologies—Foundational Building Blocks for Safety Section III of the ANPRM describes the core elements of ADS safety performance as sensing, perception, planning, and control. Although those functions are necessary for ADS performance, they are not sufficient to ensure ADS safety, which depends on an array of other functions and system capabilities and how the system interacts with the humans both inside and outside an ADS-equipped vehicle. While a mature ADS may avoid many of the human driver errors or poor choices that lead to crashes, an ADS can still find itself in crash-imminent scenarios that warrant emergency maneuvering. Crash avoidance will depend on a vehicle’s mechanical abilities and the underlying crash avoidance technologies. Certain advanced safety technologies, which will likely serve as foundational “building block” technologies for AVs, have already proven effective at preventing and mitigating crashes across all modes of highway transportation. Since 1995, the NTSB has called for installing collision avoidance technology on passenger cars and trucks. Collision avoidance technologies, especially forward collision warning and automatic emergency braking systems, have shown safety benefits in reducing the frequency and severity of crashes. Although the effectiveness of the technologies has been demonstrated, their incorporation into vehicle fleets remains slow. As a result, in May 2015, the NTSB issued recommendations to vehicle manufacturers to install the systems as standard equipment in all new vehicles. In the same report, the NTSB issued recommendations to NHTSA to incorporate a rating system into the NCAP for forward collision avoidance systems and to include those ratings on the Monroney label. See Safety Recommendation H-15-6, currently classified “Open—Acceptable Response.” As NHTSA moves toward an ADS safety framework, it is important that the agency prioritize the development of minimum performance standards for collision avoidance technologies and require the systems as standard equipment on all new vehicles. Independently of whether a vehicle is driven by a human driver or an ADS, NHTSA should focus on performance standards for collision avoidance systems. The standards could be technology-neutral and would address NHTSA’s mission to prevent, reduce, or mitigate crashes. In cars with human drivers, collision avoidance technologies are redundant systems intended to aid drivers in situations where their performance is not ideal. For an ADS, collision avoidance technologies could similarly function as redundant systems to avoid or mitigate crashes when the ADS cannot react on its own to a hazardous situation. In the Tempe crash investigation, the NTSB found that Uber Advanced Technologies Group’s (ATG) deactivation of the Volvo forward collision warning and automatic emergency braking systems without replacing their full capabilities removed a layer of safety redundancy and increased the risks associated with testing ADSs on public roads. Uber ATG did not violate any Federal Motor Vehicle Safety Standards (FMVSSs) because none exist that require a minimum level of collision avoidance performance. Postcrash, Uber ATG worked with Volvo to ensure that the Volvo collision avoidance system was independent and functional when the Uber ATG ADS was operational, thereby adding a layer of safety redundancy. Widespread deployment of collision avoidance technologies now will help save lives and can be instrumental in building public confidence in the capabilities of new technologies as higher levels of automation are introduced.

From: NHTSA
To: NTSB
Date: 7/16/2020
Response: -From James C. Owens, Deputy Administrator: On October 16, 2019, NHTSA announced its plan to propose significant updates to the NCAP in 2020, including consideration of crash avoidance technologies aimed at reducing risks to pedestrians and cyclists. NHTSA continues its research efforts into aspects of these technologies, and will be conducting research as to how best provide consumers with information relating to crash avoidance technologies on the Monroney label. NHTSA will consider next steps when the research is complete. NHTSA requests that recommendations H-19-36, H-15-6, H-15-7, and H-18-43 be classified as Open, Acceptable Response.

From: NTSB
To: NHTSA
Date: 6/26/2020
Response: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) request for comments titled “Agency Information Collection Activities; Notice and Request for Comment; Government 5-Star Safety Ratings Label Consumer Research,” published at 85 Federal Register 23598 on April 28, 2020. In its request, NHTSA proposes to conduct focus groups in four geographic markets located across the country to evaluate design and consumer information improvements to the Government 5-Star Safety Ratings section of the Monroney label. The 2015 Fixing America’s Surface Transportation (FAST) Act requires NHTSA to issue a rule to ensure that crash avoidance information is provided next to crashworthiness information on the Monroney label. NHTSA aims to use the data from the focus groups to improve consumer understanding of the government’s vehicle safety ratings and advanced crash avoidance technology system performance assessments. The data will also guide NHTSA’s development of communications to help consumers in their vehicle purchase decisions. Overall, the NTSB welcomes the apparent inclusion of safety technology in label concepts that NHTSA is proposing to evaluate, but we are also concerned that the proposed information lacks specificity about the crash avoidance and other technology to be included in the evaluated labels. The NTSB urges NHTSA to incorporate performance ratings of crash avoidance technologies and vulnerable road user protection systems on the Monroney labels, thus fully informing the public. Concerns Regarding Government 5-Star Safety Ratings Label and Proposed Information Collection Request The NTSB recognizes NHTSA’s research efforts to improve consumer understanding of the vehicle safety rating system and the assessment of crash avoidance technologies. The proposed research questions are centered around appeal of label concepts as well as comprehension, format, and how the information is displayed on the label. All those elements are important; however, the proposal lacks discussion about the content of the information to be presented. The NTSB has expressed concern about the lack of progress on expanding the Government 5 Star Safety Ratings / New Car Assessment Program (NCAP) to provide relevant information to help consumers as they consider safety in their vehicle purchase decisions. Currently, the 5-Star Safety Ratings label combines the results of the frontal crash tests, side crash tests, and a rollover resistance test into one score that indicates the overall risk of injury to a vehicle occupant if the vehicle is involved in a crash. The 5-Star Safety Ratings does not rate the performance of crash avoidance technologies nor does it include systems designed to protect vulnerable road users (such as pedestrians, bicyclists, and motorcyclists). Instead, NHTSA’s NCAP website includes icons indicating only the availability of certain crash avoidance technologies on a vehicle (even if a system is optional equipment). However, even this limited information about whether a vehicle is equipped with some level of crash avoidance technology is not included on the Monroney label. Although the performance of crash avoidance technologies varies significantly, NHTSA does not rate this performance on its website. To give manufacturers an incentive for improving performance and for informing the public about the effectiveness of these systems, performance ratings are essential. A rating system should regularly increase the criteria for achieving a top score. Based on our crash investigations and examination of various crash avoidance and other safety technologies, we offer the following comments to improve the practical utility of the proposed information collection request. NTSB Safety Recommendations The NTSB has a long history advocating for crash avoidance technologies. Since 1995, our investigations have led to the issuance of more than 25 safety recommendations in this area, many of which have been directed to NHTSA. In 1995, the NTSB issued Safety Recommendation H-95-44 to the Department of Transportation, asking it to begin testing collision warning systems in commercial fleets. Because of a lack of progress, the recommendation was classified “Closed—Unacceptable Action” in August 1999. Many of the initial recommendations that the NTSB issued pertaining to crash avoidance systems related to their use in commercial vehicles. For example, see Vehicle- and Infrastructure-Based Technology for the Prevention of Rear-End Collisions, Special Investigation Report NTSB/SIR-01/01 (Washington, DC: NTSB). Safety Recommendation H 01 6 recommended that NHTSA complete rulemaking on adaptive cruise control and collision warning system performance standards for new commercial vehicles. At a minimum, those 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 6 was classified “Closed—Unacceptable Action” in June 2015 and superseded by Safety Recommendation H 15 5. The recommendations asked NHTSA to research, develop, or improve performance standards for the technologies; inform consumers about their benefits; encourage vehicle manufacturers to install them as standard equipment; and require them on all new vehicles. A list of recent safety recommendations for crash avoidance technologies in passenger vehicles is provided below. • In 2015, the NTSB issued recommendations to vehicle manufacturers to install forward collision avoidance systems as standard equipment in all new vehicles (Safety Recommendations H-15-8 and -9). See NTSB/SIR-15/01. Safety Recommendations H-15-8 and -9 are classified “Open?Acceptable Response.” In the same special investigation report, the NTSB issued recommendations to NHTSA to incorporate a rating system into NCAP for forward collision avoidance systems and to include those ratings on the Monroney label (Safety Recommendations H-15-6 and -7). Safety Recommendations H-15-6 and -7 are classified “Open?Acceptable Response.” • In 2018, the NTSB published a special investigation report pertaining to pedestrian safety and issued numerous recommendations to NHTSA, including to develop performance tests for evaluating automatic pedestrian safety systems and to incorporate such systems into NCAP (Safety Recommendations H-18-42 and 43). See Pedestrian Safety, Special Investigation Report NTSB/SIR-18/03 (Washington, DC: NTSB). Safety Recommendations H-18-42 and -43 are classified “Open?Acceptable Response.” • In 2018, the NTSB published a safety report titled Select Risk Factors Associated with Causes of Motorcycle Crashes and issued a recommendation to NHTSA to incorporate motorcycles in the development of performance standards for passenger vehicle crash warning and prevention systems (Safety Recommendation H-18-29). See Select Risk Factors Associated with Causes of Motorcycle Crashes, Safety Report NTSB/SR-18/01 (Washington, DC: NTSB). Safety Recommendation H-18-29 is classified “Open?Acceptable Response.” • In 2019, the NTSB published a safety study on bicyclist safety that included a recommendation for NHTSA to incorporate into its NCAP testing the evaluation of a car’s ability to avoid crashes with bicycles (Safety Recommendation H 19 36). See Bicyclist Safety on US Roadways: Crash Risks and Countermeasures, Safety Study NTSB/SS-19/01 (Washington, DC: NTSB). Safety Recommendation H-19-36 is classified “Open?Await Response.” Although the NTSB has made specific recommendations for only some crash avoidance systems—forward collision warning; automatic emergency braking; and automatic pedestrian, motorcycle, and bicycle detection—we also support inclusion of other systems that show a safety benefit. See the NTSB’s response to NHTSA’s request for comments, “New Car Assessment Program,” published at 80 Federal Register 241 on December 16, 2015. https://www.regulations

From: NTSB
To: NHTSA
Date: 1/15/2020
Response: The National Transportation Safety Board (NTSB) has reviewed the National Highway Traffic Safety Administration (NHTSA) request for comments (RFC) titled “Advanced Driver Assistance Systems Draft Research Test Procedures,” published at 84 Federal Register 64405 on November 21, 2019. In its request, NHTSA presents testing procedures for nine advanced driver assistance systems (ADASs), with the goal of assessing the adequacy of the procedures. The agency emphasizes that the testing procedures are intended “for research purposes only” and are not developed to support rulemaking or the New Car Assessment Program (NCAP). The NTSB recognizes NHTSA’s research efforts; however, we urge rapid incorporation of the test procedures into NCAP for passenger vehicles and the adoption of testing protocols and associated requirements for commercial vehicles. We are concerned that limiting the application of the testing procedures will further delay the expansion of NCAP. Additionally, based on our crash investigations and examination of various collision avoidance and other safety technologies, we offer the following comments in the general areas of ADASs in passenger (light) and commercial (heavy) vehicles. ADASs in Passenger Vehicles The NTSB has a long history of advocating for crash avoidance technologies. Since 1995, our investigations have led to the issuance of more than 25 recommendations in this area, many of which have been directed to NHTSA. The recommendations have asked NHTSA to research, develop, or improve performance standards for the technologies; inform consumers about their benefits; encourage vehicle manufacturers to install them as standard equipment; and require them on all new vehicles. Collision avoidance technologies, especially forward collision warning and automatic emergency braking systems, have shown safety benefits in reducing the frequency and severity of crashes. Although the effectiveness of the technologies has been demonstrated, their incorporation into vehicle fleets remains slow. As a result, in May 2015, the NTSB issued recommendations to vehicle manufacturers to install the systems as standard equipment in all new vehicles (Safety Recommendations H-15-8 and -9). See NTSB/SIR-15/01. Safety Recommendations H-15-8 and -9 are classified “Open–Acceptable Response.” In the same report, the NTSB issued recommendations to NHTSA to incorporate a rating system into NCAP for forward collision avoidance systems and to include those ratings on the Monroney label (Safety Recommendations H-15-6 and -7). Safety Recommendations H-15-6 and -7 are classified “Open–Acceptable Response.” In December 2015, Congress mandated that NHTSA promulgate a rule within a year to require that crash avoidance information be placed alongside crashworthiness information on the Monroney labels of new vehicles. As part of the mandate, in December 2015, NHTSA initiated a request for comments titled “New Car Assessment Program,” in which the agency proposed expanding NCAP to include 5-star safety ratings for crashworthiness, crash avoidance technologies, and pedestrian protection systems. In our response to that RFC, we noted that the proposed NCAP would not only address Safety Recommendation H-15-6 but would also incorporate other safety technologies. Since the 2015 RFC, there has been no significant progress in the expansion of NCAP. Concurrent with the 2015 RFC, plans were developed for accelerated deployment of collision avoidance systems. In March 2016, NHTSA and the Insurance Institute for Highway Safety (IIHS) came to an agreement with nearly all passenger vehicle manufacturers in the United States to equip all their new vehicles with forward collision warning and automatic emergency braking systems by model year 2022. The NTSB supported the agreement as a means of accelerating the deployment of those technologies in vehicles. However, as testing conducted by the IIHS and Euro NCAP, among others, has shown, the systems differ greatly in performance. To give manufacturers an incentive for improving performance and for informing the public about the effectiveness of the systems, a ratings system is essential. Moreover, a rating system should regularly increase the criteria for achieving a top score.

From: NTSB
To: NHTSA
Date: 12/5/2019
Response: Reiterated in Safety Study SS-19-01, “Bicyclist Safety on US Roadways: Crash Risks and Countermeasures” adopted November 5, 2019 and published December 5, 2019. 4.2.3.1 Collision Avoidance Systems CASs were originally designed to prevent or mitigate collisions between motor vehicles, such as rear-end collisions. In 2001, the NTSB published a special investigation report, Vehicle- and Infrastructure-Based Technology for the Prevention of Rear-End Collisions, that made several recommendations to NHTSA to develop performance standards for collision warning systems and adaptive cruise control for commercial and passenger vehicles (H-01-6 and H-01-8) and to then require such systems in new commercial vehicles (H-01-7, NTSB 2001).74 In the ensuing years, little progress was made on these recommendations or on other recommendations pertaining to vehicle technology to prevent rear-end crashes. In 2015, the NTSB published another special investigation report, The Use of Forward Collision Avoidance Systems to Prevent and Mitigate Rear-End Crashes, to examine the real-world and predicted efficacy of currently available CAS technologies (NTSB 2015). The report concluded that CAS technologies for passenger and commercial vehicles show clear safety benefits; however, more effort was needed to speed deployment of the technologies in all vehicle types. As a result, the NTSB recommended that manufacturers install forward CASs as standard features on all newly manufactured motor vehicles (H-15-8 and H-15-9).75 The NTSB also recommended that NHTSA develop protocols for the assessment of CASs (H-15-4 and H-15-5) and that the agency expand its New Car Assessment Program (NCAP) to include a graded rating of CASs on new vehicle window stickers, also known as Monroney labels (H-15-6 and H-15-7).76 In 2018, the NTSB issued recommendations designed to expand the use of CAS technologies to additional vehicles, including school buses and motorcycles (H-18-8, H-18-19, and H-18-29).77 Also, the 2018 Pedestrian Safety report included two recommendations to NHTSA aimed at fostering the development, evaluation, and implementation of pedestrian CASs (H-18-42 and H-18-43).78 It is likely that the previous recommendations the NTSB has made concerning CASs, if implemented, would lead to safety improvements for bicyclists. It is also worth considering whether vehicle manufacturers should implement specific CASs or modify existing systems to enable detection of bicycles. There is evidence that such systems could reduce the incidence of collisions between motor vehicles and bicycles. For example, in 2015, IIHS researchers used data on crashes between motor vehicles and bicycles from several national highway crash databases to identify common crash scenarios that could benefit from the development of bicyclist-detection systems (MacAlister and Zuby 2015). They identified three crash modes that accounted for 74% of bicyclist fatalities in crashes involving a collision with the front of a motor vehicle. The IIHS researchers suggested that existing CASs could, with minor modifications, be designed to detect bicyclists, potentially mitigating or preventing up to 26% of bicyclist injuries and 52% of fatalities. Some automakers have already taken steps to incorporate bicyclist-detection systems into their CAS technology. For example, Volvo’s City Safety system has a bicyclist-detection capability that uses radar and camera data.79 Additionally, automakers are developing US-based bicycle and bicyclist surrogates that could be used to evaluate the effectiveness of bicyclist precollision systems (Yi and others 2016). Therefore, the NTSB concludes that CAS technologies could be modified to detect bicycles, which would likely reduce the incidence of collisions between motor vehicles and bicycles and mitigate injuries caused by collisions when they occur. Although in-vehicle bicycle detection systems are a relatively new technology, some organizations have taken steps to promote their implementation. For example, the European New Car Assessment Program, known as Euro NCAP, provides overall vehicle safety ratings based on (1) adult occupant protection; (2) child occupant protection; (3) vulnerable road user protection, including pedestrians and bicyclists; and (4) “safety assist,” which evaluates driver assistance and crash avoidance technologies. Since 2018, Euro NCAP has included two scenarios for bicyclist detection: one in which a bicyclist crosses a vehicle’s path and one in which a bicyclist is traveling in the same direction as the vehicle.80 The test uses a specially designed dummy bicyclist on a moving bicycle platform.81 Although no published studies have yet evaluated whether the bicycle test scenarios have improved safety, research has shown that cars with better scores on the Euro NCAP pedestrian assessment are less likely to be involved in crashes that involve severe pedestrian injury (Pastor 2013). New car ratings assessment programs, such as NCAP and Euro NCAP, provide a valuable service by evaluating and sharing information about the performance of vehicle safety systems. In the United States, research has shown that consumers are more likely to buy cars that receive high safety ratings (Cicchino 2015). Since 2015, the NTSB has recommended that NHTSA update NCAP to include ratings on the performance of CASs. Specifically, the NTSB recommended that NHTSA— Expand the New Car Assessment Program 5-star rating system to include a scale that rates the performance of forward collision avoidance systems. (H-15-6) Once the rating scale, described in Safety Recommendation H-15-6, is established, include the ratings of forward collision avoidance systems on the vehicle Monroney labels. (H-15-7) Incorporate pedestrian safety systems, including pedestrian collision avoidance systems and other more-passive safety systems, into the New Car Assessment Program. (H-18-43) In December 2015, as part of the Fixing America’s Surface Transportation (FAST) Act, Public Law 114-94, Congress directed NHTSA to “promulgate a rule to ensure that crash avoidance information is indicated next to crashworthiness information on stickers placed on motor vehicles by manufacturers.”82 Since then, NHTSA has, on two occasions, solicited public comments on potential changes to NCAP. In response, several commenters asked NHTSA to include bicycle safety in NCAP. For example, the League of American Bicyclists and the Association of Pedestrian and Bicycle Professionals asked NHTSA to create crash avoidance and mitigation testing procedures for bicyclists and pedestrians and to harmonize its testing with Euro NCAP as the Australasian NCAP program has done. In a March 2018 letter to the NTSB, NHTSA stated that the agency was reviewing public comments concerning revisions to NCAP. Although NHTSA has sought public comment on the future of NCAP, it has not yet taken any meaningful steps to modify the program to rate CASs or to incorporate tests to evaluate vehicle safety with respect to vulnerable road users, such as pedestrians and bicyclists. Therefore, the NTSB concludes that NHTSA’s delays in updating NCAP have likely slowed the development of important safety systems for vulnerable road users and their implementation into the vehicle fleet. Therefore, the NTSB reiterates Safety Recommendations H-15-6, H-15-7, and H-18-43 to NHTSA. The NTSB also recommends that NHTSA incorporate into NCAP tests to evaluate a car’s ability to avoid crashes with bicycles.

From: NTSB
To: NHTSA
Date: 11/13/2017
Response: As we noted in our June 7, 2016, letter, we are encouraged by your notice of planned enhancements to the NCAP 5-star rating system, including changes to the Monroney label. Please send us an update outlining your planned actions and a timeline for addressing these recommendations. Pending such action, Safety Recommendations H-15-6 and -7 remain classified OPEN--ACCEPTABLE RESPONSE.

From: NTSB
To: NHTSA
Date: 6/7/2016
Response: We note that, on December 16, 2015, you published a notice of planned enhancements to the NCAP 5-star rating system, including changes to the Monroney label. In our February 16, 2016, comments to your notice (enclosed), we recognized the benefits of the NCAP 5-star rating system and stated that we believe that similar ratings for crash avoidance technologies could speed the deployment of these technologies, as well as encourage manufacturers to improve them continuously. We further urged you to consider providing an ordinal scale in the rating for forward collision warning systems. We are encouraged by the progress you have made toward addressing these recommendations. Pending completion of the recommended actions and our review of the final product, Safety Recommendations H-15-6 and -7 are classified OPEN—ACCEPTABLE RESPONSE.

From: NHTSA
To: NTSB
Date: 3/21/2016
Response: -From Mark R. Rosekind, Ph.D., Administrator: With regard to Safety Recommendations H-15-4 and H-15-5, we request that these recommendations be classified as "Open-Acceptable Response." NHTSA is currently researching forward collision avoidance systems as part of its in-vehicle crash avoidance program. This progran1 encompasses projects that focus on vehicle-based equipment, systems, and technologies-such as forward collision avoidance systems-that help ensure that motor vehicles are optimally prepared to prevent crashes from occurring. These technologies involve on-board equipment, such as sensors or cameras, that do not require communication between vehicles. With regard to Safety Recommendations H -15-6 and H -15-7, we request that these safety recommendations be classified "Open-Acceptable Response." On December 16, 2015, NHTSA published planned enhancements to our New Car Assessment Program (NCAP) that would assess safety ratings for vehicles that incorporate advanced technologies, including forward collision avoidance technologies, and discussed addressing changes to the Monroney label. We believe that these new safety ratings, when adopted, will fully address Safety Recommendations H-15-6 and H-15-7.

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 strongly believes that rating systems such as NCAP influence consumer purchasing decisions and provide incentives for manufacturers to improve their vehicles’ safety systems. The NCAP 5-star safety rating has not only established minimal crashworthiness requirements, but it has also incentivized vehicle manufacturers to make and market the safest vehicles. As a result, nearly all of today’s vehicles have 4- or 5-star crashworthiness safety ratings. The NTSB recognizes the benefits of the NCAP 5-star rating system and believes that similar ratings for crash avoidance technologies could speed the deployment of these technologies, as well as encourage manufacturers to improve them continuously. As such, in May 2015, we recommended that NHTSA incorporate into NCAP a rating system for forward crash avoidance systems (Safety Recommendation H-15-6). In the RFC, NHTSA proposes three separate 5-star safety ratings—for crashworthiness, crash avoidance technologies, and pedestrian protection—as well as a single combined 5-star safety rating. The NTSB is pleased that the new NCAP would not only address our Safety Recommendation H-15-6 but would incorporate other safety technologies as well. The NTSB supports NHTSA’s proposed ratings and offers the following comments for the agency’s consideration. NHTSA states that crash avoidance systems generally have a binary result—they either prevent a crash or they do not prevent it. While this certainly would be the case with systems such as blind spot detection and rollover resistance, the performance of collision warning and crash imminent braking systems is more nuanced. Testing conducted by Euro NCAP shows considerable variability in the quality of collision warning and crash imminent braking systems; some systems are capable of mitigating high-velocity crashes while others are effective only in low-velocity conditions. Still, any system offers a higher level of protection than no system at all. A vehicle that meets the proposed performance standards would offer substantial safety benefits that should be recognized. At the same time, expanded testing protocols with highway scenarios would prompt vehicle manufacturers to improve their systems. Vehicles equipped with improved systems would offer even higher levels of protection, and as such, would deserve bonus points. Therefore, the NTSB believes that NHTSA should consider providing an ordinal scale in the rating for forward collision warning systems. The NTSB hopes that in future iterations of testing procedures for crash imminent braking systems NHTSA will include testing at moderate velocities, beyond the currently proposed maximum velocity-differential of 25 mph. In such scenarios, an ordinal scale for crash imminent braking systems should be considered, as well.