Response to Incident Reporting for Automated Driving Systems (ADS) and Level 2 Advanced Driver Assistance Systems (ADAS)

November 29, 2021
Contact: Jason Levine, [email protected] or (202) 328-7700

Re: Agency Information Collection Activities; Notice and Request for Comment; Incident Reporting for Automated Driving Systems (ADS) and Level 2 Advanced Driver Assistance Systems (ADAS), Docket No. NHTSA-2021-0070.

 

Thank you for the opportunity to provide comments on NHTSA’s request for an extension of the
information collection for incident reporting requirements for Automated Driving Systems (ADS)
and Level 2 Advanced Driver Assistance Systems (ADAS). CAS fully supports the request. This
is an ideal time to address and correct deficiencies that would otherwise limit the accuracy and
utility of safety data as ADAS proliferates and ADS continues to develop. This initiative has great
promise to provide urgently needed information regarding ADAS/ADS vehicle operation on
America’s roads. We recommend that this initial step be followed up with NHTSA’s long overdue
response to the Center’s petition for data collection rule making, and by mandating a needed
comprehensive set of metrics and data collection to establish an ADAS/ADS safety baseline and
track safety progress. Vehicles should only be permitted access to public roadways, either for
commercial use, or for testing purposes, based on empirical evidence of safety not on promises of
a speculative safety revolution.

Click here to view the Center’s Full Comment.