FMVSS No. 127 Pedestrian Automatic Emergency Braking Test Report

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Executive Summary

Pedestrian fatalities in traffic crashes remain a significant concern, particularly at night, which was when 77.7% of pedestrian fatalities occurred in 2022.1 To mitigate this problem, FMVSS No. 127 mandates the inclusion of PAEB systems in all passenger cars and light trucks by September 2029. It requires that — when tested — these systems detect pedestrians in various lighting conditions, at increased vehicle speeds, and with a 100% pass rate.2 In 2023, testing conducted by the National Highway Traffic Safety Administration (NHTSA) demonstrated that the smallest and lightest vehicle tested passed all FMVSS No. 127 tests. Four of the five vehicles tested failed at least two test scenarios. This demonstrates that meeting the standard using the current PAEB sensor suite on all vehicle sizes and weights will be challenging.
This report presents the testing plan, methodology, and results of the FMVSS No. 127 Pedestrian Automatic Emergency Braking (PAEB) tests conducted by VSI Labs in collaboration with Teledyne FLIR. The primary objective was to evaluate the performance of a thermal-fused PAEB system and several 2024 commercial-off-the-shelf (COTS) PAEB systems under both daytime and nighttime conditions.

 

Key findings include:
  • Daytime PAEB Performance: Both thermal-fused and COTS vehicle PAEB
    systems passed all daytime tests.
  • Nighttime PAEB Performance: Only the thermal-fused PAEB system passed all nighttime tests, demonstrating superior detection capabilities independent of headlight performance.
  • Thermally-Active Pedestrian Test Mannequin
    (PTM): Commercially available heated, thermally-active PTMs provide a realistic representation of a human thermal signature and are recommended for future PAEB testing protocols using thermal cameras.

 

Based on the test results and underlying perception system data, thermal cameras are essential for effective nighttime pedestrian detection. The data showed that longwave infrared (LWIR) thermal cameras see multiple times farther down the road than headlights illuminate, providing advanced warning of objects, vehicles, pedestrians, and large animals in the roadway. Advance warning provides extended braking distances (especially important for heavier vehicles), improved detection and false-positive performance, and more comfortable and safer deceleration.
Real-world corner cases are potentially more challenging than current FMVSS No. 127 protocols, emphasizing the value of automotive thermal cameras for true-positive and false-positive PAEB performance. With the ability to see through darkness, shadows, headlight and sun glare, smoke, and most fog, as well as their unique capability to detect wildlife on the roadway, OEMs may consider integrating thermal cameras to meet FMVSS No. 127 requirements as a cost-effective way to increase real-world vehicle safety.

  1. https://www.ghsa.org/sites/default/files/2024-06/2023%20Pedestrian%20Traffic%20Fatalities%20by%20State.pdf
  2. https://www.nhtsa.gov/document/final-rule-automatic-emergency-braking-systems-light-vehicles-web
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