Fred Andersky, Bendix's Director, Customer Solutions – Controls and Director, Government & Industry Affairs, helps guide the company's regulatory, legislative and advocacy efforts. He's also responsible for the marketing and customer solutions efforts of the Controls group, which develops driver-assistance technologies.With Bendix for 10 years, Andersky holds a Class A CDL.
Q: Things have picked up speed of late on the regulatory front, especially regarding equipment mandates. Of the two now most in the news— the pending mandate for Electronic Stability Control (ESC) and the possible mandate for Forward Collision Avoidance (FCA) on commercial vehicles— which could ultimately have the most positive impact on highway safety?
A: We believe both technologies have a positive impact on safety. In terms of which will have more impact, it depends on how you define “impact”– lives saved vs. crashes mitigated: From the perspective of fatalities, stability will have the larger potential impact. Why? More trucks are involved in rollovers and jackknifes that result in fatalities than in fatal rear-end collisions. According to the recently released “Large Truck and Bus Crash Facts - 2013” from the Federal Motor Carrier Administration (FMCSA), over 400 trucks were involved in stability-related fatal crashes in 2013 versus just a little over 80 trucks in fatal rear-end collisions. In terms of lives save, the likely largest impact is with stability control.
As an aside, about an equal amount of trucks were involved in stability and rear-end injury crashes– about 6,000 for each, so regarding impact on injury crashes, it’s a wash. Overall, however, there are a lot more rear-end collisions involving heavy trucks than rollover and jackknife (stability) crashes. From the FMCSA report, about 10,254 trucks were involved in rollover crashes and about 6,183 trucks were involved in jackknife crashes. However, over 23,000 trucks were involved in rear-end collisions. So, if viewed in terms of crash reduction, collision mitigation technologies will likely have a larger impact.
Q: Please explain why the final rule issued to require ESC starting on 2017 trucks has been so well received by industry stakeholders, including Bendix?
A: First, it was the right technology to choose for the mandate. ESC, or what Bendix brands as Bendix ESP, does more to help drivers in more situations– both rollovers and loss-of-control. As NHTSA commented in the rulemaking “…RSC systems are less beneficial than ESC systems in reducing rollover crashes and much less beneficial in addressing loss-of-control crashes.”
It’s not a new technology; it is a proven technology – commercially available for over 10 years. Full stability continues to prove its value to fleets as more and more have been moving towards the technology solution over the last few years. Our estimates show ESC systems outsold RSC system within the industry almost 3:1 in 2014. Plus, NHTSA’s own estimates in the final rule put ESC penetration higher than RSC penetration in 2012.
Lastly, NHTSA eliminated the “sine with dwell” (SWD) performance test it was recommending in the Notice of Proposed Rulemaking. The SWD test is similar to what we’ve incorporated at our demos as an obstacle avoidance, or double-lane change, maneuver. The industry expressed to NHTSA that this test would be burdensome. Bendix commented “(that we) found the…SWD maneuvers to take up significant area which may limit test capability, and…found difficulties with test equipment that meets the requirements of the NPRM but are not capable of complete the maneuvers.” Removing the test in the final rule meant that it also removed a number of the concerns regarding the rulemaking.
Q: By contrast, there seems to be concern on the part of suppliers that an FCA rule, if based on the most recent recommendations issued by NTSB, would not be the best way to bring this technology to bear. Is that the case and, if so, why?
A: Bendix has not voiced an opinion with regard to the NTSB proposed approach. I can share that we have consistently stated that we prefer to let the market decide on technology choices that best meet their needs as opposed to mandates. In the end, we are encouraged that the conversation around collision mitigation technologies is continuing because building awareness of this topic for vehicle operators is valuable.
What’s most important to keep in mind is that the technology is still evolving– and getting better. I say that because, in 2009, Bendix introduced Wingman ACB– radar-based active cruise with braking. It was the first step in delivering an active braking approach to collision mitigation. Two years later, we introduced Wingman Advanced, a collision mitigation technology. It combined both adaptive cruise control technology-- featured in Bendix Wingman ACB– with collision mitigation braking. So, whether or not a driver was in cruise control, if the system determined a collision was imminent, we alerted the driver and applied the brakes to help mitigate the collision. Just recently, we introduced Bendix Wingman Fusion, the integration of camera, radar and the vehicle brakes to provide an even more robust approach to collision mitigation. It’s a driver assistance system that– among its many features-- can aid the driver by applying the brakes to help mitigate a potential collision with a stationary vehicle.
A mandate today could impact the ongoing development of these and other systems across our industry. Like the ESC mandate being built on a proven technology, perhaps the approach to a collision mitigation rulemaking should take some time, allowing the technology to evolve.
Q: While the ESC rule is truck-specific, an FCA mandate might well take in cars, too. Does that duality complicate the rulemaking process and/or just make it harder for trucking advocates to draw clear distinctions from what may be needed for motorists vs. truck driver?
A: Interesting question… Keep in mind that ESC is mandated on light vehicles (FMVSS 126). In my opinion, the separate path approach is the appropriate measure to take for the agency in many cases. The physics involved in stopping or controlling a heavy vehicle are quite different from a light vehicle and it is prudent for the agency to approach these rulemakings separately. This is why the SWD test, while acceptable for cars, received a lot of concern from the industry when applied to heavy vehicles.
Another consideration is that braking systems are different– light and medium duty vehicles are typically hydraulically braked, while Class 7 & 8 vehicles are typically air-braked.
If NHTSA decides a rulemaking is appropriate, a concurrent timeline is fine, but, my view is that the rulemakings should be separate. This approach will help to ensure clarity in the requirements for each type of vehicle and for manufacturers, suppliers and their customers.
Q: Also on Forward Collision Avoidance, in your view is that even the best description for this safety technology and why?
A: It’s not really avoidance, it is mitigation. Much as we would like to say “Buy the technology and never have another crash!” that’s just not reality. We should call it collision mitigation, because that, in fact, is what it does– it can help to lessen the severity of the situation.
The most important point we can make is that the driver is still an essential part of collision and crash mitigation. Technologies like stability and collision mitigation are driver assistance systems, not driver replacement systems. Bendix safety technologies complement safe driving practices. No commercial vehicle safety technology replaces a skilled, alert driver exercising safe driving techniques and proactive, comprehensive driver training. Responsibility for the safe operation of the vehicle remains with the driver at all times.
Q: Of course, safety systems with ESC and FCA capabilities are already available for spec’ing on trucks. Of the two types, which has gained the most share with fleets so far and why might that be?
A: Stability technology has the largest share, since it has been in the industry longer. However, collision mitigation technologies are growing at a faster rate. Keep in mind, though, that stability complements collision mitigation… it doesn’t substitute or replace the technology. Collision mitigation technology is built on stability, so as collision mitigation share grows, so will stability’s share.
And, as stated earlier, it’s not surprising that collision mitigation technologies are growing faster; the data shows that more rear-end collisions occur than stability situations.
Q: Lastly, are there any other significant equipment mandates in the works or just being contemplated that trucking should be keeping a close eye on?
A: The federal government's top vehicle and clean-air regulators on June 20 formally announced their proposal for extending fuel-economy and greenhouse-gas emissions rules, and predicted positive economic and health-benefit results. The timeline for the final rule is pretty aggressive– March 2016. Environmental issues are key area of interest for this administration, so I suspect this will move along quite quickly. Industry is aware, and I’m expecting a pretty vigorous response.
Another area we’re expecting some action on is the Intelligent Transportation System initiatives– specifically the Vehicle-to-Vehicle (V2V) and Vehicle-to-Infrastructure (V2I) communications requirements. You may recall that the ANPRM (Advanced Notice of Proposed Rulemaking) came out last year for light vehicles…though there was a question or two for heavy vehicles included. Expect to see something on this sometime this year or early next…perhaps an NPRM for both? By the way, this could be an area, where a single rule may be applicable across the vehicle spectrum. In this case, we’re talking about a communications device, not something that directly impacts vehicle performance.
Also, while we now have ESC on light vehicles (Class 1&2) and heavy vehicles (Class 7&8), we still have vehicles missing– Class 3-8 single unit trucks. The agency may address this area separately, or we may see it addressed as part of another rulemaking– perhaps the collision mitigation rulemaking as it moves forward.