June 25, 2021
Contact: Jason Levine, [email protected] or (202) 328-7700
RE: Agency Information Collection Activities; Submission to the Office of Management
and Budget for Review and Approval; Automated Driving Systems 2.0 A Vision for Safety
The Center for Auto Safety (“the Center”) appreciates the opportunity to provide comments on the Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Automated Driving Systems 2.0 A Vision for Safety (ICR).
1 The Center, founded in 1970, is an independent, member supported, national non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy for all drivers, passengers, and pedestrians.
The collection of Automated Driving Systems (ADS) safety information is necessary to the proper performance of the oversight and rulemaking functions of the Department of Transportation (DOT) and National Highway Traffic Safety Administration (NHTSA) and should be required as soon as practicable. However, the wholly elective system envisioned by AV 2.0 – the Voluntary Safety Self-Assessment (“VSSA”) process – limits the practical utility of any data derived and does not adequately support key objectives laid out by the agency in its ICR. This ICR should be withdrawn and replaced by an activity that contributes to safety by requiring the collection of standardized data from all companies testing ADS vehicles on public roads.