The Distracted Driving Safety Alliance (DDSA) was invited to testify by the National Highway Safety Traffic Safety Administration (NHTSA) at today’s hearing on in-vehicle electronics and driver distractions. Here is the DDSA’s testimony, applauding NHTSA for its attention to a very important issue – distracted driving – but urging it to allow high-tech innovators and manufacturers the latitude to continue creating a safer driving environment by avoiding unnecessary regulation.
The Distracted Driving Safety Alliance
The National Highway Traffic Safety Administration’s Hearing on
Visual-Manual Driver Distraction Guidelines
For In-Vehicle Electronic Devices
Marc-Anthony Signorino, General Counsel – Distracted Driving Safety Alliance
March 12, 2012
I want to thank you for inviting the Distracted Driving Safety Alliance (DDSA) to testify this morning. First off, I’d like to extend our congratulations and appreciation to Secretary LaHood, Administrator Strickland, Associate Administrator Susan Gorcowski, Kristin Kingsley and the entire NHTSA staff for their steadfast commitment to increasing driver safety, as well as their work in putting together this hearing. We are very supportive of this process and will continue to help in any way possible.
Administrator Strickland, I also bring you warm greetings from the DDSA’s partner in youth education, Zac Ziebarth, Director of Curb Distracting Driving. He asked me to say hello, and to tell you you’re always welcome to come to Arizona State University to talk about the dangers of distracted driving.
The DDSA’s mission is to be the voice of a broad cross-section of industries committed to ending distracted driving. The DDSA is committed to working with stakeholders from all sectors – industry, government, labor, advocacy groups and consumers – to bring an end to distracted driving. In doing so, we reaffirm that distracted driving is a behavioral issue and that education, best practices, and technology are all valuable solutions in changing peoples’ driving behaviors to eliminate deadly distractions. The DDSA’s activities are centered on the following core beliefs:
- Technology can be a valuable solution to the problem of distracted driving;
- Government, industry and consumers all share a responsibility to curb distracted driving in a responsible manner that stops bad behavior without banning innovation; and
- Engaging and educating young people about the dangers of distracted driving early on will set the tone for a safer future. As such our educational program, Curb Distracted Driving, with which you are familiar, is poised to encourage thousands of new and future drivers on their roles in safer driving.
I’m certain you’ll hear ample evidence from scholars, statisticians, and manufacturers on the science behind the development of the guidelines. Our comments are aimed specifically at the policies surrounding this effort. As such, we have a number of comments and recommendations for NHTSA to consider as it moves forward not only with the first phase of guideline development, but with the process as a whole.
We applaud NHTSA’s recognition that the state of the art in technology is constantly changing, and that voluntary guidelines, as opposed to a regulatory approach, is the most appropriate method to address the dilemma of distracted driving given the complexity of the issue. The technologies we’re looking at today are more than likely going to look drastically different tomorrow.
We also commend NHTSA’s commitment to put real science behind these guidelines, as opposed to anecdotal evidence. That said, the field of scholarship in cognitive distraction is increasing, and NHTSA is correct in its mission to encourage and listen to this scholarship. While there are a number of studies on driving behavior and cognitive load, much research is still needed as the issue is very much a moving target. For instance, the current pool of new and novice drivers are digital natives, and as such will have over time a much different relationship with technology than today’s veteran drivers.
NHTSA is to be applauded for basing the proposed guidelines on those developed by the Alliance of Automobile Manufacturers as a starting point; the industry has already put much thought and effort into developing best practices, and building upon that strong foundation is an earmark of good government. The consideration of both the European and JAMA guidelines is also very welcome.
Given the convergence in technology we’re seeing, with multiple industries coming together to enhance the driving experience by increasing both safety and convenience, it’s inevitable that innovation will outpace the policy process. We encourage NHTSA to consider the voluntary guideline process as the optimal approach to address the issue of reducing driver distractions, revisiting the guidelines regularly to accommodate new innovations and trends that help or hinder the driving experience.
We do have recommendations, however, to ensure the guideline development process takes into consideration the complexities that arise when many disparate industries – autos, software, communications, network managers, handheld devices, and other manufacturers – work together to create a complex, integrated product as evidenced by today’s cars.
It’s understandable that NHTSA attempt to address the issue in bite-sized pieces – first OEM equipment with visual-manual driver interfaces, then portable and after-market devices, and then auditory-vocal interfaces.
We urge NHTSA to understand that as all three of these elements are becoming increasingly intertwined, the policies and guidelines we develop must take this into account. These guidelines are expected to impact future vehicle design. To effectively accomplish the goal of phase one, visual-manual, it is imperative we consider how the use of both portable devices and auditory-vocal interfaces are integrated with visual-manual systems now and not at some later date during phase two or three.
The technologies in all three phases are becoming interdependent and will soon be indistinguishable from each other. While expediency is critical, we need to project where driving technology is going not five years out, but one year out. As innovation evolves so fast, today’s problems will tomorrow be moot.
For instance, voice today plays a critical role in allowing drivers to engage in secondary tasks, and development is ongoing to allow it a role in primary driving tasks surrounding safety. The manual-visual guidelines must consider how voice will be integrated when they are developed.
Also, internet connectivity in cars is increasingly common, and that connectivity will be achieved through the driver’s cell phone. As an example, with the touch of one button and just my voice, I can ask my phone to find me good barbecue via Yelp, make a reservation on Open Table and send invites to my friends, all coordinated on my calendar via Outlook. That’s coming to your car very soon – and that’s a good thing. Any activity we can move off a solely hand-held platform and into an integrated, voice-activated application will be one step closer to a safer driving experience.
Because of this, we strongly recommend NHTSA includes in its phase-one guidelines that voice-activated capabilities be a standard feature in all cars by 2015, and that all manual-visual inputs be supported by voice-activated capabilities soon thereafter.
There are many benefits to this approach. First and foremost, you’re eliminating unnecessary manual-visual tasks. This will also promote the use of non-manual-visual secondary tasks. By introducing voice at its most basic level within the automobile, consumers will be further accustomed to performing other tasks by voice that they’d otherwise perform manually – including phone use, navigation input, comfort controls and music selection.
Another recommendation we have recognizes the growing prevalence for mobile applications that create an additional safety layer in the vehicle by performing voluntary lock-out services – where a parent or a fleet manager can hand their kid or employee a cell phone that locks out all but emergency calls when it senses it’s moving faster than 5 mph.
Because of this, we also recommend that NHTSA includes in its phase-one guidelines the allowance of voluntary lock-out applications, whether via mobile application or third-party hardware device, to interface with in-vehicle electronic devices.
As a last point, we ask NHTSA consider the Law of Unintended Consequences. For instance, the DDSA is completely supportive of restrictions that prohibit the use of visual-manual text messaging, as well as internet and social media browsing while the vehicle is in motion. It just makes sense. However, the guidelines also prohibit the inputting of specific addresses for navigation, as well as 10-digit phone dialing while in motion. That makes sense, too. Yet, without an integrated voice-activated control system included in the in-vehicle technology package, we have strong concerns that drivers will simply turn to their cell phones or tablet devices for navigation or 10-digit phone dialing.
Additionally, the latter two actions can safely be performed by someone sitting in the passenger seat – without forcing a driver to exit a highway or toll-road to accomplish such a task. The guidelines acknowledge this dilemma, but mandates a lock-out. A flat out ban in the guidelines will discourage innovators from developing a workable solution, and encourage drivers to find ‘work arounds,’ such as resorting to their mobile device while the car is in motion.
These are not the results anyone here wants. We urge flexibility in guideline development that can allow for appropriate technology solutions to such dilemmas – in this case one that allows the driver to be locked-out of these tasks, but accommodates passenger input.
In conclusion, the DDSA commends NHTSA for its foresight and flexibility in developing these guidelines based on, and in conjunction with, industry best-practices – and urges continued flexibility to allow for the lightning speed of innovation. As such, we urge NHTSA as it moves forward with the first phase of its guideline development to include voice-activated systems and the integration of third-party safety options.
Thank you. We’re looking forward to submitting our written comments. I’m happy to answer any questions you may have.