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Safety Recommendation Details

Safety Recommendation H-15-009
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 PASSENGER VEHICLE, TRUCK-TRACTOR, MOTORCOACH, AND SINGLE-UNIT TRUCK MANUFACTURERS: Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles.
Original recommendation transmittal letter: PDF
Overall Status: Open - Acceptable Response
Mode: Highway
Location: United States
Is Reiterated: Yes
Is Hazmat: No
Is NPRM: No
Accident #: DCA14SS001
Accident Reports:
Report #: HAR-15-02
Accident Date: 11/20/2013
Issue Date: 6/8/2015
Date Closed:
Addressee(s) and Addressee Status: American Honda Motor Company, Inc. (Open - Await Response)
Aston Martin Lagonda Ltd (Open - Await Response)
BMW North America LLC (Open - Await Response)
Daimler Trucks North America LLC (Open - Acceptable Response)
FCA US LLC (Fiat Chrysler Automobiles) (Open - Acceptable Response)
Ferrari USA (Open - Await Response)
Ford Motor Company (Open - Acceptable Response)
Fuji Heavy Industries USA, Inc. (Closed - Reconsidered)
General Motors (Open - Acceptable Response)
Hino Motors Manufacturing USA, Inc. (Open - Acceptable Response)
Hyundai Motor America (Open - Await Response)
Isuzu Motors, Inc. (Open - Await Response)
Jaguar Land Rover North America LLC (Open - Acceptable Response)
Kia Motors America, Inc. (Open - Await Response)
Maserati North America, Inc. (Open - Acceptable Response)
Mazda North American Operations (Open - Acceptable Response)
Mercedes-Benz USA LLC (Open - Acceptable Response)
Mitsubishi Motors North America, Inc. (Open - Acceptable Response)
Motor Coach Industries International, Inc. (Open - Await Response)
Navistar, Inc. (Open - Acceptable Response)
Nissan Group of North America, Inc. (Open - Await Response)
PACCAR, Inc. (Open - Acceptable Response)
Porsche Cars North America, Inc. (Open - Await Response)
Subaru of America, Inc. (Open - Acceptable Response)
Suzuki Motor of America, Inc. (Closed - Reconsidered)
Tesla Motors (Open - Await Response)
Toyota Motor North America, Inc. (Open - Acceptable Response)
Van Hool NV (Open - Acceptable Response)
Volkswagen Group of America, Inc. (Open - Acceptable Response)
Volvo Cars of North America, Inc. (Open - Acceptable Response)
Volvo Group North America LLC (Open - Acceptable Response)
Keyword(s):

Safety Recommendation History
From: NTSB
To: PACCAR, Inc.
Date: 5/9/2018
Response: We note that you continue to work with federal regulators, vendors, and your customers to develop effective AEB performance requirements that could become the framework for a federal heavy vehicle performance standard. We look forward to receiving further information from you as NHTSA develops and publishes its standards and you have the opportunity to comply with them. Until then, Safety Recommendation H-15-9 remains classified OPEN--ACCEPTABLE RESPONSE.

From: PACCAR, Inc.
To: NTSB
Date: 2/27/2018
Response: -From Pamela S. Tonglao, Counsel: This letter serves as PACCAR’s response to NTSB recommendations H-15-8 and H-15-9, which were reiterated in the report Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10, Palm Springs, California, October 23, 2016, NTSB/HAR-17/04. H-15-8 recommends that vehicle manufacturers install forward collision avoidance systems that include, at a minimum, a forward collision warning component as standard equipment on all new vehicles. H-15-9 recommends that manufacturers install autonomous emergency braking systems on all new vehicles once NHTSA publishes performance standards for such systems. PACCAR’s two manufacturing divisions – Kenworth Truck Company and Peterbilt Motors Company – have taken significant steps to increase the prevalence of collision avoidance systems in new production. Starting on July 1, 2017, Kenworth and Peterbilt made the Bendix Wingman Advanced collision mitigation system standard on the on-highway Kenworth T680 and Peterbilt 579 models. Customers may elect to delete the option during the ordering process, but the default is to include this safety feature. In 2017, the percentage of class 8 trucks built with collision mitigation systems was 26.7% for Kenworth and 20% for Peterbilt. If medium-duty chassis are included, the total is 21.3% for Kenworth and 17% for Peterbilt. For the on-highway T680 model alone, the take rate was 55.8% in 2017. We continue to share information about the substantial safety benefits of collision avoidance systems and demonstrate the technology at customer events. Moreover, both divisions are actively exploring ways to integrate collision mitigation technology into vocational trucks. Many vocational customers require equipment to be mounted in the center of the front bumper, which renders that location unavailable for radar installation. Design efforts are underway to identify ways to accommodate competing demands on limited space. Regarding autonomous emergency braking, our customers report mixed experiences with AEB functionality that is provided as part of collision mitigation systems. We remain engaged with regulators, vendors, and customers in discussions regarding system improvements to reduce the frequency of ghost braking. Thank you for giving PACCAR the opportunity to respond to the Safety Board’s recommendations.

From: NTSB
To: PACCAR, Inc.
Date: 11/21/2017
Response: -From the NTSB Highway Safety Report HAR-17-04 “Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10 Palm Springs, California, October 23, 2016.” Adopted October 31, 2017 and issued November 21, 2017: 2.7 Collision Avoidance Systems The NTSB has been advocating for various collision avoidance systems (CAS) since 1995, when the Board recommended in Safety Recommendation H-95-44 that the DOT examine the efficacy of collision warning systems (CWS) in commercial vehicles (NTSB 1995). In 2001, as part of a special investigation report, the Board issued 10 recommendations pertaining to the development and adoption of collision avoidance technologies (NTSB 2001). Although technologies have advanced considerably since 2001, the level of deployment of CAS in highway vehicles has remained minimal. More importantly, the rate of rear-end crashes, which forward CAS are designed to prevent, remains unaffected. In 2015, the NTSB published an updated special investigation report on forward CAS, including CWS and autonomous emergency braking systems, which contained six recommendations to vehicle manufacturers and NHTSA (NTSB 2015b). Specifically, the NTSB recommended that both passenger and commercial vehicle manufacturers take the following actions:89 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. (H-15-8) Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. (H-15-9) Safety Recommendations H-15-8 and -9 are classified “Open?Await Response” for the commercial vehicle manufacturers Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., and MCI; they are classified “Open—Acceptable Response” for the commercial vehicle manufacturers Hino Motors Manufacturing USA Inc., Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. With the understanding that commercial vehicles may require different performance parameters than those for passenger vehicles, the NTSB also issued the following recommendation to NHTSA: Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. (H-15-5) Based on NHTSA’s response, which did not address CAS in commercial vehicles, the NTSB classified Safety Recommendation H-15-5 “Open-Unacceptable Response.” The large dimensions of the truck, coupled with the sparse surrounding traffic, would have made the truck a detectable obstacle for a forward CAS. The NTSB concludes that the installation of CAS technology in all highway vehicles could prevent the occurrence of rear-end crashes similar to this crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., Hino Motors Manufacturing USA Inc., MCI, Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. Further, to ensure that the CAS components for commercial vehicles, particularly autonomous emergency braking systems, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: PACCAR, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: PACCAR, Inc.
Date: 1/11/2016
Response: We note that you currently offer forward CAS with AEB as optional equipment for your customers. We commend your efforts to make these technologies available, despite a lack of federal performance standards, and your efforts to educate your customers about the benefits of advanced safety technologies. Because NHTSA has not yet developed heavy vehicle CAS or AEB standards, it is not possible to determine whether your systems would meet that agency’s criteria. We look forward to receiving further information from you once NHTSA has developed and published its standards, and you have had the opportunity to compare your systems with them. Until then, we encourage you to continue your efforts to develop collision avoidance technologies and install them as standard equipment on all your new truck tractors. Pending such action, Safety Recommendations H-15-8 and -9 are classified OPEN—ACCEPTABLE RESPONSE.

From: PACCAR, Inc.
To: NTSB
Date: 9/11/2015
Response: -From Pamela S. Tonglao, Counsel: This letter responds to your correspondence of June 8, 2015, in which you inquired about PACCAR's intentions with regard to NTSB recommendations H-15-8 and H-15-9. H-15-8 recommends that vehicle manufacturers install forward collision avoidance systems that include, at a minimum, a forward collision warning component as standard equipment on all new vehicles. H-15-9 recommends that manufacturers install autonomous emergency braking systems on all new vehicles once NHTSA publishes performance standards for such systems. The NTSB's recommendations have been shared with PACCAR's two manufacturing divisions Kenworth Truck Company and Peterbilt Motors Company- where committees were already evaluating methods to increase the prevalence of collision avoidance systems in new production. The actions under consideration encompass a range of measures, from making systems standard, as H-15-8 recommends, to providing informational recommendations to customers during the order review process. Changes that impact base model cost require approval of the general manager and must be executed with price level releases, which occur on a scheduled basis. Measures that do not affect base model cost can be implemented more expeditiously. PACCAR introduced its first collision warning system into Peterbilt and Kenworth trucks in 2002. We have since seen a significant increase in the usage of collision warning systems, particularly within the last few years. For example, in 2014, trucks delivered with forward collision avoidance systems represented 6.3 percent of Kenworth's total production. In 2015, year-to date sales data show that 12.5 percent of Kenworth's new trucks were equipped with collision avoidance systems. Peterbilt and Kenworth are committed to achieving wider acceptance of these technologies. Each PACCAR truck is custom-built to meet specifications prescribed by the customer. The customer works with an authorized Kenworth or Peterbilt dealer to select features and options that suit the customer's intended application, whether it is line haul, drayage, logging, fire protection, refuse collection or some other vocational use. Once the dealer submits a truck purchase order to Kenworth or Peterbilt, the applications engineering group reviews and provides customized suggestions and warnings to the customer. Within the back-and-forth exchange between customer and manufacturer, there are meaningful opportunities to educate and effect positive change. We will do our part to ensure that fleet and individual customers alike recognize the substantial safety benefits of collision avoidance systems and the autonomous emergency braking attributes that are part of CAS. Thank you for giving PACCAR the opportunity to respond to the Safety Board's recommendations. We would be pleased to answer any questions regarding the information in this letter.

From: NTSB
To: Aston Martin Lagonda Ltd
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: BMW North America LLC
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: FCA US LLC (Fiat Chrysler Automobiles)
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: FCA US LLC (Fiat Chrysler Automobiles)
Date: 1/8/2016
Response: We note that you also currently offer AEB as optional equipment on some of your vehicle models. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems with those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: FCA US LLC (Fiat Chrysler Automobiles)
To: NTSB
Date: 9/10/2015
Response: -From Tim Czapp, Senior Manager, Vehicle Safety and Regulatory Compliance: In January of 2013, FCA began offering its first vehicles with an autonomous emergency braking system and continues to expand offerings for the feature in our portfolio. FCA supports efforts by the National Highway Traffic Safety Administration (NHTSA) to improve real world data collection and benefit analysis and also to encourage consumer education about the potential benefits of these technologies. FCA currently has eight vehicles with these technologies, from the compact Fiat 500x to full-size Dodge Durango sport utility vehicle. The Chrysler 200 and Jeep® Renegade were the first vehicles in their segments with these features and showcase our commitment to introduce such advanced technologies into mainstream, mass market products.

From: NTSB
To: Daimler Trucks North America LLC
Date: 10/1/2018
Response: We note that you are working to develop effective AEB systems that you plan to offer as standard equipment on all your vehicle lines. In addition, we are pleased that you are willing to share your development experience with NHTSA as the agency moves forward with work on a federal heavy vehicle performance standard. We look forward to receiving further information from you as NHTSA develops and publishes its standards and you have the opportunity to comply with them. Until then, Safety Recommendation H-15-9 is classified OPEN--ACCEPTABLE RESPONSE.

From: Daimler Trucks North America LLC
To: NTSB
Date: 6/12/2018
Response: -From Sean Waters, Director, Compliance and Regulatory Affairs, Daimler Trucks North America, LLC: This letter is in response to your November 21, 2017 letter to our President and CEO, Mr. Roger Nielsen, regarding the above-referenced reiterated recommendations for providing Collision Avoidance Systems by the National Transportation Safety Board. Daimler Trucks North America (DTNA) headquartered in Portland, Oregon, is the leading heavyduty truck manufacturer in North America and employs more than 15,000 people in various locations across the USA. DTNA has a strong commitment to vehicle safety as demonstrated by our history of being first to market with many safety technology systems including antilock brake systems in 1987, obstacle detection systems in 1996, driver airbag systems in 1998, stability control in 2002, lane departure warning systems in 2006, and seat belt pre-tensioner, side airbag systems for rollover protection, and adaptive cruise control all in 2007. Given our commitment to active safety systems and the increase in public interest, we would like to respond to the NTSB's reiteration of safety recommendations regarding the status of development of Collision Avoidance Systems. Specifically, we wish to respond to H-15-8 and H-15-9 noted in the following. DTNA is working toward developing and making standard our ABA autonomous emergency braking system for all models in our vehicle lineup. With the customization and variability for heavy trucks that exists as part of the commercial vehicle industry, research is needed and being conducted by DTNA regarding the performance of our ABA system on vehicles other than our new Cascadia product. When we are able to determine and guarantee that our high level of performance in safety can be achieved for ABA, DTNA will make further decisions on applying our technology as standard equipment across all of our vehicles. Accordingly, DTNA will work with NHTSA, providing our market-specific experience as the leader in safety and largest commercial vehicle manufacturer in the United States should the agency pursue the development of performance standards for autonomous emergency braking systems in heavy trucks. In closing, safety is our highest priority at Daimler Trucks and we look forward to our continued involvement and interaction with the NTSB as we share the same mission of reducing crashes and saving lives. Thank you for the opportunity to respond to your recommendations. Please do not hesitate to reach out to us should you have further questions about our correspondence with you on this important topic.

From: NTSB
To: Daimler Trucks North America LLC
Date: 11/21/2017
Response: -From the NTSB Highway Safety Report HAR-17-04 “Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10 Palm Springs, California, October 23, 2016.” Adopted October 31, 2017 and issued November 21, 2017: 2.7 Collision Avoidance Systems The NTSB has been advocating for various collision avoidance systems (CAS) since 1995, when the Board recommended in Safety Recommendation H-95-44 that the DOT examine the efficacy of collision warning systems (CWS) in commercial vehicles (NTSB 1995). In 2001, as part of a special investigation report, the Board issued 10 recommendations pertaining to the development and adoption of collision avoidance technologies (NTSB 2001). Although technologies have advanced considerably since 2001, the level of deployment of CAS in highway vehicles has remained minimal. More importantly, the rate of rear-end crashes, which forward CAS are designed to prevent, remains unaffected. In 2015, the NTSB published an updated special investigation report on forward CAS, including CWS and autonomous emergency braking systems, which contained six recommendations to vehicle manufacturers and NHTSA (NTSB 2015b). Specifically, the NTSB recommended that both passenger and commercial vehicle manufacturers take the following actions:89 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. (H-15-8) Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. (H-15-9) Safety Recommendations H-15-8 and -9 are classified “Open?Await Response” for the commercial vehicle manufacturers Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., and MCI; they are classified “Open—Acceptable Response” for the commercial vehicle manufacturers Hino Motors Manufacturing USA Inc., Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. With the understanding that commercial vehicles may require different performance parameters than those for passenger vehicles, the NTSB also issued the following recommendation to NHTSA: Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. (H-15-5) Based on NHTSA’s response, which did not address CAS in commercial vehicles, the NTSB classified Safety Recommendation H-15-5 “Open-Unacceptable Response.” The large dimensions of the truck, coupled with the sparse surrounding traffic, would have made the truck a detectable obstacle for a forward CAS. The NTSB concludes that the installation of CAS technology in all highway vehicles could prevent the occurrence of rear-end crashes similar to this crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., Hino Motors Manufacturing USA Inc., MCI, Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. Further, to ensure that the CAS components for commercial vehicles, particularly autonomous emergency braking systems, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Daimler Trucks North America LLC
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Ferrari USA
Date: 4/18/2017
Response: From the NTSB Highway accident report "Motorcoach Collision with Crash Attenuator in Gore Area, US Highway 101, San Jose, California, January 19, 2016" HAR-17-01, PB2017-101430, which was adopted on March 28, 2017: 2.6 Collision Avoidance Systems The NTSB has advocated for various CAS technologies for more than 20 years. In the investigation of a 1995 multivehicle collision in Menifee, Arkansas, the NTSB recommended that the DOT test CWS in commercial vehicles (Safety Recommendation H-95-44; NTSB 1995). Since then, we have issued 19 recommendations pertaining to collision warning, adaptive cruise control, and AEB systems in both passenger and commercial vehicles. As part of this effort, the NTSB recently issued a special investigation report in which we examined advances in CAS technologies and issued the following recommendations to motorcoach manufacturers (NTSB 2015b): H-15-8 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. H-15-9 Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. Acknowledging that the CAS performance parameters in passenger and commercial vehicles may differ, the NTSB also issued the following safety recommendation to NHTSA (NTSB 2015b): H-15-5 Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. Safety Recommendations H-15-8 and -9 are classified “Open-Await Response” for MCI, and Safety Recommendation H-15-5 is classified “Open-Unacceptable Response.” Although 20 percent of the Greyhound fleet is equipped with some type of CAS, the MCI bus involved in this crash had neither a CWS nor an AEB system. In a test scenario representing crash conditions, NTSB investigators showed that CAS would have been effective in preventing or mitigating the severity of the crash. The tested system detected the crash attenuator in 18 of 19 trials and then provided a warning 2?3 seconds before impact and activated the AEB 1-2 seconds before impact. The testing was conducted on a CAS-equipped truck-tractor. The effect of AEB in motorcoaches may vary due to differences in design of the brake systems, but the benefits of CWS remain: the technology is clearly capable of detecting the stationary hazard and warning the driver in time to mitigate the consequences of the crash. The NTSB concludes that had the bus been equipped with a CAS technology, it could have alerted the driver of the forward hazard in time to mitigate the severity of the crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to MCI. To ensure that CAS components for commercial vehicles, particularly AEB, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Ferrari USA
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Ford Motor Company
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Ford Motor Company
Date: 1/8/2016
Response: As Mr. Bahr pointed out in his letter, you currently offer AEB as optional equipment in one of your Lincoln models. In addition, we were pleased to hear of your commitment, announced on September 11, 2015, at the Insurance Institute for Highway Safety crash avoidance facility dedication, to include AEB as a standard feature on all new vehicle models. We would appreciate receiving updates on your plans to meet this worthy goal. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems with those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Ford Motor Company
To: NTSB
Date: 9/8/2015
Response: -From Wayne E. Bahr, Director Automotive Safety Office: Ford recently launched Autonomous Emergency Braking (AEB) on the 2016 Lincoln MKX. AEB is a new and emerging technology that will continue to evolve. Ford is eager to work with NHTSA and other stakeholders in the development of an appropriate test/evaluation protocol. We will continue to review customer acceptance of AEB and consider expanding the availability of AEB across our products.

From: NTSB
To: Fuji Heavy Industries USA, Inc.
Date: 2/21/2018
Response: We note that you have neither distributed nor sold heavy vehicles in the US market since at least calendar year 2015. Accordingly, Safety Recommendations H-15-8 and -9 to Fuji Heavy Industries are classified CLOSED--RECONSIDERED.

From: NTSB
To: Fuji Heavy Industries USA, Inc.
Date: 11/21/2017
Response: -From the NTSB Highway Safety Report HAR-17-04 “Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10 Palm Springs, California, October 23, 2016.” Adopted October 31, 2017 and issued November 21, 2017: 2.7 Collision Avoidance Systems The NTSB has been advocating for various collision avoidance systems (CAS) since 1995, when the Board recommended in Safety Recommendation H-95-44 that the DOT examine the efficacy of collision warning systems (CWS) in commercial vehicles (NTSB 1995). In 2001, as part of a special investigation report, the Board issued 10 recommendations pertaining to the development and adoption of collision avoidance technologies (NTSB 2001). Although technologies have advanced considerably since 2001, the level of deployment of CAS in highway vehicles has remained minimal. More importantly, the rate of rear-end crashes, which forward CAS are designed to prevent, remains unaffected. In 2015, the NTSB published an updated special investigation report on forward CAS, including CWS and autonomous emergency braking systems, which contained six recommendations to vehicle manufacturers and NHTSA (NTSB 2015b). Specifically, the NTSB recommended that both passenger and commercial vehicle manufacturers take the following actions:89 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. (H-15-8) Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. (H-15-9) Safety Recommendations H-15-8 and -9 are classified “Open?Await Response” for the commercial vehicle manufacturers Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., and MCI; they are classified “Open—Acceptable Response” for the commercial vehicle manufacturers Hino Motors Manufacturing USA Inc., Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. With the understanding that commercial vehicles may require different performance parameters than those for passenger vehicles, the NTSB also issued the following recommendation to NHTSA: Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. (H-15-5) Based on NHTSA’s response, which did not address CAS in commercial vehicles, the NTSB classified Safety Recommendation H-15-5 “Open-Unacceptable Response.” The large dimensions of the truck, coupled with the sparse surrounding traffic, would have made the truck a detectable obstacle for a forward CAS. The NTSB concludes that the installation of CAS technology in all highway vehicles could prevent the occurrence of rear-end crashes similar to this crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., Hino Motors Manufacturing USA Inc., MCI, Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. Further, to ensure that the CAS components for commercial vehicles, particularly autonomous emergency braking systems, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Fuji Heavy Industries USA, Inc.
Date: 8/18/2016
Response: We were pleased to hear of your commitment, announced on March 17, 2016, to include AEB as a standard feature on all new vehicle models by September 1, 2022—a promise you made as part of a group of 20 automakers that signed a memorandum of understanding (MOU) with NHTSA. We understand that this MOU will affect more than 99 percent of the US auto market. We would appreciate receiving updates on your plans to meet this worthy goal. We note that you currently offer forward CASs as optional equipment on several of your vehicle models, and that some of this equipment includes an automatic braking component that activates when the driver fails to respond to an imminent threat. We commend your efforts to make this technology available and encourage you to continue to develop CAS and AEB technologies and install them as standard equipment on all new vehicles. Pending such action, Safety Recommendations H-15-8 and -9 are classified OPEN--ACCEPTABLE RESPONSE. Please notify us regarding your progress in addressing Safety Recommendations H-15-8 and -9, and do not submit both an electronic and a hard copy of the same response. Thank you for your continued efforts to improve vehicle safety.

From: Fuji Heavy Industries USA, Inc.
To: NTSB
Date: 7/12/2016
Response: -From Shinichiro Sumi, President, Fuji Heavy Industries, USA, Inc.: As stated above, Subaru is making sincere efforts to deliver the commitment to make AEB a standard feature on virtually all new vehicles and will continue to provide updates for the status of our system performance once NHTSA has published its standards.

From: NTSB
To: Fuji Heavy Industries USA, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: General Motors
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: General Motors
Date: 10/22/2015
Response: As Mr. Boyer pointed out in his letter, some of your CAS, which you currently offer as optional equipment in certain new GM models, include an automatic braking component that activates when the driver fails to respond to an imminent threat. In addition, we were pleased to hear of your commitment, announced on September 11, 2015, at the Insurance Institute for Highway Safety crash avoidance facility dedication, to include AEB as a standard feature on all new vehicle models. We would appreciate receiving updates on your plans to meet this worthy goal. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems against those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: General Motors
To: NTSB
Date: 9/21/2015
Response: -From Jeff Upchurch, General Motors Liaison Engineer: The text below is a follow up to General Motors response to the NTSB Chairman’s letter dated June 8, 2015 regarding safety recommendations H-15-8 and H-15-9. GM Issues Statement on NHTSA and IIHS Request for Voluntary Industry Adoption of Standard Safety Technologies September 15, 2015 DETROIT – General Motors issued the following statement in response to the National Highway Traffic Safety Administration and Insurance Institute for Highway Safety’s challenge to original equipment manufacturers to make forward collision alert and automatic emergency braking standard on light vehicles. Statement is attributable to Jeff Boyer, GM vice president of global vehicle safety. General Motors supports the call for a voluntary industry safety agreement that would lead to making forward collision warning and automatic emergency braking standard on light vehicles. Both technologies are available today on dozens of 2016 model Chevrolet, Buick, GMC and Cadillac models. Thirty-seven models are available with forward collision alert – accounting for more than 1 million vehicles on the road – and 19 models offer both forward collision alert and automatic emergency braking. GM today offers 22 different crash-avoidance technologies on vehicles sold in the U.S., from entry-level Chevrolet models to the upcoming Cadillac CT6. Please let me know if you have any questions regarding this follow up to the response, or if you would like to discuss this matter further.

From: General Motors
To: NTSB
Date: 9/3/2015
Response: -From Jeffrey Boyer, Vice President, Global Vehicle Safety: GM has long recognized the potential benefits of these features, and continues to conduct extensive research that provides the foundation for dramatically increased installation rates. For the 2015 model year, Forward Collision Alert (FCA) is offered as optional equipment on all Cadillac and Buick models sold in the US, as well as most Chevrolet and GMC models. In addition, Front Automatic Braking (FAB) is currently available on all Cadillac models and multiple Buick, Chevrolet and GMC models. These products demonstrate the broadest offering of these features in the industry. Our extensive development has also provided critical learnings regarding the importance of design specifications and interfaces for these features to perform well and satisfy our customers. GM works diligently to offer these and other active safety technologies in a way that will appeal to consumers and thereby promote demand in vehicle purchase decisions. GM is currently reviewing its future product plans regarding FCA and FAB in light of emerging field effectiveness data. I would be pleased to discuss these topics with the Board at its convenience, perhaps including more specific information regarding GM’s research learnings and future product plans.

From: NTSB
To: Hino Motors Manufacturing USA, Inc.
Date: 11/21/2017
Response: -From the NTSB Highway Safety Report HAR-17-04 “Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10 Palm Springs, California, October 23, 2016.” Adopted October 31, 2017 and issued November 21, 2017: 2.7 Collision Avoidance Systems The NTSB has been advocating for various collision avoidance systems (CAS) since 1995, when the Board recommended in Safety Recommendation H-95-44 that the DOT examine the efficacy of collision warning systems (CWS) in commercial vehicles (NTSB 1995). In 2001, as part of a special investigation report, the Board issued 10 recommendations pertaining to the development and adoption of collision avoidance technologies (NTSB 2001). Although technologies have advanced considerably since 2001, the level of deployment of CAS in highway vehicles has remained minimal. More importantly, the rate of rear-end crashes, which forward CAS are designed to prevent, remains unaffected. In 2015, the NTSB published an updated special investigation report on forward CAS, including CWS and autonomous emergency braking systems, which contained six recommendations to vehicle manufacturers and NHTSA (NTSB 2015b). Specifically, the NTSB recommended that both passenger and commercial vehicle manufacturers take the following actions:89 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. (H-15-8) Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. (H-15-9) Safety Recommendations H-15-8 and -9 are classified “Open?Await Response” for the commercial vehicle manufacturers Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., and MCI; they are classified “Open—Acceptable Response” for the commercial vehicle manufacturers Hino Motors Manufacturing USA Inc., Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. With the understanding that commercial vehicles may require different performance parameters than those for passenger vehicles, the NTSB also issued the following recommendation to NHTSA: Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. (H-15-5) Based on NHTSA’s response, which did not address CAS in commercial vehicles, the NTSB classified Safety Recommendation H-15-5 “Open-Unacceptable Response.” The large dimensions of the truck, coupled with the sparse surrounding traffic, would have made the truck a detectable obstacle for a forward CAS. The NTSB concludes that the installation of CAS technology in all highway vehicles could prevent the occurrence of rear-end crashes similar to this crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., Hino Motors Manufacturing USA Inc., MCI, Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. Further, to ensure that the CAS components for commercial vehicles, particularly autonomous emergency braking systems, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Hino Motors Manufacturing USA, Inc.
Date: 4/13/2016
Response: We note that you do not currently offer forward CAS or AEB for your customers; however, we are pleased that you are evaluating the benefits of both systems for future installation on your vehicles produced for the US market. We commend your efforts to explore these types of safety equipment, both independently and as a member of the Truck and Engine Manufacturers Association, despite a lack of federal standards. We look forward to receiving further information from you as NHTSA develops and publishes its standards and you have had the opportunity to compare any future systems you develop against them. Until then, we encourage you to continue your efforts to develop collision avoidance technologies and, once developed, to install them as standard equipment on all your new truck tractors. Pending the completion of such actions, Safety Recommendations H-15-8 and -9 are classified OPEN--ACCEPTABLE RESPONSE.

From: NTSB
To: Hino Motors Manufacturing USA, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: Hino Motors Manufacturing USA, Inc.
To: NTSB
Date: 12/18/2015
Response: -From Shinichi Takemasa, General Manager, Technical Management Division: With respect to your safety recommendations H-15-8 and H-15-9 addressed to Mr. Yasuhiko Ichihashi, the President of Hino Motors, Ltd. (HML) on June 8, 2015, HML has the following response. Currently, HML manufactures class 4 - 8 heavy duty commercial trucks for the United States market. Certain models of these trucks are assembled in the United States by Hino Motors Manufacturing USA, Inc. At this time, HML does not offer either a forward collision warning component or automatic emergency braking systems in the United States. Nevertheless, the company is actively studying both of these concepts and evaluating the potential for their use in our products in the future. Further, as a member company of the Truck and Engine Manufacturers Association (EMA), HML participates in Association discussions and observes field test demonstrations conducted jointly between EMA and NHTSA in relation to both collision warning and automatic emergency braking systems.

From: NTSB
To: American Honda Motor Company, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Hyundai Motor America
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Isuzu Motors, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Jaguar Land Rover North America LLC
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Jaguar Land Rover North America LLC
Date: 1/8/2016
Response: As you pointed out in your letter, the CAS that you currently offer as optional equipment, includes an automatic braking component. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems with those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Jaguar Land Rover North America LLC
To: NTSB
Date: 9/1/2015
Response: -From Joe Eberhardt, President and CEO: JLRNA supports a performance standard that provides occupant protection without being overly intrusive to the driver. We welcome the opportunity to work with NHTSA and other industry partners to develop such standards.

From: NTSB
To: Kia Motors America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Maserati North America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Maserati North America, Inc.
Date: 1/8/2016
Response: As you pointed out in your letter, the CAS that you currently plan to offer as optional equipment, includes automatic braking components. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems with those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Maserati North America, Inc.
To: NTSB
Date: 8/31/2015
Response: -From Christian Gobber, President and Chief Executive Officer: Maserati S.p.A. and Maserati North America, Inc. (l\1NA) me pleased to have this opportunity to respond to your letter and provide detailed information which you have requested. Maserati is aware that the NTSB, on May 19, 2015, adopted its special investigation report, titled The Use of Forward Collision Avoidance Systems to Prevent and Mitigate Rear-End Crashes. This •report issued six new recommendations to the National Highway Traffic Safety Administration and vehicle manufactures. The report, as stated in your June 8th, 2015 letter to Maserati North America, Inc.'s President and Chief Executive Officer, Mr., Christian Gobber, reiterates two recommendations and is as follows: • -H-15-8- Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. • -H-15-9 Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. • Maserati will introduce and offer as optional equipment, starting with future model year Quattroporte and Ghibli passenger car models, and on our first ever SUV, the Levante, an Adaptive Cruise Control (ACC w/Stop & Go) system coupled with a collection of Advanced Driver Assist System (ADAS) features. These features are described below: ACC- STOP & GO System Feature: The ACC system primarily consists of a radar sensor and forward looking camera. These two components will be the technology centerpiece used in combination to provide enhanced vehicle functional capabilities. As a brief functional description of this system, the host vehicle follows the preceding target vehicle based on set target speed and time gap (distance) selected by the driver. The STOP & GO (engine ON/engine OFF) feature follows the target vehicle until the vehicle comes to a complete stop. Forward Collision Warning PLUS Feature: This feature includes the following cascaded sub-functionalities, which are driven by "tic" (time to collision) and a decision logic algorithm which verifies, and confirms the detected object: • Forward Collision Warning Visual, audible, and haptic (brake jerk) warnings, alerting/requesting the vehicle operator to apply the brakes. • Advanced Brake Assist (ABA)-Emergency Brake Assist The Emergency Brake Assist (ERA) supports the vehicle operator in the brake maneuver during critical traffic situations. The benefit of this system function rests within the buildup of additional potential brake force if the vehicle operator is not estimating the criticality of the situation, or if the vehicle operator does not manage to apply sufficient force onto the brake pedal. The result being a brake system application that potentially help mitigate an imminent collision or maybe even avoid it. • Partial Braking (AEB-P) AEB-P is an autonomous partial brake, which is applied early and eventually together with an acute warning chime. The main intention of AEB-P is to provide the vehicle operator more time to react; however, the system also helps reduce the severity of a potential accident if the driver does not react in time. • Low Speed (AEB-L) This function is active at low vehicle speeds. The system will engage once it has recognized the requirement for an abrupt deceleration event to avoid a crash, and in this case, an autonomous brake application will be initiated, thereby reducing the vehicle's relative speed to the extent possible. The vehicle/system technology described above are currently under development and will be introduced as a customer option. These systems may be ordered as standard equipment in the future as the company grows and we expand our model line.

From: NTSB
To: Mazda North American Operations
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Mazda North American Operations
Date: 10/26/2015
Response: As Mr. Ryan pointed out in his letter, some of your CAS, which you currently offer as optional equipment in certain new Mazda models, include an automatic braking component that activates when the driver fails to respond to an imminent threat. We were pleased to hear of your commitment, announced on September 11, 2015, at the Insurance Institute for Highway Safety crash avoidance facility dedication, to include AEB as a standard feature on all new vehicle models. We would appreciate receiving updates on your plans to meet this worthy goal. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems against those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Mazda North American Operations
To: NTSB
Date: 8/24/2015
Response: -From Daniel V. Ryan, Director- Public and Government Affairs: I am writing in response to your letter of June 8, 2015 sent to James O'Sullivan, Mazda's North American CEO. He has asked that I respond on his behalf to your inquiry on forward collision avoidance systems. Mazda has been a leader in bringing advanced safety systems to mass-market segments. Mazda began installing Blind Spot Monitors in our Mazda CX-9 in 2007. Since then, we have expanded our suite of safety technologies to include forward collision avoidance systems. A full description of Mazda's frontal collision avoidance systems is enclosed. As of June 2015, over 88% of models sold in 2015 by Mazda can be equipped with forward collision avoidance systems, such as Smart City Brake Support, Mazda Radar Cruise Control (MRCC) with Close Proximity Warning, and Forward Obstruction Warning. Over 53% of models sold can be equipped with more advanced forward collision avoidance systems, such as Smart Brake Support System (SBS) with Collision Warning and Distance Recognition Support System (DRSS). Later this year, Mazda will introduce the all new CX-3 to our lineup and all the above forward collision avoidance systems will be available. Many of these forward collision avoidance systems are not available in competing models, showing Mazda's commitment to bring advanced safety systems to mainstream car buyers at an affordable price. In addition to forward collision avoidance systems, Mazda has begun implementing a wide array of additional safety features. Soon, all of our models will have Blind Spot Monitoring with Rear Cross Traffic Alert, Adaptive Front-lighting System, Lane Departure Warning System, and High Beam Control either standard or available. All of Mazda's models will have Skyactiv technology by 2016. Mazda's Skyactiv technology brings a body-ring structure, manufactured with advanced materials, and engineering safety designs to every trim level regardless of price that has earned NHTSA 5-star Safety Ratings and IIHS Top Safety Pick Plus awards. Mazda continues to look for innovative ways to improve vehicle and pedestrian safety. Advancements in vehicle lighting systems increase driver night visibility allowing more reaction time to brake or avoid a collision. According to IIHS, Mazda vehicles with the Adaptive Front-lighting System had over 10% fewer property damage liability claims than expected. In Europe and Japan, the Mazda6 and CX-5 can be equipped with an LED array, a lighting system of high beams divided into four blocks that independently switch on and off. System cameras detect the headlamps of oncoming vehicles or the taillights of cars ahead and automatically turn off only one high beam block at a time, without glaring drivers of other vehicles. Driving with high beams significantly improves nighttime visibility and detection of pedestrians, other vehicles, and obstacles in the road. Unfortunately, the LED array cannot be used in the United States due to current NHTSA regulations in FMVSS- 108. Mazda remains committed to promoting advanced safety and forward collision avoidance technologies extensively in new product launches to the media, advertising, our website, www.mazdausa.com, and social media. We agree that increased consumer knowledge of the availability and benefits of these features can help create consumer demand and can help to reduce crashes. We appreciate the NTSB's attention to motor vehicle safety, and we share your commitment in making America's roads safer.

From: NTSB
To: Mercedes-Benz USA LLC
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Mercedes-Benz USA LLC
Date: 1/11/2016
Response: As Mr. Soell pointed out in his letter, your collision avoidance systems, which you currently install as standard equipment in all new Mercedes-Benz models, include an automatic braking component that activates when the driver fails to respond to an imminent threat. In addition, we were pleased to hear of your commitment, announced on September 11, 2015, at the Insurance Institute for Highway Safety crash avoidance facility dedication, to include AEB as a standard feature on all new vehicle models. We would appreciate receiving updates on your plans to meet this worthy goal. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems with those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Mercedes-Benz USA LLC
To: NTSB
Date: 9/10/2015
Response: -From Julian Soell, General Manager, Engineering Services: MBUSA supports meeting performance standards developed by NHTSA. We have supported NHTSA's efforts to include crash avoidance technologies such as forward collision warning systems in its New Car Assessment Program (NCAP). However, any performance standards should harmonize with already existing performance requirements. For example, llHS has already implemented performance standards for autonomous emergency braking in their consumer rating programs. Test procedures should be harmonized worldwide; otherwise it might cause confusion to consumers on the performance of these systems. Target systems used for collision avoidance testing should also be harmonized in order to support the distribution of FCW /DBS and CIB systems.

From: NTSB
To: Mitsubishi Motors North America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Mitsubishi Motors North America, Inc.
Date: 10/22/2015
Response: As Mr. Thiriez pointed out in his letter, the CAS that you currently offer as optional equipment in your Outlander models includes an automatic braking component that activates when the driver fails to respond to an imminent threat. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your system will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your system against those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Mitsubishi Motors North America, Inc.
To: NTSB
Date: 9/4/2015
Response: -From Stephane Thiriez, Chief Engineer- Product Strategy, Mitsubishi Motors R&D of America, Inc.: Mitsubishi Motors agrees with the NTSB that the use of Forward Collision Avoidance systems have the potential to prevent or mitigate rear-end crashes. According to NHTSA’s estimates, driver error is the primary cause in more than 95% of crashes. These safety systems could help assist the driver in critical crash scenarios. We are committed to enhancing our customers’ safety by offering Advanced Driver Assisted Systems (ADAS) technologies in our vehicles. Specifically, we offer a forward collision avoidance system, which incorporates a warning component, as well as, autonomous emergency braking. In fact, Mitsubishi Motors was one of the first vehicle manufacturers to bring advanced safety technologies into the mass (non-luxury) market segment in the U.S. Since Model Year 2014, we have offered a Forward Collision Mitigation (FCM) system on our Mitsubishi Outlander SUV. Mitsubishi Motors’ current plan is to continue to expand the availability of FCM systems in the future.

From: NTSB
To: Motor Coach Industries International, Inc.
Date: 11/21/2017
Response: -From the NTSB Highway Safety Report HAR-17-04 “Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10 Palm Springs, California, October 23, 2016.” Adopted October 31, 2017 and issued November 21, 2017: 2.7 Collision Avoidance Systems The NTSB has been advocating for various collision avoidance systems (CAS) since 1995, when the Board recommended in Safety Recommendation H-95-44 that the DOT examine the efficacy of collision warning systems (CWS) in commercial vehicles (NTSB 1995). In 2001, as part of a special investigation report, the Board issued 10 recommendations pertaining to the development and adoption of collision avoidance technologies (NTSB 2001). Although technologies have advanced considerably since 2001, the level of deployment of CAS in highway vehicles has remained minimal. More importantly, the rate of rear-end crashes, which forward CAS are designed to prevent, remains unaffected. In 2015, the NTSB published an updated special investigation report on forward CAS, including CWS and autonomous emergency braking systems, which contained six recommendations to vehicle manufacturers and NHTSA (NTSB 2015b). Specifically, the NTSB recommended that both passenger and commercial vehicle manufacturers take the following actions:89 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. (H-15-8) Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. (H-15-9) Safety Recommendations H-15-8 and -9 are classified “Open?Await Response” for the commercial vehicle manufacturers Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., and MCI; they are classified “Open—Acceptable Response” for the commercial vehicle manufacturers Hino Motors Manufacturing USA Inc., Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. With the understanding that commercial vehicles may require different performance parameters than those for passenger vehicles, the NTSB also issued the following recommendation to NHTSA: Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. (H-15-5) Based on NHTSA’s response, which did not address CAS in commercial vehicles, the NTSB classified Safety Recommendation H-15-5 “Open-Unacceptable Response.” The large dimensions of the truck, coupled with the sparse surrounding traffic, would have made the truck a detectable obstacle for a forward CAS. The NTSB concludes that the installation of CAS technology in all highway vehicles could prevent the occurrence of rear-end crashes similar to this crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., Hino Motors Manufacturing USA Inc., MCI, Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. Further, to ensure that the CAS components for commercial vehicles, particularly autonomous emergency braking systems, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Motor Coach Industries International, Inc.
Date: 4/18/2017
Response: From the NTSB Highway accident report "Motorcoach Collision with Crash Attenuator in Gore Area, US Highway 101, San Jose, California, January 19, 2016" HAR-17-01, PB2017-101430, which was adopted on March 28, 2017: 2.6 Collision Avoidance Systems The NTSB has advocated for various CAS technologies for more than 20 years. In the investigation of a 1995 multivehicle collision in Menifee, Arkansas, the NTSB recommended that the DOT test CWS in commercial vehicles (Safety Recommendation H-95-44; NTSB 1995). Since then, we have issued 19 recommendations pertaining to collision warning, adaptive cruise control, and AEB systems in both passenger and commercial vehicles. As part of this effort, the NTSB recently issued a special investigation report in which we examined advances in CAS technologies and issued the following recommendations to motorcoach manufacturers (NTSB 2015b): H-15-8 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. H-15-9 Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. Acknowledging that the CAS performance parameters in passenger and commercial vehicles may differ, the NTSB also issued the following safety recommendation to NHTSA (NTSB 2015b): H-15-5 Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. Safety Recommendations H-15-8 and -9 are classified “Open-Await Response” for MCI, and Safety Recommendation H-15-5 is classified “Open-Unacceptable Response.” Although 20 percent of the Greyhound fleet is equipped with some type of CAS, the MCI bus involved in this crash had neither a CWS nor an AEB system. In a test scenario representing crash conditions, NTSB investigators showed that CAS would have been effective in preventing or mitigating the severity of the crash. The tested system detected the crash attenuator in 18 of 19 trials and then provided a warning 2?3 seconds before impact and activated the AEB 1-2 seconds before impact. The testing was conducted on a CAS-equipped truck-tractor. The effect of AEB in motorcoaches may vary due to differences in design of the brake systems, but the benefits of CWS remain: the technology is clearly capable of detecting the stationary hazard and warning the driver in time to mitigate the consequences of the crash. The NTSB concludes that had the bus been equipped with a CAS technology, it could have alerted the driver of the forward hazard in time to mitigate the severity of the crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to MCI. To ensure that CAS components for commercial vehicles, particularly AEB, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Motor Coach Industries International, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Navistar, Inc.
Date: 4/20/2018
Response: We note that you continue to work with NHTSA to develop AEB performance requirements that could become the framework for a federal heavy vehicle performance standard. We look forward to receiving further information from you as NHTSA develops and publishes its standards and you have the opportunity to comply with them. Until then, Safety Recommendation H-15-9 remains classified OPEN--ACCEPTABLE RESPONSE.

From: Navistar, Inc.
To: NTSB
Date: 2/15/2018
Response: -From Richard C. Kempf, Certification and Compliance, Navistar, Inc.: Once the National Highway Traffic Safety Administration (“NHTSA”) issues a standard for FCAS, or what NHTSA now refers to as Autonomous Emergency Braking (AEB”), Navistar will ensure its vehicles are in compliance. Navistar expects NHTSA to proceed with rulemaking that would require AEB on heavy duty vehicles. As a member of the Truck and Engine Manufacturers Association (“EMA”), Navistar participated and contributed in a joint NHTSA and EMA AEB Cooperative Test Program in 2013 to evaluate potential test maneuvers and performance requirements for heavy duty vehicles. A similar follow-up Cooperative Test Program was performed in the fall of 2015 to test the latest technologies and further advance evaluating potential test maneuvers and performance requirements. Navistar has also worked with SAE International to finalize and publish SAE J3029 Forward Collision Avoidance and Mitigation System Vehicle Test Procedure. This procedure identifies the performance test maneuvers that should be used to validate heavy duty vehicles equipped with FCAS or AEB. We expect the results of the NHTSA and EMA Cooperative Test Programs and SAE activity would become the framework of an AEB Federal Motor Vehicle Safety Standard (FMVSS) for heavy-duty vehicles. We understand that NHTSA plans to issue its AEB Benefits Study and embark on an AEB Field Operation Test of the latest version of AEB technology in 2018. We look forward to seeing the results of this activity and plan to meet with NHTSA in the spring to continue our dialogue on AEB for heavy duty vehicles. We expect NHTSA to initiate AEB Rulemaking in the near future and we anticipate being actively engaged in that process. As stated in 2015, we strongly encourage the administration to approach any rulemaking in a holistic manner. Medium and heavy duty trucks, along with school and commercial buses come in a wide range of configurations and options to perform the diverse work and special functions they need to accomplish. As such, a “one size fits all” AEB system or regulation may not be appropriate. AEB needs to be designed or “tuned” to specific vehicle configurations so it performs properly and does not cause adverse consequences or impact driver acceptance. We appreciate the opportunity to provide this response to you. Please let us know if you need any additional information.

From: NTSB
To: Navistar, Inc.
Date: 11/21/2017
Response: -From the NTSB Highway Safety Report HAR-17-04 “Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10 Palm Springs, California, October 23, 2016.” Adopted October 31, 2017 and issued November 21, 2017: 2.7 Collision Avoidance Systems The NTSB has been advocating for various collision avoidance systems (CAS) since 1995, when the Board recommended in Safety Recommendation H-95-44 that the DOT examine the efficacy of collision warning systems (CWS) in commercial vehicles (NTSB 1995). In 2001, as part of a special investigation report, the Board issued 10 recommendations pertaining to the development and adoption of collision avoidance technologies (NTSB 2001). Although technologies have advanced considerably since 2001, the level of deployment of CAS in highway vehicles has remained minimal. More importantly, the rate of rear-end crashes, which forward CAS are designed to prevent, remains unaffected. In 2015, the NTSB published an updated special investigation report on forward CAS, including CWS and autonomous emergency braking systems, which contained six recommendations to vehicle manufacturers and NHTSA (NTSB 2015b). Specifically, the NTSB recommended that both passenger and commercial vehicle manufacturers take the following actions:89 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. (H-15-8) Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. (H-15-9) Safety Recommendations H-15-8 and -9 are classified “Open?Await Response” for the commercial vehicle manufacturers Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., and MCI; they are classified “Open—Acceptable Response” for the commercial vehicle manufacturers Hino Motors Manufacturing USA Inc., Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. With the understanding that commercial vehicles may require different performance parameters than those for passenger vehicles, the NTSB also issued the following recommendation to NHTSA: Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. (H-15-5) Based on NHTSA’s response, which did not address CAS in commercial vehicles, the NTSB classified Safety Recommendation H-15-5 “Open-Unacceptable Response.” The large dimensions of the truck, coupled with the sparse surrounding traffic, would have made the truck a detectable obstacle for a forward CAS. The NTSB concludes that the installation of CAS technology in all highway vehicles could prevent the occurrence of rear-end crashes similar to this crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., Hino Motors Manufacturing USA Inc., MCI, Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. Further, to ensure that the CAS components for commercial vehicles, particularly autonomous emergency braking systems, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Navistar, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Navistar, Inc.
Date: 10/22/2015
Response: As Mr. Kempf pointed out in his letter, the forward CAS that you currently offer as optional equipment in certain new truck tractors includes an automatic braking component that activates when the driver fails to respond to an imminent threat. Because NHTSA has not yet developed heavy vehicle AEB standards, it is not possible to determine whether your systems would meet that agency’s criteria. We note that you are working with NHTSA and industry to develop AEB performance requirements that could become the framework for a federal heavy vehicle performance standard. We look forward to receiving further information from you as NHTSA develops and publishes its standards and you have had the opportunity to compare your systems against those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Navistar, Inc.
To: NTSB
Date: 8/24/2015
Response: -From Richard Kempf, Certification and Compliance, Navistar, Inc.: Navistar continues to work with SAE to develop and finalize SAE J3029 Forward Collision Avoidance and Mitigation System Vehicle Test Procedure. This procedure identifies the performance test maneuvers that should be used to validate heavy duty vehicles equipped with FCAS. Navistar expects SAE to finalize and publish SAE J3029 later this year. Navistar has generally followed SAE’s recommended practices. Navistar expects NHTSA to proceed with rulemaking that would require FCAS, or what NHTSA now refers to as Autonomous Emergency Braking (AEB), on heavy duty vehicles. As a member of the Truck and Engine Manufacturers Association (EMA), Navistar participated and contributed in a joint NHTSA and EMA AEB Cooperative Test Program in 2013 to evaluate potential test maneuvers and performance requirements for heavy duty vehicles. Another follow-up Cooperative Test Program is scheduled for this fall to continue to better define the appropriate AEB test maneuvers and performance requirements that would become the framework of a NHTSA Federal Motor Vehicle Safety Standard (FMVSS) for heavy duty vehicles. Navistar would comply with any FMVSS that was applicable to the vehicles it manufactures. While NHTSA may well engage in a rulemaking process around FCAS, and we anticipate being actively engaged in that process, we strongly encourage the administration to approach any rulemaking in a holistic manner. Medium and heavy duty trucks come in a wide range of configurations and options in order to perform the wide and diverse applications and special functions they need to accomplish. As such, a “one size fits all” FCAS system may not be appropriate. An FCAS system needs to be designed or “tuned” to a specific vehicle configuration so it performs properly and does not cause adverse consequences or impact driver acceptance.

From: NTSB
To: Nissan Group of North America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Porsche Cars North America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Subaru of America, Inc.
Date: 8/18/2016
Response: We were pleased to hear of your commitment, announced on March 17, 2016, to include AEB as a standard feature on all new vehicle models by September 1, 2022—a promise you made as part of a group of 20 automakers that signed a memorandum of understanding (MOU) with NHTSA. We understand that this MOU will affect more than 99 percent of the US auto market. We would appreciate receiving updates on your plans to meet this worthy goal. We note that you currently offer forward CASs as optional equipment on several of your vehicle models, and that some of this equipment includes an automatic braking component that activates when the driver fails to respond to an imminent threat. We commend your efforts to make this technology available and encourage you to continue to develop CAS and AEB technologies and install them as standard equipment on all new vehicles. Pending such action, Safety Recommendations H-15-8 and -9 are classified OPEN--ACCEPTABLE RESPONSE.

From: Subaru of America, Inc.
To: NTSB
Date: 7/12/2016
Response: -From Shinichiro Sumi, President, Fuji Heavy Industries, USA, Inc.: As stated above, Subaru is making sincere efforts to deliver the commitment to make AEB a standard feature on virtually all new vehicles and will continue to provide updates for the status of our system performance once NHTSA has published its standards.

From: Subaru of America, Inc.
To: NTSB
Date: 7/12/2016
Response: -From Shinichiro Sumi, President, Fuji Heavy Industries, USA, Inc.: As stated above, Subaru is making sincere efforts to deliver the commitment to make AEB a standard feature on virtually all new vehicles and will continue to provide updates for the status of our system performance once NHTSA has published its standards.

From: NTSB
To: Subaru of America, Inc.
Date: 2/23/2016
Response: As Mr. Arcangeli pointed out in his letter, some of your CAS, which you currently offer as optional equipment in certain new Subaru models, include an automatic braking component that activates when the driver fails to respond to an imminent threat. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems against those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: NTSB
To: Subaru of America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: Subaru of America, Inc.
To: NTSB
Date: 9/4/2015
Response: -From Maurice Arcangeli, Director, Government Relations, Fuji Heavy Industries, USA, Inc., Subaru: Subaru response: Subaru has confirmed that EyeSightTM meets current draft testing procedure criteria for both Collision Imminent Braking (CIB) and Dynamic Brake Support (DBS) developed by NHTSA. We understand that the current testing procedure has not yet been finalized and Subaru’s view on the proposed draft procedure concerning the target has been incorporated into the comment submitted by the Association of Global Automakers. In addition to meeting the draft testing procedure proposed by NHTSA, EyeSightTM has been positively rated by an independent third-party, the Insurance Institute for Highway Safety (IIHS). IIHS has been conducting performance testing focused on Front Crash Prevention systems since 2013, and all of Subaru vehicles with EyeSightTM have received a “Superior” rating, the highest possible evaluation.6 As stated in our previous response, we are currently reviewing various approaches to help facilitate our decision to make these safety systems available to all of our customers.

From: NTSB
To: Tesla Motors
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Suzuki Motor of America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Suzuki Motor of America, Inc.
Date: 9/29/2015
Response: We note that Suzuki passenger cars and light-duty trucks have neither been distributed nor sold in the US market since 2013. Accordingly, Safety Recommendations H-15-8 and -9 are classified CLOSED—RECONSIDERED.

From: Suzuki Motor of America, Inc.
To: NTSB
Date: 8/14/2015
Response: -From Kenneth M. Bush, Department Manager, Government Relations: This responds to your letter dated June 8, 2015 to Suzuki Motor of America, Inc. ("SMAI"). We would like to explain SMAI's situation with respect to the subject Safety Recommendations. On November 5, 2012, American Suzuki Motor Corporation (ASMC), the previous authorized distributor of Suzuki products in the continental United States, filed a voluntary petition for relief under Chapter 11 of the United States Bankruptcy Code and announced that it would withdraw from the United States market for automobile and light-duty truck sales. ASMC dissolved as a corporation on March 31, 2013. On April1, 2013, SMAI began operations as the new distributor of Suzuki products in the continental United States, after purchasing ASMC's motorcycle, ATV, marine, and automobile parts and service operations. SMAI is not involved in the distribution or sale of automobiles or light-duty trucks in the United States, and therefore has no plans for actions to address NTSB Safety Recommendations H-15-8 and H-15-9, which relate to the installation of specific safety technologies in vehicles that are not being distributed or sold by SMAI.

From: NTSB
To: Toyota Motor North America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Toyota Motor North America, Inc.
Date: 10/26/2015
Response: As Mr. Stricker pointed out in his letter, some of your CAS, which you currently offer as optional equipment in certain new Toyota models, include an automatic braking component that activates when the driver fails to respond to an imminent threat. In addition, we were pleased to hear of your commitment, announced on September 11, 2015, at the Insurance Institute for Highway Safety crash avoidance facility dedication, to include AEB as a standard feature on all new vehicle models. We would appreciate receiving updates on your plans to meet this worthy goal. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your systems will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your systems against those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Toyota Motor North America, Inc.
To: NTSB
Date: 8/17/2015
Response: -From Tom Stricker, Vice President, Technical and Regulatory Affairs, Toyota Motor North America, Inc.: Toyota does not yet know what NHTSA will specify as the performance standards for autonomous braking; however, of Toyota's vehicles currently available with PCS that have been tested (prior to the release of the TSS and LSS+ systems), most meet the criteria for NHTSA's collision warning and have received an 'Advanced' rating by IIHS. As TSS and LSS+ offer improved forward sensing and greater speed reductions than most of the current PCS systems available, these ratings will continue to improve. On January 28, 2015, NHTSA published a request for comments on a plan to update the New Car Assessment Program (NCAP).5 The plan calls for a series of performance measures, for which it is expected that Toyota's TSS and LSS+ systems would meet or exceed the specified criteria for satisfactory performance.

From: NTSB
To: Van Hool NV
Date: 11/21/2017
Response: -From the NTSB Highway Safety Report HAR-17-04 “Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10 Palm Springs, California, October 23, 2016.” Adopted October 31, 2017 and issued November 21, 2017: 2.7 Collision Avoidance Systems The NTSB has been advocating for various collision avoidance systems (CAS) since 1995, when the Board recommended in Safety Recommendation H-95-44 that the DOT examine the efficacy of collision warning systems (CWS) in commercial vehicles (NTSB 1995). In 2001, as part of a special investigation report, the Board issued 10 recommendations pertaining to the development and adoption of collision avoidance technologies (NTSB 2001). Although technologies have advanced considerably since 2001, the level of deployment of CAS in highway vehicles has remained minimal. More importantly, the rate of rear-end crashes, which forward CAS are designed to prevent, remains unaffected. In 2015, the NTSB published an updated special investigation report on forward CAS, including CWS and autonomous emergency braking systems, which contained six recommendations to vehicle manufacturers and NHTSA (NTSB 2015b). Specifically, the NTSB recommended that both passenger and commercial vehicle manufacturers take the following actions:89 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. (H-15-8) Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. (H-15-9) Safety Recommendations H-15-8 and -9 are classified “Open?Await Response” for the commercial vehicle manufacturers Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., and MCI; they are classified “Open—Acceptable Response” for the commercial vehicle manufacturers Hino Motors Manufacturing USA Inc., Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. With the understanding that commercial vehicles may require different performance parameters than those for passenger vehicles, the NTSB also issued the following recommendation to NHTSA: Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. (H-15-5) Based on NHTSA’s response, which did not address CAS in commercial vehicles, the NTSB classified Safety Recommendation H-15-5 “Open-Unacceptable Response.” The large dimensions of the truck, coupled with the sparse surrounding traffic, would have made the truck a detectable obstacle for a forward CAS. The NTSB concludes that the installation of CAS technology in all highway vehicles could prevent the occurrence of rear-end crashes similar to this crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., Hino Motors Manufacturing USA Inc., MCI, Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. Further, to ensure that the CAS components for commercial vehicles, particularly autonomous emergency braking systems, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Van Hool NV
Date: 1/6/2017
Response: As you pointed out in your letter, as of November 1, 2015, all European motorcoach manufacturers must comply with the European Union’s (EU’s) requirement to install an approved AEB system. Because NHTSA has not yet developed heavy vehicle AEB standards, it is not possible to determine whether your EU-mandated systems meet NHTSA’s criteria. We are encouraged that you are committed to working with NHTSA’s standards to expand the use of AEB in your US motorcoach fleet. We look forward to receiving further information from you once NHTSA has developed and published its standards and you have had the opportunity to compare your systems with them. Until then, Safety Recommendation H-15-9 is classified OPEN--ACCEPTABLE RESPONSE.

From: NTSB
To: Van Hool NV
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: Van Hool NV
To: NTSB
Date: 9/9/2015
Response: -From Hugo De Roo, Area Export Manager and Filip Van Hool, Chief Executive Officer: From November 1st forward all EU coaches will have a type approved Advanced Emergency Braking System (AEBS) as mandated by Regulation (EU) No 347/2012 and UNECE Regulation No 131. These EU coaches have an electro-pneumatic braking system (EBS) developed by Wabco. Van Hool looks forward to seeing NHTSA' s performance standards for autonomous emergency braking, as part of the industry's ongoing development of forward collision avoidance systems.

From: NTSB
To: Volkswagen Group of America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Volkswagen Group of America, Inc.
Date: 10/22/2015
Response: As Mr. Zorn pointed out in his letter, the CAS that you currently offer as optional equipment includes an automatic braking component. In addition, we were pleased to hear of your commitment, announced September 11, 2015, at the Insurance Institute for Highway Safety crash avoidance facility dedication, to include AEB as a standard feature on all new vehicle models. We would appreciate receiving updates on your plans to meet this worthy goal. Because NHTSA has not yet released its AEB standards, it is not possible to determine whether your system will meet that agency’s final criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your system against those standards. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Volkswagen Group of America, Inc.
To: NTSB
Date: 9/8/2015
Response: -From Thomas Zorn, General Manager, Safety Affairs and Vehicle Testing: VWGoA, as a member of the Alliance of Automobile Manufacturers (Alliance), supports the Alliance response submitted on August 19, 2015, which emphasized that traffic fatalities are at historic lows and technology advancements are leading the way. As reported to the NTSB in our letter dated June 12, 2015 in response to NTSB Recommendation H-01 -14, VWGoA stated: VWGoA has introduced both Forward Collision Warning (FCW) and ACC on a variety of our models along with many other driver assistance systems. VWGoA offers systems with FCW among other functionalities, namely crash imminent braking and dynamic braking support, which are being considered by NHTSA for the US New Car Assessment Program (NCAP). VWGoA and its dealers inform its customers of these systems through literature provided to customers and owners, its brand websites (www.vw.com and www.audiusa.com) and other advertising materials. On July 29, 2015, VWGoA announced that it is offering a host of driver assistance features that were only previously available on the premium SUV- and that it is adding some new ones that truly democratize driver assistance for the compact sedan and compact hatchback classes. These available features include: Forward Collision Warning and Autonomous Emergency Braking (Front Assist/Pre Sense); Adaptive Cruise Control (ACC); Blind Spot Monitor with Rear Traffic Alert; the Parking Steering Assistant (Park Assist); and an active Lane Departure Warning (Lane Assist) system. In addition, some models have been added to be fitted, as standard, with the Automatic Post-Collision Braking System. This safety system uses information from the airbag sensors to help prevent secondary collisions. Analysis of crash data ascertained that around 24% of accidents involved a secondary collision after an initial impact so engineers designed the system to help avoid them. As safety is our greatest priority, we will continue to offer and encourage Collision Avoidance technologies to our consumers. As consumer demand for these systems increase, technical barriers are removed and cost of implementation of such systems deem feasible, Collision Avoidance systems will continue to proliferate through the VW Group models.

From: NTSB
To: Volvo Cars of North America, Inc.
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Volvo Cars of North America, Inc.
Date: 9/29/2015
Response: As you pointed out in your letter, the collision avoidance systems that you install as standard equipment in all new Volvo models include an automatic braking component that activates when the driver fails to respond to an imminent threat. Because NHTSA has not yet released its AEB standards, it is not possible to say at this time whether your systems meet that agency’s criteria. We look forward to receiving further information from you once NHTSA has published its standards and you have had the opportunity to compare your system against them. In the meantime, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE. We commend you for your leadership in improving vehicle safety.

From: Volvo Cars of North America, Inc.
To: NTSB
Date: 6/18/2015
Response: -From Lex Kerssemakers, Senior VP Americas and President & CEO Volvo Cars of North America: Thank you for your June 8, 2015 letter (H-15-8 and 9) regarding your recommendations on forward collision warning and autonomous emergency braking. Safety is a founding principle of Volvo Cars and Volvo Cars works hard to stay at the forefront of the industry by taking an overall approach to safety, which has proven effective in real traffic situations. In 2007, Volvo Cars launched Vision 2020. This Vision states that no one is to be killed or seriously injured in a new Volvo by 2020. Crash avoidance and active safety technologies have the potential to significantly reduce or eliminate the fatalities and serious injuries on US roadways. So they are essential to reach our goal. In addition, numerous studies of real-world crash performance data in the US and abroad show the effectiveness of these systems in reducing injuries and fatalities. These technologies will continue to be developed and they will become even more effective over time. So Volvo Cars strongly supports rapid deployment of crash avoidance technologies. The fastest most effective way for rapid deployment of these technologies is through the US New Car Assessment Program (NCAP). US NCAP is meant to give consumers the best and latest information on the safety performance of a new vehicle. If US NCAP did not include the most powerful and critical piece of information on a vehicle’s safety performance, the US government would not be fulfilling its obligation to serve the best of interest of US consumers. Therefore, Volvo Cars strongly believes that crash avoidance performance evaluations should be included in NCAP and also in ‘Stars on Cars’ on the Monroney label. So Volvo Cars fully supports the NCAP recommendations in your report (entitled The Use of Forward Collision Avoidance Systems to Prevent or Mitigate Rear-End Crashes): •?NHTSA should develop tests and standards in order to rate the performance of each vehicle’s collision avoidance systems and incorporate those results into an expanded NCAP 5-star safety rating scale. •?Issuance of a companion Safety Alert for consumers and commercial fleet owners that urges them to consider vehicles with collision warning and autonomous emergency braking functions. Specifically with regard to your recommendation H-15-8 and H-15-9: NTSB H-15-9: Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking (AEB), install systems meeting those standards on all vehicles. •?AEB has been on the market for many years. It should be encouraged by inclusion in US NCAP. US NCAP is behind other major countries on this. EURONCAP, Japan NCAP, Australia NCAP, Latin NCAP Korea NCAP, and IIHS top safety pick already include these systems in their overall scores. China NCAP has also announced its intention to include them. NHTSA should set performance standards that mirror the EuroNCAP requirements and test methods. Mandates on Forward Collision Warning and AEB would slow deployment of these technologies and could deter future technology innovation. Therefore, Volvo Cars believes the fastest most efficient way to speed up deployment is through market incentives and consumer education campaigns. It is essential for US consumers to learn about these systems through assessment programs such as NCAP in order to be given an accurate picture of what the real level of safety is when making new car buying decisions.

From: NTSB
To: Volvo Group North America LLC
Date: 7/9/2018
Response: We note that a driver assistance system that includes AEB technology comes standard with three of your truck-tractor models. We are encouraged by your dedication to increasing consumer understanding of and demand for advanced vehicle technologies and your ongoing support of the Insurance Institute for Highway Safety and NHTSA’s efforts to expand industry use of AEB. We look forward to receiving further information from you as NHTSA develops and publishes its standards and you have the opportunity to comply with them. Until then, Safety Recommendation H-15-9 remains classified OPEN--ACCEPTABLE RESPONSE.

From: Volvo Group North America LLC
To: NTSB
Date: 5/6/2018
Response: -From Tim LaFon, Vice President Regulatory Affairs: As previously shared in September 2015, the Volvo Group North America strongly supports NTSB in their vision of improving safety. We currently offer a variety of safety technologies, including a version of automatic emergency braking, and are actively working on expanding the availability of this technology to support our customers and the public. The Volvo Group shares NTSB’s desire to increase customer acceptance and usage of these technologies short of regulation. The Volvo Group has expressed its commitment to work with the Insurance Institute for Highway Safety and the U.S. Department of Transportation's National Highway Traffic Safety Administration to increase the availability and usage of automatic emergency braking technology across the U.S. heavy-duty commercial vehicle industry. I can add that the Bendix Fusion System now offered as standard on Volvo VNR and VNL, and the Mack Anthem includes autonomous emergency braking.

From: Volvo Group North America LLC
To: NTSB
Date: 4/5/2018
Response: -From Tim LaFon, Vice President, Regulatory Affairs, Volvo Group North America, LLC: My apologies for the delay in responding. I will prepare a complete response and send it to you by the end of next week. I can share that both Volvo and Mack Trucks has taken action and now offers a collision warning system in our standard product offering for Volvo VN and Anthem model truck tractors. I will go into more details in the formal response. In addition, we would be glad to work with the appropriate agencies during the develop of standards that are associated with autonomous emergency braking systems. I will expand on this in our formal response.

From: NTSB
To: Volvo Group North America LLC
Date: 11/21/2017
Response: -From the NTSB Highway Safety Report HAR-17-04 “Motorcoach Collision With Combination Vehicle After Traffic Break on Interstate 10 Palm Springs, California, October 23, 2016.” Adopted October 31, 2017 and issued November 21, 2017: 2.7 Collision Avoidance Systems The NTSB has been advocating for various collision avoidance systems (CAS) since 1995, when the Board recommended in Safety Recommendation H-95-44 that the DOT examine the efficacy of collision warning systems (CWS) in commercial vehicles (NTSB 1995). In 2001, as part of a special investigation report, the Board issued 10 recommendations pertaining to the development and adoption of collision avoidance technologies (NTSB 2001). Although technologies have advanced considerably since 2001, the level of deployment of CAS in highway vehicles has remained minimal. More importantly, the rate of rear-end crashes, which forward CAS are designed to prevent, remains unaffected. In 2015, the NTSB published an updated special investigation report on forward CAS, including CWS and autonomous emergency braking systems, which contained six recommendations to vehicle manufacturers and NHTSA (NTSB 2015b). Specifically, the NTSB recommended that both passenger and commercial vehicle manufacturers take the following actions:89 Install forward collision avoidance systems that include, at a minimum, a forward collision warning component, as standard equipment on all new vehicles. (H-15-8) Once the National Highway Traffic Safety Administration publishes performance standards for autonomous emergency braking, install systems meeting those standards on all new vehicles. (H-15-9) Safety Recommendations H-15-8 and -9 are classified “Open?Await Response” for the commercial vehicle manufacturers Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., and MCI; they are classified “Open—Acceptable Response” for the commercial vehicle manufacturers Hino Motors Manufacturing USA Inc., Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. With the understanding that commercial vehicles may require different performance parameters than those for passenger vehicles, the NTSB also issued the following recommendation to NHTSA: Complete, as soon as possible, the development and application of performance standards and protocols for the assessment of forward collision avoidance systems in commercial vehicles. (H-15-5) Based on NHTSA’s response, which did not address CAS in commercial vehicles, the NTSB classified Safety Recommendation H-15-5 “Open-Unacceptable Response.” The large dimensions of the truck, coupled with the sparse surrounding traffic, would have made the truck a detectable obstacle for a forward CAS. The NTSB concludes that the installation of CAS technology in all highway vehicles could prevent the occurrence of rear-end crashes similar to this crash. Therefore, the NTSB reiterates Safety Recommendations H-15-8 and -9 to Daimler Trucks North America LLC, Fuji Heavy Industries USA Inc., Hino Motors Manufacturing USA Inc., MCI, Navistar Inc., PACCAR Inc., Van Hool NV, and Volvo Group North America LLC. Further, to ensure that the CAS components for commercial vehicles, particularly autonomous emergency braking systems, are manufactured to optimal performance standards, the NTSB also reiterates Safety Recommendation H-15-5 to NHTSA.

From: NTSB
To: Volvo Group North America LLC
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 believes that many of these safety technologies should be required equipment in all new vehicles; however, their installation is not currently mandated. Consequently, in May 2015, we issued recommendations to vehicle manufacturers to install collision warning and autonomous emergency braking (also termed crash imminent braking) systems as standard equipment on their vehicles (Safety Recommendations H-15-8 and -9). In September 2015, ten passenger vehicle manufacturers committed to installing collision warning and crash imminent braking systems as standard equipment in their vehicles. Indeed, some manufacturers have already installed these systems on most of their vehicle models as standard equipment. However, these vehicles represent only a fraction of all new vehicles. Although the proposed changes to NCAP may not result in universal adoption of these crash avoidance technologies, they will most likely provide vehicle manufacturers with incentives to speed the deployment of such technologies in their vehicles. Consequently, the NTSB supports NHTSA’s plan to develop a 5-star rating for crash avoidance technologies. This rating would incorporate nine technologies, including collision warning and crash imminent braking systems. A vehicle model passing the rating test for a particular crash avoidance system would receive a credit for that system. The vehicle model would receive half a credit if that technology is offered as an optional safety system and full credit if it is provided as standard equipment. In 2008, the NTSB made a recommendation to NHTSA to determine the potential benefits of crash imminent (autonomous emergency) braking technologies in commercial vehicles and, if they are deemed to be effective, to require their use on new commercial vehicles (Safety Recommendation H-08-15). The research conducted by NHTSA and others has shown the considerable potential of these systems to prevent crashes, in both passenger and commercial vehicles. While we believe that crash imminent braking technology should be mandatory equipment for all new vehicles, its provision is not yet required; therefore, in May 2015, the NTSB recommended that both passenger and commercial vehicle manufacturers install these technologies as standard equipment (Safety Recommendations H-15-8 and -9). The NTSB has expressed its support of crash imminent braking technologies in its comments on the proposed rulemaking regarding the inclusion of these systems as recommended technologies in NCAP (Docket No. NHTSA-2015-0006). Although the NTSB supports the proposed testing procedures for crash imminent braking, we urge NHTSA to consider expanding the velocity parameters used in the testing procedures to make them more consistent with those used by NCAP authorities around the world, such as Euro NCAP.

From: NTSB
To: Volvo Group North America LLC
Date: 1/11/2016
Response: As you pointed out in your letter, the forward CAS that you currently offer as optional equipment to your customers includes an automatic emergency braking component. Because NHTSA has not yet developed heavy vehicle AEB standards, it is not possible to determine whether your systems would meet that agency’s criteria. We are encouraged that you are committed to working with NHTSA and the Insurance Institute for Highway Safety to expand the use of AEB throughout the US heavy-vehicle industry. We look forward to receiving further information from you once NHTSA has developed and published its standards and you have had the opportunity to compare your systems with them. Until then, Safety Recommendation H-15-9 is classified OPEN—ACCEPTABLE RESPONSE.

From: Volvo Group North America LLC
To: NTSB
Date: 9/21/2015
Response: -From Tim LaFon, Vice President Regulatory Affairs: The Volvo Group strongly supports NTSB in their vision of improving safety. We currently offer a variety of safety technologies, including a version of automatic emergency braking, and are actively working on expanding the availability of this technology to support our customers and the public. The Volvo Group shares NTSB’s desire to increase customer acceptance and usage of these technologies short of regulation. The Volvo Group has expressed its commitment to work with the Insurance Institute for Highway Safety and the U.S. Department of Transportation's National Highway Traffic Safety Administration to increase the availability and usage of automatic emergency braking technology across the U.S. heavy-duty commercial vehicle industry.

From: Volvo Group North America LLC
To: NTSB
Date: 9/15/2015
Response: -From Tim LaFon, Vice President, Regulatory Affairs: In regards to the Volvo Group Companies, I expect to have a response to you by early next week. My apologies for the delay.