Letter on Pausing Driverless Car Bill Until Uber, Tesla Crash Investigations are Complete

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

Diverse Coalition Asks Senate to Hit Pause on Driverless Car Bill Until NTSB Completes Critical Uber, Tesla Crash Investigations

Leading state and national stakeholders representing safety, public health, bicyclists, pedestrians, smart growth, consumer and environmental organizations, law enforcement and first responders, disability communities, and individuals affected by motor vehicle crashes asked the U.S. Senate to back off plans to move the AV START Act (S. 1885) that could set driverless car policy for decades to come until the National Transportation Safety Board (NTSB) completes important investigations into recent crashes involving automated driving systems that have killed at least two people – including a pedestrian walking a bicycle.  NTSB’s expert analysis of the recent crashes and the agency’s subsequent recommendations will likely have a direct bearing on issues included in the AV START Act.

The Senate returns from recess on Monday and during the next couple of weeks is expected to consider S. 1405, reauthorization of the Federal Aviation Administration (FAA).  It is possible that the AV START Act might get attached to that bill, potentially precluding any debate or amendments to the AV START Act. Attempts to advance the bill and bypass the legislative process especially before having crucial information from the NTSB would be reckless at best and deadly at worst.

Click here for a PDF of the letter.

May 4, 2018

Dear Senator:

As representatives of a diverse group of safety, public health, bicyclists, pedestrians, smart growth, consumer and environmental groups, law enforcement and first responders, disability communities and families affected by motor vehicle crashes, we write urging you to support sensible and needed safety and consumer improvements to legislation pending in the U.S. Senate, S. 1885, the AV START Act.  This bill, which addresses the development and deployment of autonomous vehicle (AV) technology or driverless cars, lacks critical public safeguards.

Just this year, at least two people have been killed in crashes involving driving automation systems – including a pedestrian walking a bicycle.  The National Transportation Safety Board (NTSB) is investigating those crashes.  As the findings from those investigations are likely to have a direct bearing on the AV START Act, we ask that it not move forward until those investigations are complete.  While we are hopeful that in the future driverless cars may result in significant reductions in motor vehicle crashes, deaths and injuries, we are very concerned that provisions in the bill put others sharing the road with AVs at unnecessary and unacceptable risk.

We urge you to adopt reasonable and responsible improvements including:

  • Requirements for safety standards such as a “vision test” for driverless technologies, cybersecurity and electronics system protections, and distracted driving requirements when a human needs to take back control of a vehicle from a computer;
  • Adequate data collection and consumer information;
  • Crash analysis data recording that includes parameters designed to aid investigators such as NTSB and the National Highway Traffic Safety Administration (NHTSA);
  • Reducing the size and scope of exemptions from federal safety standards;
  • Ensuring access for all disability communities, including wheelchair users;
  • Subjecting Level 2 vehicles to all safety critical provisions, without blocking state protections for these vehicles;
  • Eliminating a section that would allow manufacturers to unilaterally “turn off” vehicle systems;
  • Removing provisions that prohibit states and localities from protecting their citizens by regulating the AV system even when it is functioning as the driver of the vehicle; and,
  • Providing the U.S. Department of Transportation (DOT) and NHTSA with sufficient resources and authorities.

These changes would protect innovation and technological progress from consumer fears of self-driving technology that have only grown after the recent fatalities.  And, they would ensure that AVs are developed and deployed in a way that provides proper government oversight and industry accountability while prioritizing public safety.

Concern about AV safety and support for improvements is widespread.  For instance, a CARAVAN public opinion poll released earlier this year found that 64 percent of respondents expressed concern about sharing the roads with driverless cars and 73 percent of respondents support the U.S. DOT developing safety standards for new features related to the operation of driverless cars.  These sentiments have been echoed by numerous editorials and opinion pieces including:

  • The New York Times (3/31/18): “the technology that powers these vehicles could introduce new risks that few people appreciate or understand”;
  • Automotive News (3/26/18): “If it takes time to figure how to develop and test vehicles responsibly without posing an undue risk to the public, that’s time well spent”; and,
  • Los Angeles Times (3/23/18): “So far, there’s no comprehensive data on how driverless cars are performing on tests or whether the vehicles are ready for commercial use. There are no federal rules governing the deployment and performance of autonomous technology. There are no standardized tests the cars are required to pass before using public roads.”

Moreover, recent reports have suggested the bill could be attached to unrelated legislation moving through the Senate.  The AV START Act will set AV policy for decades to come and should not bypass the regular legislative process.  It is essential that the legislation be given the opportunity for discussion, debate and transparent consideration before the Senate votes.  Considering predictions by numerous auto and tech industry executives state that it will likely be many years until AVs are rolled out, it would be prudent to be deliberate in legislating our Nation’s AV policy and not rush through the AV START Act.

The Senate stands poised at a critical juncture in surface transportation policy.  We urge you to allow for the completion of NTSB’s expert analysis of the recent crashes and their subsequent recommendations before any further legislative action is taken.  It is crucial that necessary and commonsense safety improvements to ensure the safe development and deployment of AVs for all roads users are included in this legislation.

Thank you for your consideration.



Jeff Solheim, 2018 President

Emergency Nurses Association


Bill Nesper, Executive Director

The League of American Bicyclists


Christopher Michetti, MD, President

American Trauma Society


Dominick Stokes, Vice President for

Legislative Affairs

Federal Law Enforcement Officers Association


Catherine Chase, President

Advocates for Highway and Auto Safety


David Friedman, Director of Cars and

Product Policy and Analysis

Consumers Union and

Former Deputy and Acting Administrator, NHTSA


Georges C. Benjamin, MD, Executive Director

American Public Health Association


Joan Claybrook, President Emeritus

Public Citizen, and Former NHTSA Administrator


Ralf Hotchkiss, Co-Founder

Whirlwind Wheelchair International


Amy Colberg, Director of Government Affairs

Brain Injury Association of America


Leah Shahum, Founder and Director

Vision Zero Network


Dave Snyder, Executive Director

California Bicycle Coalition


Cara Spencer, Executive Director

Consumers Council of Missouri


Paul Steely White, Executive Director

Transportation Alternatives


Jack Gillis, Director of Public Affairs

Consumer Federation of America


Jason Levine, Executive Director

Center for Auto Safety


Robert Weissman, President

Public Citizen


Bill Newton, Deputy Director

Florida Consumer Action Network


Cathy DeLuca, Policy & Program Director

Walk San Francisco


Paul Winkeller, Executive Director

New York Bicycling Coalition


Dan Becker, Director

Safe Climate Campaign


Jackie Martin, President

Tempe Bicycle Action Group


John M. Simpson, Privacy and Technology

Project Director, Consumer Watchdog


Linda Sherry, Director of National Priorities

Consumer Action


Stephen W. Hargarten, M.D., MPH

Society for the Advancement of Violence and

Injury Research


Sally Greenberg, Executive Director

National Consumers League


Irene E. Leech, President

Virginia Citizens Consumer Council


Brent Hugh, Executive Director

Missouri Bicycle & Pedestrian Federation


Scott Bricker, Executive Director

Bike Pittsburgh


Melissa Wandall, President

National Coalition for Safer Roads

Founder, The Mark Wandall Foundation


Rosemary Shahan, President

Consumers for Auto Reliability and Safety


Steve Owings, Co-Founder

Road Safe America


Dawn King, President

Truck Safety Coalition


Elliott Caldwell, Executive Director

Georgia Bikes


Andrew McGuire, Executive Director

Trauma Foundation


Champe Burnley

VA Bicycling Federation


Tom Francis, Interim Executive Director



Dennis Strawn, President

West Virginia Connecting Communities


Ron Burke, Executive Director

Active Transportation Alliance


Ted Silver, Chair

Banner Elk NC Bike/Ped Committee

Program Coordinator, Cycling Studies Minor Program

Lees-McRae College


Anne Rugg, Vice President

Seacoast Area Bicycle Riders


Karin Weisburgh, Member

League of American Bicyclists Board of Directors


Ivan Vamos AICP, Retired Urban Planner


Steven Hardy-Braz

North Carolina