93000 Federal Register / Vol. 89, No. 227 / Monday, November 25, 2024 / Notices 

1Traffic Safety Facts 2021, ‘‘A Compilation of 

Motor Vehicle Traffic Crash Data.’’ U.S. Department 

of Transportation. National Highway Traffic Safety 

Administration. 

2 Ibid. 

3Swanson, E., Foderaro, F., Yanagisawa, M., 

Najm, W.G., & Azeredo, P. (2019, August). Statistics 

of light-vehicle pre-crash scenarios based on 2011– 

2015 national crash data (Report No. DOT HS 812 

745). Table ES1—Yearly Average Statistics— 

Scenario Groups Based on 2011–2015 FARS and 

GES. Washington, DC. National Highway Traffic 

Safety Administration. 

4 88 FR 34366. 

5https://www.euroncap.com/en. 

DEPARTMENT OF TRANSPORTATION 

National Highway Traffic Safety 

Administration 

[Docket No. NHTSA–2024–0078] 

New Car Assessment Program Final 

Decision Notice—Crashworthiness 

Pedestrian Protection 

AGENCY: National Highway Traffic 

Safety Administration (NHTSA or the 

Agency), Department of Transportation 

(DOT). 

ACTION: Final decision notice. 

SUMMARY: This final decision notice 

adds a crashworthiness pedestrian 

protection program to the New Car 

Assessment Program (NCAP) to evaluate 

new model year vehicles’ abilities to 

mitigate pedestrian injuries. Based on 

its previous research, NHTSA concurs 

with and adopts most of the European 

New Car Assessment Programme’s (Euro 

NCAP) pedestrian crashworthiness 

assessment methods, including the 

injury limits for test devices and the 

score calculation method used for 

impact points. NHTSA will identify 

new model year vehicles meeting a 

certain minimum safety threshold on 

the Agency’s website and other 

published literature. This notice 

responds in part to the provisions in 

Section 24213 of the Infrastructure 

Investment and Jobs Act (IIJA), which 

requires NHTSA to incorporate 

measures in NCAP for evaluating the 

protection that new vehicles provide 

vulnerable road users like pedestrians. 

DATES: These changes to the New Car 

Assessment Program are effective for the 

2026 model year. 

FOR FURTHER INFORMATION CONTACT: For 

technical issues, you may contact Ms. 

Christina Smith, New Car Assessment 

Program, Office of Crashworthiness 

Standards (Telephone: (202) 366–1810). 

For legal issues, you may contact Ms. 

Natasha D. Reed or Mr. Matthew Filpi, 

Office of Chief Counsel (Telephone: 

(202) 366–2992). You may send mail to 

either of these officials at the National 

Highway Traffic Safety Administration, 

1200 New Jersey Avenue SE, West 

Building, Washington, DC 20590–0001. 

SUPPLEMENTARY INFORMATION: 

Table of Contents 

I. Executive Summary 

A. Legal and Policy Considerations 

1. 2021 Bipartisan Infrastructure Law (BIL) 

2. 2022 U.S. Department of Transportation 

(DOT) National Roadway Safety Strategy 

(NRSS) 

II. Summary of Updates to NCAP 

III. Background 

A. Adopted Testing Devices 

B. Adopted Test Procedures 

C. Adopted Component Scoring Method 

D. Adopted Procedure for ManufacturerSubmitted Data 

E. Verification Testing Process 

F. Adopted Vehicle Scoring 

Apportionment 

IV. Summary of General Comments on 

Proposed NCAP Updates 

V. RFC Comments and Agency Decision 

A. Test Zone and Markup 

1. RFC Summary 

2. Comments Received 

3. Discussion and Agency Decision 

B. Test Devices 

1. RFC Summary 

2. Comments Received 

3. Discussion and Agency Decision 

C. Test Procedure 

1. RFC Summary 

2. Comments Received 

3. Discussion and Agency Decision 

D. Data Acquisition and Reporting 

1. RFC Summary 

2. Comments Received 

3. Discussion and Agency Decision 

E. Other Comments 

1. Comments Received 

2. Discussion and Agency Decision 

VI. Procedure in Detail 

A. Differences From Euro NCAP Tests and 

Assessment Protocols 

1. Use of the FlexPLI 

2. No FlexPLI Bumper Testing When LBRL 

Is Greater Than 500 mm 

3. FlexPLI Qualification Procedure and 

Testing 

4. Bumper Corner Definition 

5. Active Hood Detection 

6. WAD Limit 

7. Self-Reporting System 

8. NCAP Scoring Apportionment 

9. Credit Publication Process 

B. Injury Limits and Scoring Process 

1. Headform Tests 

2. Upper Legform Tests 

3. Lower Legform Tests 

C. NCAP Proposal for Awarding Credit 

D. NCAP Verification Testing 

VII. Conclusion 

VII. Economic Analysis 

IX. Appendices 

Appendix A: Questions From RFC 

Appendix B: Supplementary Tables 

Appendix C: Vehicle Scoring and 

Verification Testing Example—Passenger 

Car 

I. Executive Summary 

The National Highway Traffic Safety 

Administration’s (NHTSA) New Car 

Assessment Program (NCAP) provides 

comparative information on the safety 

performance of new vehicles and 

availability of new vehicle safety 

features to assist consumers with 

vehicle purchasing decisions and to 

encourage safety improvements. NCAP, 

like many other NHTSA programs, has 

contributed to significant reductions in 

motor vehicle related crashes, fatalities, 

and injuries since its launch in 1978, 

with annual passenger vehicle occupant 

fatalities in the United States falling 

from 32,043 to 26,325 from 2001 to 

2021.1 Unfortunately, this reduction 

was not universal in all categories of 

fatalities and injuries with annual 

pedestrian fatalities increasing by 51 

percent during the same time frame, 

from 4,901 to 7,388.2 While vehicle-topedestrian crashes are not as common as 

vehicle-to-vehicle crashes, they are 

significantly more deadly, with an 

estimated 53 out of 1000 vehicle-topedestrian crashes resulting in a 

pedestrian fatality.3 In comparison, an 

estimated 2.6 out of 1000 vehicle-tovehicle crashes resulted in a fatality. 

Despite improvements in automotive 

safety since NCAP’s implementation, far 

more work must be done to reduce the 

continued high toll to human life both 

in and outside the vehicle on our 

nation’s roads and to encourage safety 

improvements. NCAP is one of several 

NHTSA programs that advance the 

Agency’s mission to reduce fatalities, 

injuries, and economic losses on U.S. 

roadways. Historically, features rated or 

otherwise included in NCAP have 

focused largely on the protection of 

occupants in motor vehicles. However, 

NHTSA has also recognized the 

importance of protecting other 

vulnerable road users (VRUs), such as 

pedestrians, from injury and death due 

to motor vehicle crashes. NHTSA 

published a request for comments (RFC) 

notice on May 26, 2023 (May 2023 

RFC) 4 proposing to add a 

crashworthiness pedestrian protection 

program to NCAP to help address the 

rising number of fatalities and injuries 

to pedestrians. The RFC notice proposed 

largely adopting the devices and 

assessment methods used in the 

European New Car Assessment 

Programme (Euro NCAP) 5 that simulate 

a pedestrian being struck in the side by 

a vehicle traveling at 40 km/h (25 mph). 

However, instead of implementing a 

comparative rating system for 

pedestrian protection as Euro NCAP 

does, NHTSA proposed to initially 

identify new model year vehicles that 

meet a specified minimum safety 

threshold and then transition to a new 


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6The terms ‘‘headform’’ and ‘‘legform’’ are used 

to describe the pedestrian head and leg test devices, 

which are general representations of human heads 

and legs. The head and leg test devices are 

described in greater detail later in this notice. 

7https://www.nhtsa.gov/document/ncaproadmap. 

8The Monroney label, often referred to as the 

‘‘window sticker,’’ is a label affixed to new 

automobiles containing the manufacturer’s 

suggested retail price and other consumer 

information as specified at 15 U.S.C. 1231–1233. 

Continued 

rating system as discussed later in this 

section. 

NHTSA received over 2,800 

comments on the May 2023 RFC notice. 

Commenters included vehicle 

manufacturers, safety advocates, trade 

groups, research organizations, and 

individuals. Commenters broadly 

expressed support for NHTSA’s focus 

on pedestrian safety, although many 

comments did not directly respond to 

the questions asked in the notice. 

After careful consideration of all 

comments received and applicable 

regulatory considerations, NHTSA is 

largely adopting the May 26, 2023, 

proposal with some updates based on 

comments received. This NCAP update 

will test vehicles using four test devices 

used in Euro NCAP Pedestrian Testing 

Protocol, Version 8.5: adult and child 

headforms (representative of the weight 

of an adult and child head), the 

Transport Research Laboratory (TRL) 

upper legform, and the Flexible 

Pedestrian Legform Impactor (FlexPLI) 

lower legform.6 The test devices 

simulate body regions commonly 

injured in vehicle-to-pedestrian crashes 

and have successfully been used in Euro 

NCAP. This update also adopts the 

majority of Euro NCAP’s pedestrian 

crashworthiness assessment methods, 

including the injury limits for each test 

device and the method in which scores 

for each impact point are calculated. For 

pedestrian crashworthiness, NHTSA 

also deviates from its longstanding 

practice of giving NCAP credit for 

crashworthiness features based on 

testing conducted by NHTSA. 

Historically, NHTSA would give credit 

in NCAP and assign ratings based on 

testing conducted by the agency, not 

data provided by manufacturers. Similar 

to the Agency’s current NCAP crash 

avoidance credit system, vehicle 

manufacturers will provide data to 

demonstrate their vehicle models’ 

performance when subjected to the 

pedestrian impact tests. NHTSA will 

perform verification tests on select 

vehicles to corroborate manufacturers’ 

data. In the Agency’s experience, this 

methodology has proven effective at 

driving improvements in safety 

performance. 

NHTSA is not implementing a 

comparative rating system for 

crashworthiness pedestrian protection 

at this time and, instead, will identify 

new model year vehicles that meet a 

certain minimum safety threshold on 

the Agency’s website and in other 

published literature. This pass-fail 

assessment approach is intended to be 

temporary and eventually will be 

replaced with a more refined 

comparative rating approach in the 

future when other planned updates will 

be implemented. These updates include 

new program elements in 

crashworthiness and crash protection as 

well as changes to the safety 

information section on the Monroney 

label—as described in the NCAP 

roadmap.7

A. Legal and Policy Considerations 

NHTSA established NCAP in 1978 in 

response to Title II of the Motor Vehicle 

Information and Cost Savings Act of 

1972. At that time, the program 

provided consumers with frontal impact 

crashworthiness information to assist 

them in their vehicle purchasing 

decisions. Over the years, NHTSA has 

expanded the type of safety information 

provided to consumers and now 

publishes side impact crashworthiness, 

rollover propensity, and advanced 

technology information. As vehicle 

safety and consumer interest evolves, 

so, too, do the components of NCAP. 

In finalizing its decisions for this 

notice, in addition to comments 

received, the Agency sought to address 

requirements in the 2021 Bipartisan 

Infrastructure Law, enacted as the 

Infrastructure Investment and Jobs Act, 

and the U.S. Department of 

Transportation’s National Roadway 

Safety Strategy initiative. These 

considerations are described below. 

1. 2021 Bipartisan Infrastructure Law 

(BIL) 

Section 24213(b) of the BIL requires 

NHTSA to add information about VRU 

safety to NCAP to (i) determine which 

technologies shall be included, (ii) 

develop performance test criteria, (iii) 

determine distinct ratings for each 

technology, and (iv) update the overall 

vehicle rating to incorporate the new 

technology ratings in the public notices. 

In response to these requirements, 

NHTSA published an RFC in March 

2022 that proposed, among other things, 

adding Pedestrian Automatic 

Emergency Braking (PAEB) to NCAP. By 

applying the established inclusion 

criteria in the adoption of PAEB 

technology and the applicable test 

procedures and evaluation criteria 

included in the March 2022 notice, two 

of the four requirements for the 

Vulnerable Road User Safety portion of 

Section 24213(b) will be met upon the 

publication of this final decision notice. 

Further, in May 2023, the Agency 

published an RFC notice proposing to 

update NCAP by providing consumers 

with information about crashworthiness 

pedestrian protection of new vehicles. 

This final decision notice adds 

crashworthiness pedestrian protection 

safety technology evaluations into 

NCAP. As this notice identifies the 

specific technologies for inclusion and 

describes the performance test criteria 

NHTSA will use to evaluate these 

technologies, it further fulfills parts (i) 

and (ii) of Section 24213(b) of the BIL 

with respect to VRU safety. 

NHTSA will fulfill the remaining 

requirements of Section 24213(b) when 

it proposes and finalizes a new rating 

system for the crash avoidance 

technologies in NCAP, updates the 

current crashworthiness rating program, 

and proposes and finalizes an overall 

vehicle rating that incorporates crash 

avoidance and crashworthiness 

technology evaluations. 

2. 2022 U.S. Department of 

Transportation (DOT) National Roadway 

Safety Strategy (NRSS) 

DOT published the NRSS in January 

2022. The NRSS announced key 

planned departmental actions aimed at 

significantly reducing serious roadway 

injuries and deaths to reach the 

Department’s long-term zero roadway 

fatalities goal. At the core of the NRSS 

is the department-wide adoption of the 

Safe System Approach, which focuses 

on building layers of protection to both 

prevent crashes from happening and 

minimize harm when crashes do occur. 

With respect to NCAP, the NRSS 

supports program updates emphasizing 

safety features protecting people both 

inside and outside the vehicle. These 

safety features may include 

consideration of pedestrian protection 

systems, better understanding of 

impacts to pedestrians (e.g., specific 

considerations for children), and 

automatic emergency braking and lane 

keeping assistance to benefit bicyclists 

and pedestrians. The program also 

works to identify the most promising 

vehicle technologies to help achieve 

NRSS’s safety goals, such as alcohol 

detection systems and driver distraction 

mitigation systems. In addition, the 

NRSS includes a 10-year roadmap for 

the program and lists as a key 

departmental action the initiation of a 

rulemaking to update the vehicle 

Monroney label.8 As part of that 


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Notably, the Monroney label contains safety rating 

information generated under NCAP. 9European New Car Assessment Programme 

(Euro NCAP) (October 2018), Euro NCAP Pedestrian 

Testing Protocol, Version 8.5. 10European New Car Assessment Programme 

(Euro NCAP) (June 2020), Euro NCAP Pedestrian 

Protocol—Vulnerable Road User Protection, Part 

1— Pedestrian Impact Assessment, Version 10.0.3. 

11For a summary of the differences between Euro 

NCAP’s assessment protocols and NHTSA’s 

procedure, see Table B1 in Appendix B. These 

difference are also described in more detail later in 

this notice. 

12The term ‘‘Wrap Around Distance’’ (WAD) is a 

distance measurement made using a flexible tape 

measure along the front of the vehicle, as shown 

below in Figure 1. One end of the tape is held at 

ground level directly below the bumper. The other 

end is wrapped around the front end of the vehicle 

and held taut while in contact with a point on the 

hood or windshield. 

13Copyright Euro NCAP 2018. Reproduced with 

permission from Euro NCAP Pedestrian Testing 

Protocol V8.5 Figure 9. 

process, the Agency may also consider 

including information on features that 

mitigate safety risks for people outside 

of the vehicle. 

Today’s final decision notice presents 

NHTSA’s continuing actions towards 

the implementation of this broad, multifaceted safety strategy for NCAP that 

includes improved road safety for VRUs. 

II. Summary of Updates to NCAP 

A brief summary of the updates to 

NCAP included in this final decision 

notice is provided below. 

A. Adopted Testing Devices 

NHTSA will test vehicles using four 

test devices historically used in Euro 

NCAP: adult and child headforms 

(representative of the mass of an adult 

and child head), the Transportation 

Research Laboratory (TRL) upper 

legform, and the Flexible Pedestrian 

Legform Impactor (FlexPLI) lower 

legform, discussed in detail in section 

VI below. The Agency will also adopt 

most of Euro NCAP’s pedestrian 

crashworthiness test and assessment 

methodology,9 10 including the injury 

limits for each test device and the 

methods used for calculating scores for 

each impact point.11 NHTSA will 

identify new model year vehicles that 

meet a certain minimum safety 

threshold on the Agency’s website and 

in other published literature. 

B. Adopted Test Procedures 

The adopted pedestrian protection 

testing will evaluate the potential risk of 

head, upper leg, lower leg, and knee 

injuries to pedestrians hit by the front 

of vehicles. The agency expects that 

vehicles that score well in these tests 

will do so by using designs that absorb 

energy, reduce hard points of contact, 

and include a front-end profile that will 

cause less injury to a pedestrian in a 

crash. 

The crashworthiness pedestrian 

protection test procedures described in 

this final decision notice consist of 

standardized instructions to (1) prepare 

a vehicle for testing, (2) conduct impact 

tests using various test devices, and (3) 

assess a vehicle’s performance based on 

the result of the impact tests. Vehicles 

will first be prepared by measuring and 

marking the front end of the vehicle in 

a prescriptive way to locate the test 

boundaries and impact points on the 

vehicle. Points on the hood for the 

specific ‘‘Wrap Around Distance’’ 

measurements are marked, as shown in 

Figure 1.12

Figure 1: Wrap Around Distance 

(WAD) 13

The impact points will be marked on 

a 100 mm by 100 mm grid on the hood, 

windshield, and surrounding 

components for the head impact tests; in 

a line along the hood (or bonnet) leading 

edge every 100 mm for the impact tests 

at a WAD of 775 mm (WAD775) using 

the TRL upper legform; and in a line 

along the front bumper every 100 mm 

for the lower leg to bumper impact tests 

using the FlexPLI. 

NHTSA is adopting the Euro NCAP 

procedure for preparing and launching 

a test device at a marked impact point— 

specifically, the adult and child 

headforms for the hood and windshield 

area points, the TRL upper legform for 

the WAD775 points, and the FlexPLI for 

the bumper impact points. 

C. Adopted Component Scoring Method 

The vehicle’s performance will be 

scored based on the resulting injury 

assessment values from each impact 

test. For the TRL upper legform and 

FlexPLI impacts, the scoring will be 

based on a sliding scale between the 


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14The lower bumper reference line is the 

geometric trace between the bumper and a straight 

edge at a 25-degree forward incline. 

15This submission form will be specified at a 

later date. 

16The NCAP crash avoidance safety testing 

program highlights vehicles equipped with certain 

advanced driver assistance system technologies if 

the vehicles meet NHTSA’s system performance test 

criteria. Unlike the NCAP crashworthiness safety 

program, the crash avoidance safety program uses 

test data reported by vehicle manufacturers to 

determine whether a vehicle meets system 

performance criteria set forth under NCAP and 

awards credit as applicable. Each year, a certain 

number of advanced driver assistance systems are 

selected and tested to verify system performance as 

part of the NCAP crash avoidance safety testing 

program. 

17NHTSA will utilize the concepts of symmetry 

and adjacency to determine the impact test points 

for upper leg and lower leg impact testing across the 

vehicle width. To reduce test burden, the test 

assumes that a vehicle’s front end is symmetrical, 

and thus the test result on a specific point on one 

side of the vehicle will also be applied to the 

corresponding point on the other side of the 

vehicle. Likewise, an untested point would receive 

the same score as the lowest scored adjacent point. 

highest value of an injury measure 

(resulting in a score of 0) and the lowest 

value of the injury measure (resulting in 

a maximum score). For the headform 

impacts, the scoring will be based on 

discrete ranges of Head Injury Criteria 

(HIC15) values resulting in a score of 

either 0.000, 0.250, 0.500, 0.750, or 

1.000 points. The scores from each 

group of component tests (headform, 

upper leg, and lower leg) will be 

combined to provide a crashworthiness 

pedestrian protection score for the 

tested vehicle. 

A summary of the tests using the four 

adopted test devices is shown in Tables 

1–3, including applicable WAD and 

injury assessment values. The Euro 

NCAP Assessment Protocol—Vulnerable 

Road User Protection, Part 1— 

Pedestrian Impact Assessment, Version 

10.0.3, June 2020 document further 

describes the injury limits and scoring 

process for the crashworthiness 

pedestrian protection impact tests 

outlined in this notice. Details for each 

of these tests, devices, and impact 

locations can also be found in Euro 

NCAP’s Pedestrian Testing Protocol 

Version 8.5, October 2018, and certain 

details are discussed later in this notice. 

TABLE 1—ADULT AND CHILD HEADFORM TESTING SUMMARY

Adult headform test Child headform test 

Impact Velocity ........................................................................................ 40 km/h .......................................... 40 km/h. 

Impact Angle (From Horizontal) .............................................................. 65 deg ............................................ 50 deg. 

WAD ........................................................................................................ * 1500/1700–2100 mm ................... ** 1000–1500/1700 mm. 

HIC15 (Maximum Score) .......................................................................... 650 ................................................. 650. 

HIC15 (Zero Score) .................................................................................. 1700 ............................................... 1700. 

* Points rearward of the bonnet rear reference line (BRRL) between WAD1500 and WAD1700 and up to WAD2100 are assessed using the 

adult headform. 

** Where the bonnet rear reference line is between WAD1500 and WAD1700, points forward of and directly on the bonnet (hood) rear reference line (BRRL) are assessed using the child headform. Where the BRRL is rearward of WAD1700, the child headform is used up to and including 1700 mm. 

TABLE 2—UPPER LEGFORM TESTS AT WAD 775 mm 

Impact Velocity ...................................................................................................................................................................................... 20–33 km/h *. 

Sum of Forces (Maximum Score) ......................................................................................................................................................... 5000 N. 

Sum of Forces (Zero Score) ................................................................................................................................................................. 6000 N. 

Bending Moment (Maximum Score) ..................................................................................................................................................... 285 Nm. 

Bending Moment (Zero Score) ............................................................................................................................................................. 350 Nm. 

* The exact impact velocity is calculated based on the vehicle’s geometry. 

TABLE 3—FLEXPLI LOWER LEGFORM TESTS

[For bumpers with lower bumper reference line 14 500 mm or less] 

Impact Velocity ...................................................................................................................................................................................... 40 km/h. 

Ground Clearance ................................................................................................................................................................................. 75 mm. 

Tibia Bending Moment (Maximum Score) ............................................................................................................................................ 282 Nm. 

Tibia Bending Moment (Zero Score) .................................................................................................................................................... 340 Nm. 

Medial Collateral Ligament (MCL) Elongation (Maximum Score) ........................................................................................................ 19 mm. 

Medial Collateral Ligament (MCL) Elongation (Zero Score) ................................................................................................................ 22 mm. 

Anterior and Posterior Cruciate Ligaments (ACL/PCL) Elongation * .................................................................................................... 10 mm. 

* ACL and PCL elongations act as modifiers. If the stated limit is exceeded, that impact is awarded zero points regardless of the MCL or Tibia 

results. 

D. Adopted Procedure for ManufacturerSubmitted Data 

In order to receive crashworthiness 

pedestrian protection credit, a 

manufacturer must submit the results 

from its own testing to NHTSA in 

accordance with NHTSA’s specified 

procedures.15 NHTSA will accept 

predicted (simulated) results for the 

head and leg impacts on condition that 

the manufacturer also provides evidence 

of physical impact testing to verify the 

models used for the predicted data. 

E. Verification Testing Process 

NHTSA is implementing a 

verification testing process for the 

crashworthiness pedestrian protection 

program similar to that used for the 

crash avoidance testing program in 

NCAP.16 For each new model year, 

NHTSA will select and acquire vehicles 

for NCAP testing. For its 

crashworthiness pedestrian protection 

verification testing, NHTSA will select 

and test 10 head impact points and all 

necessary upper leg and lower leg 

impact test locations on each vehicle.17

The resulting NCAP data for head 

impacts will be compared to the 

manufacturer’s submitted test data 

results to determine any needed 


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18The correction factor is determined based on 

the process described in Euro NCAP’s Assessment 

Protocol—VRU Protection v-10.0.3. 

19NHTSA proposed in the RFC a scoring 

apportionment that aligned with the relative 

frequency of AIS 3+ injuries to the body regions in 

the U.S. Out of possible 36.0 points, 13.5 were 

allocated to head impacts, 13.5 points for lower leg 

impacts, and 9.0 points for upper leg impacts. 

NHTSA revised the scoring apportionment in this 

final decision notice to provide more emphasis on 

head impacts and approach alighment with Euro 

NCAP’s current scoring apportionment. Details of 

the justification are provided in Section VI. 

20https://www.euroncap.com/en/for-engineers/ 

protocols/vulnerable-road-user-vru-protection/. See 

‘‘Pedestrian Test Protocol’’ Version 8.5 and Part I 

of the ‘‘Assessment Protocol—VRU’’ Version 10.0.3. 

Part II of the ‘‘Assessment Protocol’’ and the ‘‘AEB 

VRU Test Protocol’’ do not apply and are not part 

of this proposal. 

correction factor to apply to the entire 

head impact test data set.18 The NCAP 

data for the upper leg and lower leg tests 

will replace the manufacturer’s 

provided data. 

F. Adopted Vehicle Scoring 

Apportionment 

The overall crashworthiness 

pedestrian protection score will 

combine the results from the headform 

tests, the upper legform tests, and the 

lower legform tests with a maximum 

score of 36.000 points. The scoring 

distribution is as follows: 18.000 points 

(50 percent) are allocated to test results 

using the adult and child headforms, 

9.000 points (25 percent) are allocated 

to the test results using the TRL upper 

legform, and 9.000 points (25 percent) 

are allocated to the test results using the 

FlexPLI (Table 4).19 For vehicle models 

that receive an overall score of 21.600 

(60 percent) or greater, the Agency will 

grant credit by providing a checkmark 

(or similar notation) on its website, 

http://www.NHTSA.gov. An example 

scoring calculation is provided in 

Appendix C. 

TABLE 4—SCORING APPORTIONMENT

SUMMARY

Body region Apportionment 

(%) 

Maximum 

possible 

points 

Head ............... 50 18.000 

Upper Leg ....... 25 9.000 

Lower Leg ....... 25 9.000 

III. Background 

NHTSA’s NCAP supports the 

Agency’s mission to reduce the number 

of fatalities and injuries that occur on 

U.S. roadways by providing important 

vehicle safety information to consumers 

to inform their purchasing decisions. 

Over the years, NCAP has periodically 

expanded the scope of the safety 

information the program provides to 

consumers, including through the 

incorporation of various advanced 

driver assistance system (ADAS) 

technologies in NCAP, including 

automatic emergency braking, and 

highlighted those technologies (via the 

Agency’s website) if they meet NHTSA’s 

system performance criteria. In May 

2023, the Agency published an RFC 

proposing to expand the NCAP program 

by providing consumers with 

information about crashworthiness 

pedestrian protection for new vehicles 

to spur protection for those outside of 

the motor vehicle, with a particular 

focus on pedestrian safety. 

The proposal included the addition of 

a testing program simulating a 

pedestrian being struck in the side by a 

vehicle traveling at 40 km/h (25 mph), 

with data gathered to assess injury 

potential to the pedestrian’s head, upper 

leg, and lower leg. The proposed test 

and evaluation procedures included the 

use of four pedestrian test device 

impactors: adult headform, child 

headform, the TRL upper legform, and 

the FlexPLI lower legform. NHTSA 

proposed to carry out testing in the 

manner described in the Euro NCAP 

pedestrian test protocols,20 with some 

differences explained in the RFC notice. 

According to the procedure outlined 

in the RFC notice, vehicles would first 

be prepared by measuring and marking 

the front end of the vehicle in a 

prescriptive way to locate the test 

boundaries and impact points on the 

vehicle. The boundaries for testing with 

different impactors would be 

established at discrete WAD 

measurements. 

The impact points would be marked 

on a 100 mm by 100 mm grid on the 

hood, windshield, and surrounding 

components for the head impact tests; in 

a line along the hood (or bonnet) leading 

edge every 100 mm for the upper 

legform impact tests; and in a line along 

the front bumper every 100 mm for the 

FlexPLI lower legform impact tests. The 

test procedures would provide 

instructions on how to prepare and 

launch the test devices at the 

predetermined impact points— 

specifically, the adult and child 

headforms for the hood and windshield 

area points, the TRL upper legform for 

the hood leading edge points, and the 

FlexPLI for the lower leg impact points. 

Finally, the procedures would describe 

how a vehicle is scored based on the 

resulting measurements collected from 

each impact test. 

In general, the proposed test protocols 

for hood impact tests using the adult 

and child headforms and the impact 

tests using the FlexPLI and the TRL 

upper legform are similar to that of Euro 

NCAP. However, the May 2023 RFC 

proposed some adjustments to the Euro 

NCAP testing protocol to better reflect 

pedestrian protection provided by the 

front end of vehicles in the U.S., 

improve test practices, and align with 

the self-reporting aspect of the proposed 

crashworthiness pedestrian protection 

program. 

NHTSA invited comments on the 

proposed test procedures and their 

applicability to the new U.S. vehicle 

fleet, test zone markup procedure, 

biofidelity and maintenance of test 

impactors, scoring method, and pass/fail 

assessment. The following sections 

provide details of certain aspects of the 

proposal for which comments were 

sought. 

IV. Summary of General Comments on 

Proposed NCAP Updates 

NHTSA received over 2,800 

comments from vehicle manufacturers, 

safety advocates, trade groups, research 

organizations, and individuals in 

response to the May 2023 RFC notice. 

While many comments were not direct 

responses to the questions asked in the 

notice, they broadly expressed support 

for NHTSA’s focus on pedestrian safety. 

Many commenters urged NHTSA to 

incorporate more VRU-focused safety 

initiatives beyond crashworthiness 

pedestrian protection into NCAP, 

including driver direct visibility 

evaluation and information pertaining 

to vehicle weight. Commenters also 

urged NHTSA to include safety 

measures for VRUs other than 

pedestrians, including bicyclists, 

wheelchair users, and people on 

scooters. Additionally, many 

commenters emphasized the importance 

of pedestrian crash avoidance systems 

such as PAEB and other ADAS 

technologies. 

Many comments from private citizens 

and advocacy groups such as America 

Walks, AARP, Action Committee for 

Transit (ACT), Center for Auto Safety 

(CAS), National Safety Council (NSC), 

Advocates for Highway and Auto Safety 

(Advocates), and the National 

Association of City Transportation 

Officials (NACTO) shared similar 

sentiments for increasing stringency, 

updating the 5-star rating system and 

the Monroney label, implementing a 

matching Federal Motor Vehicle Safety 

Standard (FMVSS), and voicing 

dissatisfaction with the manufacturer 

self-reporting system. Advocacy groups 

recommended directing research to 

improve understanding of female injury 

tolerances and representative test 

devices, testing at increased impact 

speeds, and aligning test layout and 


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21The LBRL is defined as the geometric trace 

between the bumper and a straight edge at a 25- 

degree forward incline. 

22The United Nations Economic Commission for 

Europe, Regulation No. 127, ‘‘Motor Vehicles 

Pedestrian Safety Performance.’’ 

23https://unece.org/transport/standards/ 

transport/vehicle-regulations-wp29/globaltechnical-regulations-gtrs. 

procedures to maximize the tested area 

of vehicles. In general, the advocacy 

groups and individual citizens who 

provided comments were supportive of 

NHTSA’s decision to include a 

crashworthiness pedestrian protection 

program within NCAP. 

Vehicle manufacturers and groups 

representing vehicle manufacturers, 

including the Alliance for Automotive 

Innovation (Auto Innovators), 

Automotive Safety Council (ASC), Ford 

Motor Company (Ford), General Motors 

(GM), American Honda Motor Company 

(Honda), Hyundai Motor Company 

(Hyundai), Rivian Automotive (Rivian), 

Tesla, and Volkswagen Group of 

America (VW), recommended 

harmonizing with Euro NCAP 

procedures to the greatest extent 

possible. These comments included 

such recommendations as the adoption 

of the advanced pedestrian legform 

impactor (aPLI) in the long term, test 

device qualification procedures, test 

zone layout, test procedures, 

documentation, point apportionment, 

and results reporting. Overall, the 

vehicle manufacturers that provided 

comments were supportive of NHTSA’s 

decision to include a crashworthiness 

pedestrian protection program within 

NCAP. 

The Agency has summarized the 

sections of the RFC, comments from the 

public, and the Agency’s responses to 

those comments into the following 

categories: test zone and markup, test 

devices, test procedure, data acquisition 

and reporting, and other comments. 

These summaries, comments, and 

NHTSA’s responses are discussed in the 

remainder of this notice. 

V. RFC Comments and Agency Decision 

A. Test Zone and Markup 

1. RFC Summary 

NHTSA requested comments on 

specific test zone details and markup 

procedures for the vehicles to be tested. 

The U.S. vehicle market differs from the 

European vehicle market; therefore, 

NHTSA raised questions concerning 

some of these potential differences. As 

a response to design trends caused by 

the Euro NCAP test protocol, NHTSA 

also requested comments on how the 

bumper test width is defined. Before 

delving into specific comments, the 

Agency believes that outlining some key 

details regarding the test zone and 

markup is important. Further detail on 

bumper corner definition, WAD limit, 

vehicles with a lower bumper reference 

line (LBRL) 21 greater than 500 mm, and 

artificial interference is provided in the 

following sections. 

a. Bumper Corner Definition 

For the lower legform impact tests, 

the FlexPLI is launched parallel to the 

travel direction of the vehicle. The 

intended impact points are spread 

laterally along the vehicle’s bumper test 

zone. The bumper test zone extends 

across the front of the vehicle to either 

the bumper corners on each side or the 

full width of the bumper beam, 

whichever is larger. 

There are currently two existing 

procedures for determining the bumper 

corners: (1) the 60-degree angle method 

specified in Euro NCAP and (2) the 

corner gauge method specified in 

European regulation UN ECE R.127, 

‘‘Uniform provisions concerning the 

approval of motor vehicles with regard 

to their pedestrian safety performance’’ 

(UNECE R127) 22 and Global Technical 

Regulation No. 9, ‘‘Pedestrian Safety’’ 

(GTR 9).23 Euro NCAP uses a vertical 

plane at a 60-degree angle to the 

vehicle’s centerline to mark the bumper 

corner (as shown in Figure 2). Euro 

NCAP then compares this width to that 

of the bumper beam, a load bearing 

structure underlying the fascia, then 

tests the larger of the two areas. In 

Europe, the use of the 60-degree angle 

method has resulted in a design trend in 

which ‘‘touch points’’ are molded into 

the lower portion of the fascia to contact 

the 60-degree plane in a manner that 

could reduce the bumper test area. 

NHTSA found that in some vehicle 

designs, the bumper test area is reduced 

to as little as 40 percent of the vehicle 

width when using the 60-degree angle 

method. When the bumper test area is 

reduced in this manner, a smaller 

portion of the vehicle’s front end is 

tested for pedestrian protection. From a 

safety perspective, a larger bumper test 

area is preferred as it allows the Agency 

to determine the crashworthiness 

pedestrian protection performance for 

more of the vehicle’s front end. 


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Figure 2: 60-Degree Angle Method 

Specified in Euro NCAP 

In contrast, UNECE R127 and GTR 9 

regulations use a corner gauge method, 

which employs a corner gauge device as 

shown in Figure 3. The corner gauge 

method identifies the corner of the 

bumper by locating the outermost point 

of contact with the gauge when it is 

moved parallel to a vertical plane with 

an angle of 60 degrees to the vertical 

longitudinal center plane of the vehicle, 

as illustrated in Figure 4. UNECE R127’s 

definition of the bumper test area also 

includes a specification to ensure that 

the entire width of the stiff bumper 

beam is included in the test area. In the 

May 2023 RFC notice, NHTSA stated 

that it tentatively plans to use the corner 

gauge method and bumper beam width 

comparison procedure for the bumper 

corner definition. 


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24Reproduced from GTR 9 Amendment 2 Figure 

5B. 

25Reproduced from GTR 9 Amendment 2 Figure 

5C. 

26See ‘‘Rationale for limiting the lower legform 

test,’’ paragraph 99 of GTR 9. 

Figure 3: Bumper Corner Gauge 24

Figure 4: Determination of Bumper 

Corner With Corner Gauge 25

As originally brought to NHTSA’s 

attention by GM, trucks and other large 

vehicles with exposed metal bumpers 

may warrant additional consideration 

based on the bumper test zone 

determination procedure above. For 

vehicles with exposed bumpers, NHTSA 

requested comments on whether the full 

width of the exposed bumper should be 

tested, or if the same corner definition 

method as non-exposed bumpers should 

be used. These exposed bumpers are 

often stylized and may be swept back at 

the outboard edges. These 

characteristics would likely result in 

inaccurate measurements when 

impacted with the FlexPLI if the impact 

angle is greater than 60 degrees. For 

vehicles with non-exposed bumpers, 

NHTSA proposed using the corner 

gauge method and bumper beam width 

test procedure. 

b. WAD Limit 

As previously mentioned, the term 

‘‘Wrap Around Distance’’ (WAD) is a 

distance measurement made using a 

flexible tape measure along the front of 

the vehicle. One end of the tape is held 

at ground level directly below the 

bumper. The other end is wrapped 

around the front end of the vehicle and 

held taut and in contact with a point on 

the hood or windshield. The maximum 

WAD in Euro NCAP’s Pedestrian 

Testing Protocol Version 8.5 for an adult 

male is 2100 mm. However, UNECE 

R127 Feb 2023 amendments include 

increasing the WAD limit from 2100 

mm to 2500 mm. Additionally, these 

amendments include tests on the parts 

of the windshield that are within this 

limit. Euro NCAP’s most recent version 

of its testing protocol, Version 9.1, has 

also increased the maximum WAD to 

2500 mm. In the RFC, NHTSA requested 

comment on whether NCAP should also 

raise the WAD limit to account for 

pedestrians who may overshoot the 

vehicle when struck at a higher speed. 

This change would assess the vehicle’s 

ability to provide protection to VRUs in 

a wider variety of crashes. 

c. Vehicles With LBRL Greater Than 500 

mm 

The LBRL is the lower boundary of 

significant points of contact between a 

pedestrian leg and the bumper when a 

vehicle’s front bumper makes contact 

with a pedestrian. The LBRL is 

determined with a 700 mm long straight 

edge held at a 25-degree angle from the 

vertical against the front of the vehicle, 

as illustrated in Figure 5. The FlexPLI 

has a poor kinematic response when 

testing a vehicle with an LBRL greater 

than 500 mm.26 If a FlexPLI test is 

conducted on such a bumper, the 

legform’s lack of an upper body 

structure could result in a condition 

where, upon impact, it is redirected 

groundward with very little tibia 

bending and knee displacement, thus 

leading to an artificially high test score. 

Such kinematics do not accurately 

represent a human-to-vehicle 

interaction. 


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27Copyright Euro NCAP 2018. Reproduced with 

permission from Euro NCAP Pedistrian Testing 

Protocal V8.5 Figure 13. 

28NHTSA noted in May 2023 RFC that the option 

to test with either legform (as permitted by Euro 

NCAP) could lead to conflicting or misleading 

scores since the test parameters and test devices 

used to generate the scorings are not the same. The 

Agency believes that to provide consumers with 

comparative vehicle safety information, vehicles 

should be subjected to the same test devices, testing 

protocals, and evaluation methods. 

29Note that some vehicles may have portions of 

the LBRL greater than 500 mm and some portions 

less than or equal to 500 mm. For those vehicles, 

the portions were the LBRL is less than or equal to 

500 mm would still undergo testing, and the 

portions that have LBRL greater than 500 mm 

would receive the ‘‘default red, no points’’ score. 

30See Euro NCAP Pedistrian Testing Protocal 

V8.5 Section 11, ‘‘Upper Legform to WAD775mm 

Tests’’ for instructions for carrying out the upper 

legform to WAD775 test. https://cdn.euroncap.com/ 

media/41769/euro-ncap-pedestrian-testingprotocal-v8.5.201811091256001913.pdf. 

31The IBRL height is identified where a vertical 

plance contacts the bumper beam up to 10mm into 

the profile of the bumper beam. 

Figure 5: Marking the Lower Bumper 

Reference Line (LBRL) 27

Euro NCAP performs bumper impact 

tests on vehicles with an LBRL greater 

than 500 mm using the TRL upper 

legform. For vehicles with an LBRL of 

425 mm to 500 mm, Euro NCAP gives 

the manufacturer the option of using 

either the TRL upper legform or the 

FlexPLI. However, for vehicles with an 

LBRL of 425 mm to 500 mm, NHTSA 

proposed to only use the FlexPLI.28

Additionally, the Agency proposed not 

testing bumper locations where the 

LBRL is greater than 500 mm for lower 

leg impacts, instead assigning a ‘‘default 

red, no points’’ score.29

d. Artificial Interference in HighBumper Vehicles 

Euro NCAP employs an impact test 

along the bonnet (or hood) leading edge 

with the TRL upper legform impactor 

known as the Upper Legform to 

WAD775mm Test.30 The WAD775 test, 

which is conducted at a WAD of 775 

mm, simulates a pedestrian’s upper leg 

and hip wrapping around the front end 

of the vehicle in the transition area 

between the bumper and the hood. 

Because the pedestrian’s hip wraps 

around the front end of the vehicle, the 

upper legform impactor is set up to 

strike the vehicle perpendicular to a line 

connecting the internal bumper 

reference line (IBRL) 31 (shown in Figure 

6) and a point representing WAD930 as 

shown in Figure 7. These tests are 

conducted at an impact velocity 

between 20 and 33 km/h (12 and 21 

mph). Maximum points are awarded for 

forces below 5 kN and bending 

moments below 280 Nm. The test setup 

is shown in Figure 7. Vehicles with 

higher front ends tend to have lower 

impact angles (relative to horizontal) 

and higher impact speeds with more 

energy. Vehicles with lower front ends 

tend to have higher impact angles 

(relative to horizontal) and lower impact 

speeds with less energy. 


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32Copyright Euro NCAP 2018. Reproduced with 

permission from Euro NCAP Pedestrian Testing 

Protocol V8.5 Figure 15. 

33Copyright Euro NCAP 2018. Reproduced with 

permission from Euro NCAP Pedestrian Testing 

Protocol V8.5 Figure 29. 

Figure 6: Internal Bumper Reference 

Line 32

Figure 7: Upper Legform to WAD775 

Test Setup 33

When testing a high-bumper vehicle, 

the WAD775 mark may appear on the 

grille of the vehicle, well below the 

bonnet leading edge. It could lead to a 

condition in which either the top or 

bottom edge of the TRL upper legform 

impactor would ‘‘catch’’ a protruding 

vehicle component, such as the top edge 

of the bumper—as shown in Figure 8. 

When this condition occurs, the 

impactor may glance off the component 

in such a way that it can absorb a 

significant amount of impactor energy 

without registering a significant moment 

or force in the instrument. NHTSA 

proposed repositioning the upper 

legform ±50 mm away from the 

WAD775 target to avoid situations 

where artificial interference occurs. 


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93010 Federal Register / Vol. 89, No. 227 / Monday, November 25, 2024 / Notices 

Figure 8: Example of Upper Legform to 

WAD775 Glancing Blow 

2. Comments Received 

a. Bumper Corner Definition 

Humanetics, Honda, Tesla, Auto 

Innovators, Advocates, and individual 

members of the public supported the 

use of the corner gauge method for 

determining a vehicle bumper’s corners. 

The ASC, Rivian, and Autoliv supported 

the Euro NCAP 60-degree angle method. 

The Center for Automotive Safety 

Research (CASR) noted that the corner 

gauge method and the Euro NCAP 60- 

degree angle method will usually result 

in the same location for the corner 

definition. Tesla reiterated the point 

that NHTSA made in the RFC, which is 

that the corner gauge method mitigates 

the effect of design trends of the lower 

portion of the fascia that could result in 

a significantly reduced bumper test area 

when using the Euro NCAP 60-degree 

angle method. Rivian stated that the 

Euro NCAP 60-degree angle method is 

the most effective method, and 

harmonization with other NCAPs is 

beneficial. Auto Innovators stated that 

the corner gauge method ensures 

pedestrians will be protected in a larger 

bumper test zone. Additionally, Auto 

Innovators supported NHTSA’s 

combined proposal of using the corner 

gauge method and bumper beam width 

procedure as it enables the evaluation of 

a larger test zone and aligns with 

UNECE R127–02. Humanetics, Honda, 

Rivian, Consumer Reports, Tesla, and 

CASR also agreed that the combined 

approach of using the corner gauge 

method and bumper beam width 

procedure is logical. 

When evaluating exposed bumpers, 

ASC, Honda, Autoliv, and Auto 

Innovators supported using either the 

60-degree angle method or the corner 

gauge method instead of testing the full 

bumper width. Auto Innovators stated 

that performing the lower leg impact 

test at the extreme width of any vehicle 

creates potential issues in terms of 

impactor response and durability and 

increases the possibility of glancing 

blows. Auto Innovators further stated 

the corner gauge method would be 

preferable to the 60-degree angle 

method for exposed bumpers. ACT, 

Rivian, CASR, and individual members 

of the public supported testing the full 

bumper width of exposed bumpers. 

ACT stated that pedestrians may be hit 

by any part of the bumper, and thus, the 

entire bumper should be evaluated. 

Multiple commenters stated that special 

considerations should not be given to 

exposed bumpers, and harmonization 

with the Euro NCAP should be 

prioritized. 

b. WAD Limit 

Regarding the WAD limit, many 

commenters supported an increase from 

the proposed 2100 mm to 2500 mm to 

harmonize with Euro NCAP and 

promote increased safety for other VRUs 

such as bicyclists whose heads may 

impact the bonnet/hood in a different 

location if struck. The ASC stated the 

increased WAD limit of 2500 mm would 

have the additional benefit of 

‘‘providing protection at higher speeds 

when [the impacted individual] 

overshoots the bonnet and lower 

windshield areas.’’ Conversely, several 

commenters, including Honda, Hyundai 

America Technical Center, Inc. 

(HATCI), and Auto Innovators, agreed 

with NHTSA’s proposed WAD limit of 

2100 mm. These commenters argued a 

WAD limit of 2100 mm is reasonable 

and appropriate for the U.S. market, 

especially considering the 

complementary effects of PAEB, which 

has the effect of reducing vehicle speeds 

prior to impact with pedestrians. HATCI 

further explained that reducing vehicle 

speed prior to impact with a pedestrian 

results in a lower likelihood of the 

pedestrian striking the vehicle at higher 

WAD locations. 

c. Vehicles With LBRL Greater Than 500 

mm 

Many advocacy groups, including 

AAA, AARP, ACT, CAS, and Consumer 

Reports, recommended not granting 

credit to vehicles with an LBRL greater 

than 500 mm, as the existing test 

procedure does not accurately gauge 

crashworthiness. 

Vehicle manufacturers and the 

Insurance Institute for Highway Safety 

(IIHS) largely opposed the automatic 

zero score on vehicles with an LBRL 

greater than 500 mm, claiming it would 

disincentivize the development of 

pedestrian safety features altogether on 

vehicles with LBRL greater than 500 

mm. Honda noted that it would be 

nearly impossible for vehicles with 

LBRL greater than 500 mm to earn an 

overall 60 percent score because that 

would require near maximum scores for 

the head tests (proposed in the RFC to 

be a 37.5 percent contribution) and 

upper leg tests (proposed in the RFC to 

be a 25 percent contribution). Honda 

stated that automakers would be 

disincentivized from providing 

pedestrian protection in any area for 

these vehicles since they would be 

unlikely to earn the overall minimum 

score (60 percent) for pedestrian 

protection credit. 


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34See NHTSA’s final rule adopting a new Federal 

Motor Vehicle Safety Standard to require automatic 

emergency braking (AEB), including pedestrian 

AEB (PAEB), systems on light vehicle. 89 FR 39686 

(May 9, 2024). 

Many automobile manufacturers 

including Auto Innovators, GM, Honda, 

and HATCI recommended testing with 

the aPLI, stating that the aPLI behaves 

in a more biofidelic manner than the 

FlexPLI for this test. Honda noted that 

adopting the aPLI legform would allow 

testing vehicles with LBRL greater than 

500 mm and thereby eliminate the issue 

it raised about the proposal 

disincentivizing pedestrian protection 

features in these vehicles. CASR and 

GM recommended testing with the 

upper leg impactor to harmonize with 

Euro NCAP. 

d. Artificial Interference in HighBumper Vehicles 

Regarding NHTSA’s question about 

repositioning the upper legform ±50 mm 

from the WAD775 target when artificial 

interference is possible, nearly all 

commenters expressed opposition due 

to a lack of repeatability or 

reproducibility of the procedure. Of the 

nine commenters that submitted a 

response to this question, seven were 

automakers or groups representing 

automakers. Ford further explained its 

stance that the allowance of this 

repositioning would introduce 

subjectivity when test laboratories 

define the impact points. This 

subjectivity would lead to discrepancies 

which would require additional testing 

to resolve conflicts, according to Ford. 

Honda agreed with adjusting the upper 

legform position, with the stipulation 

that ‘‘clear definitions of this situation 

must be included in the protocol.’’ 

Otherwise, Honda agreed with the other 

commenters that there would be 

discrepancies and conflicts among test 

laboratories. Additionally, multiple 

commenters, including HATCI and GM, 

suggested NHTSA conduct further 

analysis to determine the existence and 

extent of this artificial interference. 

Two commenters, CASR and 

Advocates, agreed with the concept of 

NHTSA’s proposal. CASR stated that the 

Agency should adjust testing heights 

when artificial interference is present 

‘‘to ensure that injurious locations are 

adequately assessed.’’ Advocates 

expressed concern that automakers 

would intentionally incorporate features 

into their vehicle front end designs to 

cause artificial interference to inflate 

their crashworthiness pedestrian 

protection ratings. 

3. Discussion and Agency Decision 

a. Bumper Corner Definition 

NHTSA has decided to use the corner 

gauge method (as used in GTR 9 and 

UNECE R127) as proposed in the RFC. 

The corner gauge method mitigates the 

effect of design trends of the lower 

portion of the fascia that could result in 

a significantly reduced bumper test area 

when using the Euro NCAP 60-degree 

angle method. NHTSA agrees with 

commenters stating that the corner 

gauge method is more likely to result in 

a larger bumper test area. A larger 

bumper test area is preferable because it 

allows for evaluation of a greater portion 

of the vehicle for crashworthiness 

pedestrian protection. 

Most comments concerning the 

general procedure for determining the 

bumper test zone agreed that the 

bumper width using the corner 

definition should be compared to the 

bumper beam width, and the larger of 

the two widths should be used as the 

bumper test zone. The hard bumper 

beam width will be compared to the 

bumper width using the corner gauge 

method, and the larger of the two 

widths will be used as the bumper test 

zone. This methodology aligns with 

Euro NCAP in that both bumper beam 

width and bumper fascia width will be 

taken into account when determining 

the bumper test zone, and most 

commenters agreed that harmonization 

is best when possible. The only 

difference between this method and 

Euro NCAP is that Euro NCAP uses the 

60-degree angle method in conjunction 

with the bumper beam width procedure. 

However, as discussed above, NHTSA 

determined the corner gauge method is 

preferable to the 60-degree angle 

method. Therefore, NHTSA will use the 

corner gauge method in conjunction 

with the bumper beam width procedure 

to determine the bumper test zone as 

proposed in the RFC. 

For vehicles with an exposed bumper, 

using the corner gauge method would 

always result in the full width of the 

bumper beam as the bumper test width. 

While pedestrians may be impacted by 

any part of the exposed bumper like 

some commenters stated, testing the 

curved edges using the current methods 

would likely not result in meaningful 

data that could be used to improve 

pedestrian safety. Therefore, in the case 

of a vehicle with an exposed metal 

bumper, NHTSA will use the corner 

gauge method to determine the corner 

location and bumper test width. This 

method provides a consistent approach 

with vehicles without an exposed 

bumper and prevents NHTSA and test 

laboratories from performing wasteful 

impact tests where the data may not be 

useful. 

b. WAD Limit 

NHTSA has decided to use a WAD 

limit of 2100 mm as originally 

proposed. As discussed below, NHTSA 

acknowledges there are potential 

benefits to an increased WAD limit of 

2500 mm, but ongoing research must be 

completed before implementing this 

increased WAD limit for NCAP. 

While some commenters agreed with 

NHTSA’s proposed WAD limit of 2100 

mm, most requested that NHTSA 

increase the WAD limit to 2500 mm to 

harmonize with Euro NCAP and provide 

increased protection for other VRUs. 

NHTSA agrees with the commenters 

that a WAD limit of 2500 mm would 

likely benefit non-pedestrian VRUs, 

such as bicyclists, as their heads tend to 

be higher off the ground than 

pedestrians. NHTSA also agrees with 

ASC’s comment that an increased WAD 

limit may provide improved protection 

for VRUs impacted at slightly higher 

speeds as their heads may overshoot the 

WAD2100 limit. However, as impact 

speeds increase, so does the likelihood 

that a pedestrian’s head overshoots the 

vehicle’s hood and windshield entirely, 

especially in vehicles with lower front 

ends. Conversely, as mentioned by 

multiple commenters, the increased 

adoption of PAEB is expected to reduce 

vehicle speeds prior to impact with 

pedestrians.34 These reduced impact 

speeds will also reduce the likelihood of 

the pedestrian’s head impacting the 

hood or windshield beyond the 

WAD2100 limit. 

Vehicles in the U.S. market are often 

larger and equipped with higher 

bumpers than European vehicles. These 

differences result in unique challenges 

from a testing perspective. NHTSA is 

conducting research to determine 

unique impact scenarios for bicyclists 

with vehicles in the U.S. NHTSA will 

use the results of this research to 

develop or enhance existing test 

procedures to assess the performance of 

vehicle front end structures (including 

the windshield area) in mitigating 

injuries and fatalities in crashes with 

bicyclists. Therefore, NHTSA will move 

forward with the proposed WAD limit 

of 2100 mm at this time, but the Agency 

will consider increasing to a WAD limit 

of 2500 mm in the future once relevant 

test procedures are developed. 

c. Vehicles With LBRL Greater Than 500 

mm 

NHTSA has decided to automatically 

issue a score of zero for any lower 

legform test points on a vehicle where 

the LBRL is greater than 500 mm. The 

Agency is not aware of any existing 

countermeasures that would improve 


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35https://www.nhtsa.gov/document/ncaproadmap. 

36Suntay, B., & Stammen, J. (2019, May). 

Technical evaluation of the TRL pedestrian upper 

legform (Report No. DOT HS 812 659). Washington, 

DC: National Highway Traffic Safety 

Administration. 

37https://www.regulations.gov/document/ 

NHTSA-2019-0112-0007. 

the lower leg safety of vehicles with an 

LBRL greater than 500 mm when tested 

with the FlexPLI. It should be noted that 

test points where the LBRL is below 500 

mm will still be tested using the 

FlexPLI, even if those above 500 mm on 

the same vehicle will not be tested. 

Multiple commenters raised concerns 

that an automatic zero score would 

disincentivize manufacturers from 

providing pedestrian protection because 

it would be nearly impossible for them 

to achieve the 60 percent minimum 

passing score without any points for the 

lower leg impact tests. As explained in 

detail later in this notice, NHTSA is 

adjusting the scoring apportionment for 

head, lower leg, and upper leg impacts 

to better account for injury severity. 

This updated scoring apportionment 

results in a lower apportionment for 

lower leg impact tests (25 percent) and 

a higher apportionment for head impact 

tests (50 percent). The updated scoring 

would make it possible for vehicles with 

LBRL greater than 500 mm to obtain 

overall pedestrian protection credit (60 

percent), even with an automatic zero 

score for the lower legform tests. 

Therefore, manufacturers of vehicles 

with LBRL greater than 500 mm may 

develop vehicle designs that improve 

pedestrian protection for the upper leg 

and head impacts to obtain pedestrian 

protection credit. 

NHTSA is conducting research on the 

suitability of the aPLI for evaluating 

vehicle designs to mitigate pedestrian 

lower extremity injuries. The Agency 

will also research the use of aPLI for 

assessing lower extremity injuries on 

vehicles with LBRL greater than 500 

mm. As noted in the NCAP roadmap,35

NHTSA plans to consider testing with 

aPLI starting with model year 2030 

vehicles. 

d. Artificial Interference in HighBumper Vehicles 

NHTSA has decided not to allow test 

laboratories the option of repositioning 

the upper legform ±50 mm from the 

WAD775 target when artificial 

interference is present, or to conduct 

multiple impacts within a ±50 mm 

range from the WAD775 target. The 

concerns about repeatability and 

reproducibility raised by automakers are 

valid, and NHTSA agrees that an 

objective definition for artificial 

interference is necessary. However, as 

NHTSA determined while testing a 2015 

Ford F–150,36 when artificial 

interference occurs, it results in 

artificially low impact values in the 

upper legform impactor. The Agency 

wants to ensure the results of these 

impact tests are accurate but needs both 

a clear definition of the problem and a 

repeatable, reproducible solution to 

account for this situation. NHTSA will 

continue to evaluate the causes and 

effects of artificial interference. After 

these evaluations, the Agency may 

decide to further define the condition 

and develop a repeatable and 

reproducible procedure to address 

artificial interference during the tests. 

B. Test Devices 

1. RFC Summary 

NHTSA requested comments on test 

devices, their qualification schedule, 

and maintenance procedures that may 

affect the FlexPLI’s performance. 

NHTSA also requested comments on the 

existence of female-specific test devices. 

Details regarding the test devices are 

grouped into four categories: femalespecific test devices, upper legform 

humidity tolerance, FlexPLI 

qualification procedures and testing, 

and FlexPLI biofidelity. 

a. Female-Specific Test Devices 

The TRL upper legform and the 

FlexPLI are based on a 50th percentile 

average adult male in both mass and 

stature. These legforms are the most 

current anthropomorphic legforms 

available that have been thoroughly 

researched and reviewed by NHTSA. 

NHTSA requested information on 

whether other legforms that represent 

smaller adult females are available, the 

injury criteria and test procedures 

associated with them, and the safety 

need for such legforms. 

b. Upper Legform Humidity Tolerance 

NHTSA has previously investigated 

the repeatability and reproducibility of 

the TRL upper legform by performing 

qualification testing and vehicle impact 

testing.37 During this testing, NHTSA 

found that the foams used in the upper 

legform are sensitive to changes in 

temperature and humidity. Therefore, 

NHTSA requested comment on 

potentially using a tighter humidity 

tolerance than other existing 

international standards to improve labto-lab consistency. 

c. FlexPLI Qualification Procedures and 

Testing 

Regarding the FlexPLI, UNECE R127 

specifies two dynamic qualification 

tests—a Pendulum test and an Inverse 

Impact test, in addition to a series of 

quasi-static tests. In UNECE R127, the 

dynamic qualification tests are 

performed before and throughout a test 

series, while the quasi-static tests are 

performed on an annual basis. Euro 

NCAP only specifies the dynamic 

Inverse Impact test and the quasi-static 

tests. NHTSA requested information on 

the Pendulum and Inverse dynamic 

tests as well as the quasi-static tests and 

how often they should be performed. 

d. FlexPLI Biofidelity 

NHTSA proposed the FlexPLI as a 

biofidelic impactor but requested 

additional information on the FlexPLI’s 

biofidelity. Previous comments that 

NHTSA has received suggested that the 

FlexPLI demonstrates reduced 

biofidelity in oblique loading conditions 

(e.g., where there is curvature in the 

vehicle profile). 

2. Comments Received 

a. Female-Specific Test Devices 

NHTSA did not receive any 

comments identifying female-specific 

impactors. Humanetics, Honda, and GM 

specifically noted that such impactors 

do not currently exist. Autoliv stated 

that other factors such as gait cycle and 

knee position have greater effect on 

injury risk than the pedestrian’s gender, 

stating ‘‘ideal representation of the atrisk population includes more than 

pedestrian gender or stature.’’ Several 

commenters including Auto Innovators 

and Honda recommended using the 

aPLI in place of the FlexPLI, stating that 

the aPLI is more biofidelic. Advocacy 

groups including the NSC, AARP, and 

VERITY Now recommended developing 

additional pedestrian test devices to 

better represent the diversity of the 

human population, including smaller 

stature adults and older adults. 

b. Upper Legform Humidity Tolerance 

The commenters that discussed the 

humidity tolerance, including Auto 

Innovators, Honda, Rivian, VW, and 

Tesla, recommended harmonizing with 

Euro NCAP guidelines, which use the 

UNECE R127 guidelines of 10 to 70 

percent humidity. CASR noted that it 

aims to certify between 10 and 55 

percent humidity for its testing because 

it has ‘‘found issues meeting 

requirements at humidity levels above 

55 percent.’’ Humanetics also 

responded, stating it certifies its upper 

legform to the same 10 to 70 percent 


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38For Euro NCAP, the inverse impact test is used 

when any lower performance limits are exceeded. 

39https://www.nhtsa.gov/document/ncaproadmap. 

40Euro NCAP Assessment Protocol v10.0.3 used 

a scoring distribution of 24 out of 36 points (66.7 

percent) for head impacts, 6 out of 36 points (16.7 

percent) for lower leg impacts, and 6 out of 36 

points (16.7 percent) for upper leg impacts. 

41The Abbreviated Injury Scale (AIS) is a 6-point 

ranking system used for ranking the severity of 

injuries. AIS 3+ Injuries means injuries of severity 

level 3 (serious), 4 (severe), 5 (critical), and 6 (fatal) 

according to the Abbreviate Injury Scale. 

www.aaam.org. 

range used in UNECE R127 and Euro 

NCAP. 

c. FlexPLI Qualification Procedures and 

Testing 

Most commenters discussing FlexPLI 

qualification recommended using both 

the quasi-static test and inverse test at 

different frequencies. Humanetics and 

Honda recommended performing the 

quasi-static test after each disassembly 

or once annually, and the inverse test 

after every 30 vehicle impacts. 

Humanetics also recommended 

performing the pendulum test after 

every 10 vehicle impacts but noted that 

between the inverse test and the 

pendulum test, the inverse test is more 

important. Honda recommended 

performing the inverse test before each 

test series and after a maximum of 10 

impacts. HATCI and GM recommended 

harmonizing with Euro NCAP, which 

performs the inverse test every 20 

impacts (maximum) or every 12 months 

and static certification tests annually. 

UNECE R127 also includes the 

pendulum test (which Humanetics 

recommended). 

d. FlexPLI Biofidelity 

All commenters discussing FlexPLI 

biofidelity except for Honda commented 

that the FlexPLI is sufficiently 

biofidelic, though they also 

recommended the aPLI over the 

FlexPLI. These commenters stated the 

benefits of the aPLI are increased 

biofidelity and/or harmonization with 

other NCAPs. Many commenters 

supported adopting the FlexPLI as a 

temporary measure and adopting the 

aPLI in the long term. 

3. Discussion and Agency Decision 

a. Female-Specific Test Devices 

The TRL upper legform and the 

FlexPLI are the most current 

anthropomorphic legforms available 

that have been thoroughly researched 

and reviewed by NHTSA. No femalespecific legform impactors were 

identified by any commenters. NHTSA 

will proceed as proposed with the TRL 

upper legform and the FlexPLI. As 

noted earlier, NHTSA is conducting 

research on the suitability of the aPLI 

for evaluating vehicle designs to 

mitigate pedestrian lower extremity 

injuries, with plans to introduce this 

device in NCAP tests in the future. The 

current aPLI is representative of a 50th 

percentile male lower extremity. 

NHTSA will consider similar devices 

representing a range of male and female 

pedestrian sizes in the future. 

b. Upper Legform Humidity Tolerance 

Most commenters supported a 

humidity range of 10 to 70 percent for 

the TRL upper legform tests. NHTSA 

recognizes the importance of 

international harmonization when 

possible; therefore, NHTSA will proceed 

with a humidity range of 10 to 70 

percent to harmonize with Euro NCAP. 

Nevertheless, NHTSA will monitor 

upper legform performance in cases 

where humidity levels are between 55 

and 70 percent and will consider the 

possible need for a tighter humidity 

tolerance. 

c. FlexPLI Qualification Procedure and 

Testing 

After taking the received comments 

into account, NHTSA has decided to 

proceed with the test schedule outlined 

in Table 5, which prescribes the inverse 

impact test after every 20 impacts, the 

quasi-static tests once per year, and only 

requires the pendulum test if any lower 

performance limits are exceeded. This 

schedule aligns with Euro NCAP, except 

for the use of the pendulum test if any 

lower performance limits are 

exceeded.38 NHTSA is choosing to use 

the pendulum test in these instances to 

accommodate labs that do not have a 

dedicated inverse testing fixture, since 

they would need to be reconfigured to 

perform the inverse impact test during 

vehicle testing. 

TABLE 5—FLEXPLI QUALIFICATION TESTING SCHEDULE

Test mode Frequency Align with Euro NCAP? 

Inverse Impact Test ........................ After every 20 impacts ........................................................................... Yes. 

Quasi-static Tests ........................... Every 12 months .................................................................................... Yes. 

Pendulum Test ................................ If testing exceeds any lower performance limits ................................... No. 

d. FlexPLI Biofidelity 

While many commenters noted the 

aPLI is more biofidelic than the FlexPLI, 

all commenters who did so also found 

the FlexPLI to be an acceptable interim 

solution while NHTSA works to 

implement the aPLI in a future action. 

As noted in NHTSA’s NCAP roadmap,39

the Agency plans to begin testing with 

the aPLI starting with model year 2030 

vehicles, pending necessary research 

and analysis, as it is designed to provide 

more biofidelic upper leg injury 

measurements than the FlexPLI, which 

will be more important for assessing 

vehicles with taller front ends. 

C. Test Procedure 

1. RFC Summary 

NHTSA requested comments on Euro 

NCAP’s test procedures and 

documentation, including test speed, 

permitted models and simulation 

software, active hoods, and scoring 

calculation and points allocation. 

Comments regarding these test 

procedures are categorized into four 

groups: apportionment of scoring, test 

speeds, documentation, and active hood 

detection. A brief discussion providing 

more detail on each of these groups is 

discussed below. 

a. Apportionment of Scoring 

In the RFC, NHTSA proposed a 

scoring method that differed from the 

Euro NCAP scoring method regarding 

points apportionment. The proposed 

points apportionment, referred to as the 

3⁄8th, 3⁄8th, 2⁄8th scoring method, 

included a maximum of 13.5 out of 36 

points (37.5 percent) for head impacts, 

13.5 out of 36 points (37.5 percent) for 

lower leg impacts, and 9 out of 36 

points (25 percent) for upper leg 

impacts.40 The proposed scoring 

method is based on the relative 

frequency of AIS 3+ injuries 41 in the 

U.S. and the proportion of those 

pedestrian injuries across body regions. 


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NHTSA requested comment on whether 

injury severity should be prioritized 

over injury frequency in this 

calculation, or whether any other 

changes should be considered to the 

proposed 3⁄8th, 3⁄8th, 2⁄8th scoring for 

head impacts, lower leg impacts, and 

upper leg impacts, respectively. 

b. Test Speeds 

The Euro NCAP test procedures are 

representative of a pedestrian crossing 

the street and being struck in the side 

by a vehicle traveling at 40 km/h (25 

mph). NHTSA requested comments on 

whether U.S. NCAP should maintain the 

40 km/h test speed to harmonize with 

Euro NCAP or consider other test speeds 

based on an analysis of crashes in the 

U.S. market. 

c. Documentation 

NHTSA proposed adopting the Euro 

NCAP crashworthiness pedestrian 

protection test devices, test procedures, 

and some (though not all) of the scoring 

methods. Between the December 2015 

notice and the May 2023 RFC, there 

were several updates to Euro NCAP 

procedures. In the May 2023 RFC, 

NHTSA proposed adopting the 

following test procedures and versions: 

(1) Euro NCAP Pedestrian Testing 

Protocol, Version 8.5, October 2018. 

(2) Euro NCAP Assessment Protocol— 

Vulnerable Road User Protection, Part 

1—Pedestrian Impact Assessment, 

Version 10.0.3, June 2020. 

(3) Euro NCAP Pedestrian Headform 

Point Selection, V2.1, October 2017. 

(4) Euro NCAP Film and Photo 

Protocol, Chapter 8—Pedestrian 

Subsystem Tests, V1.3, January 2020. 

(5) Euro NCAP Technical Bulletin TB 

008, Windscreen Replacement for 

Pedestrian Testing, Version 1.0, 

September 2009. 

(6) Euro NCAP Technical Bulletin TB 

019, Headform to Bonnet Leading Edge 

Tests, Version 1.0, June 2014. 

(7) Euro NCAP Technical Bulletin TB 

024, Pedestrian Human Model 

Certification, V2.0, November 2019. 

In the RFC, NHTSA requested 

comments on whether any changes or 

other considerations needed to be taken 

into account before adopting these 

documents. One notable change 

between this list of documents and the 

list of documents NHTSA proposed in 

2015 is the replacement of Technical 

Bulletin (TB) 013 with TB 024 (item 7 

above). Both of these documents discuss 

computer models used to validate active 

hoods for head-to-hood impact tests. 

NHTSA requested comment on TB 024 

and its relevance to U.S. NCAP. 

d. Active Hood Detection and 

Deployment 

One mitigation strategy used to lower 

risk of pedestrian injury is the use of 

active hood technology. An active hood 

system is designed to lift the hood 

upwards when the vehicle detects an 

impact with a pedestrian. This action 

increases the distance between the hood 

and any rigid components that may be 

present in the engine bay or front trunk. 

To allow active hoods to be deployed 

during pedestrian testing, manufacturers 

must be able to prove that their active 

hood systems trigger on leg-to-bumper 

impact at multiple points along the 

vehicle’s bumper. In its RFC, NHTSA 

proposed using the full vehicle bumper 

test zone for active hood detection 

testing. 

To trigger the active hoods during 

testing, Euro NCAP currently uses the 

Pedestrian Detection Impactor 2 (PDI–2) 

legform. However, NHTSA noted that 

the Informal Working Group for 

Deployable Pedestrian Protection 

Systems (IWG–DPPS) was investigating 

the use of FlexPLI in place of the PDI– 

2. NHTSA requested comments on 

whether the PDI–2 legform or the 

FlexPLI should be used for the active 

hood detection testing. 

2. Comments Received 

a. Apportionment of Scoring 

There was little support from 

commenters for NHTSA’s proposed 

scoring apportionment of 3⁄8th, 3⁄8th, 2⁄8th for head, lower leg, and upper leg 

impacts, respectively. Most 

commenters, including ACT, Auto 

Innovators, GM, HATCI, Honda, 

Humanetics, and IIHS, recommended 

the Agency place additional emphasis 

on head impact performance to better 

reflect injury severity. IIHS referenced 

multiple studies which have shown that 

the head is the most commonly injured 

body region in seriously or fatally 

injured pedestrians in the U.S., United 

Kingdom, Germany, and Japan. Autoliv 

and Consumer Reports concurred with 

the proposed apportionment but 

recommended monitoring in case the 

Agency needs to adjust further, noting 

the distribution should be based on the 

risk for Abbreviated Injury Scale (AIS) 

3+ injuries. However, HATCI 

commented that ‘‘focusing on AIS 3+ 

diminishes the large percentage of AIS 

4+ and fatal injuries that may be 

affected by the headform test.’’ 

ASC proposed an apportionment that 

more closely modeled Euro NCAP’s, 

stating: ‘‘Like Euro NCAP, ASC 

proposes that points should emphasize 

head protection as first priority . . . .’’ 

Similarly, Rivian recommended a 

scoring apportionment to align with 

Euro NCAP more closely. ASC, Rivian, 

and public citizens all suggested a 

scoring apportionment of 50 percent for 

head impacts. Auto Innovators 

recommended an apportionment with 

even greater weighting for the head 

(61.1 percent). Auto Innovators’ 

recommended apportionment applied 

the findings of the Department of 

Transportation’s publication on the 

Value of a Statistical Life to the relative 

frequency of U.S. pedestrian injuries 

based on injury severity level. 

In January 2023, Euro NCAP 

increased the percentage of points 

required to obtain a 5-star VRU safety 

rating from 60 percent to 70 percent of 

the maximum. NSC recommended that 

NHTSA should also increase the 

minimum passing score from the 

proposed 21.600 points (60 percent) to 

25.200 points (70 percent) to align with 

the current Euro NCAP 5-star rating for 

VRU safety. 

b. Test Speeds 

All of the automakers and many other 

industry groups who commented, 

including Auto Innovators, ASC, 

Consumer Reports, Autoliv, and CASR, 

agreed that the proposed test impact 

speed of 40 km/h (25 mph) is reasonable 

and sufficient for U.S. NCAP. Most 

commenters emphasized that this speed 

allows for harmonization with Euro 

NCAP and other NCAPs globally, where 

pedestrian fatalities have decreased over 

time. GM, HATCI, VW, and Auto 

Innovators also mentioned that the 

complementary benefits of PAEB 

provide further justification that the 

impact test speeds do not need to be 

increased beyond 40 km/h (25 mph). 

Honda noted that current test devices 

are only proven to be biofidelic up to 40 

km/h (25 mph), and IIHS recommended 

NHTSA complete further research into 

updated test devices and methods 

before considering increased test 

speeds. Humanetics suggested NHTSA 

should perform additional research to 

determine how vehicle designs 

optimized for higher test speeds would 

perform at lower test speeds for 

pedestrian protection. 

Other commenters, including 

advocacy groups and individual 

members of the public, stated that 

NHTSA should increase the test impact 

speeds for pedestrian protection. Salud 

America stated test speeds up to 35 mph 

(56 km/h) should be considered; an 

additional 20.2 percent of fatalities 

occur between 25 and 35 mph. Many 

advocacy groups and public citizens 

argued the test speeds should be 

increased to the highest levels possible. 

CAS stated the tests ‘‘should be 


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42https://jtlu.org/index.php/jtlu/article/view/ 

1825. 

43Since NHTSA will be utilizing the FlexPLI 

instead of the aPLI, it will not be measuring impact 

values specifically for the pelvis. The TRL upper 

legform will be used to account for the same 9 

points that Euro NCAP distributes between the 

femur and pelvis measurements. 

conducted at the highest speeds allowed 

by the technical limitations of test 

equipment.’’ In its comment, NACTO 

referenced a recent study that found, 

among other things, more than three 

quarters of the 60 most dangerous 

corridors for pedestrians in the U.S. 

have speed limits of 30 mph or higher.42

NACTO stated the test speeds should 

therefore be increased but did not 

indicate a suggested target speed. 

c. Documentation 

Most commenters supported 

NHTSA’s plan to use the documents 

and test procedures as outlined in the 

RFC, which included: 

(1) Euro NCAP Pedestrian Testing 

Protocol, Version 8.5, October 2018. 

(2) Euro NCAP Assessment Protocol— 

Vulnerable Road User Protection, Part 

1—Pedestrian Impact Assessment, 

Version 10.0.3, June 2020. 

(3) Euro NCAP Pedestrian Headform 

Point Selection, V2.1, October 2017. 

(4) Euro NCAP Film and Photo 

Protocol, Chapter 8—Pedestrian 

Subsystem Tests, V1.3, January 2020. 

(5) Euro NCAP Technical Bulletin TB 

008, Windscreen Replacement for 

Pedestrian Testing, Version 1.0, 

September 2009. 

(6) Euro NCAP Technical Bulletin TB 

019, Headform to Bonnet Leading Edge 

Tests, Version 1.0, June 2014. 

(7) Euro NCAP Technical Bulletin TB 

024, Pedestrian Human Model 

Certification, V2.0, November 2019. 

Most automakers suggested NHTSA 

follow the discussions of Euro NCAP 

and implement any updates to these 

documents as they are released to 

maximize harmonization. Specifically, 

IIHS stated that ‘‘it seems illogical to 

choose an outdated set of protocols to 

assess future vehicles.’’ The updated 

documents that IIHS referenced are the 

Euro NCAP Pedestrian Testing Protocol 

and the Euro NCAP Assessment 

Protocol, which include updates such as 

the new lower leg impactor (aPLI) and 

increased WAD limit of 2500 mm. GM 

provided a specific recommendation 

concerning TB 019, requesting that it be 

incorporated into the overall testing 

procedure instead of remaining a 

standalone document. 

Regarding TB 024, all commenters 

who responded were in favor of using 

its models and methods to calculate 

head impact times when evaluating 

active hoods. Many commenters also 

emphasized that doing so would 

harmonize with Euro NCAP. In VW’s 

opinion, ‘‘[t]he TB 024 method has 

proven its feasibility over the span of 

time it has been in effect in Europe.’’ 

Autoliv encouraged NHTSA to follow 

the next steps being discussed for Euro 

NCAP updates, including looking at the 

full body motion of pedestrians. 

According to Autoliv, ‘‘higher velocity 

of the head at impact and assessing the 

neck and thorax injuries . . . cannot be 

assessed with spherical impactor 

testing.’’ 

d. Active Hood Detection and 

Deployment 

All commenters who provided input 

on the active hood detection area agreed 

that the detection area should 

correspond to the full bumper test width 

as defined for the lower leg impact tests. 

Regarding the option of using the 

PDI–2 legform or the FlexPLI impactor, 

Honda, Rivian, Autoliv, and Tesla all 

agreed that the PDI–2 is the preferred 

testing device. Rivian specified that the 

PDI–2 has a lower mass, which allows 

for better detection of smaller stature 

adults and children. Auto Innovators 

stated that the manufacturer should 

have the option to choose which test 

device is more representative of the 

populations it intends to address. Auto 

Innovators also encouraged NHTSA to 

‘‘consider the finding of the IWG–DPPS 

and conduct any additional research 

necessary to determine whether the 

PDI–2 is an accurate surrogate for 

smaller stature pedestrians, or whether 

there is a need to consider alternate 

options.’’ In contrast, VW stated ‘‘the 

FlexPLI would be the better choice of 

the two options,’’ but did not provide 

further justification. 

3. Discussion and Agency Decision 

a. Apportionment of Scoring 

NHTSA has decided to increase the 

proportion of points for head impacts to 

align more closely with the Euro NCAP 

scoring apportionment. NHTSA agrees 

with commenters’ assertion that more 

emphasis should be placed on head 

impacts due to the higher severity of 

head injuries compared to lower leg and 

upper leg injuries. Several commenters 

offered suggestions for various scoring 

apportionments based on body region, 

but the general consensus among 

commenters was to increase the 

proportion of points for head impacts. 

As ASC included in their comment: 

‘‘Like Euro NCAP, ASC proposes that 

points should emphasize head 

protection as first priority . . . .’’ 

However, it should be noted that Euro 

NCAP recently reduced the points 

allocated to head impact testing from 24 

points (66.7 percent) in the Assessment 

Protocol—VRU v10.0.3 to 18 points (50 

percent) in v11.3. While this revised 

value is less than Euro NCAP’s previous 

apportionment, it remains higher than 

the apportionment NHTSA proposed in 

the RFC for head impacts (13.5 points, 

or 37.5 percent). 

A higher proportion of points 

allocated to head impacts aligns with 

what the advocacy groups and 

consumers stated they expect to see 

from a consumer information program. 

Additionally, it aligns with requests 

from automakers by adjusting the 

apportionment based on injury severity 

while also bringing the scoring more in 

line with Euro NCAP. 

Therefore, NHTSA has decided to 

adjust the scoring apportionment as 

follows: (1) the adult and child head 

impact test results will contribute 50 

percent of the available points for a 

maximum component score of 18.000 

points; (2) the upper leg impact test 

results will account for 25 percent of the 

available points for a maximum 

component score of 9.000 points; and 

(3) the lower leg impact test results will 

cover 25 percent of the available points 

for a maximum component score of 

9.000 points (Table 6). This scoring 

apportionment roughly aligns with the 

Euro NCAP Assessment Protocol—VRU 

v11.3 scoring of 18 points for head 

impacts (50 percent), 9 points for knee/ 

tibia impacts (25 percent), 4.5 points for 

femur impacts (12.5 percent), and 4.5 

points for pelvis impacts (12.5 

percent).43

NHTSA has also decided to keep the 

proposed minimum score to achieve 

credit as 21.600 out of the available 

36.000 points (60 percent). While Euro 

NCAP recently increased its threshold 

to 70 percent, it also simultaneously 

implemented other changes to its 

program that NHTSA did not propose. 

For example, Euro NCAP now uses the 

aPLI impactor in addition to the points 

allocation changes mentioned earlier. 

Thus, the two programs are not directly 

comparable in their current states. 

Additionally, as detailed in the NCAP 

roadmap, NHTSA plans to implement a 

new rating system beginning with MY 

2028 vehicles. Pedestrian Protection 

credit acknowledged via a checkmark is 

anticipated to last for two model years 

(MYs 2026 and 2027) as a result of the 

new rating system. During this limited 

timeframe, if the minimum passing 

score is set too high, few vehicles may 

receive credit in the near term and 

vehicle manufacturers will not have 

sufficient time to make adjustments to 


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44See NHTSA’s final rule adopting a new Federal 

Motore Vehicle Safety Standard to require 

automatic emergency braking (AEB), including 

pedestrian AEB (PAEB), systems on light vehicle. 

89 FR 39696 (May 9, 2024). 

meet the standard. This could result in 

the detrimental outcome of consumers 

losing the ability to successfully 

differentiate between vehicles as 

intended by the NCAP program. As 

such, a minimum score is appropriate at 

this initial stage of the crashworthiness 

pedestrian protection testing program. 

The Agency anticipates revisiting the 

apportionment of this scoring system as 

the NCAP VRU rating system develops. 

TABLE 6—SCORING APPORTIONMENT

SUMMARY

Body region Apportionment 

(%) 

Maximum 

possible 

points 

Head ............... 50 18.000 

Upper Leg ....... 25 9.000 

Lower Leg ....... 25 9.000 

Total 

Points ... .......................... 36.000 

b. Test Speeds 

Regarding test speeds, NHTSA has 

decided to use test impact speeds that 

simulate a pedestrian being struck in the 

side by a vehicle traveling at 40 km/h 

(25 mph) as proposed in the RFC. Most 

automakers supported harmonizing 

with Euro NCAP and maintaining 40 

km/h (25 mph) impact test speeds, 

while most advocacy groups and the 

general public supported increasing the 

test speeds to higher levels. One 

justification provided by the advocacy 

groups for testing at higher speeds is 

that U.S. roads typically have higher 

speed limits, and people typically drive 

faster than the posted speed limits. 

Further, the advocacy groups noted that 

more fatalities occur at impact speeds 

greater than 40 km/h (25 mph). NHTSA 

agrees with the commenters that 

fatalities do typically occur at higher 

speeds (70 km/h (43.5 mph) on average), 

but the practicability of designing a 

vehicle front end to achieve a high score 

becomes increasingly difficult as the 

impact speed increases due to the 

energy dissipation required. The target 

impact speed of 40 km/h (25 mph) was 

selected in part because the majority of 

pedestrian collisions occur at this speed 

or less. Further, as NHTSA determined 

in the December 2015 RFC, test speeds 

above 40 km/h (25 mph) are not 

warranted due to the changing 

dynamics of a pedestrian-vehicle 

interaction as vehicle speeds increase. 

More specifically, increased impact 

speeds result in an increased likelihood 

of the pedestrian’s head overshooting 

the vehicle’s hood and windshield. No 

commenters provided any data or 

insight into possible solutions to this 

inherent problem in terms of testing or 

scoring. 

NHTSA also agrees with the 

commenters who expressed that the 

proliferation of PAEB would tend to 

decrease the impact speed of vehicles 

with pedestrians.44 For vehicles 

equipped with a PAEB system traveling 

at speeds above 40 km/h (25 mph), an 

impact with a pedestrian may still occur 

as the vehicle slows down to speeds at 

or below 40 km/h (25 mph) if the PAEB 

system engages but is unable to fully 

stop the vehicle. Additionally, NHTSA 

agrees with commenters that 

harmonization between U.S. NCAP and 

other NCAPs globally is beneficial when 

possible. The Agency will therefore use 

test impact speeds to simulate a 

pedestrian being struck in the side by a 

vehicle traveling at 40 km/h (25 mph). 

c. Documentation 

NHTSA will maintain and update its 

own test procedures independently for 

U.S. NCAP. However, the Agency has 

decided to adopt the Euro NCAP 

crashworthiness pedestrian protection 

test devices and general test procedures 

as proposed in the RFC as a basis for its 

own protocols. Some of the documents 

have been updated to newer versions; 

NHTSA will use some, but not all, of the 

updated versions for U.S. NCAP. The 

documents that NHTSA will use for the 

crashworthiness pedestrian protection 

program are listed below. 

(1) Euro NCAP Pedestrian Testing 

Protocol, Version 8.5, October 2018. 

NHTSA has decided not to use the 

updated Version 9.1 at this time. As 

discussed above, NHTSA will use a 

WAD limit of 2100 mm for U.S. NCAP. 

Additionally, the Agency will not use 

the aPLI for leg impact tests but will 

instead use the FlexPLI for lower leg 

impact tests. 

(2) Euro NCAP Assessment Protocol— 

Vulnerable Road User Protection, Part 

1—Pedestrian Impact Assessment, 

Version 10.0.3, June 2020. NHTSA has 

decided not to use the updated Version 

11.4 at this time. As explained by the 

discussion above on the aPLI, NHTSA 

will use the FlexPLI to evaluate lower 

leg impacts. 

(3) Euro NCAP Pedestrian Headform 

Point Selection. Due to the differences 

in scoring systems and data submission, 

NHTSA will create a similar scoring 

sheet specific to the crashworthiness 

pedestrian protection program 

implemented in U.S. NCAP. 

(4) Euro NCAP Film and Photo 

Protocol, Chapter 8—Pedestrian 

Subsystem Tests, V1.4, July 2023. This 

is the updated version compared to 

V1.3, which NHTSA had proposed in 

the RFC. The updates in V1.4 did not 

affect Chapter 8, so the procedure is the 

same as what NHTSA proposed in the 

RFC. Therefore, NHTSA will use V1.4. 

(5) Euro NCAP Technical Bulletin TB 

008, Windscreen Replacement for 

Pedestrian Testing, Version 1.0, 

September 2009. This is still the current 

version used by Euro NCAP, so NHTSA 

will use it as well. 

(6) Euro NCAP Technical Bulletin TB 

019, Headform to Bonnet Leading Edge 

Tests, Version 1.0, June 2014. This is 

still the current version used by Euro 

NCAP, so NHTSA will use it as well. 

(7) Euro NCAP Technical Bulletin TB 

024, Pedestrian Human Model 

Certification, V4.0, January 2024. 

NHTSA has analyzed the updates for 

v3.0 and v4.0 of TB 024 and determined 

the most recent version (v4.0) is 

acceptable for the U.S. NCAP. 

NHTSA will continue to monitor Euro 

NCAP’s updates to these test 

procedures. In response to GM’s 

comment about embedding TB 019 into 

the Pedestrian Testing Protocol, NHTSA 

will organize all test protocols and 

documents into a single package, similar 

to those published for NCAP’s other 

crashworthiness tests. 

All commenters supported the use of 

the models and methods in TB 024 to 

calculate head impact times to evaluate 

vehicles with active hoods. Using TB 

024 harmonizes with Euro NCAP and 

most commenters agreed these methods 

and models are currently the most 

widely accepted in the industry. 

Therefore, NHTSA has decided to apply 

the models and methods of TB 024 for 

evaluating vehicles with active hoods. 

Additionally, NHTSA analyzed the 

updates to TB 024 between v2.0, which 

was current at the time of the RFC, and 

v4.0, which is the most recent version. 

The Agency determined that the most 

recent version, v4.0, is acceptable for 

U.S. NCAP and will harmonize with 

Euro NCAP by adopting this version. 

d. Active Hood Detection and 

Deployment 

All commenters who provided input 

on the active hood detection area agreed 

with NHTSA’s proposal to use the entire 

vehicle bumper test width as defined for 

the lower leg impact tests. Thus, the 

Agency will implement this plan as 

proposed. 

NHTSA has decided to use the PDI– 

2 for pedestrian detection testing with 

active hoods. Almost all of the 

commenters agreed that the PDI–2 is the 


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45Oliver Zander et al. 2023. ‘‘Development of a 

Standard for Deployable Pedestrian Protection 

Systems (DPPS) for Amendments to UN Global 

Technical Regulation No. 9 and UN Regulation No. 

127.’’ Paper Number 23–0144 of 27th ESV 

conference proceedings. 2023. 

46 Id. 

47Blue points are those where pedestrian 

protection performance measure is unpredictable, 

as indicated by the test results provided by the 

manufacturer. In Euro NCAP, blue grid points are 

limited to the following structures: plastic scuttle, 

windscreen wiper arms and windscreen base, 

headlamp glazing, and break-away structures. 

preferred impactor for active hood 

detection. As noted by multiple 

commenters, there are pros and cons for 

both the PDI–2 and the FlexPLI when 

used for active hood detection. The 

PDI–2 has a lower mass than the 

FlexPLI, which means it is more 

difficult for a vehicle to detect contact. 

It also better represents a child or small 

stature adult, like Rivian stated in its 

comment. 

NHTSA has followed the findings of 

the IWG–DPPS regarding research and 

comparisons between the PDI–2 and 

FlexPLI for active hood detection. The 

IWG–DPPS noted that the FlexPLI could 

represent a pedestrian surrogate that can 

be used for the sensing verification of a 

DPPS but can only represent a limited 

range of typical load cases.45 In 

comparison, the PDI–2 is a more 

conservative impactor as it represents 

the hardest to detect (HTD) case for 

active hood detection. According to a 

summary table in the IWG–DPPS report, 

the PDI–2 would be the first choice as 

a pedestrian representative. However, 

the report also states that while the PDI– 

2’s ‘‘very conservative and demanding 

requirements seem appropriate for 

consumer tests, it sometimes 

underestimates the loads that are 

emanated from a pedestrian onto a 

sensing system.’’ 46 These conservative 

and demanding requirements make it a 

good choice as a pedestrian 

representative for NCAP as they lead to 

a more stringent test and higher level of 

safety. Taking this into account with the 

support from the commenters, NHTSA 

has decided to use the PDI–2 for active 

hood detection in its crashworthiness 

pedestrian protection program. 

Additionally, use of the PDI–2 for active 

hood detection harmonizes the U.S. 

NCAP procedure with Euro NCAP. 

NHTSA will deploy an active hood in 

accordance with manufacturer 

instructions prior to launching the 

headform, including the irrevocable 

selection of the minimum and 

maximum period of time between 

device deployment and the impact of 

the headform to ensure full deployment 

at impact. Upon request, manufacturers 

are expected to provide information to 

NHTSA explaining the basic operational 

characteristics of their active hood 

sensor system. 

D. Data Acquisition and Reporting 

1. RFC Summary 

NHTSA requested comments on data 

recording and presentation, such as selfreporting of impact test results by 

vehicle manufacturers, how those test 

results are used during verification 

testing, and publication of results. 

Comments regarding data acquisition 

and reporting are summarized into four 

categories: manufacturer-reported data, 

correction factors during verification 

testing, publication of results, and 

optional vehicle features that affect 

testing and scoring. A brief discussion 

providing more detail on each of these 

groups is discussed below. 

a. Manufacturer-Reported Data 

NHTSA proposed to initially operate 

its crashworthiness pedestrian 

protection program in a fully selfreported manner. Vehicle manufacturers 

would be expected to report all 

predicted head, upper leg, and lower leg 

impact test data to NCAP to receive 

crashworthiness pedestrian protection 

credit for their vehicles. This 

methodology aligns with NCAP’s 

current crash avoidance program, in 

which manufacturers provide data to 

indicate whether each vehicle model 

passes various ADAS tests. Unlike Euro 

NCAP, where manufacturers may assign 

some head impact points on the hood as 

‘‘blue points’’ 47 where the head impact 

performance measure is unpredictable, 

NHTSA’s proposal did not permit 

assigning blue points on the hood and 

required the manufacturer to self-report 

with sufficient data that its vehicle 

meets the NCAP performance criteria to 

receive crashworthiness pedestrian 

protection credit. Further, Euro NCAP 

does not require automakers to submit 

any data for lower leg and upper leg 

impacts and only requires the 

automakers to submit HIC15 or color 

data for all grid locations, excluding 

blue points. NHTSA requested 

comments on what kind and how much 

data should be collected from 

manufacturers in the verification 

process. Primarily, the Agency inquired 

whether simulated data should be 

allowed and how this data should be 

validated. 

b. Correction Factors During 

Verification Testing 

NHTSA proposed to use the 

manufacturer’s supplied predicted head 

impact test data in conjunction with the 

data collected during the Agency’s 

verification testing to calculate the head 

sub-score, similar to the process used by 

Euro NCAP. The resulting NCAP data 

would be compared to the 

manufacturer’s predicted data to 

determine a correction factor to apply to 

the entire head impact test data set. 

NHTSA requested comment on the 

proposal to adjust submitted head 

impact test values by a correction factor 

calculated based on the actual test 

results. 

c. Publication of Results 

As the Agency is still considering the 

best approach to convey vehicle safety 

information on the Monroney label and 

developing a new rating system that will 

include several planned NCAP updates, 

NHTSA did not propose changes to the 

Monroney label. NHTSA requested 

comment on whether a checkmark on 

the NHTSA.gov website would be 

adequate for informing consumers of 

which vehicles achieve the minimum 

score in the pedestrian protection tests. 

d. Optional Vehicle Features That Affect 

Testing and Scoring 

Currently, NHTSA reports vehicle 

safety ratings on a per-model basis, with 

separate ratings for different drivetrains 

due to differences in rollover resistance. 

For the crash avoidance testing program, 

vehicles that are equipped with an 

ADAS technology as standard 

equipment are noted as such, as are 

vehicles that have the same technology 

as optional equipment. For the 

crashworthiness pedestrian protection 

program, NHTSA anticipates that trim 

lines or options that change the ride 

height of the vehicle, the clearance 

under the hood, or the shape of the 

headlights or bumper may have 

significant effects on the outcome of the 

crashworthiness pedestrian protection 

tests. NHTSA requested comment on 

how credit should be assigned in the 

event that multiple trim levels and 

options affect the outcome of the 

crashworthiness pedestrian protection 

tests. 

2. Comments Received 

a. Manufacturer-Reported Data 

Vehicle manufacturers largely agreed 

that simulated test results should be 

acceptable with varying degrees of 

NHTSA oversight or physical testing for 

validation. Most of the commenters that 

supported simulated data, including 


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48 52 FR 31691. 

Humanetics, Honda, Rivian, and 

Autoliv, agreed that some level of 

physical test validation would also be 

necessary. Some commenters, such as 

GM and Auto Innovators, highlighted 

the fact that allowing automakers to selfreport simulated data would provide a 

cost-effective method to get as much 

information to consumers as quickly as 

possible. Auto Innovators suggested the 

automakers should be able to self-report 

the results of either physical testing or 

Computer-Aided Engineering (CAE) 

modeling. Some commenters, including 

Hyundai, VW, and CASR, recommended 

harmonizing with Euro NCAP 

procedures, which undertake 

verification testing on all vehicles. 

AAA, ACT, and individual members 

of the public recommended only 

accepting physical tests. AAA stated 

that ‘‘only physical test results can 

provide insight into how well a system 

actually protects pedestrians.’’ 

Most respondents, including AAA, 

Autoliv, and Auto Innovators, 

recommended comprehensive test 

results should be available on an ‘‘as 

needed’’ basis. Honda recommended 

using the predicted grid color map from 

Euro NCAP while HATCI recommended 

the same, with additional details 

provided as necessary. CAS 

recommended requiring that 

manufacturers submit full test reports, 

including full data traces, photos, and 

videos. 

b. Correction Factors During 

Verification Testing 

Most commenters, including Autoliv, 

Honda, and Auto Innovators, agreed 

with NHTSA’s proposal for adjusting 

the manufacturer-provided head score 

by using a correction factor. Honda 

added that this approach ‘‘has also been 

demonstrated to be successful with 

other NCAPs.’’ GM specified its view 

that hardware data provided by an OEM 

which follows the ‘‘Assessment 

Protocol’’ process should be accepted by 

NHTSA without additional verification. 

However, GM added that ‘‘predicted’’ 

data, such as CAE data, could be subject 

to a verification test. 

c. Publication of Results 

Most commenters expressed support 

for adopting a 5-star system with several 

automakers and auto industry groups, 

including Auto Innovators, Honda, GM, 

HATCI, and Consumer Reports, 

supporting the proposed system as a 

sufficient temporary measure. Consumer 

Reports surmised that a comparative 

rating system would better allow 

consumers to make informed decisions. 

A large number of commenters, 

including Autoliv, NACTO, 

WalkMedford, the National Association 

of Mutual Insurance Companies 

(NAMIC), ASC, CAS, NSC, National 

Transportation Safety Board (NTSB), 

and San Francisco Municipal 

Transportation Agency (SFMTA), 

recommended including the ratings on 

the Monroney label. 

d. Optional Vehicle Features That Affect 

Testing and Scoring 

There was not much agreement 

among commenters on how to account 

for vehicle options that may affect 

crashworthiness pedestrian protection. 

Auto Innovators, Honda, and HATCI 

recommended clarifying which trim 

levels were tested since differences in 

trim levels may result in different 

performance. Humanetics and ACT 

recommended optional features be 

independently assessed. When optional 

features cannot be independently 

assessed, AAA recommended assigning 

credit to the worst-performing model 

while Autoliv recommended assigning 

credit to the highest-selling model. CAS 

and Consumer Reports recommended 

assigning credit to the worst-case 

configuration. 

3. Discussion and Agency Decision 

a. Manufacturer-Reported Data 

In the near term, the Agency has 

decided to move forward with its plan 

to accept self-reported data from vehicle 

manufacturers for its crashworthiness 

pedestrian protection program. NHTSA 

will accept self-reported data for head, 

upper leg, and lower leg 

crashworthiness pedestrian protection 

tests as initially proposed. This data 

may be in part derived from CAE/ 

simulation data. As several commenters 

have mentioned, requiring physical test 

data for every impact point is overly 

burdensome for manufacturers. This 

burden is magnified when considering 

the various options and trim levels 

which may affect vehicle performance. 

However, as Humanetics, Rivian, 

IIHS, and others suggested, physical 

testing of selected test points is 

necessary to validate CAE results. Thus, 

it is NHTSA’s expectation that vehicle 

manufacturers perform some level of 

physical impact testing on a productionlevel vehicle before submitting 

performance data that has been 

generated via simulation. This 

methodology aims to avoid imposing 

infeasible requirements while also 

maintaining program integrity. The 

Agency also hopes that these reasonable 

requirements will encourage 

manufacturer participation. 

NHTSA acknowledges the 

apprehension voiced by NACTO and 

others regarding uncertainty in selfreported data standards. While the use 

of NHTSA-generated data is ideal, the 

Agency’s limited resources do not 

currently allow for testing of all models 

that could receive credit as meeting 

NCAP’s criteria. Thus, self-reported data 

will be accepted to provide as much 

information to the consumer as possible. 

NHTSA will thoroughly review all data 

submitted. 

Because of the lack of NHTSAcontracted laboratories currently 

available, the Agency does not find it 

practicable at this time to require their 

use for validation of simulated data. 

Thus, for this program stage, 

manufacturer-provided physical test 

data collected to validate any supplied 

simulation data may originate from 

either in-house or third-party test 

laboratories. It is important to note that 

all NHTSA-sponsored verification 

testing will be performed at a NHTSAcontracted laboratory under Agency 

supervision. NHTSA is considering a 

plan to require vehicle manufacturers to 

use NHTSA-contracted laboratories for 

all impact testing in the future. This 

requirement is currently enforced for 

NCAP’s optional testing program; under 

this provision, vehicle manufacturers 

fund desired testing, but NHTSA 

oversees test setup, test conduct, and 

data quality control.48

NHTSA will require predicted head 

and leg response data values to provide 

credit for acceptable crashworthiness 

pedestrian protection performance. 

Specifically, NHTSA will require actual 

or predicted HIC15 for each headform 

grid point, actual or predicted upper 

legform bending moment and force for 

each bumper impact location, and 

actual or predicted lower legform tibia 

bending moment and MCL and ACL/ 

PCL elongations for each bumper impact 

location. Manufacturers will submit this 

information to NHTSA in a 

standardized format, to be detailed at a 

later date. This is an additional 

requirement beyond NHTSA’s original 

proposal, which only sought to receive 

predicted score ‘‘bands’’ for each head 

impact grid point and every upper and 

lower leg impact location. Although 

HATCI expressed concerns regarding 

the confidentiality of internal design 

processes, the Agency reasons that 

receiving more specific information will 

increase the transparency of selfreported data, thereby increasing the 

Agency’s confidence in the data 

received. The Agency hopes to alleviate 

the concerns of those who questioned 

the validity of self-reported, CAEgenerated data. The predicted data 


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49https://www.nhtsa.gov/document/ncaproadmap. 50NHTSA receives similar information in support 

of its crashworthiness and crash avoidance 

programs. 51Part 581 establishes requirements for the 

impact resistance of vehicles in low-speed front and 

rear collisions. The purpose of this standard is to 

reduce physical damage to the front and rear ends 

of a passenger motor vehicle from low-speed 

collisions. 

received from manufacturers will be 

treated as confidential and individual 

self-reported values will not be released 

to the public, similar to how selfreported data is handled currently for 

crash avoidance NCAP. NHTSA will 

convert the data received to predicted 

score ‘‘color bands’’ and proceed with 

scoring self-reported data as proposed in 

the May 2023 RFC. 

As noted earlier, vehicle 

manufacturers must provide evidence 

that a production-level vehicle has 

undergone physical impact testing. At 

this time, NHTSA will not require a 

specific number of impacts to verify 

simulated data submitted, but the 

manufacturer must identify which 

points received physical testing and 

which were predicted using a 

simulation. A test report detailing the 

findings of the vehicle manufacturer’s 

validation testing must be generated 

before submission of the 

aforementioned predicted test data to 

the Agency. Additionally, an identifying 

test report number must accompany the 

test data received for each vehicle 

model under consideration for credit. 

The comprehensive report, along with 

time-stamped supplementary videos, 

will be made available to the Agency for 

review upon submission of data for each 

vehicle model, if and when it is 

requested by NHTSA. The Agency may 

choose to implement more stringent 

physical impact requirements in the 

future to verify simulated data if it is 

deemed necessary. 

b. Correction Factors During 

Verification Testing 

NHTSA has decided to move forward 

with the proposed correction factor 

method. For the headform tests, NHTSA 

will perform physical tests at 10 head 

impact locations. The results of these 

tests will be compared to the results 

submitted by the vehicle manufacturers 

at the corresponding impact locations 

and a correction factor will be 

calculated from this comparison. This 

correction factor will be applied to all 

manufacturer-submitted head impact 

results for the vehicle model to calculate 

new results, which will then be used to 

determine the vehicle’s final head subscore. 

For the upper and lower legform tests, 

NHTSA will perform all necessary 

impact tests to characterize full bumper 

crashworthiness performance. 

Principles of symmetry and adjacency 

will be employed to efficiently cover the 

full bumper width unless the 

manufacturer supplies information 

detailing why this should not be 

assumed. This NHTSA-generated 

legform test data will replace the 

manufacturer-submitted data in the 

vehicle’s scoring calculations. 

c. Publication of Results 

To expedite implementation, NHTSA 

will continue with the plan to identify 

vehicle models that meet 

crashworthiness pedestrian protection 

testing requirements (achieve 60 percent 

of all points possible) on the Agency’s 

website. This is intended to be a 

temporary system that will be replaced 

with a more detailed comparative rating 

system in the future. This comparative 

rating system will be implemented with 

the projected updates to the Monroney 

label as described in the NCAP 

roadmap.49

d. Optional Vehicle Features That Affect 

Testing and Scoring 

As part of its annual vehicle 

information collection activities, the 

Agency will request information 

regarding predicted performance 

differences between trim lines and any 

optional features offered.50 NHTSA will 

supply this information to the public 

when it conveys performance results for 

each vehicle model. Several 

commenters supported this approach, 

including Honda and HATCI. Given the 

myriad of features and options available 

on today’s vehicle fleet, it is difficult for 

the Agency to determine which vehicle 

trims within a model will perform 

differently from others. NHTSA 

considered following Euro NCAP’s 

protocol, which is to receive data for 

only the most popular variant and apply 

this result to all variants within the 

model. However, this method may not 

be the most appropriate, as it could 

grant credit to vehicles that are 

considerably different in terms of 

crashworthiness pedestrian protection 

performance. As the initial 

crashworthiness pedestrian protection 

testing program moves forward, NHTSA 

will review test data to determine 

whether this is the most appropriate 

approach to provide information to the 

public. 

E. Other Comments 

1. Comments Received 

Some topics were discussed by 

several commenters despite NHTSA’s 

not specifically requesting comments on 

them. The two most-discussed topics 

were (1) 49 CFR part 581, ‘‘Bumper 

Standard’’ (part 581) 51 requirements 

conflicting with crashworthiness 

pedestrian protection design, and (2) 

adoption of the aPLI as opposed to the 

FlexPLI for the lower leg impact tests. 

a. Conflict With Part 581 

NHTSA had previously received 

comments from manufacturers that 

incorporating lower leg bumper testing 

based on Euro NCAP would be difficult 

due to conflicts with the bumper 

damageability requirements outlined in 

49 CFR part 581. 

In response to the May 2023 RFC, 

Honda and HATCI expressed concern 

about part 581 damageability 

requirements competing against 

crashworthiness pedestrian protection 

designs. Auto Innovators recommended 

that NHTSA modify part 581 

damageability requirements to better 

accommodate crashworthiness 

pedestrian protection designs. GM 

recommended more research into the 

feasibility of passing both part 581 and 

crashworthiness pedestrian protection 

requirements. 

b. Adoption of the aPLI 

Many commenters encouraged 

NHTSA to adopt the aPLI, the latest 

pedestrian crash testing tool 

representing a 50th percentile male leg. 

It features a Simplified Upper Body Part 

(SUBP) that simulates the upper body 

mass, allowing enhanced kinematics for 

assessing knee, upper leg, and lower leg 

injuries. The aPLI was approved for use 

by Euro NCAP in TB 029 published in 

July 2023 and many commenters 

recommended that NHTSA adopt the 

aPLI for U.S. NCAP to harmonize with 

Euro NCAP procedures. Commenters 

also noted that the aPLI can be used in 

tests where the FlexPLI may experience 

difficulty, such as on curved bumpers 

and vehicles with an LBRL greater than 

500 mm. 

2. Discussion and Agency Decision 

a. Part 581 Issues 

The Agency stated in the May 2023 

RFC that it has examined potential 

conflicts between the part 581 

requirements and pedestrian 

crashworthiness leg impact testing. 

NHTSA concluded that vehicles should 

be able to meet both part 581 

requirements and receive a non-zero 

score in the Euro NCAP lower legform 

tests. As discussed in the May 2023 

RFC, NHTSA has tested vehicles that 

meet the part 581 damageability 

requirements and receive non-zero 


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52As indicated in NHTSA’s NCAP roadmap 

(https://www.nhtsa.gov/document/ncap-roadmap), 

the Agency plans to use the aPLI for NCAP starting 

with MY 2030 vehicles. 

scores on FlexPLI legform testing. The 

example provided in the RFC was a 

2016 hatchback passenger car that 

NHTSA tested, which obtained a result 

of 4.41 out of 6.00 points (73.5 percent) 

for lower leg impact testing. As such, 

NHTSA does not believe the new 

pedestrian protection program will 

contradict the part 581 damageability 

requirements. 

b. Adoption of the aPLI 

While NHTSA concurs with 

commenters regarding the use of the 

latest testing tools, the Agency has not 

yet thoroughly evaluated the aPLI. Thus, 

NHTSA will adopt the FlexPLI as a 

temporary solution while it conducts 

the required analysis for the aPLI. The 

FlexPLI has historically been used in 

Euro NCAP testing and is adequately 

biofidelic. Given the urgent need for 

crashworthiness pedestrian protection 

testing, NHTSA’s immediate adoption of 

the FlexPLI in NCAP testing will 

prompt more rapid improvement in 

pedestrian protection than waiting to 

adopt the aPLI.52 Additionally, NHTSA 

anticipates that manufacturers and test 

facilities are familiar with the FlexPLI, 

which will smooth the adoption 

process. 

VI. Procedure in Detail 

A. Differences From Euro NCAP Tests 

and Assessment Protocols 

As previously stated, NHTSA will use 

the Euro NCAP testing protocol as a 

basis from which to conduct its 

assessment on all selected vehicles, 

including pickup trucks and large SUVs. 

For the most part, the procedures of 

Euro NCAP Testing Protocol v8.5 are 

applicable to all vehicles eligible for 

testing under U.S. NCAP (vehicles with 

a gross vehicle weight rating less than 

or equal to 4,536 kg, or 10,000 lb.). 

However, some adjustments to the Euro 

NCAP testing protocol are needed to 

align with the self-reporting aspect of 

U.S. NCAP, to better reflect pedestrian 

protection provided by the vehicle’s 

front end, and to improve test practices. 

These noteworthy changes are outlined 

in the following subsections. 

1. Use of FlexPLI 

While Euro NCAP has replaced the 

FlexPLI with the aPLI for its lower leg 

impact tests in its most recent testing 

protocol (v9.1), NHTSA will use the 

FlexPLI for U.S. NCAP testing while it 

completes further analysis on the aPLI. 

As discussed previously, the Agency 

will perform its own testing, research, 

and evaluations prior to making a 

decision to adopt the aPLI. To prevent 

a delay of the crashworthiness 

pedestrian protection program, NHTSA 

will use the FlexPLI for lower leg 

impacts. 

At the time of the May 2023 RFC, 

Euro NCAP was using its VRU Testing 

Protocol v8.5, which specified that 

manufacturers could choose whether to 

use the FlexPLI or the TRL upper 

legform for vehicles with an LBRL 

greater than or equal to 425 mm and less 

than or equal to 500 mm. Euro NCAP 

has since updated its VRU Testing 

Protocol to v9.1, which no longer allows 

manufacturers this option due to the 

adoption of the aPLI. NHTSA will not 

allow manufacturers the option to 

choose the TRL upper legform for 

vehicles with an LBRL greater than or 

equal to 425 mm and less than or equal 

to 500 mm. Instead, the FlexPLI will be 

used for all vehicles with an LBRL less 

than or equal to 500 mm. 

2. No FlexPLI Bumper Testing When 

LBRL Is Greater Than 500 mm 

For vehicles that have an LBRL value 

of greater than 500 mm, NHTSA will 

assign a ‘‘default red, no points’’ score 

to the particular point under assessment 

(e.g., some bumper points may be above 

500 mm and not tested while others 

may be equal to or below 500 mm and 

tested). The FlexPLI has a poor 

kinematic response when used to 

impact bumpers with an LBRL greater 

than 500 mm. Additionally, NHTSA is 

not aware of any existing 

countermeasures that would improve 

the lower leg safety of vehicles with an 

LBRL greater than 500 mm when tested 

with the FlexPLI. 

3. FlexPLI Qualification Procedure and 

Testing 

As mentioned previously, differences 

exist between NHTSA’s adopted 

FlexPLI qualification procedure/ 

schedule and those of other entities. 

UNECE R127 specifies two dynamic 

qualification tests—a pendulum test and 

an inverse impact test, in addition to a 

series of quasi-static tests. In UNECE 

R127, the dynamic qualification tests 

are performed before and throughout a 

test series, while the quasi-static tests 

are performed on an annual basis. Euro 

NCAP only specifies the dynamic 

inverse impact test and the quasi-static 

tests. As shown in Table 7 below, 

NHTSA prescribes the inverse impact 

test after every 20 impacts, the quasistatic tests once per year, and only 

requires the pendulum test if any lower 

performance limits are exceeded. 

TABLE 7—FLEXPLI QUALIFICATION TESTING SCHEDULE

Test mode Frequency Align with 

Euro NCAP? 

Inverse Impact Test ................................... After every 20 impacts .................................................................................................. Yes. 

Quasi-static Tests ...................................... Every 12 months ........................................................................................................... Yes. 

Pendulum Test .......................................... If testing exceeds any lower performance limits .......................................................... No. 

4. Bumper Corner Definition 

In the Euro NCAP test protocol, the 

width of the lower legform test area is 

defined by the point of contact of a 60- 

degree plane and the forward-most 

point on the vehicle front-end. This 

method is referred to as the ‘‘60-degree 

angle method.’’ Alternatively, the 

UNECE R127 and GTR 9 regulations use 

the ‘‘corner gauge method.’’ This 

method identifies the corner of the 

bumper by locating the outermost point 

of contact of the gauge when it is moved 

parallel to a vertical plane with an angle 

of 60 degrees to the vertical longitudinal 

center plane of the vehicle. Both 

methods additionally specify that the 

outer limits of the bumper test zone are 

either defined by the bumper corners 

using the 60-degree angle/corner gauge 

method or the outermost ends of the 

bumper beam, whichever is larger. 

As described in detail previously, 

NHTSA will use the corner gauge 

method instead of the 60-degree angle 

method for NCAP testing. NHTSA will 

also include the stipulation that if the 

bumper beam width differs from the 

width defined by the corners using the 

corner gauge method, the larger of the 

areas will be used. 


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53NHTSA is in the process of renewing its 

existing approved information collection (OMB– 

2127–0629) to include collecting self-reported data 

from the vehicle manufacturers for this new 

crashworthiness pedestrian protection testing 

program. 

5. Active Hood Detection 

For vehicles with active hoods, the 

Agency will require manufacturers to 

demonstrate that their system activates 

when there is a leg-to-bumper impact 

both at the vehicle centerline and as far 

outboard as the outboard end of the 

bumper test zone. This is the same 

requirement as in the Euro NCAP test 

procedure. However, NHTSA will use 

the corner gauge method discussed 

above when determining the outboard 

end of the bumper test zone. Like Euro 

NCAP, NHTSA will also use the PDI–2 

impactor for the purpose of deploying 

the active hood. 

6. WAD Limit 

When marking up the vehicle to be 

tested, Euro NCAP currently specifies 

that the WADs should be marked at 100 

mm intervals from 1000 mm to at least 

2500 mm. This 2500 mm limit was an 

increase from 2100 mm when Euro 

NCAP introduced the VRU Test Protocol 

v9.0.3 in May 2023, replacing the 

Pedestrian Test Protocol v8.5. As 

explained in detail previously, NHTSA 

will use the WAD limit of 2100 mm for 

its NCAP crashworthiness pedestrian 

protection program, but it will consider 

increasing the limit to 2500 mm in the 

future. 

7. Self-Reporting System 

In Euro NCAP, manufacturers 

typically self-report predicted head 

impact test data of their vehicles before 

Euro NCAP conducts its impact testing 

on those vehicles. However, upper leg 

and lower leg impact test data are not 

provided by the manufacturer. Instead, 

these data are gathered from the testing 

conducted by the Euro NCAP test 

facilities. U.S. NCAP will operate its 

program in a fully self-reported manner, 

with verification testing performed on a 

selection of vehicles to ensure 

accuracy—similar to the Agency’s crash 

avoidance test program.53 Vehicle 

manufacturers will report all head, 

upper leg, and lower leg impact test data 

to NCAP to receive crashworthiness 

pedestrian protection credit for their 

vehicles. As mentioned earlier, NHTSA 

will accept simulated data, but it must 

be validated by physical testing on a 

production-level vehicle. 

Specifically, NHTSA will require 

actual or predicted HIC15 for each 

headform grid point, actual or predicted 

upper legform bending moment and 

force for each bumper impact location, 

and actual or predicted lower legform 

tibia bending moment and MCL and 

ACL/PCL elongations for each bumper 

impact location. Manufacturers will 

submit this information to NHTSA in a 

NHTSA-specified standardized format 

and will include a unique test report 

number identifying the vehicle model’s 

results. This test report, along with 

time-stamped supplementary videos, 

will be made available to the Agency for 

review upon submission of data for each 

vehicle model upon NHTSA’s request. 

NHTSA will not allow the inclusion 

of ‘‘blue points,’’ which are allowed by 

Euro NCAP. Due to the unpredictable 

nature of these grid points, the 

manufacturer does not include blue 

points in computing the overall score 

for the head impact testing assessment 

submitted to Euro NCAP. Euro NCAP 

always tests the identified blue points 

(in addition to selecting grid points) and 

includes the head impact assessment at 

these blue points in computing the 

overall head impact score. For U.S. 

NCAP, for a manufacturer to self-report 

that its vehicle meets the NCAP 

performance criteria and receives 

crashworthiness pedestrian protection 

credit, the manufacturer must have 

sufficient data to support a predicted 

point/color value for every head grid 

point and every upper and lower leg 

impact test point. 

8. NCAP Scoring Apportionment 

Euro NCAP recently revised the 

apportionment of points for scoring the 

leg and head impacts. Out of a possible 

36.0 points, 18.0 points are allocated to 

head injury data, 9.0 points for lower leg 

injury data, 4.5 points for upper leg 

injury data, and 4.5 points for pelvis 

injury data. NHTSA proposed in the 

RFC a scoring apportionment that 

aligned with the relative frequency of 

AIS 3+ injuries to the body regions in 

the U.S. Out of a possible 36.0 points, 

13.5 were allocated to head impacts, 

13.5 points for lower leg impacts, and 

9.0 points for upper leg impacts. As 

previously mentioned in the Comments 

and Discussion and Agency Decision 

sections, NHTSA has decided to adjust 

the scoring apportionment to provide 

more emphasis on head impacts, which 

are more likely to be fatal than leg 

injuries, while still maintaining the 

value of the legform tests. This 

adjustment will also help align with 

Euro NCAP’s current scoring 

apportionment. The apportionment for 

U.S. NCAP is as follows: out of a 

possible 36.000 points, 18.000 points 

are allocated to head impacts, 9.000 

points are allocated for lower leg 

impacts, and 9.000 points are allocated 

for upper leg impacts. A comparison of 

each scoring method is shown below in 

Table 8. 

TABLE 8—SCORING APPORTIONMENT METHODS

Body region 

Points apportionment 

(out of 36.0 possible points) 

Euro NCAP 

(2018) 

U.S. NCAP RFC 

(2023) 

Euro NCAP 

(2023) 

U.S. NCAP 

(2024) 

Head .................................. 24.0 pts (66.67%) ............. 13.5 pts (37.5%) ............... 18.0 pts (50%) .................. 18.000 pts (50%). 

Pelvis ................................. ........................................... ........................................... 4.5 pts (12.5%).

Upper Leg .......................... 6.0 pts (16.67%) ............... 9.0 pts (25%) .................... 4.5 pts (12.5%) ................. 9.000 pts (25%). 

Lower Leg .......................... 6.0 pts (16.67%) ............... 13.5 pts (37.5%) ............... 9.0 pts (25%) .................... 9.000 pts (25%). 

9. Credit Publication Process 

In Euro NCAP, the vehicle’s VRU subscore is included in the vehicle’s overall 

safety rating. At this time, NHTSA will 

not integrate the crashworthiness 

pedestrian protection score into its 

existing comparative rating system. To 

expedite implementation of this 

program, NHTSA will identify vehicle 

models that meet the crashworthiness 

pedestrian protection testing 

requirements (earning at least 21.600 

out of 36.000 possible points, or 60 

percent) on NHTSA’s website. 

B. Injury Limits and Scoring Process 

The injury limits and scoring process 

for NHTSA’s crashworthiness 

pedestrian protection impact tests will 


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be largely the same as those in Euro 

NCAP, as outlined in the Euro NCAP 

Assessment Protocol—VRU Protection, 

Part 1—Pedestrian Impact Assessment, 

Version 10.0.3, June 2020. For U.S. 

NCAP, each group of component tests 

(i.e., headform tests, upper legform tests, 

lower leg tests) will first be scored 

individually; these component scores 

will then be summed to determine a 

crashworthiness pedestrian protection 

score for each vehicle. The exact 

number of impact points will vary 

depending on the geometry of a vehicle. 

For instance, there may be 200 head 

impact points on the hood, windshield, 

and A-pillars; 15 upper leg impact 

points on the forward edge of the 

vehicle’s front-end; and 15 lower leg 

impact points on the vehicle’s bumper 

area. Each impact point for each test 

device will be scored between 0 and 1 

point depending on the resulting injury 

values from the impact test. Each group 

of component tests (headform tests, 

upper leg tests, and lower leg tests) will 

generate its own sub-score as described 

below. The sum of each of the three subscores will result in the final pedestrian 

protection score, as defined in the 

following formula: Pedestrian Protection 

Score = Head SubScore + Upper Leg 

SubScore + FlexPLI SubScore. 

1. Headform Tests 

Each of the head impact locations on 

a vehicle will contribute equally to the 

component level sub-score for the head 

tests. Each impact location will receive 

a score between 0 and 1 based on the 

HIC15 value output from the headform 

impact test. Different ranges of HIC15

values will correspond to different 

colors and point values based on the 

Euro NCAP assessment protocol, 

summarized in Table 9. 

TABLE 9—HEADFORM SCORING

Color HIC minimum HIC maximum Points 

Green ......................................................................................................................... .............................. <650 1.000 

Yellow ........................................................................................................................ 650 <1,000 0.750 

Orange ....................................................................................................................... 1,000 <1,350 0.500 

Brown ......................................................................................................................... 1,350 <1,700 0.250 

Red ............................................................................................................................ 1,700 .............................. 0.000 

The head impact sub-score will be 

calculated according to the following 

formula: Head SubScore = 

Apportionment of Head Impacts * (Sum 

of All Head Impact Points)/(Total 

Number of Head Impact Points). 

2. Upper Legform Tests 

Each of the upper legform impact 

locations will contribute equally to the 

component level sub-score for the upper 

legform impacts. Each impact location 

can receive up to 1.00 point on a linear 

sliding scale between the upper and 

lower injury limits. This is different 

from the headform scoring method, 

where injury values will be put in 

discrete scoring bands. The worstperforming injury metric (one of three 

moments—upper, middle, or lower; or 

sum of forces) will be used to determine 

the score using the criteria shown in 

Table 10. 

TABLE 10—UPPER LEGFORM SCORING

Component Minimum injury Maximum injury Maximum points 

Bending Moment (Nm) .............................................................................................. 285 350 1.000 

Sum of Forces (N) ..................................................................................................... 5000 6000

The upper legform scoring is shown 

graphically in Figure 9 and Figure 10. 

Injury values closer to the minimum 

injury values earn more points and 

injury values closer to the maximum 

injury values earn fewer points. 


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Figure 9: Upper Legform Bending 

Moment Scoring 

Figure 10: Upper Legform Sum of Forces 

Scoring 

The upper legform impact sub-score 

will be calculated according to the 

following formula: Upper Leg SubScore 

= Apportionment of Upper Leg Impacts 

* (Sum of All Upper Leg Impact Points)/ 

(Total Number of Upper Leg Impact 

Points). 

3. Lower Legform Tests 

Similarly, each of the FlexPLI impact 

locations on a vehicle will contribute 

equally to the component level subscore for the lower legform tests. Each 

impact location can receive up to 0.500 

points from the tibia moments and up 

to 0.500 points from the ligament 

elongations, as shown in Table 11. The 

tibia score will be determined from the 

worst of the four tibia measurements— 

T1, T2, T3, or T4. The ligament 

elongation will be scored from the MCL 

as long as neither the ACL nor PCL 

exceeds the 10 mm elongation limit. If 

either the ACL or PCL exceed this limit, 

the overall ligament elongation score 

will be 0.00. 


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TABLE 11—FLEXPLI SCORING

Component Minimum injury Maximum injury Maximum points 

Tibia Bending (Nm) .................................................................................................... 282 340 0.500 

MCL Elongation (mm) ................................................................................................ 19 22 0.500 

ACL/PCL Elongation (mm) ........................................................................................ .............................. 10 ..............................

Similar to the upper legform scoring, 

the Euro NCAP assessment protocol 

awards points based on a linear sliding 

scale between the upper and lower 

injury limits using the criteria in Figure 

11 and Figure 12. NHTSA will be using 

this same linear sliding scale for the 

U.S. NCAP. Again, this is different from 

the headform scoring method, where 

injury values will be put in discrete 

scoring bands. 

Figure 11: FlexPLI Tibia Bending 

Moment Scoring 


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Figure 12: FlexPLI MCL Elongation 

Scoring 

The FlexPLI impact sub-score will be 

calculated according to the following 

formula: FlexPLI SubScore = 

Apportionment of FlexPLI Impacts * 

(Sum of All FlexPLI Impact Points)/ 

(Total Number of FlexPLI Impact 

Points). 

C. NCAP Proposal for Awarding Credit 

As stated earlier in this notice, 

NHTSA is implementing the 

crashworthiness pedestrian protection 

testing program initially by assigning 

credit to vehicles that meet NCAP 

performance test requirements. Initially, 

instead of rating a vehicle’s 

crashworthiness pedestrian protection 

on a scale of 1 to 5 stars, NHTSA will 

assign credit to vehicles that meet a 

certain minimum scoring threshold for 

crashworthiness pedestrian protection. 

Consumers will be able to compare 

crashworthiness pedestrian protection 

by identifying vehicles that NHTSA has 

designated as meeting this minimum 

level of pedestrian safety. Furthermore, 

this approach not only allows early 

adopters to participate in the program, 

but it also provides sufficient time for 

manufacturers to redesign their vehicles 

to improve pedestrian crashworthiness 

safety. 

For a vehicle to be recognized by 

NHTSA as meeting the performance 

requirements for crashworthiness 

pedestrian protection, it must score at 

least 21.600 out of 36.000 points (or 60 

percent) combined for the head, upper 

leg, and lower leg impact tests when 

tested and scored in accordance with 

the standards outlined in the previous 

sections of this notice and the modified 

apportionment scoring. 

As NHTSA is still developing a new 

rating system that will include several 

planned NCAP updates, NHTSA is not 

implementing changes to the Monroney 

label or overall vehicle rating system at 

this time. Therefore, NHTSA will 

inform consumers of vehicles that 

receive crashworthiness pedestrian 

protection credit through its website, 

http://www.NHTSA.gov. This approach 

is similar to the current crash avoidance 

testing program in NCAP. Currently, 

ADAS technologies are identified 

through the use of checkmarks on the 

Agency’s website. 

D. NCAP Verification Testing 

NHTSA will implement a verification 

testing process for the crashworthiness 

pedestrian protection that is similar to 

the crash avoidance testing program in 

NCAP. As mentioned previously in this 

notice, the manufacturer will be 

required to submit actual or predicted 

data for every head impact grid point 

and every upper and lower leg impact 

test location. NHTSA will review this 

information for accuracy and 

completeness and award credit if the 

submitted data meet the minimum 

criteria outlined previously. For each 

new model year, NHTSA selects and 

acquires vehicles for testing under 

NCAP. Consistent with the processes 

used in the crash avoidance testing 

program, NHTSA will select and acquire 

new model year vehicles for verification 

testing of their crashworthiness 

pedestrian protection performance. 

NHTSA will only select vehicles with 

test data submitted by the 

manufacturers and approved by the 

Agency as meeting the minimum 

performance criteria for crashworthiness 

pedestrian protection. 

For the upper leg and FlexPLI impact 

testing, NHTSA will conduct its own 

tests and use this data instead of the 

manufacturer’s provided data for the 

sub-scores. For the head impact testing, 

NHTSA will select 10 impact locations 

and conduct its own tests, using this 

data to calculate a correction factor. 

NHTSA’s head impact data will be 

compared to the manufacturer’s 

provided data at the corresponding 

impact locations. Consistent with Euro 

NCAP’s test procedure, each color band 

will have a 10 percent tolerance when 

comparing NHTSA’s color band/test 

values to the manufacturer’s color band/ 

test values (Table 12). For example, if a 

manufacturer submits a grid point HIC15

falling in the yellow color band but 

NHTSA’s verification test finds HIC15 to 

be 1,200, NHTSA will instead classify 

this grid point as orange. 

TABLE 12—ACCEPTABLE HIC RANGE FOR VERIFICATION TESTING

Predicted color band HIC15 range Acceptable HIC15 range 

Green ................................... HIC15 <650 ...................................................................... HIC15 <722.22 

Yellow ................................... 650 ≤ HIC15 <1,000 ......................................................... 590.91 ≤ HIC15 <1,111.11 

Orange ................................. 1,000 ≤ HIC15 <1,350 ...................................................... 909.09 ≤ HIC15 <1,500 

Brown ................................... 1,350 ≤ HIC15 <1,700 ...................................................... 1,227.27 ≤ HIC15 <1,888.89 

Red ....................................... 1,700 ≤ HIC15 .................................................................. 1,545.45 ≤ HIC15

The correction factor is then 

calculated per the following equation: 

Correction Factor = (Sum of Actual Test 

Scores)/(Sum of Predicted Test Scores). 

This correction factor is then applied 

to the manufacturer’s provided data to 

calculate the corrected head impact subscore per the following equation: 

Corrected Head SubScore = (Head 

SubScore ¥ Default Green ¥ Default 

Red) * Correction Factor + Default 

Green + Default Red. 

A detailed example of the head 

impact verification test scoring is 

provided in Appendix C. 

VII. Conclusion 

NHTSA will implement the 

crashworthiness pedestrian protection 

test devices, test procedures, and 

scoring methods as discussed above 

beginning with model year 2026 

vehicles. For that model year, NHTSA 

will assess crashworthiness pedestrian 

protection for vehicles by calculating a 

score based on head, upper leg, and 

lower leg impact data voluntarily 

submitted by manufacturers. The 

procedures and scoring methods are 

based on the Euro NCAP documents 

listed below. 

(1) Euro NCAP Pedestrian Testing 

Protocol, Version 8.5, October 2018. 

(2) Euro NCAP Assessment Protocol— 

Vulnerable Road User Protection, 

Part 1—Pedestrian Impact 

Assessment, Version 10.0.3, June 

2020. 

(3) Euro NCAP Pedestrian Headform 

Point Selection, V2.1, October 2017. 

Note: Due to the differences in 

scoring systems and data 

submission, NHTSA will create a 

similar scoring sheet specific to the 

crashworthiness pedestrian 

protection program implemented in 

U.S. NCAP. 

(4) Euro NCAP Film and Photo Protocol, 

Chapter 8—Pedestrian Subsystem 

Tests, V1.4, July 2023. 

(5) Euro NCAP Technical Bulletin TB 

008, Windscreen Replacement for 

Pedestrian Testing, Version 1.0, 

September 2009. 

(6) Euro NCAP Technical Bulletin TB 

019, Headform to Bonnet Leading 

Edge Tests, Version 1.0, June 2014. 


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54Pastor, C., ‘‘Correlation between pedestrian 

injury severity in real-life crashes and Euro NCAP 

pedestrian test results,’’ The 23rd International 

Technical Conference on the Enhanced Safety of 

Vehicles, Paper No. 13–0308, 2013. 

55Standroth, J. et al. (2014), ‘‘Correlation between 

Euro NCAP pedestrian test results and injury 

severity in injury crashes with pedestrians and 

bicyclists in Sweden,’’ Stapp Car Crash Journal, 

Vol. 58 (November 2014), pp. 213–231. 

(7) Euro NCAP Technical Bulletin TB 

024, Pedestrian Human Model 

Certification, V4.0, January 2024. 

NHTSA will identify new model year 

vehicles that meet a minimum safety 

threshold of crashworthiness pedestrian 

protection on the Agency’s website. 

This minimum safety threshold is a total 

score of 21.600/36.000 points (60 

percent) or greater, where a maximum of 

18.000/36.000 points (50 percent) are 

possible for head impacts, 9.000/36.000 

points (25 percent) are possible for 

lower leg impacts, and 9.000/36.000 

points (25 percent) are possible for 

upper leg impacts. The impact tests 

simulate a 6-year-old child and an 

average-size adult male being struck in 

the side by a vehicle traveling at 40 km/ 

h (25 mph). The area of assessment for 

the vehicle is limited to all points 

forward of the WAD2100 mm line. At 

this time, NHTSA is allowing vehicle 

manufacturers to self-report their test 

results for these impact tests to provide 

this information to consumers as soon 

as possible. Manufacturer-submitted 

data will be randomly verified by 

NHTSA through impact testing 

performed on select models. These 

changes will fulfill the mandate set forth 

in the BIL to amend NCAP to provide 

the public with important safety 

information regarding the protection of 

VRUs. 

VIII. Economic Analysis 

The changes to NCAP in this final 

decision notice would ultimately enable 

a rating system that improves consumer 

awareness of crashworthiness 

pedestrian protection systems and the 

improvements to safety that stem from 

those systems. These changes may also 

encourage manufacturers to accelerate 

the adoption of these systems. The 

accelerated adoption of pedestrian 

protection systems would drive any 

economic and societal impacts that 

result from these changes and are thus 

the focus of this discussion of economic 

analysis. Hence, the Agency has 

considered the potential economic 

effects of the inclusion of pedestrian 

protection systems in NCAP and the 

potential benefit of eventually 

developing a new rating system that 

would include this information. 

Crashworthiness pedestrian 

protection systems are unique because 

the safety improvements are attributable 

to improved VRU protection, as 

opposed to improvements in protection 

for vehicle occupants that the other 

crashworthiness components in NCAP 

provide. Their effectiveness is the 

reduction of VRU injury and prevention 

of VRU fatalities when a crash between 

a motor vehicle and pedestrian occurs. 

This effectiveness is typically measured 

by using a combination of real-world 

statistical data, laboratory testing, and 

Agency expertise. 

Crashes between pedestrians and 

motor vehicles present significant safety 

issues, and NHTSA is particularly 

concerned about the steady rise in 

pedestrian fatalities over the last several 

years. The data from countries that 

prioritize crashworthiness pedestrian 

protection systems, via both regulation 

and other consumer information 

programs, indicate that these systems 

are effective in reducing pedestrian 

injuries and fatalities. BASt in Germany 

found a correlation between Euro NCAP 

pedestrian protection scores and 

pedestrian injuries and fatalities.54 The 

Swedish Transport Administration also 

found that vehicles that score better in 

the Euro NCAP pedestrian 

crashworthiness tests tended to reduce 

injury in actual crashes.55 Although 

these studies have been limited to 

certain geographic areas, which may not 

represent the entire U.S. fleet, they do 

illustrate how these systems can provide 

safety benefits. Thus, although the 

Agency does not have sufficient data to 

determine the monetized safety impacts 

resulting from these systems in a way 

similar to that frequently done for 

mandated technologies, when compared 

to the future without this update to 

NCAP, NHTSA expects that these 

changes would likely have substantial 

positive safety effects by promoting 

earlier and more widespread 

deployment of crashworthiness 

pedestrian protection systems. 

NCAP also helps address the issue of 

asymmetric information (i.e., when one 

party in a transaction is in possession of 

more information than the other), which 

can be considered a market failure. 

Regarding consumer information, the 

introduction of a potential new 

component to the NCAP rating system is 

anticipated to provide consumers 

additional vehicle safety information 

regarding the safety of VRUs. This 

information will help them make more 

informed purchasing decisions by 

presenting the relative safety benefits of 

systems designed to protect not only 

vehicle occupants but also persons 

outside the vehicle. While NHTSA 

knows that consumers value 

information about the protection of 

vehicle occupants when making 

purchasing decisions, the Agency 

believes that most consumers are also 

interested in protecting people who 

share their roads. Hence, there is a real 

if unquantifiable value to consumers 

and to society as a whole for the Agency 

to provide accurate and comparable 

vehicle safety information about 

protecting all lives. At this time, the 

Agency does not have sufficient data, 

such as unit cost and information on 

how soon the full adoption of 

pedestrian protections systems would 

be reached, to predict the net increase 

in cost to consumers with a high degree 

of certainty. 

IX. Appendices 

Appendix A: Questions From RFC 

[1] NHTSA seeks comment on the 

topic of female leg safety. Are there data 

showing that vehicle front end designs 

that perform well in the FlexPLI and 

upper legform impact tests would not 

afford protection to female pedestrians? 

Are there any legforms representing 

female or small stature pedestrians? Are 

there female specific data and 

associated 5th percentile female specific 

injury criteria for use with a 5th 

percentile female legform impactor? 

[2] NHTSA seeks comment on what 

an acceptable humidity tolerance 

should be for the qualification tests of 

the upper legform impactor and the 

associated vehicle test with the upper 

legform. 

[3] NHTSA is requesting comment on 

the FlexPLI qualification procedures— 

specifically which procedures (dynamic 

and quasi-static) should be used for 

qualification, and how often they 

should be conducted? 

[4] An Agency study of Abbreviated 

Injury Scale (AIS) 3+ pedestrian injuries 

in the U.S. showed that the 

apportionment of points in NCAP for 

crashworthiness pedestrian protection 

should be 3/8th for head impact test 

results (37.5 percent), 3/8th for lower 

leg impact test results (37.5 percent), 

and 2/8th for upper leg impact test (25 

percent). NHTSA seeks comment on 

whether injury severity or frequency 

would be this the most appropriate basis 

for point allocation apportionment. 

[5] As concluded in the Agency’s 

FlexPLI research report, NHTSA 

believes the FlexPLI legform is 

biofidelic and seeks comment from the 

public on whether biofidelity concerns 

with the FlexPLI still remain at this 

time. 

[6] NHTSA is seeking comment on 

what procedure it should use for 


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56The Euro NCAP protocols and version used for 

this comparison are the Pedestrian Test Protocol 

v8.5 and the Assessment Protocol—VRU v10.0.3. 

marking the test zone on bumpers. In 

other words, should the procedure 

harmonize with the Euro NCAP 60- 

degree angle method or should it follow 

the GTR 9 and UNECE R127 corner 

gauge method? 

[7] GM suggested that if a vehicle has 

an exposed bumper, the bumper test 

zone should use the 60-degree angle 

method instead of testing the full 

bumper width to eliminate testing at the 

extreme edge of what may be a curved 

bumper. NHTSA requests comment on 

this concern as well, as it is similar to 

the previous question for bumper test 

zones. 

[8] Given the pedestrian death and 

injury crisis on U.S. roadways NHTSA 

is seeking comment on test speeds. 

Should test speeds for either of the head 

or leg tests be increased in an attempt 

to provide better protection to 

pedestrians in vehicle to pedestrian 

crashes? Should the area of assessment 

be increased beyond the WAD limit of 

2100 mm currently proposed to account 

for pedestrian heads overshooting the 

hood and impacting the windshield or 

the roof of the vehicle? 

[9] NHTSA requests comment on the 

seven Euro NCAP documents proposed 

in section IV. F. (Euro NCAP Pedestrian 

Testing Protocol Version 8.5, Euro 

NCAP Assessment Protocol—Vulnerable 

Road User Protection Part 1—Pedestrian 

Impact Assessment Version 10.0.3, Euro 

NCAP Pedestrian Headform Point 

Selection V2.1, Euro NCAP Film and 

Photo Protocol Chapter 8—Pedestrian 

Subsystem Tests V1.3, Euro NCAP 

Technical Bulletin TB 008 Windscreen 

Replacement for Pedestrian Testing 

Version 1.0, Euro NCAP Technical 

Bulletin TB 019 Headform to Bonnet 

Leading Edge Tests Version 1.0, and 

Euro NCAP Technical Bulletin TB 024 

Pedestrian Human Model Certification 

V2.0)—do any elements of these 

documents need modification for the 

U.S. NCAP? 

[10] NHTSA requests comment on TB 

024 and its relevance to the U.S. NCAP. 

Should the models and methods in TB 

024 or some other method be used to 

calculate head impact times to evaluate 

vehicles with active hoods? 

[11] NHTSA seeks comment on what 

level of detail should be required for 

self-reported data. Should 

manufacturers be allowed to submit 

predicted head and leg response data, or 

only actual physical test results? Should 

reporting consist of just the results for 

each test location, or should full data 

traces or a comprehensive test report 

including photographs and videos be 

required? 

[12] NHTSA requests comment on 

whether vehicles with an LBRL greater 

than 500 mm should be eligible to 

receive crashworthiness pedestrian 

protection credit because they will 

automatically receive a zero score for 

the FlexPLI bumper tests. 

[13] NHTSA requests comment on the 

proposal to reposition the upper legform 

±50 mm from the WAD775 target when 

artificial interference is present or to 

conduct multiple impacts within ±50 

mm from the WAD775 target and use 

the worst-case result when artificial 

interference is present. 

[14] NHTSA tentatively plans to use 

the corner gauge and bumper beam 

width procedure for corner definition 

for this NCAP proposal and requests 

comment on this change. 

[15] NHTSA seeks comments on 

whether there is benefit in requiring 

both the Pendulum and Inverse Impact 

dynamic qualification tests in addition 

to the quasi-static tests. Also, what 

should the qualification test schedule be 

for the FlexPLI be? 

[16] NHTSA seeks comment on what 

the required detection area should be for 

vehicles with active hoods. 

Additionally, which device should be 

used for assuring the system activates 

properly, the Flex-PLI or the PDI2? 

[17] NHTSA proposes utilizing a 

modified 3⁄8, 3⁄8, 2⁄8 scoring 

apportionment for the head impacts, 

Flex PLI impacts, and upper leg impacts 

respectively for NCAP and requests 

comment on this proposal. 

[18] NHTSA seeks comment on 

whether [a checkmark on NHTSA.gov] 

is an appropriate way to identify 

vehicles that meet the Agency’s 

minimum criteria for crashworthiness 

pedestrian protection, or if some other 

notation or identifying means is more 

appropriate. 

[19] NHTSA seeks comment on what 

options or features might exist within 

the same vehicle model that would 

affect the vehicle’s performance of 

crashworthiness pedestrian protection. 

NHTSA also seeks comment on whether 

the Agency should assign credit to 

vehicles based on the worst-performing 

configuration for a specific vehicle 

model, or if vehicle models with 

optional equipment that affect the 

crashworthiness pedestrian protection 

credit should be noted as such. 

[20] NHTSA seeks comment on the 

proposal to conduct verification testing 

as part of the crashworthiness 

pedestrian protection program by 

adjusting the head score using a 

conversion factor determined from 

laboratory tests and replacing 

manufacturer supplied FlexPLI and 

upper leg scores with NHTSA scores 

from laboratory tests. 

Appendix B: Supplementary Tables 

TABLE B1—SUMMARY OF DIFFERENCES BETWEEN EURO NCAP ASSESSMENT PROTOCOLS AND U.S. NCAP 

PROCEDURES

Subject Euro NCAP56 U.S. NCAP 

Vehicle with LBRL between 

425 mm and 500 mm (inclusive).

Manufacturer can choose to use either FlexPLI or TRL 

Upper Legform for the bumper test.

Only FlexPLI will be used for the legform to bumper 

test. 

Vehicle with LBRL >500 mm TRL Upper Legform is used instead of FlexPLI ............. Default red, no points for FlexPLI sub-score. 

Bumper Corner Definition .... 60-degree angle method is used to define bumper corners.Corner gauge method is used to define bumper corners. 

Blue Points for Head Impact 

Locations.

Allowed ............................................................................ Not allowed, manufacturers must submit predicted or 

tested head impact results for all points. 

FlexPLI Qualification Tests 

and Schedule.

Inverse test: After every 20 impacts (maximum) and 

once every 12 months, or if legform exceeds lower 

performance limits Quasi-static tests: Once per year.

Inverse test: After every 20 impacts Quasi-static tests: 

Once per year Pendulum test: If testing exceeds any 

lower performance limits. 

Point Apportionment ............ 24/36 pts (66.67%) for head ........................................... 18.000/36.000 pts (50%) for head. 

6/36 pts (16.67%) for upper leg ...................................... 9.000/36.000 pts (25%) for upper leg. 

6/36 pts (16.67%) for lower leg ...................................... 9.000/36.000 pts (25%) for lower leg. 


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57Note that the figures below are examples only; 

the requested submission format may change. 

58Euro NCAP stipulates that test points located 

on the A-pillars are default red, and test points 

located in the central portion of the windshield 

glazing away from edges or underlying components 

are default green. 

TABLE B1—SUMMARY OF DIFFERENCES BETWEEN EURO NCAP ASSESSMENT PROTOCOLS AND U.S. NCAP 

PROCEDURES—Continued 

Subject Euro NCAP56 U.S. NCAP 

Results Reporting ................ Euro NCAP Five-Star Rating System ............................. Checkmark (or similar) on NHTSA website. 

Appendix C: Vehicle Scoring and 

Verification Testing Example— 

Passenger Car 

In the hypothetical example of a 

verification test, the vehicle is assumed 

to have met NHTSA’s minimum 

requirements for pedestrian protection 

credit and verification testing: the 

manufacturer reported to NHTSA that 

its vehicle met the minimum 

requirements (i.e., at least 60 percent or 

21.600 out of 36.000 points); the 

manufacturer provided predicted and/or 

actual test data in a standardized format; 

NHTSA reviewed this data for accuracy 

and completeness; and NHTSA selected 

this vehicle for verification testing. 

Figure C1 and Table C1 are examples 

of the level of detail of head impact data 

a manufacturer would provide to 

NHTSA to receive credit for meeting 

NHTSA’s pedestrian protection criteria 

under NCAP.57 Figure C1 shows the grid 

points along the various WAD lines 

eligible for testing based on vehicle 

geometry and the manufacturer’s actual 

or predicted HIC15 for each location. 

Each grid point also contains an 

indication of whether the data provided 

is simulated data or physical test data. 

Points that were physically tested by the 

manufacturer are designated as a circled 

cell. Points with predicted head impact 

scores are not circled. Similar to the 

Euro NCAP test procedures, some points 

are considered ‘‘default red’’ and 

‘‘default green’’ based on their location 

on the vehicle.58 The rest of the eligible 

grid points are filled with actual or 

predicted HIC data from the 

manufacturer. Table C1 shows the 

tabulated data from Figure C1 and the 

manufacturer’s predicted score (81.000 

out of a possible 136.000) for the head. 

Figure C1 also denotes with an ‘‘X’’ 

which grid points were chosen for 

verification testing by NHTSA. 


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Figure C1: Example of Manufacturer’s 

Predicted Head Impact Data 

TABLE C1—EXAMPLE OF SCORING OF MANUFACTURER’S PREDICTED HEAD IMPACT DATA

Manufacturer prediction HIC min. HIC max. Point value Number 

points 

Predicted 

score 

Default Green ....................................................................... n/a n/a 1.000 18 18.000 

Green ................................................................................... ........................ <650 1.000 13 13.000 

Yellow ................................................................................... 650 <1,000 0.750 51 38.250 

Orange ................................................................................. 1,000 <1,350 0.500 19 9.500 

Brown ................................................................................... 1,350 <1,700 0.250 9 2.250 

Red ....................................................................................... 1,700 ........................ 0.000 20 0.000 

Default Red .......................................................................... n/a n/a 0.000 6 0.000 

Sum of all points excluding default points to be used for correction factor ............................................................ 112 63.000 

Predicted headform score ....................................................................................................................................... 136 81.000 

Table C2 includes both the 

manufacturer’s actual or predicted data 

for each grid point undergoing testing as 

well as NHTSA’s verification test result 

in the form of the HIC15 and resulting 

scoring band. In this example, 7 of the 

10 test points resulted in the same 

scoring band as the prediction, 2 test 

points resulted in a lower scoring band 

than the prediction, and 1 test point 

resulted in a higher scoring band than 

the prediction. One test location of 

particular interest in this example is test 

location (4,¥3). The resulting HIC15 at 

this test location was 1,046.87, outside 

the boundaries for the predicted yellow 

color band, but still within the 

acceptable HIC15 range for verification 

testing as described in Table 12. The 

manufacturer predicted that the 10 test 

points under consideration would 

contribute a score of 5.250—as shown in 

Table C2. However, verification testing 

determined that these 10 test points 

scored 4.500 instead of 5.250. Thus, the 

difference between the manufacturer’s 

predicted values and those tested 

resulted in a correction factor of 0.857 

(three significant digits) based on the 

correction factor equation: Correction 

Factor = (Sum of Actual Test Scores)/ 

(Sum of Predicted Test Scores). Table 

C2 below shows the actual test scores 

and predicted scores used for the 

calculation. 

Table C2—Example of Verification 

Testing Results and Correction Factor 


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Table C3 calculates the resulting Final 

Pedestrian Headform Score for this 

hypothetical vehicle. The correction 

factor determined above is applied to all 

grid points that are not default green 

grid points. Thus, instead of those 

points contributing a predicted score of 

63.000 points, they only contribute a 

score of 53.991 points. The 18 default 

green points still contribute a score of 

18.000 (shown in Table C1 and Table 

C3), giving the vehicle a score of 71.991, 

or, when scaled for the scoring 

allocation, a score of 9.528 out of 18.000 

points. 

For the upper legform score, Table C5 

below shows the upper legform 

verification testing results of the 

hypothetical vehicle. Note that the 

manufacturer will have submitted 

upper, center, and lower bending 

moments and upper and lower forces for 

each required impact location along the 

bumper (also accounting for symmetry 

and adjacency). These results indicate 

that the vehicle has achieved the 

minimum crashworthiness pedestrian 

protection score of 60 percent (21.600 

out of 36.000 total points). Similar to the 

data provided for the headform impacts, 

the manufacturer will have provided 

information showing which locations 

received physical testing and which 

locations did not. However, unlike those 

for the headform impacts, NHTSA’s 

verification results for the upper legform 

will replace those provided by the 

manufacturer. 

Due to vehicle geometry, a total of 13 

points were eligible for testing, and it 

was decided that testing would be at test 

location U 0. Additional tests were 

conducted at locations U +2, U –4, and 

U –6. Using symmetry and adjacency, 

all 13 test locations received scores. 

Test locations were scored according 

to Table C4, as illustrated below. Test 

location U 0 received a score of 0.000 

because all the bending moments and 

the sum of forces exceeded the 

maximum injury limits. Test location U 

+2 also received a score of 0.000. 

Although some of the bending moments 

(upper and lower) were below the 

maximum injury limit, the upper 

legform test uses the worst performing 

injury metric for the test location’s 

score. Both the center bending moment 

and the sum of forces exceeded the 

maximum injury limit. Thus, this test 

location received a score of 0.000. Had 

test location U +2 been scored based on 

the upper bending moment, it would 

have received a score of 0.475; and 

similarly, had it been scored based on 

the lower bending moment, it would 

have received a score of 0.356. Injury 

values above the minimum injury but 

below the maximum injury are scored 

on a sliding scale between 0.000 and 

1.000 points for the upper legform. On 

the other hand, test locations U –4 and 

U –6 each received scores of 1.000 

because all injury criteria were below 

the minimum injury limit. 

TABLE C4—UPPER LEGFORM SCORING

Component Min. injury Max. injury Max. point 

value 

Bending Moment (Nm) ................................................................................................................ 285 350 1.000 

Sum of forces (N) ........................................................................................................................ 5000 6000 

Using symmetry, test location U –2 

receives a score of 0.000 because that is 

what test location U +2 received. Test 

locations U +4 and U +6 receive scores 

of 1.000 because of tests conducted at U 

–4 and U –6. Using adjacency, test 

locations U +1, U –1, U +3, and U –3 

all receive scores of 0.000 because they 

are adjacent to a test location that 

received a score of 0.000. Likewise, test 

locations U +5 and U –5 each receive a 

score of 1.000, being adjacent to two 

locations each scoring 1.000. In some 

cases, a manufacturer may provide data 

explaining why its vehicle should not 

be subject to symmetry or adjacency. 

Table C6 shows the scoring for the 

hypothetical upper legform test. Overall, 

the vehicle received a score of 6.000 out 

of a possible 13.000 for the upper 

legform test. When scaled for the 25 

percent points allocation (9.000 out of 

36.000 points), the upper legform can 

receive a maximum score of 9.000 

points. This testing results in a final 

upper legform score of 4.154 out of 

9.000 points. 

BILLING CODE 4910–59–P 


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TABLE C6—EXAMPLE OF UPPER LEGFORM SCORE

BILLING CODE 4910–59–C 

Finally, Table C8 below shows the 

lower legform FlexPLI verification 

testing results of the hypothetical 

vehicle. Detailed data, to include the 

four tibia bending moments and ACL, 

MCL, and PCL elongations, has been 

received to show that this vehicle meets 

the 60 percent (21.600 out of 36.000 


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total points) pedestrian protection 

requirement. The lower legform data 

gathered by NHTSA will replace the 

data provided by the manufacturer. For 

this vehicle, all points along the LBRL 

are less than 500 mm, so all test 

locations are tested. If there were 

portions of the LBRL that were greater 

than 500 mm, those locations would not 

be tested and would be given a ‘‘default 

red, no points’’ score. Like the upper 

legform WAD775 tests, this vehicle’s 

geometry requires 13 locations to be 

scored for the bumper testing. In this 

test series, testing began at location L +1 

and additional tests were carried out at 

locations L –3 and L –5. 

Test locations were scored according 

to Table C7 as illustrated below. Testing 

conducted at location L +1 yielded a 

score of 0.932 (0.500 + 0.432). The tibia 

bending moments were all below the 

minimum injury limit, awarding full 

points for that component. The MCL 

elongation fell between the minimum 

injury limit and maximum injury limit, 

awarding partial points. For FlexPLI 

injury values above the minimum injury 

threshold and below the maximum 

injury threshold, points are awarded 

between 0.000 and 0.500 on a linear 

sliding scale. Neither the ACL nor PCL 

exceeded the limit. Thus, this test 

location received a score of 0.932. Tests 

conducted at locations L –3 and L –5 

yielded full points as none of the values 

exceeded the minimum injury limits, 

nor were the ACL nor PCL limits 

exceeded. 

TABLE C7—FLEXPLI SCORING

Component Min. injury Max. injury Max. point 

value 

Tibia bending (Nm) ...................................................................................................................... 282 340 0.500 

MCL elongation (mm) .................................................................................................................. 19 22 0.500 

ACL/PCL elongation (mm) ........................................................................................................... ........................ 10 ........................

Using the same symmetry concepts 

discussed above, test locations L –1, L 

+3, and L +5 inherited the scores from 

the opposite side. Using adjacency, test 

locations L 0, L +2, and L –2 each 

inherited a score of 0.932 because that 

was the lowest score of the two adjacent 

test locations. Test locations L +4, L –4, 

L +6, and L –6 each inherited a perfect 

score of 1.000 because both adjacent test 

locations had scores of 1.000. 

The resulting lower legform score for 

this vehicle is shown below in Table C9 

and was 12.660 out of a maximum 

13.000, or 8.765 out of a maximum 9 

when using the 50 percent, 25 percent, 

25 percent scoring allocation. 

BILLING CODE 4910–59–P 


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TABLE C8—EXAMPLE OF LOWER LEGFORM TEST RESULTS


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TABLE C9—EXAMPLE OF LOWER LEGFORM SCORE

BILLING CODE 4910–59–C In Table C10 below, the scores from 

the three component tests are summed 

and compared to the maximum 

available score. In this scenario, the 


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hypothetical vehicle had reduced 

component level scores in each of the 

three categories, but still maintained a 

total score above 21.600 (60 percent). 

Therefore, this vehicle would continue 

to receive pedestrian protection credit 

on http://www.NHTSA.gov. 

TABLE C10—EXAMPLE OF OVERALL PEDESTRIAN PROTECTION SCORE

Actual score Maximum 

score Percentage 

Headform Test ............................................................................................................................. 9.528 18.000 52.9% 

Upper Legform Test ..................................................................................................................... 4.154 9.000 46.2% 

Lower Legform Test ..................................................................................................................... 8.765 9.000 97.4% 

Total ...................................................................................................................................... 22.447 36.000 62.3% 

Received Pedestrian Protection Credit? ..................................................................................... ........................ ........................ Yes 

Issued in Washington, DC, under authority 

delegated in 49 CFR 1.95 and 501. 

Adam Raviv, 

Chief Counsel. 

[FR Doc. 2024–27446 Filed 11–22–24; 8:45 am] 

BILLING CODE 4910–59–P 

DEPARTMENT OF THE TREASURY 

Office of Foreign Assets Control 

Notice of OFAC Sanctions Actions 

AGENCY: Office of Foreign Assets 

Control, Treasury. 

ACTION: Notice. 

SUMMARY: The U.S. Department of the 

Treasury’s Office of Foreign Assets 

Control (OFAC) is publishing the names 

of one or more persons that have been 

placed on OFAC’s Specially Designated 

Nationals and Blocked Persons List 

(SDN List) based on OFAC’s 

determination that one or more 

applicable legal criteria were satisfied. 

All property and interests in property 

subject to U.S. jurisdiction of these 

persons are blocked, and U.S. persons 

are generally prohibited from engaging 

in transactions with them. Additionally, 

OFAC is publishing updates to the 

identifying information of one or more 

persons currently included on the SDN 

List. 

DATES: This action takes effect on the 

date listed in SUPPLEMENTARY

INFORMATION. 

FOR FURTHER INFORMATION CONTACT: 

OFAC: Bradley T. Smith, Director, tel.: 

202–622–2490; Associate Director for 

Global Targeting, tel.: 202–622–2420; 

Assistant Director for Licensing, tel.: 

202–622–2480; Assistant Director for 

Regulatory Affairs, tel.: 202–622–4855; 

or the Assistant Director for 

Compliance, tel.: 202–622–2490. 

SUPPLEMENTARY INFORMATION: 

Electronic Availability 

The Specially Designated Nationals 

and Blocked Persons List and additional 

information concerning OFAC sanctions 

programs are available on OFAC’s 

website. (https://www.treasury.gov/ 

ofac). 

Notice of OFAC Actions 

A. On July 25, 2024, OFAC 

determined that the property and 

interests in property subject to U.S. 

jurisdiction of the following persons are 

blocked under the relevant sanctions 

authority listed below. 

Individuals 

1. LOPEZ AMBROSIO, Whiskey Hans, 

Guatemala; DOB 03 Nov 1999; POB 

Malacatan, Guatemala; nationality 

Guatemala; citizen Guatemala; Gender Male 

(individual) [TCO] (Linked To: LOPEZ 

HUMAN SMUGGLING ORGANIZATION). 

Designated pursuant to section 1(a)(ii)(C) of 

Executive Order 13581 of July 24, 2011, 

‘‘Blocking Property of Transnational Criminal 

Organizations,’’ 76 FR 44757 (July 27, 2011), 

as amended by Executive Order 13863 of 

March 15, 2019, ‘‘Taking Additional Steps to 

Address the National Emergency With 

Respect to Significant Transnational Criminal 

Organizations,’’ 84 FR 10255 (March 19, 

2019) (E.O. 13581, as amended), for being 

owned or controlled by, or having acted or 

purported to act for or on behalf of, directly 

or indirectly, the LOPEZ HUMAN 

SMUGGLING ORGANIZATION, a person 

whose property and interests in property are 

blocked pursuant to E.O. 13581, as amended. 

2. LOPEZ ESCOBAR, Ronaldo Galindo 

(a.k.a. ‘‘Tio Roni’’), San Francisco Nueva 

Reforma, Malacatan, Guatemala; DOB 14 Sep 

1977; POB Guatemala; nationality Guatemala; 

citizen Guatemala; Gender Male; Passport 

000510054 (Guatemala) (individual) [TCO] 

(Linked To: LOPEZ HUMAN SMUGGLING 

ORGANIZATION). 

Designated pursuant to section 1(a)(ii)(C) of 

E.O. 13581, as amended, for being owned or 

controlled by, or having acted or purported 

to act for or on behalf of, directly or 

indirectly, the LOPEZ HUMAN SMUGGLING 

ORGANIZATION, a person whose property 

and interests in property are blocked 

pursuant to E.O. 13581, as amended. 

3. HERNANDEZ VANEGAS, Karen 

Stefany, Guatemala; DOB 12 Mar 2002; POB 

Livingston Izabal, Guatemala; nationality 

Guatemala; citizen Guatemala; Gender 

Female (individual) [TCO] (Linked To: 

LOPEZ HUMAN SMUGGLING 

ORGANIZATION). 

Designated pursuant to section 1(a)(ii)(C) of 

E.O. 13581, as amended, for being owned or 

controlled by, or having acted or purported 

to act for or on behalf of, directly or 

indirectly, the LOPEZ HUMAN SMUGGLING 

ORGANIZATION, a person whose property 

and interests in property are blocked 

pursuant to E.O. 13581, as amended. 

Entity 

1. LOPEZ HUMAN SMUGGLING 

ORGANIZATION, Mexico; Guatemala; Target 

Type Criminal Organization [TCO]. 

Designated pursuant to section 1(a)(ii)(A) 

of E.O. 13581, as amended, for being a 

foreign person that constitutes a significant 

transnational criminal organization. 

Dated: July 25, 2024. 

Lisa M. Palluconi, 

Deputy Director, Office of Foreign Assets 

Control, U.S. Department of the Treasury. 

Editorial Note: This document was 

received for publication by the Office of the 

Federal Register on November 19, 2024. 

[FR Doc. 2024–27462 Filed 11–22–24; 8:45 am] 

BILLING CODE 4810–AL–P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

Publication of the Tier 2 Tax Rates 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice. 

SUMMARY: Publication of the tier 2 tax 

rates for calendar year 2025 as required 

by section 3241(d) of the Internal 

Revenue Code. Tier 2 taxes on railroad 

employees, employers, and employee 

representatives are one source of 

funding for benefits under the Railroad 

Retirement Act. 

DATES: The tier 2 tax rates for calendar 

year 2025 apply to compensation paid 

in calendar year 2025. 

FOR FURTHER INFORMATION CONTACT: 

Kathleen Edmondson, 

CC:EEE:EOET:ET1, Internal Revenue 


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