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