After failing in its frontal assault on automotive smartphone use last year, the U.S. National Highway Traffic Safety Administration (NHTSA) has started 2012 with the release of a set of design guidelines as the first phase of an effort to eliminate driver distraction. The new guidelines represent an implied endorsement of OnStar-like telematics services that use an embedded module instead of a connected device.

 

NHTSA has identified more than 3,000 distraction-related fatalities from 2011 – in the process creating a new measure of the phenomenon. To better highlight the distracted driving issue, NHTSA has unveiled a more accurate way to identify crashes related to distracted driving by defining a category of “distraction-affected crashes.” NHTSA says that last year distraction-affected crashes killed 3,092 people

 

According to Department of Transportation Secretary Ray LaHood: “This new measure uses a more focused set of the distractions most likely to result in crashes – like dialing a cell phone or sending a text message while behind the wheel. But, because we’ve narrowed the potential distractions included in this new indicator, we can’t compare these first numbers with the 5,474 ‘distraction-related’ fatalities reported in 2009.”

 

In reaction to these numbers, the agency weighed in with new design guidelines last week (http://1.usa.gov/zyAVxQ) hoping to provide some direction to the auto industry regarding the operation of on-board applications such as hands-free phone dialing and navigation destination entry.

 

The agency took the guidelines route out of a recent inclination to pursue voluntary rather than compulsory cooperation from the auto industry. Guidelines can take many forms and can have different implications.

 

Guidelines can represent long-term objectives or they can represent a system of grades or rewards for actions taken in accordance with agency goals. This latter approach is reflected in the global NCAP (New Car Assessment Program) recognition for safety systems, which includes a specific system for awarding points to compliant vehicles. The alternative to the guideline is the mandate, as in the case of the European Commission’s eCall or Brazil’s Contran 245 laws.

 

LaHood, has made eliminating distracted driving his personal signature - a campaign for which he will no doubt be long remembered. In this context, agency guidelines have the ominous impact of an implied or impending mandate. In other words, NHTSA is suggesting with the guidelines that it is willing to “play nice” with the auto industry for now, but in the absence of some reciprocation the gloves may come off.

 

NHTSA out of touch?

 

Distracted driving is nothing new for the auto industry. The debate over in vehicle controls goes back as far as the 1930’s and the introduction of the first car radios.

 

When it comes to distracted driving, the issue in question is in-vehicle user interfaces and mobile device connectivity. Implicated in this conversation are technologies including:

 

            Voice recognition

            Text to speech

            Bluetooth/Wi-Fi

            Navigation

            Map/Traffic data

            Alerts/Driver monitors

            Crowd-sourcing

            Camera/LIDAR/RADAR sensors

            Sensor fusio

            Operating systems

            Displays/Gesture recognition

            Microprocessors

 

Developments impacting all of these technologies are taking shape on a weekly basis.  Advancements include larger/higher resolution displays, faster processors, more accurate/more forgiving voice recognition, enhanced wireless connectivity, more sophisticated data and sensor fusion with alerts and crowd-sourced inputs, driver eye and facial monitors, and upgraded maps and traffic information. 

  

On the horizon are holographic 3D and head-up displays and vehicles increasingly capable of at least partial autonomous operation.  And, interestingly, smartphones have an important role to play in enhancing the safe driving proposition with more up-to-date map, traffic and POI data and enhanced situational awareness for the driver.

  

From the NHTSA announcement:

  

“The proposed Phase I distraction guidelines include recommendations to:

  • Reduce complexity and task length required by the device;
  • Limit device operation to one hand only (leaving the other hand to remain on the steering wheel to control the vehicle);
  • Limit individual off-road glances required for device operation to no more than two seconds in duration;
  • Limit unnecessary visual information in the driver's field of view;
  • Limit the amount of manual inputs required for device operation.

The proposed NHTSA guidelines recommend the disabling of the following operations by in-vehicle electronic devices while driving, unless the devices are intended for use by passengers and cannot reasonably be accessed or seen by the driver, or unless the vehicle is stopped and the transmission shift lever is in park.

  • Visual-manual text messaging;
  • Visual-manual internet browsing;
  • Visual-manual social media browsing;
  • Visual-manual navigation system destination entry by address;
  • Visual-manual 10-digit phone dialing;
  • Displaying to the driver more than 30 characters of text unrelated to the driving task.

Herein lies the problem.  NHTSA has tried to avoid being coercive and overly prescriptive but the impact of the guidelines is an overwhelming endorsement of OnStar-like telematics systems.  The guidelines clearly favor call center-oriented or voice recognition-based telematics systems and services.

 

At the same time, the guidelines appear to reject or at least discourage the use of in-vehicle touch screens or displays of any kind.  The most ideal system on the market perfectly fulfilling NHTSA’s guidelines vision are those OnStar systems built around simple driver information displays located in the instrument cluster.

 

If the NHTSA guidelines were adopted today without a grandfather clause to allow for systems already on the road or in development a wide range of car makers would be at risk.  Ford, Nissan/Infiniti, BMW and others, would be exposed for offering hands-free systems that were not hands free and navigation systems that allow inputs while driving among other violations.  But GM/OnStar would likely be unscathed.

 

The guidelines will also have the impact, intended or not, of discouraging development of more advanced touch screens and larger in-vehicle displays in favor of voice interfaces.  (The guidelines make no mention of gesture recognition, further evidence of NHTSA’s detachment from mainstream automotive advances.)  In sum, the guidelines could well block advances capable of making driving safer – and large in-vehicle displays have already become critical to safe driving with the most obvious example being back-up cameras.

 

On the positive side, the NHTSA guidelines, if adopted, will give a boost not only to voice recognition technology but also to call center-based systems such as GM’s OnStar, Hyundai’s BlueLink, Mercedes Benz’s mbrace2 and BMW’s BMW Assist.  All of these subscription-based services have struggled with unsatisfactory renewal rates as customers have opted for smartphone connectivity over the embedded telematics system.  An endorsement from NHTSA will help wean customers away from their smartphones.

 

Implications

 

NHTSA ought to establish a public policy framework for wireless carriers, application developers, wireless device manufacturers and automobile manufacturerse to collaborate for the purpose of defining the nature of the driver distraction problem and agreeing on a solution.  Proclamations or guidelines coming from NHTSA without the participation of all implicated parties will not be effective.

The NHTSA guidelines for mitigating driver distraction clearly come down against the use of touch interfaces and in-vehicle displays.  Also implicated are the use of haptic and controller-based systems and touchpads for specific functions while the vehicle is in motion.

 

What is clear is that there are systems currently on the market that do not comply with the guidelines including a wide range of navigation and hands-free phone systems from a wide range of auto makers.  Most, though not all, voice-based texting systems will likely pass the no touch, no look test.  Call center-based solutions may also be favored as long as all operations can be completed with limited glances and no touch.

 

Voice recognition and text to speech solutions have come a long way.  Is voice recognition a promising technology for use in a wide range of applications?  Yes.  Does voice recognition work universally well in all environments with all speakers?  No.

 

Can poor voice recognition in an on-board system lead to frustration and distraction for a driver operator?  Yes.  Is it too soon for any organization to endorse voice as an all-purpose interface to mitigate driver distraction?  Yes.  Can a call center interaction distract a driver?  Yes.

 

NHTSA has provided guidelines that hew closely to the Alliance for Automotive Manufacturer’s own guidelines.  The AAM guidelines are normally intended as a tool to pre-empt regulatory action by demonstrating auto industry commitments to “good behavior.”  By adopting the AAM guidelines as its own, NHTSA has changed the driver distraction discussion and endorsed voice recognition and call centers over competing technologies (touch and display) still in development.

 

Where AAM’s intent was to pre-empt reform with voluntary industry guidelines, NHTSA is seeking to influence design priorities – even to the extent of potentially rendering existing systems as non-compliant regardless of their current performance outcomes.  In the end, we are left with 60 days to comment and steer NHTSA away from this well-intentioned errand and its unintended impact.