Increasing testing speeds for PAEB above 60 km/h (~37 mph) for ‘crossing path’ scenarios, 55 km/h (~35 mph) for ‘stationary along path’ scenarios, and 65 km/h (~40 mph) for ‘moving along path’ scenarios.

Price: Director of Transportation & Drainage Operations, City of Houston On behalf of the National Association of City Transportation Officials (NACTO), Kim Lucas Secretary we are pleased to provide comments in response to the National Highway Traffic Director, Department of Mobility and Infrastructure, Pittsburgh Safety Administration’s Notice of Proposed Rulemaking on Automatic Emergency Braking. [...] Nearly two-thirds (65%) of crashes resulting in pedestrian fatalities where the speed limit is included in the report are on roads where the legal speed limit is 40 mph or higher, and the most common speed limit for a road where a pedestrian is killed is 45 mph. [...] While the FMVSS will eventually require the same testing speeds during daylight and low-light scenarios, NHTSA can save hundreds of lives each year by testing PAEB systems in low-light scenarios at speeds of 65+ km/h (40+ mph), rather than at 40 km/h (~25 mph) and 50 km/h (~30 mph), on the same timeline as daytime scenarios. [...] Retaining the no-contact criterion is important for making sure vehicles of all weights and sizes are equipped with systems designed to save the lives of those outside of the vehicle. [...] NACTO and our member cities commend NHTSA and the USDOT on your continued efforts to advance the National Roadway Safety Strategy, and urge the agencies to continue regulating those vehicles that pose the greatest risk to people walking and biking on US streets.