U.S.

Department
Memorandum
of Transportation

National Highway
Traffic Safety
Administration

Subj ect ACTION: Docket Submittal, Summary ofNHTSA Date: APR ;19 2012
Brake-Throttle Override Tests for NPRM on
FMVSS No . 124 [77 FR 22638]

From Nathaniel Beuse

Director, Office of Crash A voidance S
To :

Thru 0. Kevin Vincent

Chief Counsel

Please include the provided attachment as a submittal to Docket No. NHTSA-2012-0038 . This
document, titled "Results ofNHTSA Stopping Distance Tests of Production Brake-Throttle
Override Systems" is referenced in footnote number 16 ofthe April 16, 2012 notice of proposed
rulemaking (NPRM) on Federal Motor Vehicle Safety Standard No. 124, " Accelerator Control
Systems."

Attachment (9 pages)

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Results of NHTSA Stopping Distance
Tests of Production Brake-Throttle
Override Systems

Conducted at NHTSA Vehicle Research

and Test Center, East Liberty, OH
Spring-Summer 2010

1
 Brake-Throttle Override – Testing Method
Conduct stopping distance tests in a wide-open throttle (WOT)
condition:
– Similar to FMVSS 135 High Speed Effectiveness Test, but accelerator
pedal held down while brake applied
– Brake pedal force (BPF) of 500 Newtons (112 lb)
• ‘Best Effort’ pedal force (maximum ability of test driver) used in some tests
when vehicle did not stop with 500N of BPF
– Six vehicles selected: 2 with Brake-Throttle Override (BTO), 2 without
BTO, and one vehicle tested with BTO both enabled and disabled (via re-
flash of control module)
– Test Speed: 80% of vehicle maximum (but not exceeding 99MPH)
– Three test conditions:
1. 500N continuous brake apply (similar to FMVSS 135, S7.6)
2. Modulated Brake Application - 2 cycles of a 1 sec. on/1 sec. off modulation;
then brake pedal held @ 500N on 3rd modulation cycle
3. Vacuum Inoperative – 500N continuous brake apply without vacuum assist
- extreme case representing double failure (stuck accelerator with brake boost failure)
2
 Overall Summary
(Number stops for each test configuration)
WOT with WOT with WOT with
Continuous Brake Apply Modulated Brake Inoperative Vacuum
500N BPF Best Effort 500N BPF Best Effort 500N BPF Best Effort
Dodge Caravan
(with BTO) 6/6 3/3 6/6
BMW X3
(with BTO) 6/6 3/3 0/2 3/3
Lexus ES350
(with BTO) 6/6 3/3 6/6
Lexus ES350
(BTO disabled) 0/3 1/1 0/0* 3/3 0/0* 0/4
Buick LaCrosse
(no BTO) 6/6 3/3 0/2 1/2
Ford Taurus
(no BTO) 6/6 0/1 1/1 0/2 3/4

Green = Successful stops/Number of Attempts (500N applied to brake pedal)

Yellow = Successful stops/Number of Attempts (Best Effort applied to brake pedal)
Red = Did Not Stop/Number of Attempts (500N or Best Effort braking)

*The Modulated Brake and Inoperative Vacuum test configurations at the 500N pedal force were not completed on
the ES350 with BTO disabled. The vehicle’s failure to stop in the Continuous Brake Apply condition demonstrated
that it would have been unable to stop in the more severe Modulated Brake and Inoperative Vacuum tests.
3
 Summary: WOT Stops with
Continuous Brake Apply
– BTO-Equipped:
• Caravan – 6/6 stopped
• BMW X3 – 6/6 stopped
• Lexus, BTO enabled – 6/6 stopped
– Not BTO-Equipped:
• LaCrosse – 6/6 stopped
• Taurus – 6/6 stopped
• Lexus, BTO disabled –
 500N – Did not stop (slowed to about 2.5 MPH)
 Best effort – driver able to stop vehicle
4
Stopping Distance - Continuous Brake Apply
WOT with constant brake pedal force - Average Corrected Stopping Distance

Caravan 383.6

X3 363.4 BTO

ES350+BTO 422.8

ES350 DNS @500N

Taurus 449.3
No BTO

LaCrosse 512.4

0 500 1000 1500 2000 2500

Stopping Distance (feet)

DNS = “Did Not Stop” w/ 500N Brake Force, therefore test was aborted.

5
 Summary: WOT Stops
with Modulated Brake Pedal
– BTO-Equipped:
• Caravan – 3/3 stopped
• BMW – 3/3 stopped
• Lexus, BTO enabled – 3/3 stopped
– Not BTO-Equipped:
• Lacrosse – 3/3 stopped
• Taurus –
 500N – Did Not Stop (0/1), slowed to about 25 MPH
 Best Effort – 1/1 Stopped (282 lb peak BPF)
• Lexus, BTO disabled –
 500N – Did Not Stop (slowed to about 55 MPH then began to
accelerate gradually )
 Best Effort – 3/3 stopped (300 lb peak BPF)
6
 Stopping Distance – Modulated Brake
WOT with Modulated Brake Pedal - Average Corrected Stopping Distance

Caravan 465.7

X3 469.9 BTO

ES350+BTO 669.9

ES350 DNS @500N

Taurus DNS @ 500N

DNS @500N
No BTO

LaCrosse 735.8

0 500 1000 1500 2000 2500

Stopping Distance (feet)

DNS = “Did Not Stop” w/ 500N Brake Force, therefore test was aborted.

7
 Summary: Inoperative Vacuum Testing
– BTO-Equipped:
• Caravan – 6/6 stopped
• BMW X3 –
 500N – vehicle slowed to 4 MPH then slowly increased to 20 MPH
 Best Effort – 3/3 stopped
• Lexus, BTO enabled – 6/6 stopped
– Not BTO-Equipped:
• LaCrosse –
 500N – Did not stop (0/2), slowed to about 25 MPH
 Best Effort – 1/2 stopped and 1/2 slowed to 7 MPH
• Taurus –
 500N – Did not stop (0/2), slowed to about 25 MPH
 Best Effort – 3/4 stopped, 1/4 slowed to 2.5 MPH then accelerated
gradually
• Lexus, BTO disabled –
 500N – Did Not Stop (slowed to about 60-70 MPH then creeped)
 Best Effort – 4/4 Did Not Stop (slowed to about 5 MPH)
8
 Stopping Distance - Inoperative Vacuum
WOT with Inoperative Brake Vacuum - Average Corrected Stopping Distance

Caravan 867.3

X3 DNS @500N BTO

ES350+BTO 1005.9

ES350 DNS @500N DNS @500N

Taurus DNS @500N

DNS @500N
No BTO

LaCrosse DNS @500N DNS @500N

0 500 1000 1500 2000 2500

Stopping Distance (feet)

DNS = “Did Not Stop” w/ 500N Brake Force, therefore test was aborted.