Applied Intuition Comments on NHTSA’s Proposed Regulation on Automatic Emergency Braking Systems

Aug 11, 2023

Applied Intuition provided comments in response to the National Highway Traffic Safety Administration’s (NHTSA) request for comment on a proposal to update the Federal Motor Vehicle Safety Standards (FMVSS) for automatic emergency braking (AEB) systems. We support NHTSA’s decision to include requirements for AEB and pedestrian automatic emergency braking (PAEB) in light-duty vehicles, which will provide motorists, pedestrians and other vulnerable road users vital protection from collisions.

In our comment, we recommended that NHTSA incorporate modeling and simulation software in the FMVSS testing process in order to include additional scenarios and elements only possible through virtual testing. Modeling and simulation allow for a vehicle to be put through a much more expansive set of testing scenarios and elements than are possible in real-world testing due to potential costs and the limits of physical test tracks.

We also discussed how Applied’s simulation and modeling products are currently used to verify and validate the performance of advanced driver assistance systems (ADAS) under existing Euro NCAP, and how they could similarly be applied for testing the AEB and PAEB standards found in the NPRM. Applied’s software offers OEMs and others the ability to combine simulation and physical testing to better evaluate vehicle performance and ensure all safety standards are met.

Read our full comments here.