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Comments to DOT on third automated vehicle guidance (AV 3.0)

Self-driving vehicles would represent the single biggest change in the relationship between cars and their occupants since the invention of the motor vehicle itself, and warrant diligent oversight at every step of their development to ensure that they are safe. In November 2017, we submitted comments to DOT and NHTSA to provide detailed feedback on the second version of automated driving system guidance (ADS 2.0). We commented on components of the document that give companies and states appropriate guidance, as well as areas that we recommended be stronger in order to better safeguard all consumers on our roads. We urged entities developing automated driving systems to implement, follow, and surpass NHTSA’s guidance, and not treat it as voluntary. We are very concerned that those comments, and similar ones from other organizations, have not been measurably incorporated into the newest guidance.

The ADS 2.0 version of the guidance, pertaining mainly to passenger vehicles, remains operative: it is supplemented by the newest AV 3.0 guidance, but is not replaced by it. We therefore use this comment opportunity to reinforce several key points from the feedback provided to NHTSA last year, and to strongly urge DOT leadership and the agency to address—or explain why they are not addressing—these issues. The points include:

  • Submission of the safety self-assessment should be required, and NHTSA should take steps to ensure it gets the detailed safety data needed to protect consumers;
  • NHTSA should make its AV guidance more robust—not take steps backward;
  • NHTSA should more strongly emphasize independent, third-party validation of automated driving systems;
  • The guidance to states is generally appropriate, and should be expanded; and
  • The proposed information collection is necessary, but inadequate for the agency to properly perform its functions.

We urge the agency to revisit our November 2017 comments and review that submission in full. We attach those comments to our submission today and include them in the new docket.

For the full comments, click here.