The Center for Auto Safety Submits Comments to the Department of Transportation Regarding Ensuring American Leadership in Automated Vehicle Technologies Automated Vehicles 4.0

The Center for Auto Safety is the nation’s premier independent, member driven, non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy on behalf of all drivers, passengers, and pedestrians.

For Immediate Release
April 2, 2020
Contact: Jason Levine, [email protected]

The Center for Auto Safety Submits Comments to the Department of Transportation Regarding Ensuring American Leadership in Automated Vehicle Technologies Automated Vehicles 4.0

Today, the Center for Auto Safety (“the Center”) filed comments with the Department of Transportation (DOT) regarding Ensuring American Leadership in Automated Vehicle Technologies Automated Vehicles 4.0 (AV 4.0), a set of federal guidelines theoretically intended to coordinate efforts among multiple government components and provide guidance to the auto industry on autonomous vehicle development (AV). The Center’s comments criticize DOT for once again failing to require regulations, collect AV safety data, and attempting to create the illusion that a regulatory vacuum is equivalent to a consequential set of rules.  The Center, founded in 1970, is a member supported, independent, non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy.
“One would think the country’s ongoing experience with the Coronavirus would highlight the need for federal leadership which mandates safety instead of allowing the market to figure things out on its own when it comes to public health. Yet once again, with AV 4.0, DOT has abdicated its responsibility to establish and enforce reasonable safety standards for AVs, thereby unnecessarily endangering the American public and wasting time and resources otherwise allocable to safe AV development,” said Jason Levine, executive director of the Center for Auto Safety.
DOT originally released AV 4.0 on December 23, 2019.  Despite calls by many groups, including the Center, to delay all comment periods during the current National Emergency as declared by the President on March 13, 2020, the formal comment period closes on April 2, 2020.
“AV 4.0 is misleading when it suggests that anyone has developed and promulgated meaningful AV development standards, when in fact none exist.  Engineering specifications are built on a foundation of requirements.  Absent government mandated standards, AV requirements are established by developers themselves,” said Levine. “DOT’s reliance on industry to do the government’s job will inevitably cost human lives, waste time, and increase the capital needed for AV development, and unnecessarily delay whatever attendant safety enhancement benefits the public would otherwise enjoy.”
This is the third time the Center has called on the National Highway Traffic and Safety Administration (NHTSA) and DOT to take their role as the nation’s vehicle safety agency seriously. The Center firmly believes AV technology can play a significant role in a safer transportation future and is committed to seeing its successful and safe integration into our transit ecosystem. Yet, NHTSA and DOT permitting the deployment of self-described self-driving vehicles on public roads, based exclusively on the marketing assurances of the auto industry, ignores that industry’s well-documented history of unsupported advertising claims clashing with reality.  By failing to recognize this history, NHTSA and DOT have prioritized corporate handouts over the safety of millions of American road users.
“By failing to mandate life-saving driver assistance technologies in AV, failing to require cybersecurity, and in general failing to establish rules for safe, expeditious, and accessible AV development, AV 4.0 does not embolden safety and further inhibits AV development,” said Levine, “AV 4.0 is an unfortunate and sad continuation of DOT’s policy of safety and regulatory abandonment and neglect.  Now, more than ever, Americans deserve a government focused on making their lives easier and safer. AV 4.0 fails that basic performance standard.”
Read the Center’s full comments on Ensuring American Leadership in Automated Vehicle Technologies Automated Vehicles 4.0.
Read our previous comments on AV 3.0.
Read our previous comments on AV 2.0.
Read our previous comments on AV 1.0.

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Over the last 50 years, the Center for Auto Safety has successfully led the fight for lemon laws in every state, airbags in every vehicle, and recall repairs being made at no cost to the consumer. The Center is a membership-driven organization headquartered in Washington, DC and is also home to the Safe Climate Campaign which fights global warming by working for big, specific measures to reduce greenhouse gas emissions. The Center publishes TheCarBook.com, which has for the last 40 years been America’s most comprehensive car buying guide and now offers, exclusively for members, the monthly Safety TuneUp Report, for regular alerts on safety issues relating to their cars. To learn more about the Center, please visit www.AutoSafety.org.