Reaction to first monthly NHTSA data on crashes involving vehicles with ADAS and ADS.

US National Highway Traffic Safety Administration publishes first monthly report into ADAS and ADS crashes

On 15 June, the US Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) published the first of what will be monthly reports into crashes involving vehicles with advanced driver assistance systems (ADAS) and more advanced automated driving systems (ADS).

ADAS

In brief, for SAE Level 2 ADAS equipped vehicles, 367 crashes were reported from July 2021 to 15 May 2022, resulting in six fatalities and five cases of serious injury. Tesla reported the most, followed by Honda and Subaru.

Cue the headlines, “Tesla Autopilot and Other Driver-Assist Systems Linked to Hundreds of Crashes” in the New York Times and “Teslas running Autopilot involved in 273 crashes reported since last year” in the Washington Post.

However, the United States Public Interest Research Group (US PIRG) shed light on this, explaining that “Teslas are connected to the internet and automatically report if the car was in Autopilot when it crashed. Honda asks its drivers if they were using ADAS, so it relies on hard-to-verify personal accounts. Everyone else leaves it up to the police report.”

ADS

For ADS, nearly all the data comes from California. 130 crashes were reported from July 2021 to 15 May 2022. One resulted in serious injury. Waymo reported the most incidents, followed by Transdev Alternative Solutions and then Cruise.

Reaction

Dr. Steven Cliff, NHTSA’s Administrator, said: “The data released today are part of our commitment to transparency, accountability and public safety.

“New vehicle technologies have the potential to help prevent crashes, reduce crash severity and save lives, and the Department is interested in fostering technologies that are proven to do so; collecting this data is an important step in that effort.

“As we gather more data, NHTSA will be able to better identify any emerging risks or trends and learn more about how these technologies are performing in the real world.”

Autonomous vehicle safety consultant Philip Koopman welcomed the new data, commenting: “This is an excellent first step for transparency. All of us safety advocates can wish for more data and for less redaction, but this is a crucial step forward.

“If I had one wish, it would be to divide the narrative data field into two sections: public narrative and confidential narrative, and put huge pressure on the reporting companies to minimize things put into the confidential narrative.”

On this side of the pond, The Law Commission has recommended that automated vehicles must be able to record and store data necessary for incident investigation.

Thatcham, AXA and Mercedes-Benz Cars UK respond to Drive Pilot conditionally automated driving liability announcement

Conditionally automated: Thatcham and AXA respond to Mercedes-Benz Drive Pilot liability announcement

Mercedes-Benz made global headlines in late March by taking the unusual step of announcing that it will accept legal responsibility for accidents caused by its Drive Pilot automated lane keeping system (ALKS).

The move followed the announcement, last December, that it had become the first vehicle manufacturer (VM) to meet the international UN-R157 standard for a Level 3 system, capable of “conditionally automated driving”.

Conditionally automated driving

Mercedes-Benz Cars UK was quick to emphasise that this currently only applies to Germany. “The system must safely perform the dynamic driving task when activated,” it said.

“However, the driver still has duties in public road traffic even during conditionally automated driving. It is true that they are allowed to temporarily turn away from traffic in Germany; however, they must, for example, resume the driving task at any time when requested to do so by the system.”

That sounds innocuous but it’s a major step on the road to self-driving. In cars equipped with this tech – reportedly to be available first on the new £83,000 S-Class – in Germany, where 13,000km of motorway are approved for Level 3, the car can do the driving. Just take that in.

In the UK, Thatcham is leading the development of a consumer safety rating to support the safe adoption of Automated Driving Systems (ADS).

Matthew Avery, Director of Research at Thatcham on automated driving
Matthew Avery, Director of Research at Thatcham

Matthew Avery, Director of Research at Thatcham, commented: “We’re pleased that Mercedes have made that statement, but it has to be seen in context. Firstly, the announcement was made for the German legal system, so you have to look at the legal onus on the driver to maintain control and be responsible.

“From a UK perspective, the recent Highway Code changes clarify that a bit more. It’s fairly clear within the Automated and Electric Vehicles Act (AEV Act) that the VM will ultimately be liable if their system is seen as being at fault.

“It comes back to understanding who was driving at the time of collision, and we’re not so happy that the data part is still slightly ambiguous. VMs are required to record who was driving at the time of the collision. However, it’s not clear that the data will be available in every collision, or how that data will be accessible to the insurer.

“What the Mercedes statement does do, which is helpful, is it gives confidence to the consumer that if something goes wrong, somebody will be there to pick up the bill.”

Doug Jenkins, Motor Technical Risk Manager at AXA Insurance UK, on automated driving
Doug Jenkins, Motor Technical Risk Manager at AXA Insurance UK

Doug Jenkins, Motor Technical Risk Manager at AXA Insurance UK, agrees. “On paper, the liability is clear,” he said. “But I think there is some work still to do – together – on how it would play out in practice.

“Let’s think about what happens in a claim: You’re lucky enough to be given one of these cars as a fleet vehicle and unfortunately you get sideswiped. There might well be a sticker on the windscreen with the number of an accident management company or fleet manager.

“The person who takes the first notification call will run through a script. They’ll ask what happened and you might say “They clipped me and took off the wing mirror”, you’re unlikely to say, “It was an issue with their lane assist system”.

“If it’s a sub-£5,000 claim, an accident management company might well just authorise the repair and arrange it via one of their approved repair centres. Job done. This Mercedes announcement means interfering with that very efficient process.

“We will need to develop the process of sign-off and how the costs are charged back – of course, these things will come as we get deeper into the deployment of automated vehicles.

“We’ve recently clarified our cover for electric vehicles (EVs), looking at things like cables trailing and chargers blowing up. These are new eventualities, but it’s just a case of changing the wording to respond to new customer needs.”

Please note: a version of this article was first published by the Institute of the Motor Industry’s MotorPro magazine.

Industry letter to UK Prime Minister calls for primary legislation to seize global self-driving opportunity.

Businesses urge PM to add self-driving legislation to Queen’s Speech on 10 May

The top brass from 17 major UK businesses have jointly written to Prime Minister Boris Johnson calling for the Government to announce primary legislation for automated vehicles (AVs) in the Queen’s Speech on 10 May.

The broad coalition consists of representatives from the self-driving sector – AECOM, Aurrigo, Conigital, Wayve and Westfield Technology Group – the insurance sector – Admiral, the Association of British Insurers (ABI), AXA, Thatcham Research and Zego – the tech sector – Coadec, techUK and Virgin – the finance sector – firstminute capital and Eclipse Ventures – and supermarket groups ASDA and Ocado.

Legal framework for self-driving

Together, they call for a comprehensive legal framework for the safe and sustainable deployment of AVs, citing economic and societal benefits including improved road safety and reduced emissions.

Sky News concluded that: “The letter contained a veiled warning to ministers, including the business secretary, that time was running out to keep pace with rival regulatory frameworks.”

Notably, in Germany, 13,000km of motorway are already approved for Level 3 automated driving.

In the UK, the recent Highway Code announcement to move Britain “closer to a self-driving revolution” referred to a 2025 target for having a full regulatory framework in place.

The letter quotes statistics from the Connected Places Catapult – the government’s innovation agency for the transport industry – including “an export potential worth £10.9bn by 2035.”

Connected Places Catapult self-driving market forecast
Connected Places Catapult self-driving market forecast

Dougie Barnett, Director of Customer Risk Management at AXA UK, commented: “As one of the largest motor insurers, AXA is keen to support, promote and enable the take-up of automated technology on UK roads.

“AVs would provide significant societal benefits, including safer, cleaner and more accessible roads and, via the development of the technology, would support SMEs scaling up and subsequently levelling-up throughout the UK.

“However, the development of self-driving technology needs to be underpinned by a robust legal and regulatory framework, which prioritises the safety of all road users.

“With this letter, we are urging the Government to announce primary legislation for AVs, ensuring safety remains at the heart of their development and deployment as well as advancing the benefits they bring to society.” 

Self-driving legislation letter

The letter, dated 21 April 2022 and titled “Primary Legislation for Automated Vehicles”, was addressed to PM Boris Johnson and cc’d to Grant Shapps, Secretary of State for Transport, Trudy Harrison MP, Parliamentary Under Secretary of State at the Department for Transport (DfT) and Kwasi Kwarteng MP, Secretary of State at the Department of Business, Energy and Industrial Strategy (BEIS). The full text reads…

Dear Prime Minister,

We write from across industry to highlight the benefits of automated vehicles (AVs) to the UK and call on the Government to announce primary legislation for Automated Vehicles in the upcoming Queen’s Speech. We welcome the extensive work of the Law Commissions of England and Wales, and Scotland, who have collaborated with industry to propose a comprehensive legal framework for the safe and sustainable deployment of AVs.

The UK has a unique opportunity to be a global leader in the development and deployment of AVs, or self-driving vehicles. This technology is the most exciting innovation for transport in decades and has the potential to level-up every corner of the UK, improve the country’s productivity, create jobs, reduce emissions, improve road safety, and bolster opportunities everywhere.

The industry has the potential to unleash economic growth across the whole of the UK. The global market for AVs is predicted to be worth £650bn by 2035, of which the UK is estimated to gain £41.7bn, creating 49,000 highly skilled green jobs in 2035, and a further 23,000 jobs from AV technologies. There is also an export potential worth £10.9bn by 2035 [according to the Connected Places Catapult Market Forecast For Connected and Autonomous Vehicles].

Beyond the significant economic opportunity, this transition is essential to meet the Government’s Net Zero target. Self-driving electric vehicles could greatly reduce congestion, pollution and fuel consumption. In addition, they offer huge opportunities for an increase in safety and reduction in road deaths. Research shows that a shift to AVs could bring a 93% reduction in accidents by 2040. And since road accidents are the leading cause of death among those aged 15-29, many thousands of lives are likely to be saved.

We urge the Government to consider the benefit this can bring to people’s everyday lives across the country too. Automated mobility has the potential to better connect rural communities and provide people with better access to opportunities. For example, a visually impaired person who can’t drive or navigate public transport easily will be able to stay connected to their friends and family via a self-driving mobility service. AVs also mean goods, like our everyday groceries, can be moved around the country more efficiently and safely, supporting the green transition of the last-mile delivery market which is predicted to be worth £44bn by 2025.

It is crucial that we unlock this technology and create a safe regulatory framework for people across the UK. This is a critical year in the development of this technology, as we see more examples of AVs moving closer to deployment. The Government needs to introduce legislation this year, to ensure the UK remains a world leader in AVs, and continues attracting investment to the UK. We are aware that other countries are looking to legislate this year and we strongly recommend that the UK maintains its global stance in this industry.

We would be pleased to discuss any of the above and look forward to continued engagement with the Government as the regulatory framework for the safe use of self-driving technology evolves.

Yours Sincerely,

Claudio Gienal, CEO, AXA UK&I
Alex Kendall, Co-founder and CEO, Wayve
Josh Bayliss, CEO, Virgin Group
Prof. David Keene, CEO, Aurrigo
Cristina Nestares, UK CEO, Admiral
Matthew Avery, CEO, Thatcham Research
Julian Turner, CEO, Westfield Technology Group
Don Dhaliwal, CEO, Conigital Limited
Dom Hallas, Executive Director, Coadec
Tim Steiner OBE, CEO, Ocado Group
Brent Hoberman, Co-founder & Executive Chairman, firstminute capital
Sten Saar, CEO, Zego
Seth Winterroth, Partner, Eclipse Ventures
Andy Barker, COO, AECOM
Julian David, CEO, techUK
James Dalton, Director of General Insurance Policy, ABI
Simon Gregg, Senior Vice President – E-Commerce, ASDA

Looking ahead to conditionally automated driving, owners need to understand their car’s capabilities and their responsibilities

Even before Level 3 automated driving, car manuals are epic – longer than War and Peace

As cars get ever more connected and assisted driving features on the road to conditionally automated driving (see the updated SAE Levels), drivers are ever harder pushed to find all the right buttons.

Peter Stoker, Chief Engineer at Millbrook test track, made the point in our interview last year, saying: “If you buy a new car, you should read the manual, but how many people do? Especially with Covid, more cars are being delivered with minimal interaction – it’s a case of “there’s the key, where’s the station?”

Automated driving capabilities

Just last week, Steve Gooding, director of the RAC Foundation, had this to say about changes to The Highway Code related to self-driving: “Vehicle manufacturers and sellers will have a vital role to play in ensuring their customers fully appreciate the capabilities of the cars they buy and the rules that govern them.”

Quite so. Unfortunately, no matter how thorough the handover, settings get forgotten and drivers find themselves reaching for the good old owner’s handbook. Which makes this eye-catching research by Scrap Car Comparison all the more worrying.

The salvage specialist analysed the owner’s manuals for 100 of the UK’s most popular vehicles. It found that Audi has by far the heftiest, with the R8 being longest at 616,064 words, followed by the e-tron at 603,649 words, both, incredibly, three times longer than the Ford F-Series in third at 194,305 words.

Audi R8 has the longest manual according to Scrap Car Comparison
Audi R8 has the longest manual according to Scrap Car Comparison

To put that into perspective, at an average English silent reading speed of 238 words per minute, both the R8 and e-tron manuals take over 40 hours to complete, comparable to Tolstoy’s titanic tome, War and Peace.

At a mere 76,944 words, Harry Potter and the Philosopher’s Stone is well under half the size of the 163,225-word Ford Focus manual.

Top 10 longest vehicle manuals

Rank  Vehicle Make & Model  Manual Word Count  Average Time To Read  
1  Audi R8  616,064  43 hours 9 minutes  
2  Audi e-tron  603,649  42 hours 16 minutes  
3  Ford F-Series  194,305  13 hours 36 minutes  
4  Ram Pickup 1500  177,196  12 hours 24 minutes  
5  Audi A3  174,181  12 hours 11 minutes  
6  Volvo XC40  171,457  12 hours  
7  Volkswagen ID.4  168,060  11 hours 46 minutes  
8  Jeep Gladiator  163,857  11 hours 28 minutes  
9  Ford Focus  163,225  11 hours 25 minutes  
10  GMC Sierra  158,194  11 hours 4 minutes  

The shortest manuals list is dominated by two-wheelers, with the Vmoto Super Soco CPX electric scooter taking top spot, with only 2,834 words. Only three cars made the shortest manuals top 10 – the Range Rover Evoque, Nissan Leaf and VW Polo.

Range Rover Evoque has shortest car manual according to Scrap Car Comparison
Range Rover Evoque has shortest car manual according to Scrap Car Comparison

Top 10 shortest vehicle manuals

Rank  Vehicle Make & Model  Manual Word Count  Average Time To Read  
1  Vmoto Super Soco CPX2,834 11 minutes 
2  Honda NSC 110 Vision12,146 51 minutes 
3  Honda CB125F15,029 1 hour 3 minutes 
4  Range Rover Evoque16,526 1 hour 9 minutes 
5  Honda PCX12521,083 1 hour 28 minutes 
6  Nissan Leaf21,541 1 hour 30 minutes 
7  Yamaha NMAX 12522,152 1 hour 33 minutes 
8  Honda SHi 12523,438 1 hour 38 minutes 
9  Yamaha Ténéré 70028,685 2 hours 
10  VW Polo31,897 2 hours 14 minutes 

In addition to reading length, the study also used the Flesch-Kincaid Reading Ease Score to rank the accessibility of each manual.

It found the McLaren 765LT supercar manual to be the most difficult to digest, with a Flesch-Kincaid score of 44.3, requiring the equivalent of a college-level education to understand it.

McLaren 765LT manual the most difficult to digest according to Scrap Car Comparison
McLaren 765LT manual the most difficult to digest according to Scrap Car Comparison

The Vauxhall Crossland X and BMW 2 Series completed the top three for impenetrability, all with an 18+age suitability rating.

Top 10 hardest to read vehicle manuals

Rank Vehicle Make & Model Flesch-Kincaid Reading Ease Score Age Suitability (years) 
McLaren 765LT 44.3 18+ 
Vauxhall Crossland X 44.5 18+ 
BMW 2 Series 45.06 18+ 
Ferrari 812 Superfast 45.35 18+ 
Vauxhall Grandland X 45.64 18+ 
Range Rover Evoque 45.65 18+ 
Ford Ranger 45.83 18+ 
Honda Jazz 46.38 18+ 
Nissan Frontier 46.88 18+ 
10 Mercedes GLC 47.89 18+ 

At the more accessible end of the spectrum, Tesla’s Model Y was found to be the easiest manual to understand, scoring 76.92 on the Flesch-Kincaid scale, suitable for those aged 12-13 and above.

Tesla Model Y manual the easiest to digest according to Scrap Car Comparison
Tesla Model Y manual the easiest to digest according to Scrap Car Comparison

Toyota also did well, taking second and third spots with its Tacoma and Tundra manuals.

Top 10 easiest to read vehicle manuals

Rank Vehicle Make & Model Flesch-Kincaid Reading Ease Score Age Suitability (years) 
Tesla Model Y 76.92 12-13 years 
Toyota Tacoma 76.53 12-13 years 
Toyota Tundra 76.42 12-13 years 
Chevrolet Bolt EV 74.48 12-13 years 
Fiat 500 73.97 12-13 years 
Honda NSC 100 Vision 73.42 12-13 years 
Porsche 911 Turbo S 72.55 12-13 years 
Ford Mustang Mach-E 72.07 12-13 years 
Kia Sportage 69.86 13-15 years 
10 Audi Q2 69.82 13-15 years 

Dan Gick, Managing Director at Scrap Car Comparison, commented: “Vehicle owner manuals are a great resource which can teach you not only how to get the most out of your car, but also how to maintain your vehicle so that you can drive it safely. 

“While some seem to get it right in terms of reading length and accessibility, other manufacturers may need to think about whether they’re making their manuals overly complex.”