Transport Canada I

Feed back to Transport Canada regarding

Telematics induced

Driver distraction

The phenomenon & the Product Model

Revolution in Computing and Communications is sweeping the planet. Current computing and communication trend is certain to add new capabilities and features to appliances and machines that have not changed much since they were first conceived. Such appliances range from the light bulbs in the house to the refrigerator, the stove and even the bathtub.

New and devices for old uses or devices in search of uses are causing a glut of information in technical magazines. One of the areas being affected by this revolution is the transportation industry in general and in personal transportation–cars in particular.

Computing in the car is not new. Embedded systems have been on the market for a while, but the new growth is in the area of consumer computing, communication and digitized entertainment in the car. This is Telematics.

Using existing business models products, (Communications, Automotive and Desktop computing), to achieve Telematics however, can only be done safely if the car is driven by a chauffer in complete isolation from a passenger is operating the devices.

Consumers of these three business models, (Communications, Automotive and Desktop computing), are not having a chauffer driven vehicle to allow them to use Telematics. They have created a Status Quo Product that can be described as follows:

1: Mobility and Portability of Personal data

2: Mobility/un-tethered communication

3: Mobility sources of data (In real time).

This is a new product and a life style. This is the trend and no one person, company or a nation can afford to be left behind.

Adding Telematics technology is no longer a side show to the driving experience. Not having Telematics is almost as disadvantageous as not having an internet and e-mail accounts.

The immediate future will begin to highlight such disadvantages as those who will take advantage of it will speed past their counterparts due to Telematics access.

What is the problem?: Business Models

Competing Business Models

The current industries involved, Automotive, Communication and Computing/Nomadic devices and services are competing among themselves to dominate Telematics. Statements like “Owning the customer”, “Conquering the customer”, and “Assuring continued revenue stream” and similar statements were echoed by industry leaders in their enthusiasm to explain the benefit of adapting Telematics to their products.

While this issue on its own is not unusual or negative, it serves as an example to the mind set behind the solutions presented so far on the market.

Wrong Business Models:

All industries care and want the best for their consumers. The problem we face in Telematics is in the business models of several disciplines meeting to serve an uncharted territory, without changing the models… We do not find any of the existing models are fit to service this new Product Model.

Unfortunately for the automotive industry, the Driver Distraction is manifesting it self behind the wheels because other business models products are being demanded and brought into the driving environment.

The following is our observation/conclusions about the business models that we believe attribute to the distraction problem

Cellular Carriers

1. They want users to answer the phone quickly so as not to tie up the circuit

2. Their money is made from high usage, not from missed calls

3. safe user interface means large and consumers want small and discrete devices

4. Large means more battery power and consumers want long lasting power source

5. The want consumer to answer promptly so they design phone ringers be attention getter/persistent/not pleasing

6. They still allow drivers to connect with poor signal strength even though it is a source of annoyance and distraction

All of the above are a good indications that the cellular mobility model is not fit to work in the vehicle as a solution to driver distraction.

Automotive companies

1. They can and will fit any device into the vehicle

2. certain business models want the` consumer to use their services (OnStar)

Electronic and Software manufacturers (Automotive)

1. Before Telematics, their products were mostly machine to machine products.

2. Man to machine interface was limited to Radios and Entertainment accessories which did not require cognitive interaction but still caused distraction due to the Eyes Off The Road requirement.

Electronic and Software manufacturers (Desk top and Nomadic devices)

1. They are only a link in they chain and they work to customer/consumer specifications

2. Their experience and products are designed to Desk top application/stand alone environment

In contrary to the features above, The Mobility trend sought by consumers as demonstrated by their activities demonstrate elements that did not exist before. The new elements involve Man, Machine, Infrastructure, other drivers, laws and environment with significant work load for information processing. But this time it involved doing all of the above at Driving Speed.

What is immediately needed is a Gateway that allows all of these elements into the driving environment, but it forces them into synchronous system by conforming business/product models from various industries to “Safe Driving Compatible.”

New York State case study

The study on the law passed in New York banning the use of Hand held cell phone while driving focused on effectiveness in curbing such use. The study by the Insurance Institute for Highway Safety, “Long Term Effect of New York State’s law on Handheld Cell Phone Use¹” showed that initially, consumers complied with the law and the rate of handheld phone usage while driving dropped initially but crept back up to a level close to the pre-law level.

The authors attributed this to the lack of continued publicity about the law and the enforcement of the law.

From this study, we have three conclusions that we like to share:

1. The Driving public already recognize that using handheld cell phone is not the right thing to do

2. Education, enforcement, and publicity about enforcement are necessary to keep the awareness high

The two conclusions above are shared with the writers of the report. We do however have an additional conclusion which we draw from our experience and interviews with drivers that use cell phone while driving

3. The Driving public are willing to comply with the laws, but they need an empowering solution to :

a) Enable them to answer the phone without taking their eyes off the road

b) Enable the drivers to make calls without taking their eyes off the road

Unfortunately, the current “Hands Free” solutions do not permit the users to do either, (Answer the phone if they chose or make a call). This is due to the following:

1. Lack of such feature, (Hands free are only a speaker or an ear piece that relieves the drivers from holding the phone.

2. When speech recognition is used it has proven to be unreliable and a source of irritation and distraction to the users.

Our Solution

Our solution was designed to address several existing shortcoming, which we believe will alleviate a symptom like the one experienced in New York, because we will empower the user to make and receive calls with out having to hold the cell phone.

The system is a three tier approach:

1. Assessment process (See assessment outline page)

2. Hands on Wheels user interface (See Product page)

3. Intelligent assistant option (for advanced features)

Here are the highlights of the solution capability:

1. All Telematics activities can be initiated and responded to only by placing hands on the wheels (between 9:15 and 10:10).

2. Accepts any Nomadic or Built in system that can communicate with another CPU

3. Allows drivers to make or receive calls without “taking eyes off the road or hands off the wheel”

4. Permits the addition of numerous applications but will not permit more then one ongoing activity at a time

5. All feed back to the driver are speech based and may be displayed on a HUD

6. The interaction with the system will stop unless the driver keeps his hands on the wheels (between 9:15 and 10:10). This will assure that the driver will not take additional load to driving.

7. If the driver faces excessive maneuvering the call or activity are placed on hold until the hands are back on the wheels (between 9:15 and 10:10).

8. Accommodates handicapped by allowing single sensor operation

9. For a single Telematic application e.g. phone, Will require one active sensor and only one hand on the wheel while driving

10. Same application or system can be fitted to any vehicle, but the assessment process will configure the system differently to meet driving application need within safety guideline.

Critique AIAM Guidelines 1/3
Item	Guidelines		Our position
The Lack of HMI guideline is a serious short coming. Speech recognition has been around long enough to issue a judgment on its role as a solution or contribution to driver distraction.
1	Section 1.0 Installation Principles System will be located and fitted to conform to applicable standards, e.g., SAE, ISO, and regulations, e.g., FMVSS, CMVSS, and manufacturer-specific installation instructions.	Disagree: *manufacturer-specific installation instructions.* As evident by the deployment of rear seat entertainment screens that completely blocks the Inside rear view mirror, manufacturers guideline are not enough guarantee against poorly implemented design.
	1.2 No part of the system should obstruct the driver’s field of view as defined by applicable regulations.	Agree (Not a new concern or solution)
	1.3 No part of the physical system should obstruct any vehicle controls or displays required for the driving task.	Agree (Not a new concern or solution)
	1.4 Visual displays that carry information relevant to the driving task and visually intensive information should be positioned as close as practicable1 to the driver’s forward line of sight.	Agree BUT: No visually intensive information should be made available to driver during driving Display location and position must be adjustable to accommodate individuals seating preferences and comfort
	1.5 Visual displays should be designed and installed to reduce or minimize glare and reflections.	Agree (Not a new concern or solution)
2	Section 2.0 Information Presentation Principles 2.1 Systems with visual displays should be designed such that the driver can complete the desired task with sequential glances that are brief enough not to adversely affect driving.	Disagree 1. Information should be presented to the driver so one glance is sufficient to get desired Status 2. Audible option should be available
	2.2 Where appropriate, internationally agreed upon standards or recognized industry practice relating to legibility, icons, symbols, words, acronyms, or abbreviations should be used. Where no standards exist, relevant design guidelines or empirical data should be used.	Agree

Critique AAM Guidelines 2/3
Item	Guidelines		Our position
	2.3 Available information relevant to the driving task should be timely and accurate under routine driving conditions.	Agree (Not a new concern or solution)
	2.4 The system should not produce uncontrollable sound levels liable to mask warnings from within the vehicle or outside or to cause distraction or irritation.	Agree (Not a new concern or solution)
3	3.0 Principles on Interaction with Displays and Controls 3.1 The system should allow the driver to leave at least one hand on the steering control.	Disagree: Any system that requires at least one hand to be off the steering wheel is an *invitation to lane departure risk* due to two factors 1: Human physiology and the subconscious Linkage between booth arms 2: Possibility of eyes moving away from the road
	3.2 Speech-based communication systems should include provision for hands –free speaking and listening.	Agree (Not a new concern or solution)
	Starting, ending, or interrupting a dialog, however, may be done manually.	Disagree According to Japanese statistics, > 42% of cell phone related accident occur when a driver attempts to answer a call
	A hands-free provision should not require preparation by the driver that violates any other principle while the vehicle is in motion.	Disagree No adjustment/preparation of any sort by the driver while vehicle speed is Greater then Zero MPH
	3.3 The system should not require uninterruptible sequences of manual/visual interactions.	Agree (We recommend that only one action is required to execute any step and that multiple steps be avoided.)
	The driver should be able to resume an operator-interrupted sequence of manual/visual interactions with the system at the point of interruption or at another logical point in the sequence.	Agree

Critique AAM Guidelines 3/3
Item	Guidelines		Our position
	3.4 In general (but with specific exceptions) the driver should be able to control the pace of interaction with the system. The system should not require the driver to make time-critical responses when providing input to the system.	Agree (Coincides with the European guidelines)
	3.5 The system’s response (e.g. feedback, confirmation) following driver input should be timely and clearly perceptible.	Agree (Not a new concern or solution)
4	Section 4.0 System Behavior Principles 4.1 Visual information not related to driving that is likely to distract the driver significantly (e.g., TV, video and continuously moving images and automatically scrolling text) should be disabled while the vehicle is in motion or should be only presented in such a way that the driver cannot see it while the vehicle is in motion.	Agree (Information not important to driver or driver information should not interfere with the driver and the driving function)
	4.2(a) System functions not intended to be used by the driver while driving should be made inaccessible for the purpose of driver interaction while the vehicle is in motion.	Agree (Our patent cover such features)
	(b) The system should clearly distinguish between those aspects of the system, which are intended for use by the driver while driving, and those aspects (e.g. specific functions, menus, etc) that are not intended to be used while driving.	Agree (Our assessment process covers such area)
	4.3 Information about current status, and any detected malfunction, within the system that is likely to have an adverse impact on safety should be presented to the driver.	Agree (Not a new concern or solution)

Critique JAMA Guidelines 1/2
Item	Guidelines		Our position
The Lack of HMI guideline is a serious short coming. Please see our analysis of the New York State regulatory experience.
1	The downward viewing angle and upper edge of the visual display are specified in mathematical terms	Disagree Display location and position must be adjustable to accommodate individuals seating preferences and comfort
2	Televised pictures and recorded video images are forbidden; only static, easy to-read images that are relevant to driving are permitted;	Agree
3	Dialing of a ten-key number on a cellular telephone is forbidden;	Disagree: Dialing a number on a key pad of any length should not be allowed if a vehicle is at a speed > 0 MPH
4	Data input, search, and selection of addresses, telephone numbers, or other information are not permitted;	If input method involves visual attention of any duration and if a vehicle is at a speed > 0 MPH Then we Agree
5	With regard to navigation systems,
5a	maps may not scroll	Disagree, in many cases, Maps that rotate to reflect real world position/orientation are important to certain drivers and such feature should be a choice
5b	may not be searched by topic, area name, or point of interest	If input method involves visual attention of any duration and if a vehicle is at a speed > 0 MPH Then we Agree
5c	cursor may not be used to set or revise the destination;	If input method involves visual attention of any duration and if a vehicle is at a speed > 0 MPH Then we Agree
5d	Requirements are laid out governing the complexity and scale of maps	Agree in principle that layout should be simple clutter free with no animation
5e	Addresses and telephone numbers of locations may not be displayed on maps	Agree
5f	nor may descriptive information appear such as advertisements, for hotels and restaurants	Agree in principle that layout should be simple clutter free with no animation
5g	Travel time displays must be recognizable at a glance, without requiring complex calculation by the driver;	Agree
Critique JAMA Guidelines 2/2
Item	Guidelines	Our position
5h	When dynamic traffic information is superimposed on an electronic road map, the map must be automatically simplified to make comprehension easier;	Agree All information must be audible Or presented symbolically
5i	For written traffic information, scrolling of text is not permitted and the information must not exceed 30 characters or words in length.	Disagree All information must be audible Or presented symbolically With graphics and numbers. 30 character in Kanji is a lot of information, but 30 words in English is difficult to read and comprehend on the fly.

Answers to the possible Strategies 1/2
Item	Question	Our position
1	Question 1: Is the status quo in dealing with this problem of driver distraction sufficient?	Disagree: *By allowing only the industry and the market trend to deal with the problem, we are betting on a single minded track to determine a solution.* *The industry speech recognition effort and its failure to deliver a solution is an example of the status quo failure to solve the problem*
2	Question 2: Should a public awareness campaign be initiated to warn people of the dangers of driver distraction from telematics devices?	Agree: Any education is a good education, but the truth is that education without a solution is going to cause similar results to that of the New York state law, and will end up in frustration and failure
3	Question 3: Should MOUs be negotiated to voluntarily commit the automotive industry in Canada to follow certain human factors design guidelines, provide telematics information on event data recorders, contribute to a vehicle features database and apply a driver-system integration process when designing telematics devices?	Somewhat agree, BUT: We suggest that we look at the activity in Europe, where the government, Industry and academia are working together to produce a solution and to shore up and create new opportunities in the ITS area. Please see www.ertico.org for Work groups and their focus. All industries effecting and causing such problem should be included in the MOU This may include the government *sponsoring diverse approaches* to solving the problem and finally picking up a solution or a method over others.
4	Question 4: Should an advisory be issued to industry stating the need to follow strict safety guidelines and a driver-system integration process when designing telematics devices?	Agree The current guidelines issued by the industry are being violated by the industry it self. Example: The following is a caption from page 46 of the AMA *“Finally, reach to the system controls should be possible without requiring a hand to be placed through openings in the steering wheel.”* In Practice, Driver Advocate system by Motorola/Chrysler, positions the controls specifically through the opening in the steering wheel (See Automotive Engineering October 2003, Page 42.)

Answers to the possible Strategies 2/2
Item	Question	Our position
	Question 5: Should a regulation be made requiring manufacturers to follow a human factors process standard for designing telematics devices?	Agree First, an open and participatory activity should take place like that going on in Europe now.
	Question 6: Should a regulation be made requiring telematics devices to be automatically disabled when a vehicle is moving? What should be included?	Disagree: Telematics users will resort to nomadic devices if their built in equipment is turned off. We refer you back to our answer in Question 5 and to our analysis of the state of New York law case.
	Question 7: Should a regulation be made requiring manufacturers to follow JAMA guidelines?	Disagree JAMA guideline fails to empower drivers to safely interact or control the system, which is a serious deficiency. We refer you back to our analysis of the state of New York law case.
	Question 8: Should manufacturers be required to limit the total glance time away from the road and maximum glance duration for in-vehicle tasks?	Agree Any glance away from the road is a cause for concern We recommend Audible and/ some form Head up display
	Question 9: Should Transport Canada make a regulation requiring manufacturers to a- Prohibit the use of open architectures b- Configurable interfaces c- Set limits on the design and number of functions available through multifunction interfaces on telematics devices?	a- Disagree: Open architecture should not be banned but all Nomadic equipments should be controlled by a common safety standard via the vehicle system b- Disagree: Configurable interfaces must be subject to standards (Not like PC desk top) but it should not be banned because it can help reduce cognitive workload c- Agree: Especially when the vehicle is in motion.
	Question 10: Are there any suggestions for other regulatory initiatives, including provincial/territorial restrictions on driver behaviour, or non-regulatory initiatives that could be explored to limit the risk of collisions caused by driver distraction from telematics devices?	1: Breaking down telematics application and usage to Skills Levels, just like in any other driving privilege licensing, e.g. Operator permit, Chauffer permit, truck driving permit etc. 2: Require drivers to be sufficiently trained and licensed to operate Telematics while driving.