In comments to the National Highway Traffic Safety Administration (NHTSA) on its NPRM regarding the creation of a framework for automated driving safety, SAFE noted that it appreciates the acknowledgement from NHTSA that this notice represents a departure from previous agency notices regarding automated driving systems (ADS), as it looks beyond existing Federal Motor Vehicle Safety Standards (FMVSS) toward the creation of a safety framework specifically tailored to ADS. SAFE also applauds the regulators’ ambition to move at the speed of ADS developers’ innovation.
SAFE believes NHTSA is now positioned to shape standard setting with regard to safety, but should not define how companies specifically achieve such goals. Consequently, in the broader interests of both regulator and developer at this nascent stage of the industry’s development, SAFE considers the agency’s core focus at this time to be on defining a standard for what it requires in terms of safety. The agency should allow companies to access all pathways and opportunities available for innovation regarding how they achieve such a standard. As a result, at this time SAFE recommends that NHTSA not adopt prescriptive measures and instead focus on adding a relevant safety benchmark to the FMVSS and continuing all the work NHTSA already has underway to update the FMVSS for ADS.