In June, the National Highway Traffic Safety Administration (NHTSA) issued a Standing General Order requiring manufacturers and vehicle operators of Level 2 advanced driver assistance systems (ADAS) and/or automated driving systems (ADS) to report crashes involving those vehicles. NHTSA said that the data will help them identify potential safety issues and impacts resulting from the operation of advanced technologies on U.S. roads. NHTSA intends to publicly release this data in an effort to increase transparency.

This new crash reporting requirement comes as more companies are integrating ADAS technologies into their vehicles and as more ADS testing and pilot deployments are happening across the country. Increasing transparency and awareness of these systems’ performance—based on real-world data—is important. Auto Innovators supports that goal. The challenge we note, however, is one of ensuring that the data is collected and released in a way that allows NHTSA and the public to accurately compare the safety performance of these technologies to the safety performance of vehicles that do not have these technologies.

NHTSA analysis shows that the vast majority (94%) of vehicle crashes involve human error as a critical factor. ADAS and ADS features provide safety benefits by replacing or supplementing fallible human drivers with technology which cannot get drunk, bored, or distracted. That is why we are optimistic that the data will show that vehicles with these technologies are safer than human-driven vehicles.

In fact, our analysis of publicly available ADS crash reporting data in California demonstrates just that. Based on 2019 data, which is the last full year of driving not impacted by COVID, vehicles driven by an ADS were involved in half as many crashes per mile driven as human-driven vehicles. This is even more impactful when considering that all of the vehicles driven by an ADS are currently still in the testing phase and have not yet fully validated the safety of their systems for public deployment. We can conduct this analysis because California also reports the total number of miles driven by ADS-equipped vehicles each year within the state.

At Auto Innovators, we are committed to helping ensure that consumers understand the fundamental difference between Level 2 ADAS and ADS. In Level 2 systems, the human driver is responsible for driving and must stay fully engaged at all times. In contrast, when engaged, the automated driving system is managing the driving task. To avoid creating additional customer confusion and to ensure that an appropriate analysis can be done on these distinct technologies, it will be critical that NHTSA report the ADAS data separately from the ADS data.  

We are hopeful that any NHTSA-released data will be done in a way that allows the public to compare the performance of these technologies to the performance of human-driven vehicles. Only with the appropriate context, including information on how many ADS-equipped vehicles are currently in operation throughout the country and the total miles driven by them, can we make important, constructive conclusions about the overall safety performance of these technologies.