R Street Institute submits comments on USDOT’s AV 3.0
While AV 3.0 represents an important next step in this conversation, there is still much more to do to ensure a streamlined policy framework for the development and deployment of Highly Automated Vehicles (HAVs).
As USDOT continues this process, it is crucial that the Department issue more granular guidance to states and cities on practical implementation issues concerning congestion caused by HAVs and secure data storage for voluntary data sharing agreements.
In addition, the Department should seek to clarify and streamline regulatory guidance and processes for automated rail systems. Barriers like crew size regulations in particular present a major barrier to the ready adoption of automated systems because they confuse and diminish the Department’s unified approach to automated safety technologies.
To ensure that HAVs can be deployed in an iterative manner, NHTSA should scope their traditional post-market testing regime around the specific environments in which HAVs are being deployed. This will require manufacturers to maintain close lines of communication with NHTSA and keep them updated of any changes in the environment.
R Street Associate Vice President of Government Affairs, Ian Adams adds, “R Street applauds USDOT for their multimodal approach to automation, which brings uniformity to the treatment of automation across the scope of its regulatory purview. This is a strong message in favor of tech-neutrality in regulation and an example of regulatory humility in the governance of emerging technology.”