Having now read the United States federal driverless vehicle policy in detail, I continue to be impressed. The policy document has clear guidance for safety standards and it clearly delineates a boundary between federal and state’s regulatory responsibilities. It also acknowledges the importance of existing regulations (i.e., Federal Motor Vehicle Safety Standards). I also appreciate how the policy document outlines many of the issues and barriers associated with driverless vehicles that require further study (e.g., cyber security, data protection, etc). While I know this is a first cut and there will be many stakeholders providing input still, I thought I’d mention a few ideas that I would have liked to see mentioned (even as considerations….not requirements):
- Since the impacts on vehicle miles travelled (VMT) is still unclear (and a significant risk), government (at the federal or state level) is in a position to encourage electric power technology to minimize greenhouse gas emission impacts.
- While data recorders are required for safety purposes, it would be quite forward-thinking if the federal or state governments required anonymized reporting of vehicle miles travelled and even vehicle occupancy to support road user charge pilots.
- Connected vehicle technology is an entirely different technology; however, most experts agree that the greatest safety benefits will be achieved when the driverless and connected vehicle technologies are combined. It is surprising that this document doesn’t acknowledge that.
- I acknowledge that the liability issue has been and is intended to be a state issue, but I’m unclear on why this is the case. Wouldn’t insurance providers, auto manufacturers, and state government agencies all benefit from consistency in liability approaches across state borders?
- Will driverless vehicles with Level 5 functionality be able to transport unaccompanied children? Maybe this is thinking too far out, but I think this will become a huge question once the SAE Level 5 vehicles are publicly available.
- I understand that the policy document intended on delineating federal and state policies, but what about local governments? It would have been nice to see the federal government acknowledge the very important role that local governments have in developing policies that will mitigate the VMT impact, manage costs and revenues associated with the introduction of AVs, and re-imagine their transit systems (to name a few local policy issues).
Do you agree with this feedback? Any others to add to this list?