CAS Comment on AV TEST Data Collection

October 29, 2020

Office of the Administrator
c/o James C. Owens, Deputy Administrator

National Highway Traffic Safety Administration Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue SE

West Building, Ground Floor, Room W12-140 Washington, DC 20590-0001

Submitted electronically via

RE: Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Automated Vehicle Transparency and Engagement for Safe Testing (AV TEST) Initiative, Docket No. DOT-NHTSA–2020–0070

Dear Deputy Administrator Owens,

The Center for Auto Safety (“the Center”) appreciates the opportunity to provide comments on the notice and request for comment regarding the Automated Vehicle Transparency and Engagement for Safe Testing (AV TEST) initiative. The Center, founded in 1970, is an independent, member supported, non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy. In 2020, we are celebrating 50 years of advocacy for consumer automotive safety and informed choice.

The AV TEST initiative proposes using government resources for the purpose of providing “information to the public about Automated Driving System (ADS) testing operations in the U.S. and applicable State and local laws, regulations, and guidelines.”1 Instead, the public would be better off visiting the promotional website of each AV manufacturer after conducting their own Google search. At least that way, there would not be any confusion about the biased nature of the promotion or the lack of government oversight.

Motor vehicle crashes remain one of the primary causes of premature death, and the leading cause of death for those under age 30. These crashes cost the U.S. approximately $1 trillion every year. Sadly, NHTSA has estimated the first six months of 2020 have resulted in the highest death rate per vehicle mile traveled in the U.S. in over a decade. The Center firmly believes ADS 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’s refusal to even require the submission of test data relating to ADS development is an implicit encouragement of the deployment of unproven technology guided by artificial intelligence on public roads. These self-described self-driving vehicles are being unleashed on America in the hope that nothing too horrible will happen, in the absence of NHTSA analyzing validated engineering data demonstrating safe ADS performance.

Read full comment here.