Comment from Randall Brodersen

I am writing in support of the comments made by the League of American Bicyclists. If the U.S. is to meet the safety goals laid out in the National Roadway Safety Strategy, NHTSA must be on board in making vehicles safer for bicyclists as well as pedestrians. Though the National Highway Traffic Safety Administration(NHTSA) has made progress on its proposal to make automatic emergency braking (AEB) standard on new vehicles for pedestrians, there is not a standard for cyclists. Has NHTSA forgotten cyclists? I have read the League’s comments and want to highlight those that resonate with me. I find it troubling that there are regulations and testing standards used across Europe that can be easily adopted in the U.S., but don’t appear to be under consideration. As NHTSA notes, the United Nations (UN) Economic Commission for Europe (ECE) Regulation No. 152 specifies a “car to bicycle” test and standards, but NHTSA’s proposed regulation does not include anything similar. From NHTSA’s description of its testing it is unclear if NHTSA is holding itself to different standards of performance that are more or less stringent than those that appear in ECE Regulation No. 152. NHTSA also does not discuss any of the bicyclist-AEB international consumer testing through New Car Assessment Programs (NCAPs) that exists separate from ECE Regulation No. 152. According to publicly available testing protocols, Euro NCAP, China NCAP, Japan NCAP, Korean NCAP, and Australasian NCAP all have bicyclist-AEB testing that NHTSA could have reviewed, discussed, or otherwise considered. The League has consistently asked NHTSA for bicyclist safety to be included in crash avoidance and/or AEB technology testing since 2015. Despite providing many comments, and many supporters providing comments, NHTSA continues to ignore or fail to discuss the merits of bicyclist-AEB while creating new ways to push consideration of bicyclist-AEB into the future. Congress has directed NHTSA to harmonize its testing with international and third-party tests through Section 24213(c) of the Bipartisan Infrastructure Law. Including a performance standard for bicyclist-AEB in this FMVSS would harmonize with ECE Regulation No. 152. I agree with the League of American Bicyclists and request NHTSA to use established testing protocols that have been used for years in other nations to provide American consumers with vehicles that are as safe as those sold in other countries and provide them with information about that level of safety.