Statement on Proposal by NHTSA to Allow Exemptions from Safety Standards for Automated Driving Systems (ADS)

  • December 20, 2024
150 150 Advocates for Highway and Auto Safety

Contact: Shane Austin
[email protected]
202.425.2776

FOR IMMEDIATE RELEASE

Statement by Cathy Chase, President of Advocates for Highway and Auto Safety (Advocates), on Proposal to Allow Exemptions from Safety Standards for Automated Driving Systems (ADS)

(Washington, D.C. – December 20, 2024) Today, the National Highway Traffic Safety Administration (NHTSA) released a Notice of Proposed Rulemaking (NPRM) establishing a first step to consider exemptions for ADS-equipped vehicles from any Federal Motor Vehicle Safety Standard (FMVSS). It is important to note that vehicles with ADS deployed for testing already do not have to comply with current FMVSSs, and companies wanting to sell or commercialize vehicles with ADS already can apply for exemptions from FMVSSs.

Oddly, this proposal was released soon after NHTSA issued a set of studies touting that FMVSSs have saved over 860,000 lives and 49 million nonfatal injuries from 1968-2019.  Additionally, NHTSA has opened investigations into multiple companies operating vehicles with varying levels of automation that have been involved in serious and fatal crashes. Expanding the deployment of ADS – and without the safety protections provided by FMVSSs – at this time seems premature and lacks independent research and data to support the action.

Under § 30111(a) of the National Traffic and Motor Vehicle Safety Act, FMVSSs must be practicable, meet the need for motor vehicle safety, and be stated in objective terms. NHTSA must, among other things, consider all relevant, available motor vehicle safety information, consider whether a standard is reasonable, practicable and appropriate for the types of motor vehicles or motor vehicle equipment for which it is prescribed, and consider the extent to which the standard will further the statutory purpose of reducing traffic crashes and associated deaths and injuries. This NPRM does not adhere to the principles of these requirements.

Moreover, automakers recently petitioned NHTSA to reconsider the Final Rule issued on April 29, 2024, requiring automatic emergency braking (AEB) in new vehicles by 2029. With the auto industry vociferously stating it is not feasible to comply with parts of the AEB rule with widely used braking technologies in five years, allowing far more complex technology to control more driving functionalities without meeting minimum safety standards is incongruous at best and potentially deadly at worst.

In 2022, over 42,500 people were killed in motor vehicle crashes on U.S. roadways and an additional 2.38 million were injured. Early estimates for 2023 remain historically high. Instead of moving forward with policy to allow unproven ADS-equipped vehicles not in compliance with minimum safety standards on public roads, NHTSA should be bringing requirements for Congressionally-mandated, proven safety systems over the finish line, including AEB for commercial motor vehicles, impaired driving prevention systems and detection and alert systems to prevent pediatric heatstroke (“hot cars”) fatalities and injuries.

Furthermore, numerous opinion polls, including one commissioned and released by Advocates earlier this month, show the public continues to express their trepidation with still developing driverless car technology on public roads. Nearly 90% responded with concern, including 65% who noted their concern is “very” or “extremely” high.

Since 2020, Advocates has developed a policy statement called the AV Tenets which offers a path forward for vehicles with ADS that puts people and safety first. The AV Tenets are supported by over 65 organizations.

This NPRM ignores the havoc created by vehicles with ADS already on the roads and opens the floodgates for more of them with even fewer safety protections. The promise of data collection should not come at the peril of all road users.

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About Advocates
Advocates for Highway and Auto Safety is an alliance of consumer, medical, public health, law enforcement and safety groups and insurance companies and agents working together to make America’s roads safer. Advocates’ mission is the adoption of federal and state laws, policies and programs that prevent motor vehicle crashes, save lives, reduce injuries, and contain costs.