Statement on New Expert White Paper Revealing Inconsistencies and Dangerous Safety Gaps in Development of Partially Autonomous Vehicle Technology

  • March 12, 2020
150 150 Advocates for Highway and Auto Safety
CONTACT: Pete Daniels / / 202-408-1711 / 301-442-2249 (C)


Statement of Cathy Chase, President,

Advocates for Highway and Auto Safety

On New Expert White Paper Revealing Inconsistencies

and Dangerous Safety Gaps in Development of

Partially Autonomous Vehicle Technology


Insurance Institute for Highway Safety (IIHS) findings
confirm the need for minimum performance standards


A new IIHS white paper released today reinforces the urgent need to require minimum performance standards for cars with partially autonomous driving systems.  IIHS found different systems in different cars operating differently in similar situations.  It is precisely this kind of confusing technological landscape that is best addressed through a process where all manufacturers adhere to the same minimum performance standards to improve safety and ensure systems are operating as expected by consumers.  Moreover, the IIHS white paper identifies needed improvements to driver monitoring and engagement to ensure the driver remains an alert and engaged participant in the driving task, as required by partially autonomous driving systems.

Advocates for Highway and Auto Safety (Advocates) has consistently urged Congress to take action to overcome the known and foreseeable issues with partially automated systems as outlined in the IIHS report.  In testimony before Congress earlier this year, Advocates noted the need for a minimum performance standard to address the growing problem of “automation complacency” which refers to the tendency of humans to lose focus when a vehicle’s automated systems take over some of the driving task.  We commend IIHS for detailing the dangers posed by this dangerous behavior as automated systems grow increasingly more available in new cars.  The report also warns that it is currently too easy for drivers to use autonomous features in driving environments that go beyond the scope of the technology’s capabilities.  Advocates seeks to address this problem by calling for a standard that would restrict the use of automated features to scenarios in which they can be used safely, known as the operational design domain (ODD).

Today’s IIHS report comes just a few weeks after the February 25, 2020 National Transportation Safety Board (NTSB) meeting during which the independent investigatory agency called for swift action to prevent crashes involving partially autonomous vehicles including the need to develop standards for driver monitoring systems.  NTSB’s findings following the investigation of a March 2018 fatal crash of a Tesla in Mountain View, California, note that the approach of the National Highway Traffic Safety Administration (NHTSA) “to the oversight of automated vehicles is misguided, because it essentially relies on waiting for problems to occur rather than addressing safety issues proactively.”

Commonsense safeguards to overcome dangers posed by partially autonomous vehicles that are already on our roadways must be part of our Nation’s first legislation on autonomous vehicles (AV).  Considering the U.S. Department of Transportation (DOT) has only issued non-binding voluntary guidelines regarding AVs, Advocates urges Congress to require DOT to issue minimum safety performance standards, conduct thorough oversight, and require industry accountability to ensure the safety, accessibility and public acceptance of developing autonomous driving technology.