Consumer Reports (CR), the independent, nonprofit, and nonpartisan member organization, writes regarding the February 4, 2026, hearing, “Hit the Road, Mac: The Future of Self-Driving Cars.” We ask that this letter be included in the hearing record.
For 90 years, CR has used rigorous research, independent testing, and evidence-based advocacy to advance vehicle safety innovations that protect consumers. We have championed everything from seat belts and anti-rollover systems to the latest crash avoidance technologies that can help prevent tragedies and reduce injuries both inside and outside the vehicle.
As the Committee considers a federal framework for autonomous vehicles (AVs), we urge you to prioritize a consumer-centered approach that holds manufacturers and AV technology developers accountable, and ensures that safety and innovation go hand in hand. While we agree that AVs hold the potential to improve safety and mobility, they remain in a developmental stage, and there is much unknown about how AVs will ultimately affect consumers on our roads. As such, any federal framework must take a prudent approach and be built upon rigorously evaluated safety data, not an unproven assumption that all AVs are safer than human drivers.
Whether the Senate’s framework is based primarily on companies’ safety cases or their compliance with performance standards—and we do think enforceable safety standards are important to include, even if the framework is primarily centered on safety cases—it is insufficient for manufacturers or developers of safety-critical AV technology to grade their own homework. Safety claims, incident reports, and compliance with federal standards should be independently verified, with objective confirmation that the automated driving system operates safely on a consistent basis. Among other things, this means that the system can handle challenging environmental conditions, and detect and respond appropriately to all road users, including pedestrians, cyclists, law enforcement, and emergency responders. If an automated driving system is assuming the role of a human driver, then—at a bare minimum—it needs to be held to the standards for safe driving that we expect of human drivers in any given situation on the road.
These recommendations align with consumers’ views. According to a December 2024 Consumer Reports nationally representative survey, two out of three U.S. adults think vehicle safety standards should be stricter for AVs than those for traditional passenger vehicles, and just 3% think safety standards for AVs should be less strict than for traditional passenger vehicles. About six in ten (59%) strongly support a “vision test” requirement for AVs, with an additional 20% responding that they somewhat support this requirement.
At the same time, we also recognize that AV technology blurs the line between the regulation of vehicle design, primarily a federal role, and the regulation of driver behavior, which typically falls to states and localities. Because the automated system is now the driver, some industry groups would solve this dilemma by broadly preempting state authority to regulate AVs.
In our view, it would be a profound mistake to sweep away state and local safeguards. State and local officials already play a vital role regulating AV operations in their communities, in places where AVs have been deployed. These officials truly are on the front lines of road safety, overseeing AVs’ interactions with first responders, school zones, and human-driven vehicles. They must retain the authority to protect their residents and manage their streets—and consumers agree. According to the same December 2024 Consumer Reports nationally representative survey referenced above, 52% of U.S. adults think their local government should keep the power to decide whether and how autonomous vehicles are allowed on roads in their community, compared to just 21% who say their local government should not keep this power.
Effective oversight of AV technology also depends on regulators and the public having access to meaningful, high-quality safety data that goes beyond reports of severe crashes and fatalities. We support the establishment of a comprehensive national data repository that includes information on near-misses, system disengagements, hard braking, evasive steering, and other safety-critical events necessary to evaluate real-world system performance. Safety data should be specific and detailed enough to allow for meaningful analysis of system performance and safety outcomes. Company claims regarding “confidential business information” should be permitted only for true trade secrets, and not for safety data or to hide concerning or embarrassing incidents from public scrutiny.
Additionally, the baseline expectation for AVs should be that they meet Federal Motor Vehicle Safety Standards (FMVSS). Relying on general exemptions from FMVSS for deployment—particularly on the basis of “overall safety level” compared to traditional vehicles—is likely to be opaque and unaccountable to the public compared to the rulemaking process. While AV-related updates may be needed to FMVSS, and some have already been implemented, FMVSS have performance requirements, not design mandates, which permit innovation while ensuring safety. Exemptions from FMVSS should be limited to equipment required for the driving task which may be fully replaced by automation, and granted only if backed by safety evidence provided through a publicly defined National Highway Traffic Safety Administration (NHTSA) process.
Looking ahead, while we agree that AVs have the potential to bring meaningful independence for numerous Americans, including people with disabilities and older adults, this potential will only be realized if a federal framework explicitly mandates accessibility. The market alone will not guarantee that these vehicles are accessible to wheelchair users or those with sensory impairments. Legislation should guarantee that AVs are designed with universal access in mind, including accessible human-machine interface and physical accommodations.
We thank the Committee for its consideration of our comments, and look forward to working with all member offices to ensure that a federal framework for AVs puts consumers and their safety first.