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NHTSA Seeks Comments on Automated Driving System Safety

Date: December 8, 2020

The National Highway Traffic Safety Administration (NHTSA) officially published an advanced notice of proposed rulemaking (ANPRM) last week seeking public comment on the development of a framework to govern the safety of automated driving systems (ADS). Comments are due Feb. 1, 2021.

The approach the agency is taking with this ANPRM is different from previous notices related to ADSs. NHTSA is seeking input on how a new framework can be established that combines a range of tools and metrics to guide the evaluation and demonstration of ADS safety. The ANPRM envisions a phased-in framework approach that would avoid placing design-specific rules that might impede or hamper innovation. As with previous AV guidance documents from the U.S. Department of Transportation, the framework is intended to evolve as ADS technology evolves.

“Although the establishment of an FMVSS for ADS may be premature, it is appropriate to begin to consider how NHTSA may properly use its regulatory authority to encourage a focus on safety as ADS technology continues to develop.

NHTSA identified four primary functions on which to focus first:

  • Sensing:  How the ADS receives information about its environment through sensors.
  • Perception:  How the ADS detects and categorizes other road users, infrastructure, and conditions, and predicts behavior.
  • Planning:  How the ADS analyzes a situation and plans routes and reacts, accordingly
  • Control:  How the ADS executes the driving functions necessary to carry out its continuously updated driving plan.

NHTSA is open to a variety of pathways for implementation and oversight – from voluntary programs to setting regulations. The agency also recognizes that any future regulatory standards will need to be technologically neutral and performance focused. In the ANPRM, there are 24 questions posited by NHTSA asking for public comment about their proposed safety framework, agency research, their potential administrative methods, and their statutory authority.

MEMA will work with members on response comments. If you’re interested in getting involved in the MEMA’s Vehicle Safety Subcommittee, please contact Leigh Merino.

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