Center for Auto Safety comment on RFC on ADAS Test Procedures

March 5, 2020
James C. Owens, Acting Administrator
National Highway Traffic Safety Administration Dockett Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue SE
West Building, Ground Floor, Room W12-140 Washington, DC 20590-0001
Submitted electronically via
RE: Request for Comments on Advanced Driver Assistance Systems Draft Research Test Procedures; Docket Number NHTSA-2019-0102
Dear Acting Administrator Owens:
The Center for Auto Safety (Center) appreciates the opportunity to comment on the agency’s potential procedures for testing Advanced Driver Assistance Systems (ADAS). The Center, founded in 1970, is a national, independent, non-profit, member-driven consumer advocacy organization dedicated to making all drivers, passengers, and pedestrians safer by improving vehicle safety and quality. Over the last five decades, the Center has focused on advancing safety technology for all consumers from airbags to anti-lock braking, from electronic stability control to automatic emergency braking. We have long supported innovative technology proven capable of reducing deaths, injuries, and crashes, on the nation’s roads.
Accordingly, on behalf of our members nationwide, the Center urges the National Highway Traffic Safety Administration (NHTSA) to expedite the introduction of ADAS technologies into passenger and commercial vehicles by issuing an updated New Car Assessment Program (NCAP) in 2020, followed quickly by mandatory performance standards for ADAS technologies. Vehicle crashes continue to claim close to 40,000 lives in the United States every year and remain the leading killer of young people in America.
The current leadership of the Department of Transportation (DOT) has made many public pronouncements about speeding innovation by eliminating mandatory regulations,1 yet it is now undertaking a process which slows to a crawl the potential for introduction of life saving technology.