SAE Design Guidelines Need DOT Testing Guidelines

The National Highway Traffic Safety Administration (NHTSA) Highly Automated Vehicle (HAV) Guidelines are clearly just a ‘How To’ for engineering design.

Automotive Manufacturers and Safety Advocates understand the Design Guidelines but are calling for more information in regards to the Testing Guidelines.

The NHTSA Automated Vehicle Guidelines refer to the “SAE Standard J3016” for their Levels of Automation Design but do not clarify the Levels of DOT Automation Testing.

These guidelines where released late last September and were open for public comment until mid November. They include a 15 point assessment for the development of automated vehicles.

These assessments address safeguarding consumer privacy, reacting to failures of automatic systems, and protecting passengers in a collision.

The NHTSA that administers traffic safety regulations for DOT further noted how it will be asserting its ability to recall any automatic system and or autonomous vehicle that does not meet its safety standards.

This is clearly a very big step in the progress of automatic driver systems but after reading all these papers it becomes clear to safety engineering designers that it is missing the next step in clarity, how will these levels of design be tested?

The SAE (Society of Automotive Engineers) have provided each other with a clear path for progressive design objectives.

As shown in the SAE chart above there is a logical progression of how the levels of automated system designs will take over for the driver.

These design levels obviously must overlap as they progress from some autonomous involvement through levels of driver involvement to no driver requirements in the fully automatic level.

Now put yourself in a safety engineering designer’s position and review this SAE chart from a perspective of trying to clearly define each level of testing.

These overlaps of automation are a nightmare when trying to define how to test each of these engineering levels. The conditions for each test and the required results will be very lengthy and very hard to keep clearly on target.

There needs to be a separation of these SAE Design Guidelines from the DOT Defined NHTSA Safety Testing.

Here’s my example based on professional experience and observations…

First and foremost there is the primary objective that will always be to reduce fatalities from collisions.

The DOT Level 0 Tests are to determine survival vulnerability of all the people in the vehicle.

These tests are still based on actual collisions of production vehicles being crashed into and or into barriers. The major difference is that every seat location will be tested and the pass and fail survival ratings are very clear and to the point.

The addition of collision avoidance to the NHTSA Safety Testing must also be clear and to the point.

There can not be any overlaps of levels in these testing procedures. Assisting technologies must be able to only assist. Technologies that assist the driver can not take over any level of driving from the driver. Automatic means it can take over from the driver at some level of conditions within a range of speed.

Further the SAE Level 2, Partial Automation and Level 3, Conditional Automation and Level 4, High Automation are based on functions for more conditions and the performance increases can only be measured at increasing speeds.

Other than simplifying the SAE Design Levels that need to be expansive in order to allow for a full range of designs, these DOT Testing Levels are much less conditional.

These DOT Testing Levels are very clear and can be simulated under laboratory conditions without risk to the testing technicians.

This DOT Level 2, Assist and Level 3, Automatic Testing Definitions are clearly divided and are still both simply based on Performance At Speed.

For Example: The manufacturer will submit how their Automatic Driver will work under what conditions and at what speeds. After the design is tested as a Driver Automatic System at the Front / Side it can be put on the sticker in the Avoidance column in the row of the Speed it Passed.

This proposed NHTSA Collision Testing Sticker Rates Performance At Speed Passed.

This Collision Avoidance and Protection Safety Ratings System Works Now & For Our Future Safely.

I would estimate the DOT-L3 Test of a SAE-L3 Automatic Pilot is not that far off from 3 or 4 Stars for day clear-weather on divided-roads. However it will be considerable progress in ten years if the infrastructure is in place for the automotive manufacturer to get 6 to 8 Stars in the DOT-L3 Test of a SAE-L4 Automatic Pilot especially for day/night moderate-weather on divided-roads.

I am an engineering designer trying to make a difference in traffic safety with innovations and regulations and my specific agenda is made clear that I am advocating to increase collision protection testing speeds for interest in the “Tether-A-Way Safety Occupant Compartment Mounting System”.

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