State Farm Insurance Companies Issues Public Comments to DOT – InsuranceNewsNet

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WASHINGTON, August 27 — State farm insurance companies, Bloomington, Ill.made a public comment to US Department of Transportation. The comment was written and published on August 22, 2022.

The comment, on Case No. NHTSA-2022-0021-0001, was sent to Anne Carlsoninterim administrator of the National Highway Safety Administration.

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Thank you for giving me the opportunity to comment National Highway Safety Administration (NHTSA) Notice of Proposed Rulemaking (ANPRM) regarding increasing the amount of pre-crash time and vehicle data that Event Data Recorders (EDRs) are required to capture posted on June 22, 2022. State Farm Mutual Automobile Insurance Company (state farm) has a long history of advocating for improved automotive and road safety for the benefit of its customers and the general public and recognizes NHTSA’s work in balancing innovation and safety considerations. As with NHTSA, state farm supports automotive technological advances insofar as they improve automotive and road safety.

state farm is the nation’s largest auto insurer with over 40 million active auto insurance policies. Its 19,400 agents and more than 53,000 employees process approximately 87 million policies and accounts, including handling tens of thousands of auto insurance claims every day.

state farm is very active in promoting research to increase safety on WE roads and highways. state farm supports developments that have the promise of saving lives and preventing injuries, including ongoing research and consumer education on the impact of advanced automotive technologies. state farm has been actively involved in providing information to NHTSA on safety-critical event data created by current Advanced Driver Assistance Systems (ADAS) and Automated Driving Systems (ADS) technologies and ensuring that Access to relevant pre-accident EDR data is made available to law enforcement and other parties, including insurance companies. To this end, state farm is grateful that the ANPRM for EDR proposes to increase the recording time of the EDR and the vehicle data items captured by the EDR.

Automated vehicle technology will have a significant impact on how insurers protect policyholders and claimants against loss and financial risk. state farm supports technological developments that promise to save lives and prevent injuries, including the integration of higher levels of automation into vehicles to minimize human error factors and encourage safer driving behavior. While highly automated vehicles will reduce or eliminate many hazards on the roads, drivers will still need to be protected against the unexpected. In addition, technologies such as data collection after accidents can help make vehicles even safer in the future.

As a promoter of technological advances that will improve automotive safety, state farm participates in a number of research opportunities across the country. state farm is a founding member of the University of Michigan MCity program and is a member of the National Center of Excellence for Surface Transportation Safety hosted by the Virginia Tech Transportation Institute. In addition, state farm has also published consumer research and has been a key participant in a number of automated vehicle forums and conferences, including the National Transportation Safety Board program on Advanced Driver Assistance Technologies, the International SAE Government/Industry Meeting and the AUVSI/TRB Symposium on Automated Vehicles. These efforts have helped to position state farm as a thought partner and technology leader in automated driving systems.

state farm must gather and analyze a number of data points in order to effectively underwrite auto insurance policies, determine liability and appropriate settlement amounts in over 10 million auto insurance claims each year. NHTSA developed its Federal Automated Vehicle Policy Guidance which was released in 2016 (Guidance) highlighting the importance of data access in determining the performance of automated vehicle technology. In addition, this data is essential in determining the facts of a collision and the assessment of fault. Consequently, state farm appreciates the following guidance language:

For crash reconstruction purposes (including during testing), it is recommended that ADS data be stored, retained, and readily available for retrieval as is current practice, including applicable privacy protections, to accident event data recorders.

Vehicles must record, at a minimum, all available information relating to the accident, so that the circumstances of the accident can be reconstructed. This data should also contain the status of the ADS and whether the ADS or the human driver was in control of the vehicle before, during and immediately after an accident. Entities must have the technical and legal ability to share relevant recorded information necessary for accident reconstruction purposes with government authorities. (Emphasis added)

state farm already submitted comments to NHTSA regarding minimum recommended EDR requirements. The base of state farm recommendations stem from his sponsored research engagement with Carnegie Mellon on the functionality of automated vehicles in various situations. Work with the Pennsylvania Department of Transportation, Carnegie Mellon carried out tests in Pennsylvania and identified the following approach to handling accident information. An ADS EDR must contain at least:

* Individual sensor data (static and moving obstacles)

* Forward and cabin views

* Sensor Fusion Outputs (Obstacle Classification)

* Location – where the vehicle is in terms of latitude and longitude

* Driving background – at intersection, lane change, speed, etc.

* Decision making – traffic light status, slowdown

* Current and predicted trajectory and velocity profiles

* Health status of hardware and software tasks

* V2X communications

In terms of duration, only the last 5 minutes (with a maximum of 10 minutes) of driving data should be stored in the ADS data logger depending on by Carnegie Mellon research to date. state farm The position, consistent with the spirit of AV 2.0, is that ANPRM regarding EDRs further supports a standardized framework for data availability.

It is important to note that access to ADAS data is a key issue for many stakeholders. The American Association of Motor Vehicle Administrators (AAMVA) released its “Jurisdictional Guidelines for the Safe Testing and Deployment of Highly Automated Vehicles” highlighting in a number of sections the need to make crash data available to law enforcement and other parts. Moreover, the Governor’s Highway Safety Association (GHSA) Automated Vehicle Safety Expert Group: The Engaging Drivers and Law Enforcement workshop highlighted that data access is a critical issue for law enforcement and other stakeholders.

For the reasons stated by NHTSA in the Rulemaking Analyzes and Notices section, state farm supports NHTSA authority through ANPRM process to increase pre-crash EDR recording time from 5 seconds to 20 seconds recording time and 2 second sampling rate samples per second (Hz) at the enhanced rate of 10 Hz.


In conclusion, state farm appreciates the opportunity to provide NHTSA with feedback on ANPRM regarding EDRs and to continue to advance the goal of improving automotive and road safety for the benefit of its customers and the general public. state farm commends NHTSA for taking this step in promoting a standardized approach to existing capabilities to capture, access, and analyze relevant pre-crash data. state farm looks forward to continuing to work with NHTSA on rulemaking and other issues related to automated vehicles.

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


Maria L. Hagglund

Advice, Public Policy Resource Group

State farm insurance companies

Corporate Law Division

Mobile: (309) 533-9409

E-mail: [email protected]

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TARGETED NEWS SERVICE (founded in 2004) provides nonpartisan news and information on “edited journalism” for news organizations, public policy groups and individuals; as well as “collected” public policy information, including press releases, reports, speeches. For more information, contact MYRON STRIPPEDeditor, [email protected], Springfield, Virginia; 703/304-1897;

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