Mayor Wu’s Letter to National Highway Traffic Safety Administration

Mayor Wu supplied feedback in response to NHTSA’s proposed updates to the New Automotive Evaluation Program.

June 2, 2022

Dr. Steve Cliff
Deputy Administrator
Nationwide Freeway Site visitors Security Administration
Division of Transportation
1200 New Jersey Avenue S.E., West Constructing
Washington, D.C. 20590-0001

Pricey Deputy Administrator Cliff,

On behalf of The Metropolis of Boston we’re happy to supply the next feedback in response to NHTSA’s proposed updates to the New Automotive Evaluation Program (NCAP).

Since 2015, the Metropolis of Boston has dedicated to a Imaginative and prescient Zero program geared toward eliminating site visitors crashes and fatalities on our metropolis streets. The Metropolis has drastically expanded funding and workers capability to expedite safer roadway redesigns, present fast response enhancements in crash places, and conduct nation main engagement programming. Boston has taken coverage approaches as properly – equivalent to instituting a citywide velocity restrict of 25 mph to cut back the damaging impacts of rushing on metropolis streets – and we had been the primary metropolis within the nation to enact a side-underride ordinance in direct response to a number of deadly side-impact crashes between cyclists and huge vans within the metro space. The techniques method espoused by Imaginative and prescient Zero is extra than simply higher roadway designs, it must be about safer autos for these inside and out of doors the cabin.

In Boston, the place the vast majority of resident’s work journeys contain strolling for a portion or all of their journey, we’re grateful that NHTSA is exploring find out how to shield individuals outdoors of the automobile in addition to inside. In The Affiliation Between Pedestrian Crash Sorts and Passenger Automobile Sorts report by the Insurance coverage Institute for Freeway Security (IIHS) in March 2022 it was concluded that “Mild truck autos had been extra more likely to be concerned in sure pedestrian crash sorts, implying a doubtlessly problematic visibility of pedestrians close to the entrance corners of those autos.” In a metropolis infamous for a sophisticated and non-rectilinear roadway community, we view this as a big downside for our residents, however one the place the authority to enact change sits on the federal stage.

Nationally, fatalities and critical accidents amongst pedestrians and cyclists have skyrocketed by greater than 50 p.c over the previous ten years, dramatically outpacing general roadway fatalities. Newly launched estimates from NHTSA present that almost 43,000 individuals died in crashes in 2021, a ten.8% bounce from 2020. Whereas we haven’t skilled the identical development in Boston, we do nonetheless common greater than 10 fatalities every year. Updates to NCAP haven’t saved tempo with these realities, and worldwide equivalents have surpassed the U.S. program. Present automobile requirements and ranking techniques have failed to guard individuals outdoors of vehicles, particularly in multimodal city environments. These dangers will improve within the coming years as electrical autos convey heavier curb weights and quick acceleration to our city streets.

The Metropolis of Boston is inspired to see NHTSA take the essential step of incorporating security options that shield individuals outdoors of autos into NCAP. Nevertheless, the proposed adjustments to the Program can go additional. Along with incorporating a number of long-overdue technological adjustments, the ranking system should deal with the outsized roles that automobile velocity, measurement, weight, and visibility from the motive force’s seat play in figuring out security outcomes. To assist alleviate the nationwide site visitors security disaster, NHTSA ought to guarantee no automobile receives a 5 star ranking with out scoring extremely within the following classes:

• ADAS options able to sensing and defending individuals outdoors autos: This RFC incorporates necessary applied sciences into NCAP, together with blind spot detection and intervention (BSI/BSW), lane holding help (LKS), and pedestrian computerized emergency braking (PAEB). To maximise security advantages to individuals outdoors autos, NHTSA’s testing protocols for these techniques should account for documented shortcomings of ADAS options. These applied sciences are identified to be much less dependable in darkish lighting, inclement climate, whereas turning, touring at larger speeds, or at detecting individuals of colour. NHTSA can considerably enhance automobile security not solely by reserving five-star scores for autos geared up with ADAS, however guaranteeing these techniques carry out to a excessive normal.
• Pedestrian safety and crashworthiness/survivability for individuals outdoors the automobile: Since 2010, NHTSA has documented that giant high-front autos current elevated dangers to individuals strolling and biking. With very giant SUVs and lightweight vans making up an ever-increasing share of vehicular site visitors and driving a big share of fatalities and critical accidents amongst pedestrians and cyclists, federal motion to handle automobile measurement is lengthy overdue. NHTSA’s proposal to incorporate a crashworthiness pedestrian safety testing program in NCAP in 2022 is a chance to replace automobile take a look at standards to make sure security for the widest potential vary of individuals. NHTSA can accomplish that by following the instance of Transport For London and choose, as their default “take a look at case,” a considerably smaller than common particular person, to make sure that all individuals are correctly thought of within the crashworthiness testing. Designing take a look at standards constructed across the smaller-than-average particular person will lead to elevated security for everybody.
• Direct visibility from the motive force’s seat (“direct imaginative and prescient”): Cameras, mirrors, sensors and different ADAS options can’t exchange the necessity for direct sight. Giant autos, equivalent to SUVs, mild vans, and heavy vans, have giant blind spots and visibility issues, that are immediately linked to decreased security and will increase in fatalities. A current IIHS examine discovered that pick-up vans are 4 instances extra possible, and SUVs are 3 instances extra possible, to trigger a deadly crash when making a left flip due to restricted visibility from the motive force’s seat. Knowledge from the USDOT Volpe Middle reveals that when drivers are working vans with low visibility from the motive force’s seat they can detect pedestrians in a crosswalk in entrance of them solely 13% of the time, versus 100% in autos that supply higher visibility from the motive force’s seat. NHTSA ought to use present instruments, equivalent to USDOT’s Blind Zone Calculator that was experimented with within the Metropolis of Boston at its early stage and worldwide direct imaginative and prescient requirements, to judge and deal with the security impacts of blind spots on giant autos. Autos with low direct visibility from the motive force’s seat mustn’t obtain 5-star scores. Having higher requirements will assist push {the marketplace} to the place Boston want to be – with extra direct imaginative and prescient autos out there.
• Clever velocity help techniques that robotically restrict unsafe speeds: Automobile velocity performs a important function in figuring out the probability and severity of site visitors crashes, accidents, and fatalities. Crashes usually tend to happen as a driver’s velocity will increase, as does the probability of a crash being deadly. Clever velocity help (ISA) is a software confirmed to cut back speed-related crashes and fatalities. This know-how is already broadly deployed throughout Europe and Euro NCAP’s ranking system supplies a mannequin for NHTSA to comply with in contemplating ISA. NCAP can act as an incentive for automakers to make ISA normal in all autos, by reserving full credit score solely the place it’s out there.

The Metropolis of Boston drastically appreciates NHTSA’s consideration of those feedback and guaranteeing that buyers have the required data wanted to make selections. Safer autos are a pillar of USDOT’s Nationwide Roadway Security Technique and NHTSA can do extra to leverage NCAP and guarantee shoppers have a complete understanding of auto security. We welcome additional alternatives to information the continued growth of the NCAP program as NHTSA takes necessary steps in the direction of incorporating the security of individuals touring outdoors private autos into this system.

Sincerely,

Michelle Wu
Mayor of Boston