By Member Michael Graham
I recently participated in my first NTSB Board meeting as a member. We deliberated the findings of a crash involving a Tesla that drove into a gore area and struck a crash attenuator on a highway in Mountain View, California, killing the driver. Although this investigation was focused on level 2 automation safety issues, we also discussed the building blocks of autonomous vehicles—collision avoidance systems (CAS). In this crash, the vehicle was equipped with forward collision warning (FCW) and automatic emergency braking (AEB), elements of a CAS, but they were not designed for this kind of collision. Additionally, we discussed how testing protocols for CAS should be more demanding, and that one way to do that is through the National Highway Safety Administration’s (NHTSA) New Car Assessment Program (NCAP), its 5-star safety rating system for new automobiles. During the Board meeting, we highlighted vehicle rating systems in other countries, especially the European NCAP (Euro NCAP), and how they could—and should—be a model for the United States.
We believe a robust NCAP is vitally important for safety. A rating system helps manufacturers assess a vehicle’s crashworthiness, which is critical, but the NCAP can also be a great tool for consumers to assess which vehicles have advanced safety technologies and provide a guide for how they work. Additionally, such a rating system gives manufacturers an incentive to improve performance. A rating system that regularly increases the criteria for achieving a top score and promotes competition, compels automakers to continually improve the technology.
The US NCAP currently only provides crashworthiness (occupant protection) ratings; it doesn’t rate advanced safety technologies, such as FCW or AEB. These technologies are already on our roadways today and American consumers have no resources available to them to evaluate the effectiveness of collision avoidance technologies. Some consumers may even be totally unaware what CAS their automobiles come with.
In May 2015, the NTSB released a report touting the benefits of CAS and recommended that NHTSA expand the NCAP 5-star rating system to include a scale that rates CAS technology such as FCW performance. It also recommended it include the ratings on the legally required Monroney label, a window sticker that provides official data about the vehicle to consumers. We were pleased to see that, shortly after the report was released, NHTSA proposed a rule for testing procedures that would be similar to the more comprehensive testing done by European regulators. More importantly, NHTSA proposed expanding the NCAP 5-star rating to include a CAS rating, as well as pedestrian protection rating. Unfortunately, NHTSA has yet to publish a final rule to make this proposal a reality. It has issued several requests for comments regarding various aspects of testing protocols, but hasn’t moved forward to implement expansion.
The Euro NCAP, which was developed in 2009—nearly 15 years after the US NCAP—offers crashworthiness ratings as well as ratings on pedestrian protection (including cyclists) and driver-assistance and crash-avoidance technologies. Its safety assist rating for CAS is determined from tests of AEB, lane keeping, seat belt warnings, speed warning systems, and others. Euro NCAP ratings are displayed with the consumer in mind, with easy to read and compare pictures, diagrams and tables. There is currently no federal resource for rating CAS for US consumers
The Euro NCAP, as well as organizations in Australia and Japan, recognizes what we have long known: that car-to-car rear impacts are among the most frequent crash types, making it critical to rate technologies that address these safety issues. NHTSA has established test protocols and performance specifications for FCW and AEB as part of the US NCAP. For example, if a vehicle model is equipped with FCW or AEB, and has passed NHTSA’s minimum testing protocols, NHTSA’s website will state that such a vehicle may be equipped with those features; however, that only indicates that those systems have met NHTSA’s minimum performance criteria, and the vehicle only receives a pass or fail grade. CAS that meet the performance specifications are listed only as “recommended safety technologies” in the US NCAP. We know that various FCWs differ greatly in their performance—this pass/fail rating is not enough.
Additionally, although the US NCAP and the Euro NCAP use similar scenarios in their test protocols, the Euro NCAP uses a variety of targets, such as vehicles, bicyclists, and pedestrians; tests at a greater range of speeds; and, most importantly, rates system performance. Our Mountain View report recommends that the US NCAP be expanded even further to test forward collision avoidance systems performance using common obstacles, such as traffic safety hardware, cross-traffic vehicle profiles, and other applicable vehicle shapes or objects found in the highway operating environment.
Without a US NCAP to rate collision avoidance technologies, US consumers have had to turn to insurance research organizations for this kind of information. The Insurance Institute for Highway Safety (IIHS), for example, offers consumers vehicle reviews and ratings and issues its top safety picks. IIHS tests evaluate two aspects of safety: crashworthiness (how well a vehicle protects its occupants in a crash) and crash avoidance and mitigation (technology that can prevent a crash or lessen its severity). This is a great first step for consumers in the United States, but we need our regulators to step up and do the same.
The US NCAP has fallen behind its counterparts with respect to the safety information it provides to American consumers about CAS. We know that CAS can be very effective and can save lives, making it even more important to educate consumers about these critical technologies—their benefits as well as their limitations. That’s why this issue has been on the NTSB Most Wanted List for several years now.
We urge NHTSA to again become a global leader by incorporating CAS and other safety performance measures in the US NCAP, and by adopting testing protocols for CAS in commercial vehicles and requiring them on all new heavy vehicles. European and other international organizations have figured out the importance of offering these expansive rating systems to help save lives and improve transportation safety. It’s time for the United States to catch up.