`
`U.S. Department
`Of Transportation
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`National Highway
`Traffic Safety Administration
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`PRELIMINARY REGULATORY EVALUATION
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`FMVSS No. 405
`EVENT DATA RECORDERS (EDRs)
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`Office of Regulatory Analysis and Evaluation
`National Center for Statistics and Analysis
`November 2012
`
`People Saving People
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`OWNER Ex. 2028, page 1
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`

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`TABLE OF CONTENTS
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`
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`EXECUTIVE SUMMARY ------------------------------------------------------- E-1
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`
`
`I.
`
`INTRODUCTION ------------------------------------------------------ I-1
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`
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`
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`II.
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`REQUIREMENTS OF THE PROPOSAL --------------------------- II-1
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`III. BENEFITS, COSTS, AND LEADTIME ----------------------------- III-1
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`
`IV. REGULATORY FLEXIBILITY ACT, ------------------------
`UNFUNDED MANDATES REFORM ACT,
`AND PAPERWORK REDUCTION ACT ANALYSIS
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`IV-1
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`
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`OWNER Ex. 2028, page 2
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`E - 1
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`EXECUTIVE SUMMARY
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`
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`This Preliminary Regulatory Evaluation (PRE) analyzes the potential impacts of a
`
`proposal to establish a Federal Motor Vehicle Safety Standard (FMVSS) No. 405, Event
`
`Data Recorders. The proposed rule would require all light vehicles with a gross vehicle
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`weight rating (GVWR) of 3,855 kilograms (8,500 pounds) or less and an unloaded
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`vehicle weight of 2,495 kilograms (5,500 pounds) or less to be equipped with EDRs that
`
`meets the data elements, data capture and format, data retrieval, and data crash
`
`survivability of 49 CFR Part 563, Event Data Recorders (Part 563).
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`
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`Part 563 was established on August 2006. It specifies the definition and performance
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`requirements of Event Data Recorders (EDRs) including the standardization of crash data
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`elements, data collection and accuracy, survivability, and retrievability of the data. The
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`compliance date for Part 563 was September 1, 2012.1
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`
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`Proposal
`
`Essentially, the proposal would mandate EDRs for all vehicles with a GVWR no greater
`
`than 3,855 kilograms (kg; 8,500 pounds) and an unloaded vehicle weight not greater than
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`2,495 kg (5,500 pounds) (hereafter, applicable vehicles). Through FMVSS No. 405,
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`compliance to specific provisions of Part 563 would be subject to the recall and remedy
`
`provisions of 49 U.S.C. §§ 30118 and 30120. Specifically, Part 563 requires an EDR to:
`
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`1 71 FR 51043, August 28, 2006. Amended in January 14, 2008 (73 FR 2179) and corrected on February
`13, 2008 (73 FR 8408). Further amended on August 5, 2011 (76 FR 47478). Further amended 77 FR 47552
`(August 9, 2012).
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`OWNER Ex. 2028, page 3
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`E - 2
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`a. Record the 15 essential data elements specified in Table 1 of Part 563
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`b. Record up to 30 additional data elements if the vehicle is equipped to record these
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`elements in Table II of Part 563
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`c. Function after full-scale vehicle crash tests specified in FMVSS Nos. 208 and
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`214, and
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`d. Have the capacity to record and lock data from a crash where the frontal air bag
`
`deploys or where the side air bag deploys and lateral delta v is captured.
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`
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`In addition, Part 563 requires vehicle manufacturers to make a retrieval tool for the EDR
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`information commercially available and to include a standardized statement in the
`
`owner’s manual indicating that the vehicle is equipped with an EDR and describing its
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`purposes.
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`
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`The proposal does not modify any of the Part 563 data elements, data capture and format
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`requirements, data retrieval specifications, or data survivability and crash test
`
`requirements. However, by September 1, 2014, the proposed new FMVSS No. 405
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`would require manufacturers of all applicable vehicles to install EDRs in compliance
`
`with Part 563.
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`
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`Technological Feasibility
`
`The agency estimated that about 91.6 percent of 2010 model year (MY) applicable
`
`vehicles are equipped with EDRs. The remaining 8.4 percent (1.2 million) of the light
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`vehicles, mostly high-end luxury brand vehicles, are not equipped with an EDR.
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`OWNER Ex. 2028, page 4
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`E - 3
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`However, these vehicles generally have the state-of-the-art electronic systems, safety
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`technologies, and vehicle communication network. Therefore, the proposal is expected
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`not to require significant redesign on their sensing technologies, software, electronic
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`systems, and in-vehicle communication systems.
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`
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`Benefits
`
`The proposal would close the EDR installation gap and allow the agency and safety
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`researchers to comprehensively understand ever more complex vehicles’ electronic
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`systems and to identify critical issues relating to the performance of safety devices.
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`Furthermore, by requiring standardized information, such as crash severity, air bag
`
`deployment status and safety belt use, to be recorded on all applicable vehicles, the
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`proposal may improve data availability to advanced automatic crash notification (AACN)
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`systems, which evaluate the need for and the level of emergency response to traffic
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`crashes.
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`
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`Mandating that all light vehicles required to have frontal air bags be equipped with EDRs
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`will enable the agency to use EDR data in assessing the performance of particular vehicle
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`models in determining the need for conducting a safety defect investigation that may lead
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`to a recall of the vehicle for repair or replacement of problem parts or systems.
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`Additionally, many of the vehicles anticipated to continue to lack EDRs, absent a
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`mandate, are high end vehicles that have advanced safety technologies, including
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`advanced collision avoidance technologies. The proposal thus will further facilitate crash
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`investigations and research, which will enable the development of safer vehicles.
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`OWNER Ex. 2028, page 5
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`E - 4
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`Costs
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`The estimated annual total costs associated with the proposal would be $26.4 million
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`(2010 dollars) which is measured from a baseline of 91.6 percent EDR installation to 100
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`percent installation. Assuming 16.5 million light vehicles with a GVWR less than 4,535
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`kilograms (10,000 pounds) sold per year and 15.7 million were applicable vehicles, 8.4
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`percent of these without EDRs amounted to 1.32 million vehicles annually that would be
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`impacted by the proposal. This cost reflects hardware for housing the recorded data, the
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`need for technology improvements, as well as assembly costs, compliance costs, and
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`paperwork maintenance costs2 for those 1.32 million vehicles. The cost per affected
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`vehicle is estimated to be $20.
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`
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`Alternatives
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`No other alternatives were examined in the PRE. The cost of the proposal is less than
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`$136 million. Thus, the proposed rule is not subject to the requirements of section 205 of
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`the Unfunded Mandates Reform Act of 1995 that requires the agency to examine
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`significant alternatives if a rule would result in the expenditure by State, local, or tribal
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`governments, and private section, in the aggregate, of more than $136 million (2010 $)
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`annually.
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`
`
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`2 These paperwork maintenance costs consist of the costs to modify the owner’s manual with the required
`statement specified in 49 CFR 563.11.
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`OWNER Ex. 2028, page 6
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`E - 5
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`Leadtime
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`The compliance date of the proposal is September 1, 2014. Multi-stage vehicle
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`manufacturers and alterers must comply with the proposal beginning on September 1,
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`2015. This leadtime should enable vehicle manufacturers of the 8.4 percent of fleet that
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`are not equipped with an EDR have time to make the necessary design changes as they
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`introduce new make/models and minimize the compliance costs. The proposed lead time
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`should also address the practical concerns of many new electric and hybrid electric
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`manufacturers who are entering the market and who may not have been planning to
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`install EDRs.
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`OWNER Ex. 2028, page 7
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`I - 1
`
`CHAPTER I. INTRODUCTION
`
`
`This preliminary regulatory evaluation (PRE) accompanies the National Highway Traffic
`
`Safety Administration’s (NHTSA) Notice of Proposed Rulemaking (NPRM) to establish
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`a Federal Motor Vehicle Safety Standard (FMVSS) No. 405, Event Data Recorders
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`(EDRs). The proposed rule would require all applicable light vehicles manufactured on
`
`or after September 1, 2014 to be equipped with an EDR. Specifically, FMVSS No. 405
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`would require compliance with the crash test performance and survivability requirements
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`in Part 563. This would mean that the data elements required by the regulation, with
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`certain exceptions, must be recorded in the format specified by the regulation, exist at the
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`completion of the crash test, and be retrievable by the methodology specified by the
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`vehicle manufacturer. As part of a FMVSS, these requirements would be subject to the
`
`recall and remedy provisions of 49 U.S.C. §§ 30118 and 30120. These EDRs would also
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`need to comply with any of the remaining provisions under Part 563. The covered
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`vehicles are all light vehicles with a GVWR no greater than 3,855 kg (8,500 pounds) and
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`an unloaded vehicle weight of 2,495 kg (5,500 pounds) or less. Specialty vehicles are
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`excluded. EDRs were typically recording information from the air bag control module of
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`passenger vehicles. Therefore, Part 563 limited its applicability to vehicles that are
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`required to be equipped with air bags. These vehicles are called applicable vehicles
`
`hereafter.
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`
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`Background
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`On August 28, 2006, the agency established Part 563 which standardizes performance
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`requirements for the accuracy, collection, storage, survivability, and retrievability of
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`OWNER Ex. 2028, page 8
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`I - 2
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`onboard motor vehicle crash event data in all applicable vehicles voluntarily equipped
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`with EDRs.3 Later, on January 14, 2008, the agency amended Part 563 to make several
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`technical changes to the regulatory text and to set a later compliance date of September 1,
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`2012.4 The new compliance date helped manufacturers to avoid incurring significant
`
`redesign costs for EDR system architectures outside of the normal product cycle.
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`
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`EDR as specified in Part 563 is a function or device installed in a motor vehicle to record
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`technical vehicle and occupant information for a brief period of time (i.e., a few seconds)
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`before and during a crash for the purpose of monitoring and assessing vehicle safety
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`system performance. EDRs have been available in various forms in certain vehicles since
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`the 1970s to gather real-world performance data for various vehicle safety systems. Most
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`commonly, EDRs were incorporated into the vehicle air bag control systems to monitor
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`the air bag performance.
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`
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`Since 1991, the agency has been assessing the potential use of real-world EDR crash data
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`for improving vehicle safety and crash data collection. In 1998, the agency sponsored
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`two EDR working groups to identify crash data elements that can be recorded and be
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`used to support the agency’s mission of reducing highway deaths, injury, and societal
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`costs and to examine critical issues relating to the implementation of EDRs. The working
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`groups were comprised of members from industry, academia, and other government
`
`
`3 71 FR 50998, 51043 (August 28, 2006), amended 73 FR 2168, 2179 (January 14, 2008), corrected 73 FR
`8408 (February 13, 2008), further amended on August 5, 2011 (76 FR 47478), further amended 77 FR
`47552 (August 9, 2012).
`
`4 73 FR 2168 (January 14, 2008). Vehicles that are manufactured in two or more stages, or that are altered
`after having been previously certified to the Federal Motor Vehicle Safety Standards (FMVSS) have a
`compliance date of September 1, 2013.
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`OWNER Ex. 2028, page 9
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`I - 3
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`organizations. In August 2001, the first EDR Working Group published a final report on
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`the results of its deliberations.5 In May 2002, the second working group, the NHTSA
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`Truck & Bus EDR Working Group, published its final report.6 NHTSA also developed a
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`website for highway-based EDRs.7 These efforts culminated in establishing Part 563.
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`
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`EDR Installation
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`In 2006 when promulgating the Part 563 final rule, the agency estimated that 64 percent
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`of 2005 model year (MY) applicable vehicles were equipped with some forms of EDRs.
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`In recent years, EDR technologies have advanced significantly and more manufacturers
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`have voluntarily equipped their vehicles with EDRs. Based on the industry’s response to
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`the agency’s New Car Assessment Program (NCAP) survey on 2010 MY vehicles, 91.6
`
`percent of the 2010 MY applicable vehicles were already equipped with EDRs. This
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`average was derived from the manufacturers’ reported EDR installations for 2010 MY
`
`light vehicles and weighted by their corresponding projected vehicle sales. Table I-1 lists
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`the industry’s response on their projected 2010 MY vehicle sales, EDR installation rates,
`
`and the derived weighted overall EDR installation rate for the applicable 2010 MY fleet.
`
`
`
`
`
`
`
`
`
`
`5 Event Data Recorders, Summary of Findings by the NHTSA EDR Working Group, August 2001, Final
`Report, Docket No. NHTSA-99-5218-9
`
`6 Event Data Recorders, Summary of Findings by the NHTSA EDR Working Group, May 2002, Final
`Report, Volume II, Supplemental Findings for Trucks, Motorcoaches, and School Buses, Docket No.
`NHTSA-2000-7699-6
`
`7 The web address is “http://www.nhtsa.gov/EDR”
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`
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`OWNER Ex. 2028, page 10
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`I - 4
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`Reasons for the Proposal
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`As shown in Table I-1, approximately 8.4 percent applicable MY 2010 vehicles did not
`
`incorporate EDRs. The majority of these vehicles were clustered in a special segment
`
`(i.e., luxury brands) of market. These vehicles are more likely than the typical vehicles to
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`be equipped with advanced safety features and electronic systems. Additionally, during
`
`the investigation of unintended acceleration and pedal entrapment allegations relating to
`
`certain Toyota models, the agency found that the EDR data was helpful. EDR data
`
`allowed the agency (as well as vehicle manufacturers) to better understand driver-vehicle
`
`interaction and crash causation, to effectively identify safety defects in the vehicle design
`
`and/or performance, and to resolve conflicting information the agency received. In
`
`addition, the agency has incorporated EDRs into the agency’s real-world database
`
`whenever EDR data were obtainable [such as the National Automotive Sampling System
`
`– Crashworthiness Data System (NASS-CDS)]. The incorporation of the EDRs has
`
`improved crash data quality and influenced research for safer vehicles. Furthermore, the
`
`agency also acknowledges the potential of EDR data for advancement of AACN systems
`
`and emergency management service providers. Therefore, the agency proposes to
`
`mandate EDRs for all applicable vehicles. In addition to the general benefits of EDR
`
`data, the inclusion of the specific segment of vehicles that are not expected to be
`
`equipped with EDRs would allow a more comprehensive evaluation of vehicle safety and
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`broadly address highway safety issues. Mandating EDRs would also aid the agency in
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`assessing the performance of all applicable vehicles in determining the need for, or
`
`conducting, safety defect investigations.
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`
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`OWNER Ex. 2028, page 11
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`I - 5
`
`Table I-1
`Estimate of the Number of EDRs in 2010 MY Light Vehicles with
`A GVWR of 3,855 Kilograms (8,500 Pounds) or Less
`
`Manufacturers
`
`Sales
`
`Percent of Sales
`
`% With EDRs
`
`# of EDRs
`
`Audi
`
`BMW
`
`Chrysler
`
`Daimler AG
`
`Ford Motor Co.
`
`General Motors
`
`Honda
`
`Hyundai
`
`Jaguar
`
`KIA
`
`85,735
`
`342,825
`
`944,876
`
`113,940
`
`1,613,410
`
`2,536,952
`
`1,019,650
`
`456,000
`
`20,900
`
`302,000
`
`0.7%
`
`2.9%
`
`8.1%
`
`1.0%
`
`13.8%
`
`21.7%
`
`8.7%
`
`3.9%
`
`0.2%
`
`2.6%
`
`0.0%
`
`0.0%
`
`99.9%
`
`0.0%
`
`100.0%
`
`100.0%
`
`100.0%
`
`100.0%
`
`100.0%
`
`100.0%
`
`0
`
`0
`
`943,931
`
`0
`
`1,613,410
`
`2,536,952
`
`1,019,650
`
`456,000
`
`20,900
`
`302,000
`
`26,100
`
`Land Rover
`
`Mazda
`
`Mitsubishi
`
`Nissan
`
`Porsche
`
`Subaru
`
`Suzuki
`
`Toyota
`
`Volkswagen
`
`Volvo
`
`26,100
`
`220,000
`
`64,817
`
`778,890
`
`24,140
`
`216,000
`
`37,603
`
`2,606,280
`
`195,960
`
`66,953
`
`0.2%
`
`1.9%
`
`0.6%
`
`6.7%
`
`0.2%
`
`1.9%
`
`0.3%
`
`22.3%
`
`1.7%
`
`0.6%
`
`100.0%
`
`100.0%
`
`100.0%
`
`100.0%
`
`0.0%
`
`0.0%
`
`100.0%
`
`100.0%
`
`0.0%
`
`100.0%
`
`220,000
`
`64,817
`
`778,890
`
`0
`
`0
`
`37,603
`
`2,606,280
`
`0
`
`66,953
`
`
`11,673,031
`Total
`Source: NHTSA’s NCAP Industry Survey for 2010 MY light vehicles
`
`91.6%
`
`10,693,486
`
`
`
`
`
`Organization of the Remaining Analysis
`
`Chapter II of this PRE discusses the proposal. Chapter III discusses the benefits, cost,
`
`and leadtime of the proposal. Finally, Chapter IV examines the impacts of the proposal
`
`on small business entities.
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`OWNER Ex. 2028, page 12
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`
`
`II - 1
`
`CHAPTER II. REQUIREMENTS OF THE PROPOSAL
`
`
`
`The proposal would establish FMVSS No. 405, Event Data Recorders, requiring
`
`applicable vehicles to be equipped with an EDR by September 1, 2014. Applicable
`
`vehicles include passenger cars, multipurpose passenger vehicles, light trucks, and vans
`
`with a GVWR of 3,855 kilograms (8,500 pounds) or less and an unloaded vehicle weight
`
`of 2,495 kg (5,500 pounds) or less with the exception of walk-in type vans or vehicles
`
`that are designated to be sold exclusively to the U.S. Postal Service.
`
`
`
`
`
`Basically, the proposed FMVSS No. 405 would require data elements of Table I of Part
`
`563, with certain exceptions, to be recorded in the format specified by the regulation,
`
`exist at the completion of the crash test, and be retrievable by the methodology specified
`
`by the vehicle manufacturer. As part of a FMVSS, these requirements would be subject
`
`to the recall and remedy provisions of 49 U.S.C. §§ 30118 and 30120. The remainder of
`
`Part 563 will remain a voluntary regulation. The proposal does not modify any of the
`
`Part 563 data elements, data capture and format requirements, data retrieval
`
`specifications, or data survivability and crash test requirements.
`
`
`
`In summary, Part 563 requires:
`
`1) EDRs to record 15 essential data elements with a standardized data format
`
`including sampling rate, recording time duration, range, accuracy, resolution, and
`
`filter class for each event (Table I of Part 563),
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`OWNER Ex. 2028, page 13
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`II - 2
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`2) EDRs to record up to 30 additional data elements with a standardized data format
`
`(including sampling rate, recording time duration, range, accuracy, resolution, and
`
`filter class for each event), if the vehicle is equipped to record these elements8
`
`(Table II of Part 563),
`
`3) EDRs to have the capacity to record and lock data from a crash where the frontal
`
`air bag deploys or where the side air bag deploys and lateral delta v is captured
`
`4) EDRs to have the capacity to record up to two events other than when frontal or
`
`side air bags deploy.
`
`5) EDRs to function during and after the full-scale vehicle crash tests specified in the
`
`FMVSS Nos. 208 and 214. The data elements must be retrievable for at least 10
`
`days after the crash tests,
`
`6) vehicle manufacturers to ensure the availability of download tools for the EDR
`
`data, and
`
`7) vehicle manufacturers to include a standardized statement in the owner’s manual
`
`indicating that the vehicle is equipped with an EDR and describing the purposes
`
`of EDRs.
`
`
`
`
`
`
`Table II-1 in this document lists the 15 data elements and their corresponding format
`
`requirements including record time, sampling rate, data range, accuracy, and data
`
`resolution. Table II-2 in this document lists the 30 optional data elements to be recorded
`
`under specified conditions9 along with their data formats. These additional data elements
`
`
`8 “If recorded” means if the data are recorded in non-volatile memory for the purpose of subsequent
`downloading.
`
`9 If the data element is recorded or the vehicle is equipped with the specific safety device
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`OWNER Ex. 2028, page 14
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`II - 3
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`are required if vehicles were equipped to record these elements. Two of the data
`
`elements “Frontal air bag deployment, time to nth stage, driver” and “Frontal air bag
`
`deployment, time to nth stage, right front passenger” are required if vehicles were
`
`equipped with frontal air bags with a multi-stage inflator and the EDR optionally records
`
`the data. An EDR is required to record and lock these elements when a frontal air bag
`
`deploys or when the side air bag deploys and lateral delta v is captured. For other events,
`
`where the data is not locked, data from up to two events is captured and recorded.
`
`
`
`
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`OWNER Ex. 2028, page 15
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`N.A.
`
`-100 to 100 km/h + 10%
`
`1 km/h
`
`N.A.
`
`+ 3 ms
`
`2.5 ms
`
`0 – 300 ms or
`0 to end of event
`plus 30 ms,
`whichever is shorter
`0- 200 km/h
`
`0 – 100%
`
`On/off
`
`+ 1 km/h
`
`+ 5%
`
`N.A.
`
`2/s
`
`2/s
`
`2/s
`
`0 – 250 ms or
`0 to end of event
`plus 30 ms,
`whichever is shorter
`0 – 300 ms or
`0 to end of event
`plus 30 ms,
`whichever is shorter
`0 – 300 ms or
`0 to end of event
`plus 30 ms,
`whichever is shorter
`-5.0 to 0 s
`
`-5.0 to 0 s
`
`-5.0 to 0 s
`
`At time of
`download
`-1.0 s
`
`Maximum delta-V,
`Longitudinal
`
`Time, Maximum delta-V,
`Longitudinal
`
`
`
`
`Item
`#
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`II - 4
`
`
`Data Elements
`Delta-V, Longitudinal
`
`Table II-1
`Required Essential Data Elements and Formats
`
`Recording Time* Sampling
`
`Accuracy
`Rate
`Range
`100/s
`-100 to 100 km/h + 10%
`
`
`Resolution
`1 km/h
`
`Speed, vehicle indicated
`
`Engine throttle, % full
`(accelerator pedal % full)
`Service brake, on/off
`
`Ignition cycle, crash
`
`Ignition cycle, download
`
`Safety belt status, driver
`
`Frontal air bag warning
`lamp
`
`Frontal air bag
`deployment time, Driver
`(1st stage, in case of
`multi-stage air bags)
`Frontal air bag
`deployment time, RFP
`(1st stage, in case of
`multi-stage air bags)
`Multi-event, number of
`events (1 or 2)
`
`Time from event 1 to 2
`
`Complete file recorded
`(yes or no)
`
`* Relative to time zero
`s: second; ms: millisecond; km/h: kilometer per hour; RFP: right front outboard passenger; N.A.: not
`applicable
`
`-1.0 s
`
`N.A.
`
`0 – 60,000
`
`+ 1 cycle
`
`N.A.
`
`0 – 60,000
`
`+ 1 cycle
`
`N.A.
`
`On/off
`
`-1.0 s
`
`N.A.
`
`On/off
`
`N.A.
`
`N.A.
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+2 ms
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+2 ms
`
`Event
`
`N.A.
`
`1, 2
`
`As needed
`
`N.A.
`
`0 - 5.0 s
`
`Following Other
`Data
`
`N.A.
`
`Yes/no
`
`N.A.
`
`0.1 s
`
`N.A.
`
`1 km/h
`
`1%
`
`On/off
`
`1 cycle
`
`1 cycle
`
`On/off
`
`On/off
`
`1 ms
`
`1 ms
`
`1, 2
`
`0.1 s
`
`Yes/no
`
`OWNER Ex. 2028, page 16
`
`

`

`
`
`II - 5
`
`Table II-2
`Required Additional Data Elements and Formats Under Specified Conditions*
`
`Item
`#
`1
`
`
`Data Elements
`Lateral acceleration
`
`Recording
`Time**
`N.A.
`
`Sampling
`Rate
`N.A.
`
`
`Range
`At option of
`manufacturer
`At option of
`manufacturer
`At option of
`manufacturer
`– 100 to 100
`km/h
`
`
`Accuracy2
`At option of
`manufacturer
`At option of
`manufacturer
`At option of
`manufacturer
`+10%
`
`
`Resolution
`At option of
`manufacturer
`At option of
`manufacturer
`At option of
`manufacturer
`1 km/h
`
`+ 3 ms
`
`+ 3 ms
`
`0 – 300 ms or
`0 to end of
`event plus 30
`ms, whichever
`is shorter
`0 – 300 ms or
`0 to end of
`event plus 30
`ms, whichever
`is shorter
`0 – 10,000
`rpm
`- 1,080 0 to
`1,080 0
`On/off
`On/off/
`engaged
`250 0 CW to
`250 0 CCW
`N.A.
`On/off
`On/off/auto N.A.
`
`+ 100 rpm
`
`+ 10 0
`
`N.A.
`N.A.
`
`+ 5 %
`
`2.5 ms
`
`2.5 ms
`
`100 rpm
`
`10 0
`
`On/off
`On/off/
`engaged
`+ 1%
`
`On/off
`On/off/auto
`
`Time, maximum delta-V,
`Lateral
`
`Time, maximum delta-V,
`resultant
`
`Engine RPM
`
`ABS activity
`
`Stability control
`
`Steering input
`Safety belt status, RFP
`Frontal air bag suppression
`switch status, RFP
`Frontal air bag deployment,
`time to Nth stage, Driver1
`Frontal air bag deployment,
`time to Nth stage, RFP1
`Frontal air bag deployment, Nth
`stage disposal, Driver1
`Frontal air bag deployment, Nth
`stage disposal, RFP1
`Side air bag deployment time,
`Driver
`
`Vehicle roll angle (degree)
`
`-1.0 up to 5 s 10/s
`
`-5.0 to 0 s
`-5.0 to 0 s
`
`2/s
`2/s.
`
`-5.0 to 0 s
`
`2/s
`
`-1.0 s
`-1.0 s
`
`N.A.
`N.A.
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+ 2 ms
`
`1 ms
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+ 2 ms
`
`1 ms
`
`Event
`
`N.A.
`
`Yes/no
`
`N.A.
`
`Yes/no
`
`Event
`
`N.A.
`
`Yes/no
`
`N.A.
`
`Yes/no
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+ 2 ms
`
`1 ms
`
`5
`
`Maximum delta-V, Lateral
`
`N.A.
`
`– 100 to 100
`km/h h
`
`+10%
`
`1 km/h
`
`Longitudinal acceleration
`
`N.A.
`
`Normal acceleration
`
`N.A.
`
`Delta-V, Lateral
`
`N.A.
`
`N.A.
`
`100/s
`
`N.A.
`
`N.A.
`
`2/s
`
`0 – 250 ms or
`0 to end of
`event plus 30
`ms, whichever
`is shorter
`0 – 300 ms or
`0 to end of
`event plus 30
`ms, whichever
`is shorter
`0 – 300 ms or
`0 to end of
`event plus 30
`ms, whichever
`is shorter
`0 – 300 ms or
`0 to end of
`event plus 30
`ms, whichever
`is shorter
`-5.0 to 0 s
`
`2
`
`3
`
`4
`
`6
`
`7
`
`8
`
`9
`
`10
`11
`
`12
`
`13
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`OWNER Ex. 2028, page 17
`
`

`

`II - 6
`
`Recording
`Time**
`Event
`
`Sampling
`Rate
`N.A.
`
`
`Range
`0 – 250 ms
`
`
`Accuracy2
`+ 2 ms
`
`
`Resolution
`1 ms
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+ 2 ms
`
`1 ms
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+ 2 ms
`
`1 ms
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+ 2 ms
`
`1 ms
`
`Event
`
`N.A.
`
`0 – 250 ms
`
`+ 2 ms
`
`1 ms
`
`
`
`Item
`#
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`26
`27
`
`
`Data Elements
`Side air bag deployment time,
`RFP
`Side curtain/tube air bag
`deployment time, Driver
`Side curtain/tube air bag
`deployment time, Right side
`Pretensioner deployment time,
`Driver
`Pretension deployment time,
`RFP
`Seat track position, Driver
`Seat track position, RFP
`Occupant size classification,
`Driver
`
`28
`
`29
`
`30
`
`Occupant size classification,
`RFP
`Out of
`Occupant position
`position
`classification, Driver
`Out of
`Occupant position
`position
`classification, RFP
`* If the specific data element was recorded or if the vehicle is equipped with the specific safety devise
`**Relative to time zero
`s: second; ms: millisecond; km/h: kilometer per hour; RFP: right front outboard passenger; N.A.: not
`applicable
`1 List this element n-1 times, once for each stage of a multi-stage air bag system.
`2Accuracy requirement only applies within the range of the physical sensor. For vehicles manufactured
`after September 1, 2014, if measurements captured by a sensor exceed the design range of the sensor, the
`reported element must indicate when the measurement first exceeded the design range of the sensor.
`
`-1.0 s
`-1.0 s
`-1.0 s
`
`N.A.
`N.A.
`N.A.
`
`-1.0 s
`
`-1.0 s
`
`N.A.
`
`N.A.
`
`Yes/no
`Yes/no
`5th percentile
`female or
`larger
`Child
`
`N.A.
`N.A.
`N.A.
`
`Yes/no
`Yes/no
`Yes/no
`
`N.A.
`
`Yes/no
`
`N.A.
`
`Yes/no
`
`-1.0 s
`
`N.A.
`
`N.A.
`
`Yes/no
`
`OWNER Ex. 2028, page 18
`
`

`

`
`
`III - 1
`
`CHAPTER III. BENEFITS, COSTS, AND LEADTIME
`
`
`
`This chapter estimates the costs of the proposal and discusses benefits and leadtime. As
`
`described in Chapter I, Introduction, the agency estimated that 91.6 of applicable 2010
`
`MY vehicles already were equipped with EDRs. Assuming that the percentage of
`
`applicable vehicles equipped with EDRs would remain at this level without a mandate,
`
`the cost of the proposal thus is measured from the 91.6 percent (baseline) to the 100
`
`percent of all applicable light vehicles to be equipped with EDRs.
`
`
`
`An EDR is required to store certain event-related information (e.g., air bag deployment)
`
`before or during a crash. The stored data are extremely valuable for crash investigation,
`
`defect identification and verification, safety research, and developing emergency
`
`response systems. Although the agency believes that the proposal will improve vehicle
`
`safety, the safety benefits are difficult to quantify. Therefore, the benefits of this
`
`proposal are discussed qualitatively.
`
`
`
`Benefits
`
`
`Mandating the installation of EDRs in light vehicles required to have frontal air bags
`
`would provide for a standardized set of EDR data elements and formats throughout most
`
`of the light vehicle fleet rather than on just those manufacturers who chose to voluntarily
`
`install EDRs. This would expand and, therefore, potentially enhance the utilization of the
`
`recorded information and lead to further improvements in the safety of current and future
`
`motor vehicles.
`
`OWNER Ex. 2028, page 19
`
`

`

`
`
`III - 2
`
`Although the benefits of this NPRM derive from expansion of EDR coverage, we will
`
`briefly review the general benefits related to EDRs. Part 563 standardizes data recorded
`
`by voluntarily-installed EDRs across all applicable vehicles and requires the development
`
`of data access tools. This mandate is expected to enhance the utilization of the recorded
`
`information in research and crash investigation, improve the quality of real-world crash
`
`data, and enhance the injury severity prediction algorithms used by the AACN systems
`
`and emergency medical services (EMS).
`
`
`
`Since the establishment of Part 563 in 2006, an increasing percentage of vehicles have
`
`incorporated the EDR technology from 64 percent for 2005 MY vehicles to 91.6 percent
`
`for the 2010 MY vehicles. In the mean time, automotive safety researchers, vehicle
`
`manufacturers, AACN and EMS providers, government agencies, and other members of
`
`the safety community are increasingly using the EDR data to improve highway/vehicle
`
`safety and to reduce injury severity outcomes.
`
`
`
`EDR data improve crash investigation and crash data collection quality to assist safety
`
`researchers, vehicle manufacturers, and the agency to understand vehicle crashes better
`
`and more precisely. While crash investigators gather insightful information about the
`
`dynamics of crashes, some of these parameters cannot be determined (such as anti-lock
`
`braking system or electronic stability control functioning status) or cannot be as
`
`accurately measured (such as the change in velocity) by traditional post-crash
`
`investigation procedures such as visually examining and evaluating physical evidence,
`
`e.g., the crash-involved vehicles and skid marks. Further, some vehicle crash dynamics
`
`OWNER Ex. 2028, page 20
`
`

`

`
`
`III - 3
`
`related to rollover (such as roll angle, roll rate and normal acceleration) cannot be
`
`effectively estimated by crash investigators post-crash. Data collected by the EDR can
`
`provide a direct means for measuring these needed crash parameters.
`
`
`
`Moreover, the agency has increasingly incorporated EDR data into the agency-collected
`
`real-world crash databases (e.g., NASS-CDS). EDR data elements such as delta v and
`
`belt use status have been used to cross-verify those recorded in the NASS-CDS. EDR
`
`recordings of advanced restraint systems such as advanced air bags have been used to
`
`examine the performance of these systems.
`
`
`
`Based on these experiences, the agency agrees with the conclusion from a 2005 report
`
`published by the National Academies that EDR data can improve the accuracy of real-
`
`world crash databases and its long term benefit is its influence on vehicle safety (NCHRP
`
`report).10
`
`
`
`
`
`Furthermore, the advent of AACN and its use by EMS providers is dependent upon the
`
`standardized collection of crash information in the vehicle and the availability of critical
`
`crash information such as crash severity (delta v), seat belt use status, air bag deployment
`
`status, etc. Thus, EDRs will enable and further enhance the development and usefulness
`
`of AACNs by EMS providers.
`
`
`
`
`10 NCHRP Project 17-24, “Use of Event Data Recorder (EDR) Technology for Highway Crash Data
`Analysis.”, Transportation Research Board of the National Academies
`
`
`OWNER Ex. 2028, page 21
`
`

`

`
`
`III - 4
`
`In addition to the general benefits derived from EDR installation, there are benefits
`
`specific to this NPRM to mandate EDRs. Specifically, EDR data have provided the
`
`agency and manufacturers valuable insight during the investigation of unintended
`
`acceleration and the sticking and pedal entrapments11 related to certain Toyota vehicles
`
`with an electronic throttle control. The EDR data, supplemented with follow-up
`
`conversations with the complainant and crash scene evidence, provided objective
`
`information regarding the pre-crash operation of the vehicles. The objective assessment
`
`enabled the agency and manufacturers to identify the defect, to resolve conflicting
`
`information, and to verify the validity of complaints.12 EDR data can have significant
`
`value in aiding the agency in assessing the performance of particular vehicle models in
`
`determining the need for, or conducting, a safety defect investigation that