Comments on NHTSA-2020-0106-0478

Comments on proposed rule on Automated Driving Safety,
NHTSA-2020-0106-0478.

When evaluating safety of automated-driving-vehicles (ADVs), be sure to
weight miles driven by where they are driven and the exposure to
pedestrians, cyclists, and other vulnerable road users (VRUs).

Particulate pollution and noise both damage the health of people near
roads, and to the extent that ADVs can be designed to reduce these
emissions, they should. This might be accomplished through better
management of speed, braking, and cornering, and also simple reduction
in vehicle size.

ADVs will be able to pass other ADVs with smaller clearances than human
drivers need, and because of this, could more regularly leave more space
when passing pedestrians, cyclists, other VRUs. People can stumble or
swerve; any resulting crash would not be directly caused by an ADV, but
an ADV could take steps to avoid or mitigate it. Eventually, ADVs can
allow narrowing of lanes in general. This will free up more room for
pedestrians and cyclists, making them more comfortable and reducing
their conflicts (bikes on the sidewalk, pedestrians in the bike lane).

ADVs should not use street parking in urban areas; they should instead
drop-off and pick-up their passengers at loading zones, and then proceed
to off-street parking. This maximizes convenience for their users, and
allows street space to be reclaimed for other purposes.

ADVs can provide is improved road comfort for cyclists and pedestrians.
Two examples are better crosswalk interactions with pedestrians and
better approach to red lights around cyclists. For crosswalks, the
best-for-pedestrian behavior is to make it clear to a pedestrian, as
soon as it is seen that they wish to cross, that you understand, and
will certainly yield to them. A driver might slow down significantly
well before the crosswalk and flash headlights (on a bicycle, it works
to call out “I see you” and wave/nod). When approaching a red light,
human drivers sometimes drive at full speed to the end of a line of
cars, passing cyclists along the way who later reach and pass the
driver. ADVs can be designed to avoid such no-time-saved passing;
reduced acceleration and braking will also reduce noise and energy use.

Any automatically driven truck should include sensors at all of the
usual truck blind spots, and such trucks should moderate speed whenever
there is a risk of a pedestrian movement (e.g. a stumble) that might
cause an overrun.

NHTSA should work to defuse the vehicle-size “safety” arms race.  ADVs
provide a means for doing this with the promise of an order of magnitude
reduction in crashes (if that’s not possible, I’m not sure why we are so
excited about ADVs), but probably not until their adoption is
widespread. Till then, any ADV owner will likely worry about sharing the
road with fallible human drivers and upsize accordingly. NHTSA could
address this earlier with independent regulations on vehicle size;
larger vehicles reduce safety for other road users, so this is
absolutely within any mission to increase road safety.  Or perhaps,
require anti-collision radar on all vehicles above a certain weight (for
example, 3000lbs), to help provide assurance that a vehicle good at
avoiding its own crashes is less likely to be hit by a larger
human-piloted vehicle.  This will also help mitigate problems caused
during ADV adoption, where ADVs will respond to hazards much more
quickly than the humans around them (in particular, behind them);
putting more vehicles on the road now with anti-collision radar would
reduce this future problem.

I would hope that I do not need to provide references to support claims
that particulate and noise pollution are bad for health, but just in case:
(particulate pollution)
https://news.mit.edu/2013/study-air-pollution-causes-200000-early-deaths-each-year-in-the-us-0829
https://www.nber.org/papers/w21787
https://www.sciencenews.org/article/list-diseases-linked-air-pollution-growing
(noise pollution)
https://www.who.int/quantifying_ehimpacts/publications/e94888/en/
https://www.newyorker.com/magazine/2019/05/13/is-noise-pollution-the-next-big-public-health-crisis

For “better practices” around pedestrians and cyclists, I have video,
collected on my daily commute through Cambridge, MA.
(signaling to pedestrians in crosswalks)
https://www.youtube.com/watch?v=bkrrJ7fOF9I
https://www.youtube.com/watch?v=icw5q9pGkcU

(passing cyclists unnecessarily)
https://www.youtube.com/watch?v=ftpaxn1SP0Y
https://www.youtube.com/watch?v=8x6wpt26DV0

This last example is quite long, but demonstrates that if ADVs had wider
knowledge of traffic jams and red lights, they could make more use of
safer, quieter, and energy-saving use of no-more-speed-than-necessary to
make it to reach their goal. This driver was notably aggressive, yet
saved no time at all.
https://www.youtube.com/watch?v=aZp2Ml5nYz8