Dear Administrator Martinez:

On behalf of TechFreedom and the R Street Institute, we respectfully submit these comments in response to Federal Motor Carrier Safety Administration’s request for comments on its advanced notice of proposed rulemaking, “Safe Integration of Automated Driving Systems-Equipped Commercial Motor Vehicles.”

TechFreedom is a post-partisan think tank dedicated to promoting the progress of technology that improves the human condition, R Street is a free-market think tank with a pragmatic approach to public policy challenges. Together, we applaud FMCSA for this particular effort to curb regulatory barriers impeding the promise of automated systems, while acknowledging potential risks and unintended consequences that could result from such capabilities.

Exciting developments are underway in the commercial trucking industry that promise enhanced safety, efficiency, and reliability. Even today, Automated Driving Systems (“ADS”) installed in commercial motor vehicles (“CMVs”) show promise as tools for crash-reduction. In light of these developments, the Federal Motor Carrier Safety Administration’s (“FMCSA”) decision to review its regulations (“FMCSRs”) to ensure that innovation is given the maximum opportunity to improve the safety of the nation’s roads could not be occurring at a better time.

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