ALLIANCE FOR AUTOMOTIVE INNOVATION
COMMITTEE ON ENERGY AND COMMERCE
SUBCOMMITTEE ON CONSUMER PROTECTION & COMMERCE
U.S. HOUSE OF REPRESENTATIVES
“Autonomous Vehicles: Promises and Challenges of Evolving Automotive Technologies”
February 11, 2020
President and CEO
Good morning Chairwoman Schakowsky, Ranking Member McMorris Rodgers and distinguished members of the subcommittee. On behalf of the members of the Alliance for Automotive Innovation (Auto Innovators), thank you for the opportunity to testify today regarding automated vehicle technologies and the tremendous promise that they offer to the traveling public, the economy and the future of this country.
This January, the Alliance for Automotive Innovation was formed to become the singular, authoritative and respected voice of the automotive industry in the United States. Our 35 members include auto manufacturers who produce nearly 99 percent of the cars and light trucks sold in the U.S., along with original equipment suppliers, technology companies, and other automotive-related value chain partners. Our industry employs roughly 10 million Americans, in addition to those who are employed in the technology and mobility sectors directly.
Our mission at Auto Innovators can be distilled to three words: safer, smarter, and cleaner. We work with policymakers, including each of you on this Committee to find intelligent solutions to reduce crashes, improve the environment, and enhance personal transportation. Today’s hearing is important, timely and fully consistent with our association’s mission. Our organization represents the companies and partnerships that are working to deliver safer, smarter, and cleaner transportation options to the American public.
This Committee has a proud history demonstrating leadership on these issues in a fully bipartisan fashion. More than two and a half years ago, the House overwhelmingly passed legislation written by this Committee to advance these safety innovations. It provided a regulatory framework for the safe testing and deployment of AVs. Then, and now, Congress has a great opportunity to advance highway safety and expanded mobility. In a challenging legislative environment, it’s fair to say that few other likely actions by Congress this year could deliver benefits as far-reaching and wide-ranging.
In the time since the House approved the SELF DRIVE Act, the rapid pace of innovation has continued. The technologies and systems now being developed and tested will make getting from place to place safer and more efficient, and expand access to millions of Americans who currently lack adequate transportation options.
AV technologies could not come at a better time. The numbers are sobering: In 2018 alone, 36,560 people – or 100 people a day — died in the two million traffic crashes on our nation’s roadways. The National Highway Traffic Safety Administration (NHTSA) has found that 94 percent of car crashes are attributable to human choice or error. By supplementing or even replacing the human driver with advanced sensors and other technology, we can dramatically decrease the frequency and severity of these crashes. Unlike conventional human drivers, AVs can’t get distracted, drive impaired or fall asleep at the wheel.
AVs can also provide numerous social and economic benefits, including less congestion, lower fuel consumption, and increased mobility for older adults and people with disabilities. Smart transportation information networks are already helping us get around congestion, increasing efficiency and saving time and resources. AVs will magnify these benefits by employing options such as harmonized speed control to reduce bottlenecks and optimized routing to get you from point A to point B faster, using less energy.
AVs can also extend transportation to those who currently lack access. According to a recent U.S. Department of Transportation study, 25.5 million Americans age five and older have self-reported travel-limiting disabilities. For this portion of the population, increased access to transportation can improve quality of life by increasing independence, enabling people to reach health care and employment opportunities.
Of course, this Committee understands the need to ensure that the federal government’s safety authorities work to bolster public confidence and public acceptance of AVs. The previous AV legislation written by this Committee actually increased – not decreased – the role of NHTSA in overseeing these new technologies. Nothing in that legislation relaxed current standards or procedures, and the DOT retained its defect identification, investigation and enforcement authorities. Further, this Committee’s past efforts also required automakers and tech companies to submit reporting requirements to DOT before proceeding with testing or deployment of these safety technologies.
It is important to recognize that successful testing and deployment of AVs rests on a robust federal safety agency, increased public awareness and education, and coordination between federal, state and local governments. The DOT must retain its safety and enforcement authorities over each level of automation, and AV developers must work to increase public awareness which builds trust in the technology. Congress has an important role: to help provide the legislative and regulatory landscape that can enable the full safety, environmental, social and economic benefits of AVs.
There are three key recommendations I would like to offer today as Congress works to help realize these benefits:
One is the need to establish a regulatory framework that allows for the safe testing and deployment of automated vehicle technologies. As we are all aware, the pace of AV innovation is occurring faster than DOT can update the existing Federal Motor Vehicle Safety Standards (FMVSS). While the DOT has taken important steps to research and request comment on existing FMVSS barriers for AVs, much work is needed to account for the fact that manual driver controls, such as the steering wheel, brake pedal and gear shifter, may no longer be needed in certain types of automated vehicles. In the interim, FMVSS exemptions are necessary to act as a bridge for the safe deployment of AV technologies which will then help generate the real-world data that is needed to establish new safety standards for AVs. The exemption process at NHTSA has a current threshold of 2,500 vehicles per manufacturer. This annual 2,500 vehicle threshold should be increased if we truly want to realize the safety, economic and social benefits of AVs. Again, all exemption requests are considered on a case-by-case basis. This Committee took an important step in this regard last Congress when it passed the SELF DRIVE Act. And just last week, NHTSA granted Nuro’s exemption request for their low-speed delivery vehicle, which will have an overall level of safety equivalent to that of a conventional vehicle. NHTSA is requiring reports from Nuro, including operational information about the vehicle and AV system. We look forward to continuing to work with the DOT and this Committee on updates to the current exemption process to ensure NHTSA has the robust data necessary to establish future regulations.
Second is the need to reinforce and clarify the roles of federal, state and local authorities for automated vehicle technologies. The current lack of clarity will result in a dangerous patchwork of laws and regulations developing across the country that will hinder the ability for automated vehicle technologies to be safely deployed, thereby delaying or negating the safety benefits that would otherwise occur. We firmly believe that states should continue to have jurisdiction and oversight of driver licensing, registration, insurance, traffic laws and enforcement. However, it is not helpful to anyone if there are conflicting laws and regulations when it comes to a vehicle’s design, construction, and performance. This Committee has a long history of understanding the importance of uniform standards, and we will continue to work with the Committee and state and local stakeholders on this important issue.
Third is an understanding that any legislation that this Committee or Congress ultimately passes is not the final word on the subject. Both the Congress and federal safety authorities will further refine and adjust AV policy in the future. As under the previous and current Administrations, NHTSA will continue to work to address regulatory barriers to AVs and craft new regulations once the real-world data is available. Undoubtedly, states will continue to promulgate legislation and regulations pertaining to AV operation (licensing, registration, insurance, traffic laws and enforcement) and create AV stakeholder groups to evaluate the specific circumstances in their state.
Additionally, we continue to work to underscore the widespread support that exists for the creation of a clear Federal regulatory structure that can help to safely test and deploy these life-saving safety technologies. Working with Mark Riccobono and the National Federation of the Blind, as well as other advocates for those with limited or no access to transportation, more than 100 companies, representing automobile manufacturers, suppliers, new mobility providers, and others have joined together through the Coalition for Future Mobility to make it clear how important these safety and mobility technologies are to our entire nation.
Private sector entities have invested tens of billions of dollars to advance this transformative technology. According to one analysis, Cruise, Ford, Toyota, Uber, Apple, Waymo and other companies have spent $16 billion through 2019 on technologies for automated vehicles. In Arizona, Florida, Michigan and other states across the country, prototype vehicles are being tested, under limited and controlled conditions, carrying groceries, delivering pizzas, and ferrying passengers. Companies understand that consumers will need to be comfortable with the overall safety of these technologies before they fully embrace them. That is also why we call on this Committee and Congress to expand the exemption process which will help to increase public awareness and trust for these critical safety and mobility solutions.
While this work is going on in the research labs of auto and technology companies, and on our nation’s roadways, the speed and quality of development also depends on government oversight and encouragement – such as the DOT’s recent update to the AV 4.0 guidance document, the Voluntary Safety Self-Assessment process, and ongoing work from the National Highway Traffic Safety Administration, Federal Highway Administration, Federal Motor Carrier Safety Administration, and Federal Transit Administration to alleviate regulatory barriers and develop a multi-modal approach to provide transportation solutions.
That said, there’s additional authority that only Congress can provide to ensure there’s an appropriate federal framework to spur the development of life-saving technologies, including the parameters for their testing and deployment. Congressional action can and should be complementary to realize the shared vision that we all have for a safer, cleaner, and smarter transportation system.
In closing, we need to be mindful of some basic realities. We should not be satisfied with the fact that more than 36,000 Americans lost their lives on our roads in 2018.
From my perspective as the President and CEO of the Alliance for Automotive Innovation, there are no other safety or mobility solutions that hold as much promise or provide as many benefits to the traveling public as automated vehicle technologies.
Effectively, the worst outcome would be for Congress to delay the enactment of meaningful legislation that would establish the needed federal framework to realize these safety and mobility solutions.
It is also important to note that there is a global search, and a global race, to get to the point where these technologies are on our roadways. The U.S. currently has a leadership position, and it is where international companies have chosen to invest their resources. But America’s leadership position is not guaranteed forever.
The Congress, and specifically this Committee, has played a central role in improving motor vehicle safety and mobility. Legislation can provide the clarity and structure needed to allow the safe testing and deployment to go forward with appropriate protections. And as I stated previously, any legislative action is the beginning, and not the end, of Congressional activity.
This hearing is part of that process, and we are grateful to the committee for being able to provide testimony today.
 Travel Patterns of American Adults with Disabilities by Stephen Brumbaugh, US DOT, Office of the Secretary of Transportation, Bureau of Transportation Statistics, September 2018.