The Center for Auto Safety comments on NPRM regarding Occupant Protection for Automated Driving Systems

May 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 www.regulations.gov
RE: Notice of Proposed Rulemaking, Occupant Protection for Automated Driving Systems,

Docket No. NHTSA–2020–0014

Dear Deputy Administrator Owens,

The Center for Auto Safety (“the Center”) appreciates the opportunity to provide reply comments on the notice of proposed rulemaking (NPRM) regarding Occupant Protection for Automated Driving Systems. The Center, founded in 1970, is an independent, member supported, non-profit consumer advocacy organization dedicated to improving vehicle safety, quality, and fuel economy, celebrating 50 years of advocacy for consumer automotive safety and informed choice.

It is a misallocation of limited government resources to engage in rulemaking on fully autonomous driving system-equipped vehicles, which do not exist at this time, when so many nearer-term technology improvements with immediate impact on the safety of occupants of conventional vehicles, pedestrians, and other vulnerable road users now languish due to NHTSA inaction. Indeed, NHTSA’s enthusiasm for adapting regulations for fully ADS-equipped vehicles is a dangerous and unnecessary diversion from the immediate needs of mandating existing life-saving automotive technology.

The Center has long advocated mandating requirements for automatic emergency braking, V2X deployment, pedestrian protection, updated NHTSA crash test standards, and updated seat back standards, all of which inexplicably continue to suffer. These failures on NHTSA’s part to undertake the work on performance standards which could be applied to vehicles rolling off assembly lines by the millions in the coming years suggest a lack of a proper focus on the agency’s statutory mission to maximize safety for all drivers, passengers, and pedestrians. Instead, by issuing this NPRM, NHTSA is once again diverting resources to adapting rules for potential, but perhaps never realized, ADS technology; this is a tragic mistake that unnecessarily costs far too many lives each year in pursuit of an illusory goal.