Unintended Acceleration, Unintended Consequences

Automotive News reports that in response to the recent issues surrounding unintended acceleration, Federal Regulators are expected to undertake a rulemaking to require brake override and event data recorders (EDR) on passenger vehicles.

The changes for brake override, where engine power is reduced when the brakes and throttle are pressed simultaneously, have mostly to do with software and should be fairly straightforward to implement.

However, one unintended consequence could be that it will no longer be possible to heel-and-toe a car equipped with a manual transmission.  That's a technique used during performance driving, where the driver "blips" the throttle while shifting and braking to keep the engine at a higher RPM for more and faster power delivery once the next gear is selected.

Event Data Recorders (EDR), also known as "black boxes" will be a bit more involving.  The costs will vary greatly with the rule's requirements.  I worked on this issue for 6 years for heavy trucks and there are a lot of things to consider.  They've also been required to record data a certain way on passenger cars IF those cars were equipped with such a device.  Typically, manufacturers install them to trigger and record data to protect themselves from liability.

NHTSA's cost estimate for these devices in the 2004 rulemaking was laughable, the low end starting about $0.50 to install them on each new car.  Let's hope whatever comes out is reasonable and effective.

Stating the Obvious (Someone Has To Do It)

This is sort of funny. The statement is obvious but to their credit they would be remiss if they did not make it.

On December 2, 2009 NHTSA (National Highway Traffic Safety Administration) published a notice in the Federal Register (page 63181) about ejection mitigation containing this little gem:

According to agency data, occupants have a much better chance of surviving a crash if they are not ejected from their vehicles.

Effectiveness of Anti-Lock Brakes

NHTSA published a reqeust for comments in yesterday's Federal Register about a Technical Report on The Long-Term Effect of ABS in Passenger Cars and LTVs (based on 1995 to 2007 data), some good some not really... Here are the basic findings:

1. "ABS has close to a zero net effect on fatal crash involvements."

2. Fatal run-off-road crashes of pass cars increased 9%.

3. Fatal collisions with pedestrians decreased 13%

4. Collisions with other vehicles on wet roads decreased 12%.

5. "ABS is quite effective on nonfatal crashes, reducing the overall crash-involvement rate by 6% in passenger cars."

Here's the link: text, PDF

"Cash For Clunkers" Rulemaking Published

I don't believe in conspiracies. Except for this one. The Government comes up with the acronyms first, and then chooses words that will fit. How else do we explain words that say little except for the cute little acronyms they form hmmm?

The summary of the "Consumer Assistance to Recycle and Save Act of 2009" and notice of upcoming rulemaking proceeding was published today. NHTSA, in conjunction with EPA, is to have everything ready by July 24th.

In a nutshell, trade in your old gas guzzling car or truck (must have been manufactured after mid-1984) toward a brand new one that guzzles a little less and get a $3,500 to $4,500 discount off the new one, as long as the sticker is under $45,000.

Your old vehicle will be shredded or crushed to get it off the road. You will need to have owned and insured/registered it for at least the past year to be eligible. The details are laid out on the last page of the PDF below.

Overall this will probably reduce pollution somewhat and give a slight nudge toward alleviating the recession.

Source: NHTSA (Txt, PDF)

Safety Rulemaking & Research Priorities

The Natinoal Highway Traffic Safety Administration (NHTSA) published a request for comments (due Aug. 31, 2009) on its Safety Rulemaking & Research Priority Plan 2009-2011. Here are a few interesting insights gleaned from the report.

In 2007 there were more than 6 million police-reported crashes in the U.S., over 41,000 people were killed, 2.5 million injured, and it is estimated the cost to society was $230 billion (about $750/person).

Four types of crashes account for 85% of all fatal crashes, as well as 75% of all road fatalities (presumably including pedestrians?):

Run-Off-Road (23%)
Rear-End (28%)
Lane Change (9%)
Crossing Path (25%)

Makes sense. The higher the speed and/or directional difference between objects in a collision, the greater the risk.

Light trucks present a higher fatality risk than passenger cars in frontal crashes with other motor vehicles (37% and 32% of fatal crashes, respectively).

Light trucks also present a significant fatality risk in non-collision rollovers, "accounting for 23 percent of crash fatalities."

This will not be helped by CAFE standards which is assessed in part on vehicle footprint, which is based on track width and wheelbase and thus encourages larger overhangs. This reduces vehicle stability compared with placing wheels at the furthest corners of the vehicle.

Crash avoidance programs are the highest priority at NHTSA as they offer the greatest benefits.

Source: NHTSA (Text, PDF)

Daytime Running Lamps Will Not Be Required

Back in 2001 GM had petitioned NHTSA (National Highway Traffic Safety Administration) to require vehicles to be equipped with daytime running lamps (DRL). It took a while but today the agency published a denial of the petition.

Here's the official summary:

This document denies a petition for rulemaking submitted by General Motors on December 20, 2001. The petitioner requested that the agency amend the Federal motor vehicle safety standard (FMVSS) on lamps, reflective devices, and associated equipment to require the installation of daytime running lamps on passenger cars, multipurpose passenger vehicles, trucks, and buses that have a gross vehicle weight rating under 4,536 kilograms (10,000 lbs). NHTSA has reviewed the petition and performed an extensive analysis of real world crash data. Based on the results of our study we were unable to find solid evidence of an overall safety benefit associated with daytime running lamps and are therefore denying the petition for rulemaking. The agency maintains its neutral position with respect to the safety benefits from the use of daytime running lamps.

Links to full document: Text and PDF formats.

Drove It Like He Stole It...

Car Thefts In 2007, compiled by NHTSA: html or PDF formats

NHTSA Fuel Economy Proposal

The new CAFE (Corporate Average Fuel Economy) proposal is going to have unintended consequences. It’s based on the premise that each manufacturer’s fleet should have an average based on the size of each model and the number of vehicles produced.

The size of each model is based on its “footprint”, that is the track width multiplied by the wheelbase, and that the smaller this area is the higher the fuel economy (MPG) of the vehicle must be. It is intended that this would raise the average fleet fuel economy.

I also believe this is NHTSA’s solution to their dilemma of how to categorize a vehicle as a passenger car or a light truck, a dilemma that has become markedly more of an issue with so many different models now available from manufacturers.

However, this proposed regulation potentially won’t achieve its objective because manufacturers will build larger, less efficient models than they could since they have lower fuel economy hurdles to clear, relative to smaller vehicles. It’s a disincentive for manufacturers to offer smaller (and presumably more efficient) vehicles.

If that is the case then the way to have a more efficient vehicle fleet is to leave it to the market to demand more efficient vehicles by voting with its money. So why have the burden of this additional change?

Every manufacturer should be accountable to one standard, and not have their thresholds based on their product mix. Foundations should be built on level ground. NHTSA should clarify the definitions of automobiles and light trucks, and apply these definitions to all vehicle manufacturers the same way.

Here’s a link to the proposal (scroll down to National Highway Traffic Safety Administration):

http://www.access.gpo.gov/su_docs/fedreg/a080428c.html

How to Not Effect Change

Save everyone a whole lot of time. If you're going to petition NHTSA to change a regulation, especially one that affects as many people and companies as FMVSS 121 (air brake systems) then have some data to back up your claim... otherwise you might wait a year and a half from the time you petition to the time you get rejected.

NHTSA Grants Tesla Airbag Exemption

This is late but the National Highway Traffic Safety Administration (NHTSA) granted Tesla's petition for an exemption on advanced airbags on January 28th. The roadsters will, however, be equipped with standard dual airbags (like the ones that were around before "smart" airbags). Read the full PDF here.

AutoBlogGreen quoted my comments to NHTSA on the Tesla petition for a 3 year waiver on advanced airbags. Here's the letter I wrote last year (PDF) in support of the exemption.

NHTSA Roof Crush Resistance Proposal

Published in today's Federal Register, the Supplemental Notice of Proposed Rulemaking (SNPRM) requests public comment by March 17, 2008 on a proposal to change the standard (FMVSS 216). Note: This SNPRM does not apply to convertibles.

The basic idea is a plate is used to apply a force of 2.5 times the vehicle weight to the roof over the front seat area. The roof cannot collapse more than 127 mm (5 inches), or come in contact with the head of a seated 50th percentile male dummy. The current requirement is a force of 1.5 times vehicle weight (limited to 5,000 lbs), and does not prohibit roof component intrusion.

Looks like Toyota has done their homework best on FMVSS 216. All four of their 2007 vehicles tested were ranked near the top of both tests (Scion tC, Tacoma, Camry, Yaris) with the Scion tC ranked highest on the 2-sided test. The 2006 VW Jetta had the highest overall strength-to-weight ratio (SWR) in the single-sided test.

However, it must be added that when looking at roof strength alone, the absolute highest peak strength goes to the 2006 Volvo XC90 by a long shot with a rating of 90,188 N (20,268 lbs) which is a lot more than any of the other vehicles. It just happens to weigh 2,020 kg (4,453 lbs) which cuts down its SWR a bit. There is some truth in advertising - and this roof could theoretically support an adult male elephant.

Another interesting tidbit is that, in this test, the 2006 VW Jetta roof is stronger than that of the Hummer H3, which weighs 685 kg (1,510 lbs) more. The Subaru Tribeca also did well. The lowest strength result? The 2007 Pontiac G6 at 33,393 N (7,504 lbs).

The impact of this rule (no pun intended) will probably be diminished over time, which is a good thing as that means fewer people will be killed or injured through rollovers. The reason the effect may become less pronounced, as NHTSA points out, is the mandate for electronic stability control systems (ESC) starting in September 2011. This will reduce vehicles from rolling over in the first place.

Along with many other trends, this proposal indicates that future vehicles will have to be lighter, and yet have stronger structures. However, adding strength often adds weight, and vehicles don’t need more weight above the center of gravity, such as the roof. Conclusion: Wear your seatbelt, don't rollover, and you’ll probably be fine without this standard.

(full document available here - scroll down to National Highway Traffic Safety Administration for details)