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S. 1885, the AV START Act, Fails to Provide Minimal Safety Protections for Consumers

Shockingly, S. 1885, the Senate bill on automated vehicles (AVs) known as the AV START Act, would allow potentially millions of vehicles on the market to be exempt from meeting existing safety standards. The failures of unproven driving automation systems already have led, tragically, to crashes which have resulted in at least three deaths. The National Transportation Safety Board (NTSB) has several open investigations which will produce findings likely to have a direct bearing on the AV START Act. The bill should not be advanced until those investigations are complete and critically-needed changes are made to ensure safety.

The AV START Act could set policy on driverless cars for decades to come. Comprehensive safeguards, sufficient government oversight, and industry accountability are essential. The bill, in its current form, fails to provide these minimal safety protections.

The reasonable improvements outlined below will address known and foreseeable problems with driverless car technology. Moreover, they will help to bolster public trust in this nascent technology.  We ask for all members of Congress to support the following commonsense improvements:

  • Limit the size and scope of exemptions from federal safety standards;
  • Require minimum performance standards such as a “vision test for cars” for those with driverless technologies, cybersecurity and electronics system protections, and distracted driving requirements when a human needs to take back control of a vehicle from a computer;
  • Provide for adequate data collection and consumer information;
  • Compel all AVs to capture detailed crash data in a format that will aid investigators such as the NTSB and the National Highway Traffic Safety Administration (NHTSA);
  • Ensure access and safety for members of all disability communities which have differing needs;
  • Subject Level 2 (partially automated) vehicles to all safety critical provisions;
  • Prohibit manufacturers from unilaterally “turning off” vehicle systems such as the steering wheel and gas pedal which is not allowed under current law;
  • Maintain the right of states and localities to protect their citizens by regulating the AV system in absence of federal regulations; and,
  • Provide NHTSA with sufficient resources and authorities.

These changes would protect innovation while providing essential protections for AV occupants as well as everyone sharing the roads with them for many years to come. We strongly urge all members of Congress to insist on the adoption of these urgently-needed safety requirements in S. 1885, the AV START Act.