N a t i o N a l H i g H w a y t r a f f i c S a f e t y a d m i N i S t r a t i o N
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`OWNER Ex. 2031, page 1
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`This publication is distributed by the U.S. Department of
`Transportation, National Highway Traffic Safety Administration,
`in the interest of information exchange. The opinions, findings,
`and conclusions expressed in this publication are those of the
`authors and not necessarily those of the Department of
`Transportation or
`the National Highway Traffic Safety
`Administration. The United States Government assumes no
`liability
`for
`its contents or use
`thereof.
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`If
`trade or
`manufacturers' names or products are mentioned, it is because
`they are considered essential to the object of the publication
`and should not be construed as an endorsement. The United
`States Government does not endorse products or
`manufacturers.
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`OWNER Ex. 2031, page 2
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`1. Report No.
`DOT HS 811 040
`4. Title and Subtitle
`Technology Applications for Traffic Safety Programs: A Primer
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`2. Government Accession No.
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`7. Author(s)
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`9. Performing Organization Name and Address
`United States Department of Transportation
`Volpe National Transportation Systems Center
`Research and Innovative Technology Administration
`55 Broadway
`Cambridge, MA 02142
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`
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`3. Recipient's Catalog No.
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`5. Report Date
`September 2008
`6. Performing Organization Code
`RTV-3B
`8. Performing Organization Report No.
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`10. Work Unit No. (TRAIS)
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`11. Contract or Grant No.
`HS-31
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`13. Type of Report and Period Covered
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`14. Sponsoring Agency Code
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`12. Sponsoring Agency Name and Address
`
`National Highway Traffic Safety Administration
`1200 New Jersey Avenue SE.
`Washington, DC 20590
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`15. Supplementary Notes
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`16. Abstract
`This document explores how emerging digital and communications technology can advance safety on the
`Nation’s highways. The range of technology described in this report is available or will be available in the near
`future to improve traffic safety. As new traffic safety applications become widespread and implementation costs
`decrease, there could be a network of advanced systems that improve traffic safety by providing information and
`services to drivers, traffic operations agencies, emergency services personnel, and law enforcement
`professionals. Discussions in this report include a general overview of traffic safety technology; the use of
`technology to reach traffic safety goals using the framework of the “Four E’s” of engineering, enforcement,
`education, and EMS; and the technical and non-technical challenges for these technology applications.
`18. Distribution Statement
`22. Key Words
`
`Technology, Haddon Matrix, Automated Crash
`Notification, Telematics, Sensors, Human-Machine
`Interface
`19. Security Classif.(of this report)
` Unclassified
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`20. Security Classif.(of this page)
` Unclassified
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`21. No. of Pages
` 58
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`22. Price
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`Table of Contents
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`Executive Summary........................................................................................................vii
`Introduction....................................................................................................................... 1
`The Need for New Traffic Safety Technologies.......................................................................... 1
`Organization of the Report .......................................................................................................... 1
`Traffic Safety Trends........................................................................................................ 2
`Driving Trends............................................................................................................................. 2
`Traffic Safety Technology ................................................................................................ 5
`“Toolbox” of Components and Technologies.............................................................................. 5
`Communications.......................................................................................................................... 6
`Vehicle-Roadway System............................................................................................................ 7
`Global Positioning Systems....................................................................................................... 10
`Other Vehicle-Roadway System Components........................................................................... 11
`Examples of Integrated Technology Systems............................................................................ 13
`Reaching Traffic Safety Goals with Use of Technology .............................................. 15
`The “Four E’s”........................................................................................................................... 16
`Challenges for Technology Applications Serving Traffic Safety Programs.............. 34
`Technical Design Challenges..................................................................................................... 34
`Technical Design Principles ...................................................................................................... 37
`Non-Technical Challenges......................................................................................................... 39
`Conclusion ....................................................................................................................... 41
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`Table of Tables
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`Table 1. Fatalities, Injuries, and Crashes from 1990 to 2006...........................................................2
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`Table 2. Total Injuries and Crashes in 1990, 2000, and 2006 ..........................................................3
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`Table 3. Examples of Crash Scenarios, Using the Haddon Matrix ................................................15
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`Table 4. Engineering Haddon Matrix.............................................................................................21
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`Table 5. Emergency Response Haddon Matrix..............................................................................26
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`Table 6. Crash Factors and Fatalities .............................................................................................27
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`Table 7. Education and Information Haddon Matrix .....................................................................33
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`Table 8. The Automotive Environment..........................................................................................34
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`Table of Figures
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`Figure 1. Highway Fatalities and Fatality Rates 1994-2005 ............................................................3
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`Figure 2. Vehicle Operating Parameters Measured by Sensors .......................................................8
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`Figure 3. Haddon Matrix Format....................................................................................................15
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`Figure 4. Crash Type Distribution 2002.........................................................................................16
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`Figure 5. Rear-end Crash Avoidance Technology .........................................................................18
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`Figure 6. Example of Vehicle-to-Roadway Communication in Intersection Crash Avoidance
`Technology.....................................................................................................................................18
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`Figure 7. Components of Emergency Response Services ..............................................................22
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`Figure 8. Example of an In-Vehicle Visual Stop Sign Warning ....................................................32
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`Abbreviations
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`
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`ABS
`
`ACN
`
`CVO
`
`ECU
`
`EDR
`
`EMS
`
`ETC
`FHWA
`FMCSA
`GPS
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`HMI
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`ITS
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`MEMS
`MVEDR
`PSAP
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`NHTSA
`USDOT
`VMT
`
`
`antilock brake system
`automatic crash notification
`commercial vehicle operations
`electronic control unit
`event data recorder
`emergency medical services
`electronic toll collection
`Federal Highway Administration
`Federal Motor Carrier Safety Administration
`global positioning system
`human-machine interface
`intelligent transportation system
`microelectromechanical system
`motor vehicle event data recorder
`Public Safety Answering Point
`National Highway Traffic Safety Administration
`United States Department of Transportation
`vehicle miles traveled
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`vi
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`EXECUTIVE SUMMARY
`
`
`This document explores how emerging digital and communications technology can
`advance safety on the Nation’s highways. The range of technology described in this report is
`available or will be available in the near future to improve traffic safety. As new traffic safety
`applications become widespread and implementation costs decrease, there could be a network of
`advanced systems that improve traffic safety by providing information and services to drivers,
`traffic operations agencies, emergency services personnel, and law enforcement professionals.
`
`
`Technologies
`Electronic communications is the key to traffic safety technologies. Types of
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`communications systems and example applications include:
`
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`• Vehicle to driver, in which the vehicle communicates information to drivers when
`predetermined criteria are met, such as if a vehicle drifts out of its lane.
`• Vehicle to vehicle, which enables communication among vehicles for such applications
`as crash avoidance technologies and allowing law enforcement officials to acquire
`identification information about a particular vehicle.
`• Vehicle to and from roadside, in which roadside communications devices send and
`receive message to and from passing vehicles. The most common application of this
`technology is electronic toll collection, but there are many potential traffic safety
`applications.
`• Vehicle to and from traffic and emergency call centers, including such applications as
`automatic crash notification that notifies an emergency call center when a vehicle has
`been involved in a crash.
`
`
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`Haddon Matrix
`The Haddon Matrix is a useful construct to assess the various stages of a crash (before,
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`during, and after) and factors that contribute to crashes (human, vehicular, and environmental).
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`This report applies the Haddon Matrix to each of the “Four E’s” of traffic safety:
`
`
`• Engineering - Examples include antilock brake systems that prevent skidding and
`electronic stability traction control that helps avoid vehicle rollovers and other loss-of-
`control situations. Engineering interventions generally occur in the pre- and during-
`crash phases of the Haddon Matrix.
`• Emergency response – Examples include automated crash notification systems that
`notify emergency call centers that a vehicle has been in a crash; improved 911 services
`that can detect the location of cell phone callers (enhanced 911); and 911 services that
`can handle non-voice communication such as video and data streams (next-generation
`911). Emergency response technologies apply to the post-crash time period.
`• Enforcement and regulations – Examples include alcohol interlocks that prevent drunk
`drivers from starting their vehicles, electronic vehicle tags that allow law enforcement
`personnel to identify specific vehicles, and cameras that detect and identify vehicles that
`run red lights. Enforcement and regulatory activities occur primarily before a crash.
`• Education and information – Examples include various driver information applications
`that inform the driver about road and traffic conditions. Education and information
`activities affect primarily per-crash conditions.
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`Challenges
`As with all new technology applications, traffic safety technologies come with a variety
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`of design challenges that must be met prior to full implementation. The human-machine interface
`(HMI) is perhaps the most important consideration in traffic safety technologies. The primary
`requirement of the in-vehicle HMI is to deliver the needed or desired information while
`minimizing driver distraction. This can be done through careful placement of the HMI device
`within the vehicle and by the way it relays relevant information. Available technologies for HMI
`include voice activation, speech recognition, dashboard lights and icons, heads-up or panel
`displays, audio devices, voice synthesizers, haptic systems, and onboard printers. Other
`challenges include the need to protect the security and privacy of data, the need for the various
`technologies to be interoperable, and the need to ensure that the data generated and
`communicated by these new technologies are accurate and reliable. There are other challenges
`that are less technical in nature, such as encouraging wide-spread deployment and managing
`inter-organizational issues related to new technology applications.
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`INTRODUCTION
`
`This report explores new and emerging traffic safety technologies and how they can be
`used on the vehicle-roadway system to prevent crashes, increase compliance with traffic laws,
`and improve incident management and crash investigations. It is intended primarily for NHTSA
`field staff who are traffic safety professionals but not technology experts or experts in the field of
`intelligent transportation systems (ITS). State DOT safety staff and public safety professionals also
`might find it useful.
`
`The Need for New Traffic Safety Technologies
`The number of highway vehicle miles traveled (VMT) in the United States grows each
`year, as do the numbers of drivers per household, of vehicles per household, and of vehicles per
`driver. The increase in seat belt use, the introduction of air bags, and the crackdown on drunk
`drivers have combined to decrease the absolute number of fatalities as well as fatality rates per
`VMT. However, there are still about 42,000 traffic fatalities per year.
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`A significant reduction in highway fatalities will require new, emerging, and future
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`technologies. Technology is the means by which the performance of drivers, vehicles, and the
`roadway can be monitored and adjusted in a way that improves the overall level of safety on the
`highways. These technologies should be able to:
`• Deliver safety information to drivers and vehicles and assist drivers in taking action to
`reduce the potential for crashes;
`• Provide crash- and safety-related information to emergency responders to reduce response
`time;
`• Provide information and automated processes that allow law enforcers to target high-risk
`drivers and reduce the labor involved in all aspects of traffic law enforcement; and
`• Improve traffic safety education and outreach activities to create better prepared drivers
`who can take advantage of new safety technology applications.
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`Organization of the Report
`Section 2 provides background on traffic safety trends and Federal traffic safety goals.
`
`Section 3 describes the basic emerging technology toolkit and presents specific traffic safety
`technology applications that are currently in use or are being researched. Section 4 examines how
`these technologies and applications can be used to improve traffic safety. It addresses issues
`related to vehicle and roadway engineering, emergency response, law enforcement, and education
`and outreach. Section 5 presents some of the challenges and drawbacks to using advanced safety
`technologies and discusses ways to overcome them. The most important of these considerations
`are data privacy and human-factors issues because of their potential for unintended (and possibly
`dangerous) consequences. Section 6 concludes the report by highlighting successful technology
`applications and reiterating the potential for new and emerging technologies to have similar
`success.
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`TRAFFIC SAFETY TRENDS
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`Improving the safety of the Nation’s transportation system is USDOT’s highest priority.
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`Its goal is to reduce the Year 2000 highway fatality rate of 1.5 people per 100 million VMT to 1.0
`by 2011, using the following performance measures:
`• Reducing the rate of motorcycle fatalities;
`• Reducing the rate of nonvehicle occupant fatalities;
`• Reducing the rate of drunk-driving crashes;
`•
`Increasing seat belt use; and
`Increasing use of restraints for infants and children up to 7 years old.1
`•
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`Driving Trends
`The ever-increasing dependency on automobile travel in the United States is clear:
`• From 1990 to 2006, the number of licensed drivers grew from 167 million to 202
`million, an increase of 20%, about equal to the total change in the U.S. population.2
`During the same period, the U.S. population over the age of 16 increased by 16.5%;3
`the number of registered motor vehicles, by 27.5%; and the number of workers over
`the age of 16, by 28%.4
`• From 1990 to 2001 (the most recent year for which vehicles-per-household data are
`available), the mean number of people per household increased slightly, from 2.56 to
`2.58, or less than 1%, while the mean number of vehicles per household increased
`from 1.77 to 1.90, or 7.3%.5
`In 1990, 87% of the U.S. population over the age of 16 had a driver’s license. By
`2005, that number had increased to 90%.6
`In 2005, the ratio of private vehicles to licensed drivers was 1.15, indicating that
`there are more registered passenger vehicles than licensed drivers.7
`• From 1980 to 1990, total VMT increased from 1.5 to 2.1 billion, or by approximately
`40%. Between 1990 and 2000, this figure increased an additional 28%. By 2005,
`total highway VMT had increased to 3 billion.8 This means that VMT doubled in the
`25 years between 1980 and 2005.
`
`•
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`•
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`Despite the mounting exposure of Americans to hazards on the road, both absolute levels
`and rates of injuries and fatalities per VMT have declined over time, as shown in Table 1.
`
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`Table 1. Fatalities, Injuries, and Crashes from 1990 to 20069
`Fatalities
`Injuries
`(per 100M VMT) Change (%)
`(per 100M VMT) Change (%)
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`Year
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`1990
`1995
`2000
`2006
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`2.08
`1.73
`1.53
`1.41
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`–17
`–11
`–8
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`151
`143
`116
`85
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`–5
`–19
`–27
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`During the same period, the absolute number of passenger vehicle fatalities declined,
`from 44,599 in 1990 to 42,642 in 2006, or by approximately 4.4%. While fatalities decreased
`overall during this 16-year period, they increased by approximately 1.5% from 1997 to 2006.
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`The fatality rate, although at a historical low, showed signs of leveling off at 1.5 per million
`VMT. Figure 1 illustrates these trends.
`
`Fatalities per 100M VMT
`
`1.80
`1.75
`1.70
`1.65
`1.60
`1.55
`1.50
`1.45
`1.40
`1.35
`1.30
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`Fatalities
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`Fatalities per
`100M VMT
`
`1995
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`1996
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`1997
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`1998
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`1999
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`2001
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`2002
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`2003
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`2004
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`2005
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`44,000
`43,500
`43,000
`42,500
`42,000
`41,500
`41,000
`40,500
`40,000
`39,500
`39,000
`1994
`
`Total Fatalities
`
`2000
`Year
`Figure 1. Highway Fatalities and Fatality Rates 1994–200510
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`The absolute increase in fatalities can be attributed entirely to an increase in deaths of
`motorcycle riders, which more than doubled from 1997 to 2006, increasing from 2,112 to 4,810
`fatalities per year. From 2000 to 2006, there was an absolute increase of 697 passenger-vehicle
`fatalities. During the same period, motorcycle deaths increased by 1,913.11
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`Between 1990 and 2000, the number of injured people on highways declined slightly
`each year, from 3.23 to 3.19 million, a 1% improvement, before decreasing sharply (by 19%) to
`2.58 million in 2006. The total number of highway crashes went from 6.47 to 6.39 million from
`1990 to 2000, a decline of 1%, and it decreased further, to 5.97 million, in 2006, a 7% drop, as
`shown in Table 2.12
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`Table 2. Total Injuries and Crashes in 1990, 2000, and 2006
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`3.23
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`6.47
`3.19
`–1.3
`6.39
`2.58
`–19.1
`5.97
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`Year Total Injuries(in Millions) Change (%) Total Crashes(in Millions) Change (%)
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`1990
`2000
`2006
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`–1.2
`–6.6
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`The percentage of total fatalities related to alcohol declined from 51% in 1990 to 41% in
`2006. Passive and active restraints—seat belts and air bags—also contributed to a total decrease
`in passenger-car fatalities. Seat belt usage increased from 58% of vehicle occupants in 1994 to
`80% in 2000.13 In 2007 NHTSA reported seat belt use at 82%.14 NHTSA estimates that seat belt
`usage saved approximately 15,383 lives in 2006.15
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`The losses from highway crashes can be expressed in dollars as well as in lives. In 2000,
`NHTSA estimated the total cost at more than $230 billion each year, including almost $33 billion
`spent on medical treatment. These costs also reflect lost income and other care-related
`expenses.16
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`Another trend worth noting in the context of traffic safety is the changing demographics
`of the American public as the population ages. Drivers who are 75 and older have higher fatality
`rates than all age cohorts except the youngest.17 Loss of visual acuity, restricted mobility, and
`slowed reaction time contribute to the decreasing ability with age to cope with challenging traffic
`conditions. New technology applications such as collision warning systems can help to
`ameliorate some of the traffic safety effects of aging.
`Not only is there an increasing percentage of older Americans who continue to drive,
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`ride, and walk, but more of them want or need to continue to drive at older ages. These trends are
`already pronounced and will only accelerate as the Baby Boomers age. The U.S. Census Bureau
`estimates that the population of Americans over 62 will increase by 87% between 2005 and 2030.
`The number of oldest Americans—those over 82—is expected to increase by the same
`percentage. This is in contrast to an overall population increase of 23%.
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`OWNER Ex. 2031, page 14
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`TRAFFIC SAFETY TECHNOLOGY
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`This section describes the technology building blocks that can be used alone or in
`combination to create systems or groups of systems that enhance traffic safety. As traffic safety
`applications become widespread and implementation costs decrease, there could be a network of
`advanced systems that improve traffic safety by providing information and services to drivers,
`traffic operations agencies, EMS personnel, and law enforcement professionals.
`
`The combination of digital intelligence and wireless communications is being applied to
`vehicle and roadway safety systems, and there is great potential for future enhancements and
`applications. Inside the vehicle, digital intelligence allows for reliable safety-critical equipment
`such as traction control, antilock brakes, and air bags. Telematics—the combination of computer
`and communications technologies—allow the car and its occupants to communicate with the
`outside world. ITS and the Intelligent Vehicle Initiative, whose goal is “to accelerate the
`development and commercialization of vehicle-based driver assistance products that can assess
`the driving environment in ways that drivers cannot,”18 allow communications between vehicles,
`between vehicles and the roadway, and among elements of the larger transportation-related
`network of resources.
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`Onboard automotive electronics systems such as traction control and stability control
`enhance the ability to safely operate a vehicle. Telematics provide the capability for Mayday
`notification to a private provider’s call center and possibly for automatic crash notification (ACN)
`directly to a public-safety answering point. ITS provides real-time traveler information on
`recurrent and nonrecurrent congestion. The Intelligent Vehicle Initiative will automate crash
`avoidance. Robust communications and digital networks will allow EMS, law enforcement, and
`public-safety organizations to communicate electronically with drivers and vehicles in ways that
`will enhance highway safety.
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`“Toolbox” of Components and Technologies
`The toolbox comprises a growing set of components and underlying technologies that can
`be assembled in many ways to create a wide range of existing, emerging, and future traffic-safety
`and enforcement applications. The capabilities made possible by networks enable voice and data
`communications among in-vehicle and roadway electronic devices, vehicle operators, public-
`safety communications centers, traffic management centers, and private-sector service providers.
`For example, collision-warning systems can be implemented with any of several technologies to
`gauge the distance between a vehicle and objects. These systems might use dedicated short-range
`communication (DSRC) for electronic communication between vehicles and the roadway, or they
`could use radar, infrared, and ultrasonic devices.
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`The technology available for traffic safety and enforcement is affected by trends that
`drive technological progress in general. The most notable trend is that changes in information
`technology and telecommunications are rapid and constant, in contrast to longer decision-making
`and implementation periods associated with the automobile industry and public agencies.
`Although the implications of these trends are seen most vividly in the consumer electronics
`market, they have strong significance for traffic safety and traffic law enforcement.
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`Key Communications Concepts
`Bandwidth: The data rate or frequency range
`of a communications system. The higher the
`bandwidth, the greater the amount of data that
`can be transmitted in a given time period.
`Operating band/radiofrequency spectrum:
`The portion of the electromagnetic spectrum at
`which a device operates. In the United States,
`the FCC regulates radiofrequencies. The
`International Telecommunications Union
`regulates frequencies internationally.
`Operating range: The maximum physical
`separation of devices within which the system
`can operate.
`Sharply increasing speed and bandwidth
`available for communications applications are
`making features such as real-time transmission
`of video images both technically and
`financially feasible.
`
`Communications
`Communications is the core technology
`needed for traffic safety systems. Wireless
`voice and data networks transmit the messages
`and other information among traffic system
`elements (including people) that make
`automated systems powerful. They can track
`uniquely identified objects worldwide in real
`time and transmit large amounts of data (such as
`video images) to and from mobile data
`terminals.
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`Communications technologies can
`transmit data between in-vehicle devices and
`allow data being generated within vehicles to be
`sent to an external entity such as a public safety
`response center. Data from an onboard system
`such as a sensing diagnostic module or a motor
`vehicle event data recorder (MVEDR) can be
`transferred to handheld, portable, or fixed
`external devices by crash investigators, vehicle
`operators, or repair shops.
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`Communications are enabled through technology standards. For example, if cell-phone
`companies had not developed communications standards, subscribers from one company could
`not call those from another vendor. Standards ensure that various devices can connect with others
`that use the same standards.
`
`Transportation-specific standards are being promoted by alliances of automobile and
`semiconductor manufacturers, telecommunications companies, computer communications
`professional organizations, and government agencies for use in telematics and ITS applications.
`For example, one of the earliest transportation-related communications standards was developed
`to allow vehicle emissions data to be downloaded by inspectors.
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`Types of Communication Systems
`Future vehicle networks will have “plug-and-play” capability for mobile devices. This
`capability allows direct installation of devices without the need for installation of drivers; one
`simply plugs the device into a host computer and the device works. Such easily installed mobile
`devices could serve as input and output to the in-vehicle network as well as to external networks.
`Current handheld systems include:
`• Cellular phone with GPS capability;
`• PDA;
`• Pager;
`• Laptop or tablet computer with wireless capability; and
`• Key fob implemented for remote key entry.
`
`
`
`Vehicle-to-Vehicle
`Vehicle-to-vehicle communication is particularly useful for applications requiring
`communication between a patrol car and another vehicle. (Note that this discussion excludes the
`specialized area of intercommunication among mobile units belonging to public safety agencies.)
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`Also related to this type of communication is the ability of a laptop or other handheld system to
`query systems in a nearby vehicle. Police or other emergency service providers, such as tow-
`truck operators, could provide specific information to vehicle operators and obtain information
`directly from in-vehicle systems. It is expected that DSRC will provide one of the mechanisms
`for this type of communication. Uses of vehicle-to-vehicle and handheld-to-vehicle
`communications include:
`• Aiding crash-avoidance systems;
`• Signaling a crash or breakdown in the communicating vehicle;
`• Signaling a crash or breakdown in the road ahead;
`• Providing warning of an approaching emergency services vehicle such as an
`ambulance or police car;
`•
`Informing the driver that a traffic-law infraction is occurring; and
`• Acquiring identification or other data from the target vehicle.
`
`Vehicle to and from Roadside
`ITS devices at the roadside will have the ability to communicate with passing vehicles,
`generally using DSRC. Traffic signals, dynamic message signs, traffic condition monitors, and
`environmental sensor stations may all acquire the ability to communicate local conditions directly
`to drivers. In-vehicle signage and synthesized voice interfaces will present the information to
`drivers.
`
`Conversely, the vehicle will be able to communicate with local roadside devices. Data
`used by traction control devices could alert roadside equipment that the roadway is becoming
`dangerously slippery. One way to characterize roadside equipment is by the permanence of its
`location. Permanently installed equipment includes traffic signals, toll booths, truck weigh
`stations, and garage doors. Mobile equipment includes portable changeable message signs and
`vehicle-mounted warnings.
`
`Vehicle to and from Traffic and Emergency Call Centers
`It is important for traffic and emergency call centers to be able to locate vehicles,
`equipment, and 911 callers. Emerging technologies are making this process easier and more
`accurate. For example, cell phone carriers are required to provide the infrastructure to
`automatically deliver the phone number and the location of caller with the 9-1-1 call itself. Some
`public-safety agencies are including location-based services in their intercommunications
`initiatives so that all units responding to an emergency or incident know the locations of all
`assets.
`
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`Private-sector call or communications centers are maintained as part of telematics and
`antitheft car-locating services. In current applications, only the automobile occupant or an event
`affecting the automobile (such as a crash) initiates contact with these centers. In the future,
`contact initiation by third parties, such as law enforcement agencies, through such centers or by
`the centers themselves may be possible.
`
`Vehicle-Roadway System
`The communications technologies and applications described above link devices to form
`a road-vehicle-operator system that uses digital data to control the vehicle directly or to provide
`decision-support information to the vehicle operator. These devices include sensors, computers
`or electronic control units, actuators/controllers, data recorders, and the human-machine interface
`(HMI). The sensors digitize physical signals that are processed by a computer and can be
`recorded by an event data recorder. Through computer processing, actuators and controllers
`
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`OWNER Ex. 2031, page 17
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`activate vehicle brakes, steering, or other systems such as ACN. Messages or prompts can be
`delivered to the operator visually, aurally, or k