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NHTSA Takes Most Important ADAS Action So Far Leave a comment

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Automatic emergency braking (AEB) is now the most important advanced driver-assistance system (ADAS) product—at least in the U.S. On May 31, the National Highway Traffic Safety Administration (NHTSA) announced it is adding both AEB and pedestrian AEB (PAEB) to its two main programs for increasing vehicle safety: the New Car Assessment Program (NCAP) and a Federal Motor Vehicle Safety Standard (FMVSS) regulation. The government agency is doing so due to AEB’s potential to prevent many fatalities and mitigate a large number of non-fatal injuries.

NCAP provides comparative information on the safety performance of new vehicles to assist consumers with vehicle-purchasing decisions and to encourage safety improvements.

This proposed regulation is the most important and impactful ADAS rule that the NHTSA has ever made.

This ADAS tech deployment has an aggressive testing procedure that will provide the public with growing, lifesaving and injury-mitigating technologies. Hopefully, the NHTSA will succeed in getting early voluntary deployment from many auto OEMs.

AEB-PAEB is comprehensive and is much stronger than the current voluntary AEB, which is only for frontal crashes. A big change is that AEB testing specifies crash avoidance—not just mitigation. The mandate adds pedestrian AEB for daytime and nighttime crashes. AEB testing also increases test speeds that include the speed at which most frontal and pedestrian crashes occur. Test speed is up to 100 km/hour for frontal crashes and up to 65 km/hour for pedestrian crashes.

The NHTSA’s estimated benefits of the AEB-PAEB mandate are excellent. Yearly fatalities prevented is 362, with 66% coming from PAEB. Yearly non-fatal injuries mitigated are projected at over 24,300, with frontal AEB accounting for 89%. The NHTSA believes these estimates are conservative.

The mandate is good news for ADAS sensor suppliers. The AEB mandate will increase the number of sensors and/or sensor capabilities. Better cameras will be needed for nighttime operation, with infrared cameras becoming a big opportunity. Radars may go to 4D imaging sensors. LiDAR will likely be more common with the AEB mandate.

Here is a summary of this important mandate, including the NHTSA’s rationale, key features, cost and benefits.

Looking back at NHTSA ADAS activities

The NHTSA has researched ADAS technology for longer than 25 years—especially front-end collisions. It published several collision-avoidance reports in the late 1990s and 2000s. From this research, it learned about the technology of forward-collision–warning (FCW) systems and vehicle-crash–avoidance scenarios wherein FCW systems could play an effective role in alerting a driver to brake and avoid a crash. In 2009, the NHTSA synthesized this research in the development and conduct of controlled track-test assessments on three vehicles equipped with FCW. This prepared the agency to start adding ADAS technologies to NCAP, with a lot of activity since then:

  • Model year 2011. The NHTSA recommended FCW, lane-departure warning and electronic stability control (ESC) for points in NCAP ratings. ESC became a mandate for model year 2012.
  • Model years 2014–2017. The NHTSA recommended rear backup video for NCAP ratings. It became a mandate in model year 2018.
  • November 2015. The NHTSA recommended AEB for NCAP ratings.
  • December 2015. The NHTSA released a key report with extensive information on AEB, FCW and blind-spot detection. This type of report is called a request for comments (RFC), and it is used when the NHTSA wants feedback from the auto industry.
  • The NHTSA made a voluntary agreement with most auto OEMs to include AEB in all light vehicles sold by 2022. This was very successful, and over 90% of vehicles sold in 2022 had AEB.
  • Spring 2021. The NHTSA announced its intention to make AEB a mandate as an FMVSS.
  • March 2022. The NHTSA released its most important RFC, with extensive information and future plans on ADAS technology. The RFC had 236 pages and included a 10-year roadmap for ADAS, NCAP and future rating systems. The report is available here.
  • May 2023. The first result of the 2022 RFC was announced with a mandate for FCW, AEB and PAEB. The NHTSA mandate document is available here.

It has taken a while for the NHTSA to get up to speed, so to speak, on ADAS. But it is now moving fast, with more to come.

NHTSA’s AEB rationale

The NHTSA’s main job is to lower vehicle crashes and their medical and economic impact in the U.S. To accomplish this goal with ADAS tech, the agency has a procedure. It has four prerequisites for determining which ADAS technology to deploy as part of NCAP or FMVSS. The figure below summarizes the procedure.

To identify the safety need, the NHTSA made a comprehensive analysis of its detailed database of vehicle crash data. The database goes back to at least 1966, with increasing details in the last 25 years.

The NHTSA’s analysis of the safety need focuses on the calendar year 2019 because it is the most recent year without the effect of the Covid pandemic. Much of the data comes from the Fatality Analysis Reporting System (FARS), which is a nationwide census providing annual data on fatal injuries in vehicle crashes. FARS data is available here.

The ADAS mitigation analysis relied on the NHTSA’s extensive research and testing of ADAS systems summarized in the previous section. The agency also cooperates with the Insurance Institute for Highway Safety (IIHS), Consumer Reports and other organizations that rate and/or test ADAS vehicles. IIHS has especially good perspectives on the positive impact of AEB through its auto insurance members.

Estimation of the safety benefits also leveraged the NHTSA’s ADAS and NCAP research, testing and related activities. Cost-benefit analysis is standard procedure for all NHTSA mandates, and it has long experience in modeling estimated costs and benefits. The auto industry is likely to add its own perspectives on cost benefits, especially with regard to the costs that the auto industry must pay when the mandate starts.

ADAS testability relies on multiple sources and expertise. The sharp increase in AEB-equipped vehicles has allowed the NHTSA and many other organizations to test and rank ADAS-equipped vehicles. The NHTSA has done extensive ADAS testing, with AEB receiving the most attention. As part of the AEB-PAEB proposal, it published a detailed report on the testing required for the new mandate—with a page count exceeding 750 pages. The publication is available here. A shorter version (113 pages) is available here.

How AEB solves part of safety problem

The NHTSA initiated the AEB mandate to reduce the frequency of rear-end crashes, which is the most prevalent vehicle crash type, and to target one of the most concerning and current urgent traffic safety problems: the rapidly increasing numbers of pedestrian fatalities and injuries.

Frontal crashes or rear-end crashes for the victim vehicle are very common, although most are not deadly. Up to 2,000 people in the U.S. die in rear-end crashes each year, making up 5% to 7% of total crash fatalities.

Pedestrian crashes are deadly and have been increasing in recent years. They tend to happen at night and at higher speeds. About half of fatal pedestrian crashes happen on roads with a speed limit of 40 mph or lower and half on roads with a speed limit of 45 mph or higher.

The next figure summarizes how AEB, including pedestrian AEB, can solve part of the vehicle crash problem. The top red blocks show the safety needed for frontal crashes and pedestrian crashes. Frontal crashes accounted for 32% of total crashes in 2019, 5% of fatalities and 21% of all injuries. Pedestrian crashes were only 4% of all crashes, 17% of fatalities and 5% of all injuries in 2019.

The ADAS solution that the NHTSA is proposing is summarized in the blue box. The agency is requiring FCW to alert the driver to any impending collision with a forward obstacle. The key to both frontal and pedestrian AEB is that vehicles must pass all NHTSA-specified testing without hitting the front vehicle or a pedestrian. The testing requirements are much tougher than the current voluntary AEB systems. This will greatly increase the benefit of future AEB-PAEB vehicles—especially as the AEB-PAEB or vehicles in use grows in the next decade or two. Another major improvement is that pedestrian AEB has to be tested in daytime and nighttime conditions.

This crash-avoidance requirement is specified for all NHTSA testing conditions. This does not mean that crash avoidance will happen in all traffic and driving conditions. The testing technology is not safe enough to test the AEB systems at all legal speed limits. PAEB is tested up to 65 km/hour (40.4 mph). Frontal AEB is tested up to 100 km/hour (62.1 mph).

The NHTSA’s projected AEB-PAEB benefits are shown in the green boxes. A total of 362 fatalities per year is projected to be prevented, with PAEB accounting for 66%, or 238 lives saved. Frontal AEB will have the most injuries mitigated at 89% of the total 24,321 injuries mitigated. The NHTSA believes these estimates are conservative.

The agency also estimated the cost of adding FCW-AEB-PAEB to the vehicles and believes there will only be software costs added per car. The NHTSA issued these prepared remarks:

“Because common hardware is used across lead vehicle AEB and PAEB systems, specific system functionality can be achieved through upgraded software. Therefore, the incremental cost associated with this proposed rule reflects the cost of a software upgrade that would allow current systems to achieve lead vehicle AEB and PAEB functionality that meets the requirements specified in the proposed rule. The incremental cost per vehicle is estimated at $82.15 for each design-cycle change of the model. When accounting for design cycles and annual sales of new light vehicles, the total annual cost associated with the proposed rule is approximately $282.2 million, in 2020 dollars.”

The $282.2 million figure is an average of $17.97 per vehicle, with the NHTSA assuming a sales volume of 15.7 million units per year.

The design-cycle cost of $82.15 per vehicle is not included in the cost estimates. It is possible that some part of the software development cost should be added to the total annual costs because each model is updated every three to four years. Additionally, there are yearly software maintenance costs.

AEB-PAEB mandate deployment

When the NHTSA makes FMVSS-based mandates, there are always some timing uncertainties. There is a 60-day comment period, which could be extended. The agency may need some time to update the proposal.

If the final FMVSS rule is published by the end of August, most of the AEB-PAEB features will be required by model year 2027, which starts Sept. 1, 2026. The most stringent testing features are mandated for one year later or model year 2028. If the NHTSA’s final rule is published later in 2023 or before September 2024, the mandate deployment is delayed another year—model year 2028 and model year 2029.

The NHTSA is hoping to get a voluntary agreement with most auto OEMs for early deployment of the AEB-PAEB mandate. This was very successful for the first AEB recommendation and there is a good chance it will happen again. Many OEMs have come a long way in ADAS technology and could implement AEB-PAEB quicker than the mandate timeline.



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