State Farm Insurance Companies Submit Public Comments to DOT

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WASHINGTON, Aug. 27 — State Farm Insurance Companies, Bloomington, Illinoishas made a public comment to a US Department of Transportation. A comment was written and posted Oga. 22, 2022.

Comment, on Docket No. NHTSA-2022-0021-0001, submitted to Ann Carlsonmanaging director of National Highway Traffic Safety Administration.


Thank you for the opportunity to comment on National Highway Traffic Safety Administration (NHTSA) Notice of Advance Rulemaking (ANPRM) regarding the amount of pre-crash time and vehicle data that Event Data Recorders (EDRs) must record printed on. June 22, 2022. State Farm Mutual Automobile Insurance Company (State Farm) has a long history of promoting improvements in automobile and highway safety for the benefit of its customers and the general public and recognizes NHTSA’s work in trying to balance innovation and safety thinking. As with NHTSA, State Farm it supports the advancement of automotive technology to the extent that it contributes to the safety of vehicles and highways.

State Farm is the nation’s largest auto insurer with over 40 million auto insurance policies. Its 19,400 agents and more than 53,000 employees operate nearly 87 million policies and accounts, including processing thousands of auto insurance transactions every day.

State Farm is very busy promoting research to increase security on US roads and highways. State Farm supports activities that have the promise of saving lives and preventing injuries, including continuous research and consumer education on the effects of advanced vehicle technologies. State Farm has been working to provide support to NHTSA on the critical safety issues being developed by Advanced Driver Assistance Systems (ADAS) and Automated Driving Systems (ADS) vehicle technologies and to ensure that access to relevant pre-crash EDR data is legally available. enforcers and other parties, including insurance companies. To this end, State Farm I appreciate that the ANPRM for EDRs proposes to extend the EDR recording period and vehicle data items captured by the EDR.

Automated vehicle technology will have a major impact on how insurers protect policyholders and policyholders against loss and damage. State Farm supports the development of technology that holds the promise of saving lives and preventing injuries, including integrating advanced automotive technology to reduce human error and promote safe driving. Although cars with advanced technology can reduce or eliminate many dangers on the road, drivers will still need to be protected from the unexpected. Furthermore, technology such as data collection in the event of an accident can help improve the future of automobiles.

As a supporter of technological advancements that can improve vehicle safety, State Farm participates in several research opportunities across the country. State Farm is a founding member of University of Michigan MCity program and is a member of National Surface Transportation Safety Center for Excellence written by Virginia Tech Transportation Institute. In addition, State Farm has also published consumer research and has participated in several forums and conferences for self-driving cars, including The National Transportation Safety Board Advanced Driver Assist Technologies Program, SAE International Government/Industry Meeting, and AUVSI/TRB Automated Vehicle Symposium. These actions have helped the position State Farm as a thought partner and leader in automotive technology.

State Farm They must collect and analyze a large amount of data to properly underwrite auto insurance, determine liability, and make appropriate payments for more than 10 million auto insurance claims each year. NHTSA developed Federal Automated Vehicle Policy Guidance issued in 2016 (Guidance) highlighting the importance of data acquisition in determining the performance of automated vehicle technology. Also, such data is very important in determining the reality of the collision and assessing the liability. The reason, State Farm appreciates the following language:

For accident reconstruction purposes (including during testing), it is recommended that ADS data be stored, maintained, and readily available for retrieval in their current state, including privacy protections, for accident data recordings.

Vehicles must record, at least, all available information related to the accident, so that the events of the accident can be reconstructed. This data should also include ADS status and whether ADS or a human driver was in charge of the vehicle leading, during, and after the accident. Organizations must have the ability and legal right to share with government authorities the recorded information needed for disaster reconstruction purposes. (Emphasis added)

State Farm previously submitted comments to NHTSA regarding minimum EDR requirements. The basis of State Farm site his ideas came from doing research he was supported by Carnegie Mellon on vehicle performance in different situations. Working with Pennsylvania Department of Transportation, Carnegie Mellon took the test in Pennsylvania and identified the following method of dealing with information related to accidents. ADS EDR must contain:

* Individual notifications (fixed and moving obstacles)

* Looking forward and inside the cabin

* Sensor fusion output (barrier group)

* Localization – where the car is based on latitude and longitude

* Driving vehicles – at intersections, changing lanes, speeding, etc.

* Decision making – traffic congestion, delays

* Current and planned routes and running history

* Responsible for the health of hardware and software applications

* V2X communication

Depending on the length of time, recording of the last 5 minutes (more than 10 minutes) of driving should be stored in the ADS data recorder according to Carnegie Mellon History research so far. State Farm site The mandate, consistent with the spirit of AV 2.0, is that the ANPRM regarding EDRs also supports a standardized data access system.

It is important to note that access to ADAS data is a major issue for many stakeholders. The American Association of Motor Vehicle Administrators (AAMVA) issued “Jurisdictional Guidelines for the Safe Testing and Deployment of Highly Automated Vehicles” shows in several sections the need to provide data related to damage to the police and other groups. Also, a Governor’s Highway Safety Association (GHSA) Professional Vehicle Safety Association: The Working Drivers and Law Enforcement Forum, highlighted data availability as a critical issue for law enforcement and other stakeholders.

For reasons stated by NHTSA in the Rulemaking Analyzes and Notices section, State Farm supports NHTSA’s authority through the ANPRM process to increase the EDR recording time before failure from a recording time of 5 seconds to a recording time of 20 seconds and a sample rate of 2 samples per second (Hz) to 10 Hz.

The end

Finally, State Farm appreciates the opportunity to provide NHTSA’s comments on the ANPRM related to EDRs and continue to advance the goal of improving vehicle and road safety for the benefit of customers and the public at large. State Farm commends NHTSA for doing so by advancing the standard approach to existing technology to capture, access, and analyze critical data prior to delivery. State Farm He hopes to continue working with NHTSA on rulemaking and other autonomous vehicle issues.

If you have any questions or comments, please contact me at (309) 735-4685 or [email protected].


Maria L. Hagglund

Councilor, Public Policy Resource Group

State Farm Insurance Companies

Corporate Law Division

Cell: (309) 533-9409

Email: [email protected]


Introduction here:

TARGETED NEWS SERVICE (founded in 2004) features unbiased ‘edited journalism’ summaries and information from media organizations, policy groups and individuals; and ‘gathering’ public policy information, including articles, reports, speeches. For more information contact MYRON CRIESeditor, [email protected], Springfield, Virginia; 703/304-1897;