Five Star Ratings for Collision Mitigation/Avoidance Systems

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1 Motor & Equipment Manufacturers Association Comments on New Car Assessment Program (NCAP); Request for Comments Docket No. NHTSA July 5, 2013 Introduction The Motor & Equipment Manufacturers Association (MEMA) represents more than 1,000 companies that manufacture motor vehicle parts for use in the light- and heavy-duty vehicle original equipment and aftermarket industries. MEMA represents its members through four affiliate associations: Automotive Aftermarket Suppliers Association (AASA); Heavy Duty Manufacturers Association (HDMA); Motor & Equipment Remanufacturers Association (MERA); and, Original Equipment Suppliers Association (OESA). These comments are in response to the National Highway Traffic Safety Administration (NHTSA) request for comments regarding near- and long-term upgrades to the New Car Assessment Program (NCAP). Motor vehicle parts manufacturers are the leaders in the development of innovative technology critical to creating increasingly more safe and energy-efficient vehicles. Suppliers collaborate with original equipment manufacturers (OEMs) to develop and evolve technologies that improve vehicle performance, safety, fuel economy, and emissions through a variety of components. Supplier companies are becoming increasingly responsible for producing significant segments of motor vehicles; they frequently solely design and engineer those parts and systems. Because of the suppliers critical role in evolving and engineering new components, they will continue to be vital to the motor vehicle industry as regulations, industry standards, and consumers demand more safe and environmentally-friendly vehicles. Enhancing future elements of the NCAP can be key to encouraging the adoption and penetration of advanced safety technologies into the marketplace. It is clear that there are a wide variety of existing, evolving, and emerging vehicle technologies all with some tangible safety benefit. NCAP should surely utilize and incorporate improved and/or new technologies. More importantly, the vehicle technologies MEMA addresses herein have ripened and matured since the last NCAP enhancements were initiated in Unfortunately, these systems are only available on a limited number of vehicles. At the current pace of market penetration, these technologies may not significantly impact crash statistics for a considerable period of years. MEMA emphasizes that these systems are commercially available and can be deployed in high volume. Consumer understanding and acceptance of these technologies, as rated safety technologies, are a key component to realizing the actual safety benefits much sooner. NCAP is vital to that process. MEMA has consistently urged NHTSA to remain technology-neutral whether it is a regulatory mandate or as part of the NCAP. However, NCAP can provide objective, government-

2 July 5, 2013 Page 2 of 6 evaluated safety technologies and information so that consumers can decide what vehicle meets their safety needs. Considering the pace of technology, as well as the variety of technologies here today and coming tomorrow, NCAP is the ideal path forward without the need for regulatory mandates to let the marketplace respond to consumer demand. Five Star Ratings for Collision Mitigation/Avoidance Systems In recent years, the rate of motor vehicle-related injuries and fatalities has been steadily decreasing. Major advances and adoptions of passive safety technologies have played a key role in this decline. Improvements to crashworthiness technologies, such as seatbelts, air bags, and tempered glass, have helped more passengers survive crashes and reduce the severity of injuries. Unfortunately, recent preliminary figures for 2012 may end up being the first year-to-year increase since This potential reinforces the fact that industry must remain ever vigilant in its quest to develop advanced technologies to improve safety and mitigate collisions or prevent them from happening in the first place. The NCAP is a means by which NHTSA can encourage the faster adoption and penetration of important vehicle safety technologies into the marketplace and can propel consumers understanding of the various technologies and systems. In 2009, MEMA and its member companies that manufacture collision avoidance/collision mitigation components and systems were encouraged by the agency s revisions to the NCAP beginning with model year 2011 vehicles. The enhanced program not only introduced more stringent crash tests and a new 5-Star Safety Rating system, but also established new confirmation tests for three technologies Electronic Stability Control (ESC), Forward Collision Warning (FCW), and Lane Departure Warning (LDW) systems. MEMA urges NHTSA to revisit the issue of developing a comprehensive rating system for collision mitigation/avoidance technologies as part of the pending update to the NCAP. A rating system is a natural evolution of the agency s efforts to increase the safety impact of the NCAP and to enhance the distribution of critical information to consumers. The NHTSA vehicle safety ratings format is the most direct and tangible method to communicate, in an understandable way, all of the appropriate, important information consumers need to make an informed, educated purchasing decision when comparing vehicle-to-vehicle. When the NCAP program was revised in 2009, the automotive industry and NHTSA were still in the early stages of assessing collision avoidance systems. There were significant obstacles and challenges that had to be addressed in developing test procedures and compliance tests for technologies such as FCW. It was also more difficult to differentiate among the various systems and identify specific, repeatable tests. However, both NHTSA and the industry have made tremendous progress over the past few years and the current situation is notably different. The industry and the driving public stand to benefit from the significant resources that NHTSA has invested into evaluating systems like Crash Imminent Braking (CIB) and Dynamic Brake 1 Traffic Safety Stats bulletin Early Estimate of Motor Vehicle Traffic Fatalities for The First Nine Months (January September) of 2012 DOT HS , National Highway Traffic Safety Administration, (December 2012)

3 July 5, 2013 Page 3 of 6 Support (DBS). Today, there is access to a much wider repository of experience and expertise in testing collision avoidance systems. 2, 3 NHTSA s commitment to providing 5-Star Safety Ratings for vehicle crashworthiness has proven to be a leading factor in the design and production of safer vehicles in the United States. The dissemination of this critical information to the public has also educated consumers on how to compare different vehicles for their levels of protection and safety performance. Consumers understand and respect the 5-Star Safety Rating system. As U.S. consumers are increasingly more familiar with and knowledgeable about collision avoidance systems, a similar ratings approach for these technologies would resonate well with consumers. This improvement to the NCAP would emphasize the increasing importance of collision mitigation/avoidance systems in the vehicle. Clearly, there is parity between crashworthiness and crash avoidance one is not inferior to the other; the combination of rating these two categories of safety systems will offer the consumer the highest possible level of safety. This is consistent with the stated goal of NCAP, namely to create market forces to drive manufacturers to continually enhance the safety of their vehicles beyond the minimum federal safety requirements. In its budget request for fiscal year 2014, NHTSA cited its intent to continue to educate consumers about the crash test and advanced technologies information programs through partnerships, website and other outlets. Including collision mitigation/avoidance systems in the NCAP 5-Star Safety Rating system should also serve as a component of this strategy. NHTSA has invested significant resources in order to enhance its understanding of these systems and this investment should be translated into a more complex approach to evaluating advanced safety technologies for the good of consumers and drivers. MEMA recognizes that NHTSA has a separate docket 4 related to CIB and DBS and is currently planning to arrive at an agency decision on how to proceed with these forward collision mitigation technologies. In that docket, NHTSA published potential evaluation test methods; consequently, the industry responded with several OEMs and suppliers providing data and other information about their expertise as innovators and developers of these technologies. In the event that the agency decides to proceed with rulemaking for these technologies, the typical rulemaking timetables do not lend themselves to expediency. Incorporating these technologies into the NCAP program prior to promulgating potential rulemakings would help fill any timeline gaps and promote motor vehicle safety to the consumer. In the case of electronic stability control, a similar approach was used; MEMA urges the agency to handle collision mitigation/avoidance technologies similarly. Additionally, technology improvements to lane departure prevention (LDP) systems have built upon the LDW systems currently under the 2011 NCAP enhancements. Depending on the 2 Advanced Braking Technologies that Rely on Forward Looking Sensors, Docket No. NHTSA (July 2012) 3 Special Issue: Crash Avoidance, They re Working: Insurance claims data show which new technologies are preventing crashes Insurance Institute for Highway Safety/Highway Loss Data Institute,(July 3, 2012) 4 Docket No. NHTSA (July 2012)

4 July 5, 2013 Page 4 of 6 LDP system, there are different operational modes and approaches to these systems that provide various levels of driver assistance (typically, based on sensors and steering inputs). Active steering controls can also provide additional haptic warnings or torque nudges to alert and provide directional assistance to the driver. As NHTSA acknowledges in its notice, these active systems go beyond the warning and provide actual steering and braking input to correct unintended drifting. The active characteristics of these advanced LDP systems will ultimately yield more safety benefits over just warning systems alone. All of these technologies are among the more mature and readily available collision mitigation technologies that exist today, and have the greatest potential to reduce fatalities and injuries in the near term. Accordingly, MEMA urges NHTSA to add CIB, DBS, and LDP technologies to the NCAP as near-term enhancements. Warning and Other Preventative Safety Technologies Blind spot detection warning and advanced lighting are preventative safety measures that would benefit from being included as a future NCAP enhancement. Sensors and other inputs can monitor the vehicle surroundings and see where the driver cannot (e.g. blind spot detection) or they can augment a driver s field-of-view (e.g. advanced vehicle lighting). The better the visual or non-visual information inputs are to the driver, the more quickly they can react to potential hazards. In addition to audio or visual warning signals, haptic warning signals such as wheel vibration, torque nudges are also effective complements to these systems. For example, wheel vibration pulses can be refined to the side from which the warning is coming (left or right) or can be felt in the entire wheel in order to guide the driver s attention and subsequent reaction. These technologies are mature, commercially available, and enhance driver safety. Therefore, MEMA recommends that these technologies also be included as near-term enhancements to the NCAP. Crash Notification Technologies Automatic collision notification (ACN) and advanced automatic collision notification (AACN) systems are available today and can complement overall safety benefits by helping to reduce fatalities and injuries. Utilizing vehicle sensors activated in a collision (e.g. airbag deployment or seatbelt pre-tensioners), these systems can activate an automatic emergency call to a telematics service provider. These systems can provide GPS location and open a voice channel to the driver. In certain advanced systems, the system can estimate injury severity based on data inputs received from other sensors, such as changes in vehicle velocity and number of passengers. The information provided by ACN and AACN systems go beyond just the utility of the data this information actually helps save lives and reduce injuries by improving notification and response times. In an accident, every minute counts. ACN and essential real-time data provided so quickly after an incident provides prompt emergency care for drivers and passengers. Furthermore, AACN injury estimate assessments can facilitate decision making as to which area medical facility will be best suited to treat the occupants, such as a trauma center. These systems reduce reliance on witnesses, bystanders, or the occupants to make contact with emergency services to report the incident. Essential and correct vehicle data such as VIN, vehicle

5 July 5, 2013 Page 5 of 6 make/model, and power train type help reduce confusion or error for those responding to the incident and allow the focus to be on triage. Various experts from vehicle industry, public health organizations, and government bodies 5, 6, 7, 8, 9 have studied the value ACN and AACN systems bring to the safety equation. Furthermore, in the near term, there are natural synergies between these notification technologies and the digital-based next generation 9-1-1, which can only strengthen the overall safety benefits and public health. Inclusion under NCAP builds upon the momentum gained in recent years in technology advances and on the foundation of analyses demonstrating the benefits. Naturally, the NCAP information about these systems would be made readily available to the consumer when making purchasing decisions. Ultimately, this will encourage drivers to demand these systems and for OEMs to adopt them more widely in their product offerings, thus, increasing the overall penetration in the nation s fleet. Therefore, particularly because these systems are available today, MEMA recommends that NHTSA include crash notification technologies as part of the near-term NCAP enhancements. Communicating NCAP Information MEMA welcomed NHTSA s promise in the 2011 NCAP enhancements final rule to conduct a comprehensive study of consumer research on the entire Monroney Label. In addition to reviewing the label s safety information component, NHTSA specifically noted that they would consider adding advanced collision avoidance safety information to the label. MEMA subsequently provided comments supporting the NHTSA proposed information collection request to the Office of Management and Budget to permit the agency to conduct focus groups and glean additional data on consumer expectations. 10 MEMA recognizes that NHTSA is addressing these matters in a separate proceeding. However, MEMA reiterates its recommendation to NHTSA to incorporate information about NCAP safety technologies on the physical label. Notwithstanding NHTSA s request under this particular docket to avert comments on subjects like the Monroney Label, but taking into account MEMA s aforementioned comment and recommendation to establish a 5-Star ratings framework for active safety technologies (CIB, DBS, LDP), MEMA strongly recommends inclusion of this important safety information on the label to help assure maximum impact and benefit to consumers. 5 Gerberding, Julie L.; Falk, Henry; Arias, Ileana; Hunt, Richard C.; National Center for Injury Prevention and Control, Division of Injury Response Recommendations from the Expert Panel: Advanced Automatic Collision Notification and Triage of the Injured Patient, Centers for Disease Control and Prevention (2008) a.pdf 6 Association of Public Safety Communications Officials, and veds/aacn andveds resources.html 7 William J. Lehman Injury Research Center, University of Miami, Miller School of Medicine, Department of Surgery. lehman injury research center/research/crash study 8 Comments of the National Emergency Number Association, National Highway Traffic Safety Administration Strategic Planning, Docket No. NHTSA (Jan. 7, 2009) 9 Kononen, D.W.; Flannagan, C.A.; Wang, S.C.; General Motors, Univ. of Michigan Transportation Research Institute, Universty of Michigan Medical Center, "Identification and Validation of a Logistic Regression Model for Predicting Serious Injuries Associated with Motor Vehicle Crashes" Accident Analysis Prevention (2010) 10 NHTSA (Nov. 7, 2011)

6 July 5, 2013 Page 6 of 6 Conclusion NHTSA addresses many other safety technologies in its notice and MEMA believes they all have merit and should all be considered for inclusion into the NCAP whether it is near- or long-term. For the near term, however, the technologies mentioned above are likely to be the ones that will provide more immediate impact on safety by mitigating or avoiding collisions and reducing injuries and fatalities. Also, MEMA expects that many of its member companies will provide specific, detailed comments related to their products and technologies. MEMA urges NHTSA to include active safety technologies under the 5-Star Safety Rating system so that consumers have a complete safety systems profile by which to compare vehicles. MEMA also recommends warning technologies that increase visibility and notification systems that improve emergency response would be very beneficial to enhancing the NCAP. Lastly, MEMA continues to support NHTSA s efforts to research and evaluate ways to best communicate important NCAP information to the consumer, particularly placing this information on the label. MEMA and the companies it represents are confident that NHTSA will take the appropriate steps to enhance the NCAP. Programs similar to this help the agency meet its overarching goal to save lives, prevent injuries, and reduce economic costs resulting from collisions. Respectfully submitted, Ann Wilson Senior Vice President, Government Affairs Leigh S. Merino Director, Regulatory Affairs