Key Benefits of Automated Vehicles
Automated Driving Systems (ADS) and ADS-equipped vehicles, colloquially known as autonomous vehicles, have the vast potential to increase road safety, enhance mobility for the elderly and people with disabilities, and improve transportation efficiency across the nation. To meet this potential, we must focus on developing appropriate public policies as well as common industry safety standards and technology-neutral safety performance benchmarks. Also, public-private consortia, broad-based consumer education coalitions, and global standards bodies can play a critical role in building the trust necessary to test and deploy ADS-equipped vehicles at scale, and save thousands of lives in the United States.
C_TEC encourages U.S. legislators and regulators to consider the principles below in order for America to assume a leadership position and invest in this globally competitive sector. These principles were developed by C_TEC’sAutonomous Vehicle Working Group, which consists of a broad and diverse set of leading companies and trade associations, including original equipment manufacturers (OEMs), technology companies, transportation network companies, insurers, telecommunications providers, automotive suppliers, trucking, and retail.
The following policy principles will ensure that the United States remains a leader in automated vehicle (AV) innovation and that America’s policy framework can be a model for other countries worldwide.
ENSURE A SAFETY FIRST APPROACH
As an industry and nation, our first and foremost collective goal must be safety. The safe development, testing, and deployment of ADS and ADS-equipped vehicles are essential to build and retain public trust in order to realize the multifold benefits that these vehicles will deliver for society. Therefore, safety is C_TEC’s top priority.
PRESERVE EXISTING DELINEATION OF REGULATORY ROLES
For America to be at the forefront of innovation, policymakers must create an environment for ADS technology to advance. Clarity and certainty of regulatory roles are crucial to spur investment in the United States amid the global race among nations to lead in this sector. C_TEC believes that policymakers should preserve the existing clear delineation of traditional federal, state, and local roles for motor vehicle regulation, as well as interstate commerce, in the context of automated vehicles.
Absent federal clarity, the current patchwork of regulations creates uncertainty, which hinders economies of scale and continued ADS development and testing in the United States. In short, preserving existing federal authority over testing and deployment regarding the design, construction, and performance of ADS and ADS-equipped vehicles and components is critical to ensure American leadership in this highly competitive global industry.
PROMOTE TECHNOLOGY AND STAKEHOLDER NEUTRALITY
The transportation industry is undergoing a rapid transformation. Consistent with this evolution, the AV industry includes a breadth of stakeholders from traditional original equipment manufacturers (OEMs) and suppliers to technology companies and other new entrants. To ensure a level playing field that facilitates safety and innovation and increases new investment and jobs in the United States, all stakeholders’ testing and/or deploying ADS and ADS-equipped vehicles should be subject to the same testing and deployment policies under a uniform federal framework.
C_TEC also supports ongoing proactive industry collaboration in leading standards bodies to develop a technology and stakeholder-neutral ADS safety validation approach, which may set forth consensus-based minimum safety performance requirements, guidelines, or benchmarks. These efforts must be open to all AV industry stakeholders to ensure that the United States benefits from diverse expertise, as well as wide acceptance and adoption of the approach. Any new U.S. Department of Transportation (USDOT) ADS working group should ensure similar composition.
ADVANCE SAFE AUTOMATED VEHICLE DEVELOPMENT, TESTING AND DEPLOYMENT
Testing is essential to advancing ADS performance and thus strengthening motor vehicle safety. To demonstrate that an ADS-equipped vehicle is at least as safe as a human driver, C_TEC recognizes the need for metrics beyond vehicle miles traveled and disengagements. Therefore, policymakers should encourage the broad AV industry to collaboratively develop a technology-neutral and transparent performance-based model for ADS safety decision-making in conjunction with leading standards bodies.
Also, to increase consumer trust, C_TEC supports a comprehensive test of the safety of a vehicle’s decision-making and perception systems. Consistent with the USDOT recognition that on-road testing is one of several aspects for ADS safety assurance, C_TEC recognizes that ADS/AV safety testing can be performed along multiple paths, for example, (i)on-road testing; (ii) verification of the vehicle’s decision-making to an industry accepted, performance-based safety model; and (iii) testing of the vehicle’s perception system using data sets.
MODERNIZE FEDERAL MOTOR VEHICLE SAFETY STANDARDS AND REGULATIONS
ADS-equipped vehicles may include unconventional designs that are incompatible with some existing Federal MotorVehicle Safety Standards (FMVSS). Therefore, some FMVSS may need to be modernized to encompass advances inADS technology. As the USDOT considers which regulations may need to be modernized, USDOT’s existing temporary exemption authority allows the introduction of new motor vehicle features or designs where the petitioner’s data supports that those innovations provide a safety level at least equal to the safety level of the standard. This data-intensive exemption process provides a valuable opportunity to demonstrate the safety benefits of ADS technologies and inform future rulemakings.
C_TEC supports making this exemption process available to all petitioners (e.g., traditional OEMs, suppliers, tech companies, and new entrants) on a level playing field. To ensure that the United States continues to lead in this sector and reduce barriers to deployment, C_TEC supports increasing the number of ADS-equipped vehicles that may be exempted and lifting the current cap of two years for each exemption.
To learn more, please contact Matt Furlow at email@example.com
Building the Foundation for the Future of Transportation
CNN BUSINESS: Some manufacturers have less than 5 days’ supply of computer chips, Commerce Department warns
New York (CNN Business) Some manufacturers that rely on semiconductors are down to less than…
C_TEC Comments to the FTC on Proposed FY 2022-2026 Strategic Plan
Federal Trade Commission 600 Pennsylvania Avenue, NW Washington, D.C. 20580 RE: FTC Draft Strategic Plan for FY 2022-2026 (FTC-2021-0061-0001) …
U.S. Chamber Letter of Support for Nomination of Laurie Locascio as Director of NIST
TO THE MEMBERS OF THE UNITED STATES SENATE: The U.S. Chamber of Commerce supports the…
C_TEC Comment Letter on Incident Reporting for Automated Driving Systems and Level 2 Advanced Driver Assistance Systems
Dr. Steven Cliff Deputy Administrator National Highway Traffic Safety Administration Washington, DC 20590 RE: Incident Reporting for Automated Driving Systems (ADS) and…
How Embark Trucks is Driving Innovation
Embark Trucks, based in California, is using automated vehicle technology to make the roads safer,…
Multi-Association Letter to USDOT on Automated Vehicles
The Honorable Pete ButtigiegSecretaryU.S. Department of Transportation1200 New Jersey Avenue, SEWashington, D.C. 20590 Dear Secretary…
U.S. Chamber Applauds Passage of the U.S. Innovation and Competition Act, Focus on R&D Investments to Help American Competitiveness
WASHINGTON, D.C. – The following statement can be attributed to Neil Bradley, executive vice president and…
C_TEC Statement on Reintroduction of the SELF DRIVE Act
In response to the Congressman Bob Latta’s reintroduction of the SELF DRIVE Act, C_TEC…
The Weekly Download
Subscribe to receive a weekly roundup of the Chamber Technology Engagement Center (C_TEC) and relevant U.S. Chamber advocacy and events.
The Weekly Download will keep you updated on emerging tech issues including privacy, telecommunications, artificial intelligence, transportation, and government digital transformation.