As we shared in June the National Highway Traffic Safety Administration announced a proposed rule – adding both AEB and pedestrian AEB (PAEB) to its two main programs for increasing vehicle safety: the New Car Assessment Program (NCAP) and a Federal Motor Vehicle Safety Standard (FMVSS) regulation.
While we believe this rule is holds incredible potential to prevent many fatalities and mitigate a large number of non-fatal injuries, we did find it important to comment on one point.
While preliminary testing has demonstrated the efficacy of thermal imaging in pedestrian detection, formal testing of PAEB systems, as would be required by the proposed rule will depend on the availability of test equipment that accurately represents the appearance of pedestrians not only to visible cameras and radar but to the new thermal cameras provided by Owl and others.
In the proposed rule, the requirements for pedestrian mannequins to be used with cameras and radar are included in detail in paragraph VIII A. However, this section also indicates that NHTSA is not currently prepared to include specifications for mannequins that can be seen by thermal imagers in the rule. 
Owl would respectfully like to suggest that the rule take a slightly different position. Our comment letter reads:
Mannequin Thermal Signature
Mannequins with thermal signatures similar to those produced by human pedestrians have already been produced. Some of these, including the mannequins in the Owl tests, had external heated blankets to simulate skin temperature in the test environment but 4Active Systems, the company referenced at the beginning of paragraph VIII A, has already manufactured a mannequin, the 4Active HT, which incorporates a five-zone heating system, Attachment No. 3 is the operating manual for this mannequin.
In this same paragraph, the proposed rule mentions the standard ISO 19206-2:2018 covering pedestrian mannequins. While this edition of the standard does not include a specification for heated mannequins, the committee responsible for ISO 19206 has already announced that it will convene a meeting later in 2023 to consider the requirements for a heated mannequin specification and is actively soliciting new members who are experienced in thermal imaging. Thus, it can be expected that sometime before the proposed rule goes into effect, ISO 19206-2 will include a specification for pedestrian mannequins intended for use with thermal detection systems.
Therefore, as paragraph VIII A 5 states, insufficient study of the requirements for an appropriate heated pedestrian mannequin have been done to support inclusion of a specification in the rule. We believe, however, that given the existence of thermal testing underway for over five years with the support and financing of several manufacturers of automobiles and autonomous vehicles, and the growing interest from both standards bodies and manufacturers of pedestrian mannequins, NHTSA should include in the proposed rule the following requirement:
Proposed Rule Modification
“In order to provide vehicle manufacturers the broadest portfolio of detection options in PAEB systems, the protocol for PAEB testing shall include, by the date this rule becomes effective, the use of pedestrian mannequins that produce thermal signatures representative of real-world pedestrians in the applicable test environments.”
Owl AI believes that this is a feasible requirement because sample mannequins with extensive test data already exist and because the organizations have already acknowledged the need to include thermal imaging in their documents.
Further, we believe this will support the essence of the rule – clarifying the testing requirements and standards in a way that more closely mirrors the problem – detecting pedestrians, at night.
Read the full comment letter here
and the full rule proposal here(750 pages)
or here (abbreviated to 113 pages)
