Advocates’ Statement on U.S. DOT 3.0 AV Guidelines

  • October 4, 2018
150 150 Advocates for Highway and Auto Safety

FOR IMMEDIATE RELEASE                                             

October 4, 2018

Contact: Eric Naing 202-408-1711, cell: 217-493-8294,


Statement of Cathy Chase,

President of Advocates for Highway and Auto Safety,

On U.S. DOT’s 3.0 Autonomous Vehicle (AV) Policy


Despite At Least Six Dangerous or Deadly Crashes Involving Cars with Autonomous Capabilities, U.S. DOT Offers Up Hands-Off Approach to Hands-Free Driving to the Endangerment of All Road Users

Today, the U.S. Department of Transportation (U.S. DOT) released weak, voluntary guidelines allowing manufacturers of autonomous vehicles (AVs) to use our Nation’s roads and highways as proving grounds for unproven technology.  Instead of being called “3.0” guidelines, they should be considered “-1.0” guidelines because they throw our Nation’s AV policy in reverse.  AV manufacturers will continue to introduce extremely complex, supercomputers-on-wheels into the driving environment with meager government oversight and accountability.

Cars with autonomous capabilities have been involved in multiple crashes that have resulted in at least three fatalities, including the death of Elaine Herzberg, a pedestrian walking a bicycle who was struck and killed by a self-driving Uber earlier this year in Tempe, AZ.  Many of these crashes are under open investigations by the National Transportation Safety Board (NTSB).  The public needs and deserves the U.S. DOT to effectively evaluate and regulate these vehicles before they are sold and used on public roads.  Unfortunately, today’s unenforceable guidelines do little to prevent more deaths and injuries from happening.

While U.S. DOT has lauded the Federal Aviation Administration’s voluntary reporting systems for incident data as a model for the way to handle AVs, this offering ignores the strong safety oversight and federal regulation of airplanes and actual autopilot systems specifically.  These regulations are the reason U.S.-registered, scheduled passenger airlines have had only one fatality in nine years.  The AV 3.0 policy guidelines include no standards or regulations such as functional safety requirements to ensure the safe performance of automated driving systems in cars and trucks.

Under the 3.0 guidance, instead of publishing information that would allow the public to accurately gauge the safety performance of an AV system, companies making driverless cars are instead allowed to release glossy marketing brochures like the ones previously submitted by a few manufacturers.  Simply put, the public deserves more.  All road users should be given access to safety information about an AV they may ride in, purchase, drive next too, or encounter as a pedestrian or bicyclist.  Yet once again, U.S. DOT is allowing AV manufacturers to keep this critical data under wraps.

Further, the 3.0 guidance fails to regulate commercial motor vehicles.  Numerous companies are attempting to develop a self-driving truck, and it’s crucial that these 80,000 lb. vehicles controlled by tens of millions of lines of computer code are adequately regulated.  Unfortunately, U.S. DOT’s 3.0 guidance fails to address the serious safety concerns that arise when multiple driverless trucks platoon in close proximity.

New data released yesterday found that over 100 people are killed each day on average in motor vehicle crashes.  Now is not the time for U.S. DOT to take its hands off the wheel when it comes to safety.  Advocates has always been a steadfast supporter of proven safety technologies, from airbags to automatic emergency braking, and we believe AVs have great potential to save lives in the years to come.  However, this promise is endangered without widespread public acceptance.  Numerous opinion polls have found that Americans harbor strong and enduring concerns about these vehicles.  In fact, a survey set to be released next week by J.D. Power and the National Association of Mutual Insurance Companies (NAMIC) found that Americans remain highly skeptical of automated vehicle technology, based largely on safety concerns.

Unfortunately, the 3.0 guidelines will not assure the public that unproven, unreliable and unsafe AVs will be kept out of the marketplace.  Without real oversight from the U.S. DOT and minimum performance standards for AVs, the public will be left defenseless, especially as the U.S. Senate races to pass flawed legislation, AV START Act (S. 1885), that would preempt state action on driverless cars and allow potentially millions of these vehicles exempt from major safety standards to be sold to the public.  We urge the Senate to pump the brakes on the artificial urgency to race through this legislation which is lacking critical safeguards.