Proposal to amend footnote 25 to reduce the maximum number of recorded DCAS warnings from 15 to 10 per current ignition cycle. The justification presented cites data burden reduction while retaining information about habitual driver disengagement patterns. Supporting documentation references two autopilot collision cases—Florida 2016 and California 2018—where recorded warnings within existing data retention periods would have revealed repeated disengagement that current recording parameters miss, demonstrating that 10 warnings combined with extended recording duration enables identification of ineffective warning strategies.
Passive Safety