Today, CEI was joined by R Street Institute and TechFreedom in comments submitted to the National Highway Traffic Safety Administration (NHTSA) on the recently released Federal Automated Vehicles Policy (FAVP) guidance document. CEI’s initial response to the FAVP can be found here. The comment letter is here.
The guidance document sets forth best practices and discusses various issues related to deployment of vehicle automation systems. Much of the FAVP is either positive or benign. However, there are several troubling aspects and areas in need of clarification, which we address in detail. These include:
- NHTSA should revise its data, privacy, and cybersecurity recommendations to reduce the likelihood of useful data practices being unnecessarily prohibited, which could negatively impact state insurance regulation and the availability of improved insurance projects.
- NHTSA should omit elaborate discussion about the ethics of potential computer-directed crashes, which is beyond the scope of its mission and beyond the current technical capability of developers.
- NHTSA should eliminate an unworkable contradiction in its guidance, demanding that states refrain from codifying its safety assessment while subsequently recommending that states mandate “compliance” with the voluntary Safety Assessment as a condition for state permit approval.
- NHTSA should include a cross-state driver license reciprocity provision in its Model State Policy to urge states to avoid unnecessarily limiting the test driver labor pool in metropolitan areas that span across state borders.
- NHTSA should regularly post updates on administrative requests and actions related to vehicle automation systems in a simple summary format to allow the public to easily track agency activity related to these emerging technologies.
- NHTSA should cease any requests for additional regulatory authority and focus on more efficiently and effectively using its existing authorities to speed consumer deployment of vehicle automation systems.
For more detail, read our full comment letter on the FAVP here.