The development of automated vehicles (AVs) offers the potential to enable tremendous societal benefits by improving vehicle safety and access to transportation for disabled people, the elderly, and others who cannot currently drive themselves. Development of AVs could significantly enhance the safety and efficiency of goods movement, helping better meet consumer demand while promoting innovation and growth across various sectors of the economy. AVs may likewise improve safety by reducing the severity and frequency of automobile accidents and will mitigate other inefficiencies of current motor vehicle use, such as congestion.
TechNet supports policies that encourage the safe deployment of fully automated vehicles on public roads in the United States. These policies include the promotion of and investment in infrastructure and other architecture that will enable and accelerate AV operations.
TechNet is concerned that well-intentioned state policy frameworks could unintentionally stifle innovation and impede the safety benefits of this technology. As such, states should avoid adopting policies that will create or maintain barriers to the testing, development, and deployment of this technology and the benefits that come with it.
The state program supports the following principles:
· Regulations should be avoided that impose conflicting burdens on vehicles with varying levels of technology.
· State policymakers should avoid vehicle performance standards, safety regulations, or certifications that supplement or go beyond, overlap, or conflict with federal law, regulations, or automated vehicle guidance. A patchwork of policies will stifle or impede innovation.
· Frameworks, regulations, and constructs that restrict competition or limit operation of AVs to only one segment of innovators or automotive technologies should be avoided. Policies should ensure companies that test or deploy fully automated vehicles are accountable for the safety of their products. Policies should be technology-neutral, avoid picking winners and losers, prioritize public safety, and protect intellectual property.
· A human operator for operation, testing, and deployment should not be required. Policymakers should not predetermine how the technology will develop or legislate technology by specifying the role of a human in its development.
· Local ordinances, or other formal local sign-off, as a prerequisite for testing or deployment within a state should not be required. TechNet believes that a patchwork of local laws and regulations would be unnecessarily burdensome and could impede travel between jurisdictions.
· Maintaining the system of self-certification by the manufacturer, not a pre-market approval process. Support voluntary compliance with the guidelines outlined in “Preparing for the Future of Transportation: Automated Vehicles3.0.”
· The operation of AVs in the state should be subject to the same accident and operating reporting requirements as other human-driven vehicles, but no more. These existing laws are sufficient to address the states’ interest in assessing road safety.
· Policies that promote the investment in the infrastructure needed to enable and support AV operations.
· State laws and regulations should be updated to remove legal barriers to driverless deployment of AVs on public roads.
· Use of definitions and terminology consistent with the Society of Automobile Engineers (SAE) J3016.
· Avoiding special licensing and registration for AVs and special permits for testing or development.
· Maintaining existing laws and policies on negligence, insurance, and product liability, unless and until the need for change is demonstrated.
· Narrowly-focused, testing-only bills without a clear path to the deployment of automated vehicles should not be implemented.
· Government should not mandate the sharing of businesses’ data that it cannot adequately analyze and use to promote further innovation.