Global Automakers

Prepared Remarks of Steve Gehring at NHTSA Public Workshop on Automated Driving Systems

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October 20, 2017

Global Automakers' Vice President of Vehicle Safety and Connected Automation Steve Gehring spoke at NHTSA's Public Workshop "Automated Driving Systems: Voluntary Safety Assessments" on October 20.  His remarks follow.  

Good morning, my name is Steve Gehring, Vice President of Vehicle Safety and Connected Automation at the Association of Global Automakers, a trade association representing the U.S. operations of international motor vehicle manufactures, original equipment suppliers, and technology providers. Our members are making significant investments and progress in the research and development of automated vehicles, and we appreciate the opportunity to provide comments on the updated Federal AV Guidance. In my remarks today, I will provide some initial perspectives on the Vision for Safety 2.0, as well as some general suggestions for building upon the guidance moving forward.

It is well recognized that AV systems, across all levels of automation, will provide significant opportunities for improving safety, efficiency, and mobility; and with the increase in highway fatalities, it is important, now more than ever, that the policy environment continues to support the safe testing and deployment of innovative technology. To that end, we support NHTSA’s strong statements on the appropriate role of state and federal government with regards to the development of automated vehicle policy.

Consumer trust and confidence are critical to the adoption of new technology, and we are encouraged that the administration has embraced a Safety Assurance Process that provides the necessary flexibility to develop, test, and deploy highly automated vehicle systems. With more research and data needed to understand how best to regulate the performance of AV systems, we believe the federal guidance, supported by NHTSA’s existing authority, strikes the right balance for promoting safety and innovation. At the same time, the process also provides an opportunity for manufacturers and other entities to demonstrate transparency to the public on how they are addressing priority safety elements identified within the guidance.

Specific to each of the guidance areas, we appreciate that the agency has sought to provide additional clarification to help address ambiguities within the original Federal Policy. We also agree with the agency’s decision that while issues such as ethics, data sharing, and privacy are important areas to consider as vehicles become more connected and automated, these items do not necessarily apply directly within the context of a safety self-assessment but should be discussed through broad stakeholder engagement, separately from the NHTSA guidance.

Our members agree that the Voluntary Safety Self-Assessment process will help support innovation and encourage open communication with the public. However, we also recognize there are questions regarding the specific types of information that should be included as part of such an assessment, whether it be for testing or deployment. While providing a template may be useful for some companies in helping to determine the level of information to provide, the guidance should continue to encourage freedom for manufacturers to disclose relevant information in a format that works best for them. This is an emerging area, and how manufacturers or other entities may communicate relevant safety information to the public is likely to evolve as we gather more experience and a greater understanding of consumer expectations. In any case, NHTSA should maintain that any supporting template(s) are consistent with the guidance, and make clear that the agency is not dictating a specific format or style for how information is presented to the public.

Related to this, we appreciate the guidance underscoring the importance of identifying the appropriate level of detail and transparency that can be provided without compromising confidential business information. However, recognizing that the agency may at some point in the future request additional information related to a VSSA or automated vehicle design, it is critical that NHTSA ensure proprietary data is protected, given the significant investment in new technology.

As we continue to develop our written comments on the guidance, we would like to provide the following initial recommendations for the agency to consider moving forward:

  • Recognizing the voluntary nature of the Safety Self-Assessment, we believe there is some public benefit for the agency to develop and maintain a website that provides links for consumers and other policymakers to access VSSAs publically disclosed by manufacturers.
  • To complement the model state policy, NHTSA should consider organizing a public workshop (or series of workshops) to convene a national discussion on the key policy issues affecting states. This would not only help better align the respective roles of state and federal government, but would also provide a forum to ensuring a more uniform national approach to AV policy.
  • While the guidance provides helpful recommendations for manufacturers to consider in the development there are still a number of regulatory barriers that need to be addressed for both the testing and deployment of automated vehicles. It is critical that NHTSA continue to aggressively research how best to modernize existing regulations to support deployment of these life-saving technologies in the short term.
  • Finally, we believe it would also be helpful for the agency to consider the development of a research priority plan and share it with the public to help better understand how we can avoid duplication and collectively work toward the shared goal of increased safety and mobility.

In conclusion, we believe it is important that we have the right process in place to assure both the agency and the public that automakers are designing their systems with safety first in mind. I would like to just reiterate that we believe the agency has made a number of significant improvements to the Federal Guidance. We appreciate the opportunity to provide remarks here today, and we look forward to continued engagement with both NHTSA, and other stakeholders, to ensure the policy framework continues to support the testing and deployment of automated vehicles.

Our Members