Recommendation to the National Highway Transportation Safety Administration on Possible Notice of Proposed Rulemaking for Vehicle-to-Vehicle Communications

Submitted by the Members of the Intelligent Transportation Systems Program Advisory Committee (ITSPAC)
August 9, 2013

These comments are submitted by the Members of the Intelligent Transportation Systems Program Advisory Committee (ITSPAC), a Federal Advisory Committee appointed by the US Secretary of Transportation as directed by Section 5305(h) of the SAFETEA-LU P.L. 109-59 Legislation. ITSPAC members are experts in the fields of transportation (state and local, road, transit, and freight), automobile manufacturing, automotive electronics, mobile communications, public policy, Internet, engineering research, and vehicle safety.

The ITSPAC is very aware of NHTSA’s current testing and research of vehicle-to-vehicle communications (V2V) technology. We recommend that NHTSA accelerate and complete the technical and policy research necessary to support the implementation of V2V technology. According to NHTSA’s studies, V2V has the potential to influence over 80% of non- impaired light vehicle target crashes. We agree that this technology has enormous potential for making road transportation safer than it is today. We believe that implementation and eventual widespread deployment of V2V technology will contribute significantly to further reductions in the annual number of crashes and crash-related fatalities.

NHTSA has identified various alternatives to facilitate the implementation of V2V into the U.S. fleet such as “Recommendations”, inclusion in its New Car Assessment Program (NCAP), or rulemaking for mandatory fitment. The ITSPAC believes that the rulemaking approach offers the most promising opportunity to reduce crash-related fatalities, injuries and property loss because it would necessitate vehicle fleet-wide implementation of V2V, whereas the other two approaches are voluntary by nature.

Therefore, the ITSPAC urges NHTSA to proceed with the rulemaking process that will lead to widespread deployment of vehicle-to-vehicle communications.

The rulemaking process provides a transparent forum for government, industry and general public to work together to find the most effective solution for implementing the system, leveraging the years of research and development conducted by the U.S. DOT Research and Innovative Technologies Administration as well as many related studies and trials conducted by industry and academia.

The ITSPAC is honored to be part of this landmark achievement in automotive safety and we look forward to a successful deployment of V2V technology and especially to witnessing the reduction of crashes and fatalities on the nation’s roads.

The Members of the Intelligent Transportation Systems Program Advisory Committee (ITSPAC)

Mr. Robert P. Denaro, Chairman
ITS Industry Consultant

Professor Hans Klein, Vice-Chairman
Associate Professor, School of Public Policy
Georgia Institute of Technology

Professor Teresa Adams
Chair, Transportation Management and Policy
Program and Director, National Center for Freight and
Infrastructure Research and Education
University of Wisconsin–Madison    

Professor Stephen Albert
Western Transportation Institute
Montana State University      

Mr. Scott Belcher
President and Chief Executive Officer
Intelligent Transportation Society of America          

Mr. Roger Berg
Vice President, Wireless Technologies
DENSO North America Research and Development           

Mr. Joseph A. Calabrese
Chief Executive Officer and
General Manager/Secretary-Treasurer
Greater Cleveland Regional Transit Authority          

Mr. John Capp
Director of Global Active Safety Electronics
General Motors Corporation  

Ms. Paula Hammond, P.E.
Former Secretary
Washington State Department of Transportation      

Mr. Sonny Holtzman
The Holtzman Group 

Mr. Steve Kenner
Global Director of Automotive Safety
Ford Motor Company            

Mr. Ronald F. Kirby
Director of Transportation Planning
National Capital Region Transportation Planning Board
Metropolitan Washington Council of Governments

Mr. J. Peter Kissinger
President and Chief Executive Officer
American Automobile Association Foundation for Traffic Safety

Mr. Scott J. McCormick
Connected Vehicle Trade Association

Professor Raj Rajkumar
George Westinghouse Professor, Department of Electrical and Computer Engineering
Carnegie Mellon University

Mr. Bryan Wayne Schromsky
Director, Federal Government and Public Safety
Verizon Wireless

Mr. Ton Steenman
Vice President/General Manager
Intelligent Systems Group
Intel Corporation

Mr. Kirk T. Steudle, P.E.
Michigan Department of Transportation

Mr. George T. Webb
County Engineer
Palm Beach County, Florida