MEMA Weighs in on Federal Automated Vehicle Policy

Date: November 23, 2016

MEMA, the voice of a mobility industry on the forefront of innovation and new safety technologies, submitted comments to the National Highway Traffic Safety Administration (NHTSA) on Nov. 22 regarding the recently released “Federal Automated Vehicles Policy.”
 
During this important comment phase, MEMA praised NHTSA for providing proactive guidance at a time when technologies are just emerging. However, MEMA also outlined several issues and concerns and urged NHTSA to not risk impeding technological development and listen to industry voices as they develop their policy.
 
In its comments, MEMA urged for broad-based clarity. For example, MEMA requested that NHTSA ensure that its policy clearly treat test vehicles separately from production vehicles and that testing documentation requirements are clear, fair and achievable in order to facilitate innovation. MEMA’s comments also emphasized a need to clearly identify the roles and responsibilities of vehicle manufacturers and their suppliers, and outlined concerns about intellectual property protections. Finally, MEMA encouraged NHTSA to coordinate policymaking efforts with the global community to increase chances of alignment for all stakeholders, including consumers, government, industry, and safety advocates.
 
“We are committed to reducing or eliminating fatalities on our roads, and automated vehicles will be critical to reach that goal,” said MEMA President and CEO Steve Handschuh. “We are encouraged by the inclusion of the state policy recommendations in NHTSA’s guidelines, but we do have concerns that the guidelines as currently drafted risk inhibiting life-saving innovations. As the leading trade association representing more than 1,000 companies in the mobility industry, we sincerely hope NHTSA will carefully review our concerns and make appropriate adjustments to improve the policy and lay the groundwork for technological advances.”
 
Three key takeaways addressed in MEMA's comments:

  • Support of NHTSA’s approach to establish policy guidance versus regulations through a transparent, iterative process involving all stakeholders and that does not impede innovation;

  • Urge NHTSA to treat systems and vehicles for testing and production separately in the context of the Automated Vehicle (AV) Policy -- particularly with regards to the Safety Assessment Letters, roles and responsibilities of entities, data recording and sharing, model state policy and NHTSA exemptions; and,

  • Request that NHTSA issue an immediate update of the AV Policy, which is critically important to provide fundamental clarifications and to make appropriate changes based on stakeholders’ input.

MEMA’s comments represent just one step in a multi-pronged effort to communicate concerns about the policy to regulators and legislators to advance members’ business interests. Most recently, on Nov. 17, MEMA testified before members of Congress at the House Energy and Commerce Subcommittee on Commerce, Manufacturing and Trade during a hearing on self-driving vehicles.
 
MEMA and its four specialized divisions comprise the leading international trade association in the fast-changing mobility industry, and legislators and regulators rely on MEMA’s input for a wide range of policies that affect MEMA membership. Testifying before Congress is one way MEMA represents the industry in Washington, D.C. For more information on NHTSA’s AV Policy, contact Leigh Merino.

About MEMA
The Motor & Equipment Manufacturers Association (MEMA) and its four specialized divisions comprise the leading international trade association in the fast-changing mobility industry. Representing vehicle suppliers that manufacture and remanufacture components, technologies, and systems for use in passenger cars and heavy trucks, MEMA serves as a critical bridge between high-tech capabilities in new vehicles—such as autonomous vehicles and vehicle connectivity—and the “nuts and bolts” of vehicle manufacturing. MEMA works at state, Federal, and international levels to ensure that the marketplace and public policy support the development of advanced, transformative technologies that enable safer, smarter, and more efficient vehicles. By directly employing more than 734,000 Americans and generating a total employment impact of 3.6 million jobs, MEMA’s member companies are the largest sector of manufacturing jobs in the U.S. MEMA’s members are represented through four divisions: Automotive Aftermarket Suppliers Association (AASA), Heavy Duty Manufacturers Association (HDMA), Motor & Equipment Remanufacturers Association (MERA) and Original Equipment Suppliers Association (OESA). For more information on how MEMA is leading transformation in the mobility industry, visit www.mema.org.

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