The Center for Auto Safety Comments to the DOT Regarding Ensuring American Leadership in Automated Vehicle Technologies Automated Vehicles 4.0

April 2, 2020
Secretary Elaine Chao
U.S. Department of Transportation
1200 New Jersey Ave. SE
Washington, DC 20590
Submitted electronically via www.regulations.gov
RE: Ensuring American Leadership in Automated Vehicle Technologies Automated Vehicles 4.0, Docket No. DOT-OST-2019-0179
Dear Secretary Chao:
Under the current national crisis facing the United States, which has led to the President declaring a state of National Emergency, The Center for Auto Safety (the Center) again raises the question the wisdom of your Department carrying on its relentless slog of enabling manufacturers in their quest to place unregulated autonomous vehicles on the road. The National Highway Traffic Safety Administration’s (NHTSA) sole focus at this moment should be on steps it can take to immediately increase the safety of Americans, either through enforcement or regulations that ensure all vehicles will come equipped with the latest, proven, safety equipment.
However, as there has been no delay in the due date for comments on the document titled “Ensuring American Leadership in Automated Vehicle Technologies Automated Vehicles 4.0” (AV 4.0), our comments are below.
With almost 40,000 crash deaths involving motor vehicles and over 2.5 million serious injuries on our roads every year, there is no time to waste in moving forward towards deploying safe vehicle technology, be it autonomous or otherwise. 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, 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.

We speak from experience. Since the Center’s founding 50 years ago, our sole mission has been improving consumer protection when it comes to vehicle safety. On behalf of our members across the country, and drivers, passengers, and pedestrians everywhere we have always been proponents of advanced safety technology, often far earlier than member of the industry or the federal government.
While there have been many life-saving and performance-enhancing technological advancements in vehicles the last five decades many philosophical problems remain. None is perhaps more insidious than the idea that car companies, and their new friends in Silicon Valley, should be given the ability to sell unproven driverless car technology absent proof they are meeting mandatory safety and performance requirements. At its heart, AV 4.01 is an abdication of the federal government’s responsibility to establish and enforce reasonable safety standards for AV development, thereby unnecessarily endangering the American public and wasting time and resources otherwise allocable to safe AV development.

Read the full comments here.