NHTSA Orders Crash Reporting for Vehicles Equipped with Advanced Driver Assistance Systems and Automated Driving Systems

[Tam]

Who was complaining that CA DMV reporting system was too burdensome ANNUALLY for SAE Level 3 and above?

The Federal reporting system sounds much stricter especially, now it involves SAE Level 2 and above and it's DAILY.

On Tuesday, 6/30/2021, NHTSA Orders Crash Reporting for Vehicles Equipped with Advanced Driver Assistance Systems and Automated Driving Systems:

"NHTSA’s order requires covered entities to report crashes that occur on public roads in the United States based on the following:

• Within one day of learning of a crash, companies must report crashes involving a Level 2 ADAS or Levels 3-5 ADS-equipped vehicle that also involve a hospital-treated injury, a fatality, a vehicle tow-away, an air bag deployment, or a vulnerable road user such as a pedestrian or bicyclist. An updated report is due 10 days after learning of the crash.
• Every month, companies must report all other crashes involving an ADS-equipped vehicle that involve an injury or property damage.
• Reports must be updated monthly with new or additional information.
• Reports must be submitted for any reportable crash, about which a company receives notice, beginning 10 days after the company is served with the order.
• Reports must be submitted to NHTSA electronically using a form that requires important information regarding the crash. NHTSA will use this information to identify crashes for follow-up.

The order requires vehicle and equipment (including software) manufacturers of Level 2 ADAS or Levels 3-5 ADS systems and vehicles and operators of ADS-equipped vehicles to report crashes where the Level 2 ADAS or Level 3-5 ADS system was engaged during or immediately before the crash. "

 

[diplomat33]

Who was complaining that CA DMV reporting system was too burdensome ANNUALLY for SAE Level 3 and above?

The Federal reporting system sounds much stricter especially, now it involves SAE Level 2 and above and it's DAILY.

On Tuesday, 6/30/2021, NHTSA Orders Crash Reporting for Vehicles Equipped with Advanced Driver Assistance Systems and Automated Driving Systems:

"NHTSA’s order requires covered entities to report crashes that occur on public roads in the United States based on the following:

• Within one day of learning of a crash, companies must report crashes involving a Level 2 ADAS or Levels 3-5 ADS-equipped vehicle that also involve a hospital-treated injury, a fatality, a vehicle tow-away, an air bag deployment, or a vulnerable road user such as a pedestrian or bicyclist. An updated report is due 10 days after learning of the crash.
• Every month, companies must report all other crashes involving an ADS-equipped vehicle that involve an injury or property damage.
• Reports must be updated monthly with new or additional information.
• Reports must be submitted for any reportable crash, about which a company receives notice, beginning 10 days after the company is served with the order.
• Reports must be submitted to NHTSA electronically using a form that requires important information regarding the crash. NHTSA will use this information to identify crashes for follow-up.

The order requires vehicle and equipment (including software) manufacturers of Level 2 ADAS or Levels 3-5 ADS systems and vehicles and operators of ADS-equipped vehicles to report crashes where the Level 2 ADAS or Level 3-5 ADS system was engaged during or immediately before the crash. "

It is not daily. They don't need to submit reports daily. Serious crashes must be reported within 1 day. So whenever a serious crash happens, it must be reported within the day. That's not the same thing as filing reports daily. Other crashes must be reported on a monthly basis. And the order says reports must be updated monthly, not daily.

I do think this is a good thing. It should allow for greater transparency since manufacturer won't be able to hide or distort their crash data. And it should allow for more reliable data on ADAS and AV safety. It should also help with measuring AV safety since we will have reliable AV crash data to compare with human crash data. It should also allow for greater accountability since the NHTSA will have information on AV crashes and be able to investigate in a timely manner. If the AV is deemed at fault, then the manufacturer can be made to fix the problem. So it should help make ADAS and AV's safer in the future. This will be good for the consumer.

 

[mikes_fsd]

This is a correct step.
Probably will have a couple of revisions down the line, but they need a baseline.

 

[Tam]

...So it should help make ADAS and AV's safer in the future...

But who must report because Honda was boasting its advancement toward Autonomous Vehicles but as the reporting mandate comes out, it now says it's exempted because it's Level 1 ADAS.

 

[diplomat33]

But who must report because Honda was boasting its advancement toward Autonomous Vehicles but as the reporting mandate comes out, it now says it's exempted because it's Level 1 ADAS.

According to the article you linked, Honda is only wanting to exempt their systems, AcuraWatch and Honda Sensing, because they are L1. AccuraWatch and Honda Sensing are not Honda's autonomous driving systems. Honda would not exempt any autonomous driving systems that they would deploy.

The main takeaway I got from the article is that automakers and AV companies don't like that L2 was lumped in with L3+. They feel it conflates driver assist with autonomous driving. It would require the same reporting for Tesla's system which is L2 as it would for say Waymo's L4 driverless. They are concerned about what is called "autonowashing" which is where driver assist systems are mistaken for autonomous driving.

I understand their concern but we still need crash data on L2 systems. So those systems should still report their crashes. But maybe they want better categorization where the crash reports would also include the SAE level, who was responsible for the driving or whether the vehicle was driverless? Or maybe they just want L2 crashes to use a different form?

 

[Tam]

According to the article you linked, Honda is only wanting to exempt their systems, AcuraWatch and Honda Sensing, because they are L1. AccuraWatch and Honda Sensing are not Honda's autonomous driving systems. Honda would not exempt any autonomous driving systems that they would deploy...

How would Honda would self evaluate its system as L1?

My understanding of L1 is it is capable of doing 1 out of 2 functions either Cruise Control or AutoSteer.

My understanding of L2 is it is capable of doing 2 out of 2 functions both Cruise Control or AutoSteer.

There's a video demo of Honda Sensing on how to defeat its AutoSteer 10-second nagging:

 

[diplomat33]

How would Honda would self evaluate its system as L1?

My understanding of L1 is it is capable of doing 1 out of 2 functions either Cruise Control or AutoSteer.

My understanding of L2 is it is capable of doing 2 out of 2 functions both Cruise Control or AutoSteer.

There's a video demo of Honda Sensing on how to defeat its AutoSteer 10-second nagging:

The SAE defines L2 as doing both functions but it must "sustained":

SAE L2: The sustained and ODD-specific execution by a driving automation system of both the lateral and longitudinal vehicle motion control subtasks of the DDT with the expectation that the driver completes the OEDR subtask and supervises the driving automation system.

On the feature page, Honda lists Road Departure Mitigation System that will nudge the steering if the car might leave the lane and Lane Keeping Assist System that will adjust steering to help the car stay in the lane. So I think Honda is arguing that Honda Sensing is not doing steering in a sustained way since it is only adjusting or nudging the steering, not doing steering "full-time". The only function that is done in a sustained way is the adaptive cruise control. Hence, it is only doing 1 function in a sustained way, so it is L1 according to the SAE.

What is Honda Sensing® Suite? Features & More | Honda

Feel secure in any Honda vehicle. Our active and passive safety systems and technology assist in keeping you as collision-free as possible on the road.

automobiles.honda.com

 

[Tam]

...So I think Honda is arguing that Honda Sensing is not doing steering in a sustained way since it is only adjusting or nudging the steering, not doing steering "full-time"...

Honda's theory is not the same as in practice, because the videos show drivers don't need to steer as long as they respond to the 10-second nag (completely legal and as designed) or to defeat the 10-second nag (not recommended nor designed by the manufacturer).

So what should the government go by? Manufacturer's explanation as ADAS Level 1 or the car's real performance?

 

[diplomat33]

Honda's theory is not the same as in practice, because the videos show drivers don't need to steer as long as they respond to the 10-second nag (completely legal and as designed) or to defeat the 10-second nag (not recommended nor designed by the manufacturer).

So what should the government go by? Manufacturer's explanation as ADAS Level 1 or the car's real performance?

Well, the SAE document says the manufacturer gets to decide the SAE level. But I agree that in practice, that might not work. Certainly, we've seen issues like with Honda and Tesla where the manufacturer says one thing but customers use the system differently. I would be in favor of regulators having the power to classify all automated driving systems. I think that could solve the problem you mention.