Consumer Reports (CR), the independent, nonprofit, and nonpartisan member organization, welcomes the opportunity to provide comments to the National Highway Traffic Safety Administration (NHTSA) on the proposed United Nations Global Technical Regulation (GTR) on Automated Driving Systems (ADS) and NHTSA’s request for input as it evaluates the regulation’s technical merit and relevance to future U.S. policy.
Consistent with NHTSA’s request for comment, CR’s feedback focuses on (1) the technical merit and safety value of the draft GTR’s performance and assessment framework, (2) how its provisions could interact with existing U.S. safety standards and authorities, and (3) the data and reporting elements necessary for credible oversight.