The Most Important ADAS Mandate  – EE Times

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In early May 2024, NHTSA’s mandate for FCW, AEB and PAEB appeared in the Federal Register, which means it became the law of the land. It is designated FMVSS #127 and can be downloaded here. 

This column is a summary of this most important ADAS mandate for AEB and especially for PAEB. 

• NHTSA’s mandate methodology
• Vehicle crashes: Target population for frontal & pedestrian crashes
• Forward crash avoidance: Key tests
• PAEB crash avoidance: Key tests
• Yearly incremental vehicle costs
• Yearly AEB and PAEB benefits
• Cost and benefit summary
• Summary

NHTSA’s mandate methodology

NHTSA has a specific methodology to assess which ADAS technologies deserve a mandate. NHTSA compiles detailed historical statistics on all crashes and analyzes what type of collisions are most common. The focus is on how many fatalities, injuries and property-only damage crashes occur. NHTSA compiles such data on a yearly and monthly basis including information by state.

NHTSA also estimates the negative financial impact on society in terms of all economic and other costs to society. This is a complicated estimate and is only performed every 5-10 years. NHTSA’s latest report was done for 2019 and was published in December 2022 with an update in February 2023. NHTSA’s 297-page detailed report is available here.

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Based on all its crash data. NHTSA has a procedure for determining which ADAS technology to focus on. NHTSA has a four-step methodology for determining when and which ADAS technology to deploy as part of NCAP or mandate. The next figure summarizes the procure, which was used for the AEB-PAEB NRPM in May 2023 and the final rule for the mandate released in May 2024.

The safety need was quantified by a comprehensive analysis of NHTSA’s vehicle crash database. The database has 50+ years of information with increasing details in the last 25 years. This includes sorting crashes by major groups such as forward collisions, lane departure crashes, pedestrian crashes, collisions due to blind spots, intersection crashes and cross-traffic crashes. NHTSA’s analysis of the PAEB safety was focused on calendar year 2019 crash data because it is the most recent year without the effect of the Covid pandemic’s increased risky driving behavior that increased crash fatalities. 

NHTSA’s problem mitigation analysis relies on its research and testing of ADAS vehicles. NHTSA also cooperates with and/or uses data from Insurance Institute for Highway Safety (IIHS), Consumer Reports and other organizations that rate and/or test ADAS vehicles. IIHS has especially good data on the positive impact of AEB through its auto insurance members’ data. 

Assessment of the safety benefits also leveraged NHTSA’s ADAS and NCAP research, testing and related activities. This includes sensor abilities, ADAS software and hardware capabilities and cost implications. Cost-benefit analysis is standard procedure for all NHTSA mandates, and it has extensive experience in modeling and estimating crash costs and benefits value of avoiding fatalities and injuries.

AEB-PAEB crashes: target population.

A key factor in NHTSA’s analysis is how many crashes the mandate can target. NHTSA’s estimates are summarized in the next two tables. The first table shows the number of pedestrian crashes that may have a positive impact from the mandate.

The injuries are segmented into multiple categories based on severity with MAIS 5 being most severe. NHTSA estimates that over 19,500 pedestrian injury crashes and over 2,500 fatality crashes are targets for potential mitigation. The actual yearly savings are lower.

The next table has similar estimates for forward crashes into other vehicles. This table also includes total crashes and the large number of PDO vehicles involved in crashes.

NHTSA is targeting a total of nearly 1.12 million forward crashes that includes over 142,000 injury crashes and 394 fatality crashes. It also includes crashes involving 1.68 million vehicles with property damage only (PDO).

Forward crash avoidance: key tests

NHTSA is proposing lead vehicle AEB performance tests requiring a vehicle to automatically brake and supply sufficient braking to avoid contact with the lead vehicle under three specific test scenarios—stopped lead vehicle, slower-moving lead vehicle and decelerating lead vehicle. The proposed speed ranges were selected based on the speeds at which rear-end crashes tend to happen, which is up to 100 km/h depending on scenario.

The next table is a summary of eight test categories NHTSA will use. There are two tests for stopped vehicles—one without manual braking and one with manual braking. The speed range of the vehicle is 10-80 km/h for no manual braking and 70-100 km/h with manual braking.

There are two tests for slower moving lead vehicles—one without manual braking and one with manual braking. The lead vehicle is driving at 20 km/h in both tests. The subject vehicle is driving at 40-80 km/h with no manual braking and 70-100 km/h with manual braking.

There are four tests for decelerating lead vehicles—two without manual braking and two with manual braking. The lead and follow vehicles drive at the same speed before decelerating—one test at 50 km/h and one at 80 km/h.

It is noticeable that NHTSA did not modify the forward crash tests and the above tests are the same as proposed in the NPRM in May 2023.

PAEB crash avoidance: key tests

The PAEB proposal requires that the vehicle completely avoid a collision with a pedestrian test mannequin during all specific test track scenarios. 

The proposed speed ranges and other key parameters are based on the observed capabilities of recent PAEB systems, limitations of the pedestrian test mannequins and common crash speeds. Manual brake application by the driver is not a parameter of the proposed PAEB test scenarios.

The proposed series of on-track tests fall into three scenarios based on the pedestrian test mannequin actions. A summary of the 12 tests is listed in the next table.

In the first scenario, the test mannequin travels perpendicular to the vehicle’s path and included six tests. Speed ranged from 10 to 60 km/h with daylight and nighttime conditions with lower and upper beams. In the obstruction test, vehicle speed is 10-50 km/h.

In the second scenario, the test mannequin is stationary within the path of the vehicle and vehicle speed is 10-55 km/h. Three lighting conditions are included—daytime and nighttime with lower and upper beams.

In the third scenario, the test mannequin is moving along the travel path of the vehicle. Vehicle speed is 10-65 km/h. The same three lighting conditions are tested.

In all scenarios, the test is set up such that the subject vehicle would collide with the test mannequin if it did not automatically brake.

VSI Labs thought the proposed PAED tests were difficult, and we were surprised no changes were made by NHTSA—the above tests are the same as listed in the NPRM.

Yearly incremental vehicle costs

NHTSA’s estimate of incremental vehicle cost is shown in the next table. Software is the largest cost factor at $282 million or nearly 80% of total. Hardware cost added almost $72 million or slightly over 20%.

In the PAEB NPRM NHTSA’s total annual cost was $282.2 million and only included software cost as NHTSA did not think additional hardware was needed. 

Yearly AEB and PAEB benefits

NHTSA estimated the benefit of AEB-PAEB in terms of fatalities avoided and non-fatal injuries mitigated. The estimates include injury costs and benefits for each type of injuries and fatality. The next table summarizes NHTSA’s estimate of the yearly benefit of AEB, PAEB and total. The injuries mitigated and the prevented fatalities are the same as in the NPRM from 2023, but more details were included.

A total of 362 fatalities will be prevented per year—124 by AEB and 238 by PAEB. PAEB is most important for lower fatalities and accounts for 66% of preventable deaths. Mitigated non-fatal injuries are estimated at over 24,300 with AEB accounting for 89% of the total. NHTSA believes these benefits are conservative and are likely to be better.

The above table also includes average cost per injury and fatality—in thousands of dollars. The average  cost per fatality is nearly $12 million. The average cost per injury is $200,000 and ranges from $66,000 for a MAIS 1 injury and $6.4 million for a MAIS 5 injury.

Total benefits for AEB-PAEB per year is estimated to reach $9.19 billion from avoiding 362 fatalities and mitigating over 24,300 injuries. Total benefit estimate in the NPRM was $8.21 billion. 

Cost and benefit summary

NHTSA provided an economic cost-benefit analysis of the AEB-PAEB mandate, which includes estimates of the monetary value of a person’s life. The economic value estimate of a life is used to quantify the benefit of avoiding fatalities. Estimates for the value of a life are used to compare the lifesaving and risk-reduction benefits of new policies, regulations, and related activities. When calculating the value of life, it is important to discount and adjust it for inflation and real income growth over the years. NHTSA is using two discounts, 3% and 7%, to show a range. For more information on the value of life calculations, Wikipedia has good explanations. 

NHTSA’s cost-benefit analysis of the AEB-PAEB mandate shows it is very cost effective as summarized in the next table. NHTSA’s FMVSS proposal has more details on how the benefits and costs are calculated.

The table shows when discounted at 3% and 7%, the cost per equivalent life saved ranges from $0.55 to $0.68 million. Because the cost per equivalent life saved is less than the comprehensive economic cost of a fatality, the proposed rule is considered cost-effective. The net benefits from the proposed rule are calculated at about $7.26 and $5.82 billion, respectively. Positive net benefits indicate that the proposed rule generates a net benefit to society.

Summary

ADAS is starting to make an impact on automotive safety, but recent technologies can provide much additional life-saving benefits. NHTSA is now willing and ready to add ADAS functions to NCAP and as mandates. 

A quick look at the history of pedestrian fatalities shows why it was imperative for NHTSA to add a mandate that includes PAEB. The next figure includes two historical data graphs from NHTSA. The left chart shows how pedestrian fatalities declined from 1980 to 2010 and then grew by over 100% by 2022 to surpass the 1980 fatalities. 

The right chart shows how nighttime pedestrian fatalities have grown by 86% between 2010 and 2021—from 3,030 fatalities in 2010 to 5,645 pedestrian deaths in 2021. Daytime pedestrian deaths have grown at a lower rate—nearly 39%. This figure shows why NHTSA needed a mandate with improved PAEB capabilities and why the tests are as stringent as current technology allows.

The next figure is a summary of how NHTSA’s FMVSS #127 solves the AEB-PAEB safety problem. The top of the figure shows the safety needs for frontal and pedestrian crashes.

The middle of the figure shows the ADAS solution including FCW, AEB and PAEB features and maximum speed tests. The bottom of the figure shows the AEB and PAEB benefits in terms of fatalities prevented and injuries mitigated.

The AEB-PAEB mandate is the most important ADAS regulation in the U.S. so far and more are expected. The takeaway is that NHTSA will add ADAS features at a much more aggressive rate and speed than in previous decade. The implications for the auto industry are that ADAS will have another golden decade or more as a key safety technology.