The Competitive Enterprise Institute (CEI), the R Street Institute, and TechFreedom together sent comments to the National Highway Traffic Safety Administration (NHTSA) expressing concern about parts of the Federal Automated Vehicles Policy guidance document. The guidance document sets forth best practices and discusses various issues related to deployment of vehicle automation systems.
“Vehicle automation systems have the potential to greatly improve the safety of our roads and improve the mobility of the disabled and elderly,” said Marc Scribner, CEI research fellow. “Government safety regulators must be careful, even at this early stage, to avoid conflicting requirements and policies that stifle innovation.”
Read the comment letter to NHTSA.
The coalition stated it pointed to “several troubling” aspects of the guidance document and areas in need of clarification and urged the following amendments:
• 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 the agency’s 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 to Congress for additional regulatory authority for itself and focus on more efficiently and effectively using its existing authorities to speed consumer deployment of vehicle automation systems.