BriefCASE: Challenges of Phantom Braking

Autonomous emergency braking (AEB), a system first introduced in
2008 by Volvo as Volvo City Safety, has become the unlikely source
of a rift between the US regulatory body the National Highway
Traffic Safety Administration (NHTSA) and the automakers'
representative body in the country, the Alliance for Automotive
Innovation (AAI).

From their initial Volvo use case of avoiding low-speed
accidents in city driving, AEB systems have evolved significantly.
They now utilize a bank of cameras, sensors, radar and lidar to
identify potential obstacles, including pedestrians and cyclists,
and automatically engage brakes to avoid or mitigate
collisions.

Allied with this evolving remit, millions of vehicles in the US
are currently under investigation for phantom braking, or the
unexpected activation of AEB systems. Toyota, Subaru, Ford, Honda
and GM vehicles have all been subject to recalls in the US to fix
cases of unexpected activation of AEB systems.

To try and address this issue NHTSA has set stringent
requirements for AEB systems (encapsulated in the Federal Motor Vehicle Safety Standard (FMVSS)
No. 127 for those with time on their hands) that will come into
effect from Sept. 1, 2029.

The problem here is that FMVSS No. 127 is so far out in front of
AEB boundaries established in other countries that the AAI
considers it unworkable. For example, Europe's regulations for AEB
under the General Safety Regulation set speeds between 12.4mph and
37.3mph for AEB operation, while NHTSA wants AEB to be capable at
speeds of up to 60mph.

Automakers, in the main, like to be able to act with regulations
that are as homogeneous as possible. Regulations that are broadly
the same enhance speed to market and reduce development costs. The
AAI went even further in June in a letter to NHTSA stating that the
AEB mandate is “practically impossible with the current
technology”. The AAI maintained that although automakers worked
with the NHTSA and Insurance Institute for Highway Safety to
develop AEB systems, the new standards significantly deviate from
the initial agreement on the expected capabilities of the
technology (worth recalling here AEB's genesis as Volvo City
Safety). The letter highlighted several technical challenges
regarding the implementation of the AEB mandate.

According to the AAI, the NHTSA's assumption that existing AEB
systems will not significantly contribute to rear-end collisions is
flawed given that not all vehicles on the road are equipped with
compliant systems. Moreover, the AAI criticized the NHTSA's lack of
comprehensive data to substantiate claims that false positives are
rare or that the new requirements will not exacerbate the
issue.

The AAI recommended that the NHTSA perform a comprehensive risk
assessment to quantify the potential rise in rear-end collisions
from rule-compliant AEB activations and assess the associated
disbenefits, justifying the acceptability of these risks. The AAI
stressed that without this evaluation, the regulatory framework may
compromise safety rather than enhance it, repeating past
experiences with other safety mandates when unintended consequences
arose from stringent performance standards.

A closer examination of this spat over one of the more
established ADAS (advanced driver assistance systems) technologies
is illustrative of the difficulties the industry is facing in
moving toward a globally harmonious manifestation of the industry's
vision for automated driving. Simply, what's allowable for a Level
4 car in Mainland China, might not be permissible in California or
Michigan. What looks like on the surface a localized disagreement
over a subset of ADAS technology demonstrates the regulatory
difficulties the industry wrestles in the implementation of
increasingly complex technologies.

Authored By: Hrishikesh S, Research Analyst, Supply
Chain & Technology, S&P Global Mobility

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