Self-driving car systems MUST ensure safety of people who bicycle and walk: MoBikeFed statement on proposed federal regulations

The Federal Highway Administration and NHTSA are currently developing federal regulations for autonomous vehicles--driverless cars.

Though autonomous vehicle technology has huge potential to improve road safety for all users of our transportation system, current systems have a huge and unfortunate blind spot when it comes to people who walk and bicycle--particularly with regard to cyclists.

MoBikeFed weighs in with USDOT and NHTSA to support safety for people who walk and bicycle

In the public comment period that closed yesterday, the Missouri Bicycle & Pedestrian Federation joined other bicycle & pedestrian groups across the country in calling for tough regulations around autonomous vehicle safety for people who bicycle and walk.

We were pleased today to hear full-throated support for bicycle and pedestrian safety in the public comments by U.S. Secretary of Transportation Elaine Chao in her headline speech at the National Bike Summit Monday.  We will be expecting the USDOT to fully implement the safety policies that Secretary Chao so clearly articulated in her speech.

MoBikeFed weighs in with Congress in support of safety for people who walk and bicycle

Simultanously, Congress is working on legislation related to autonomous vehicles, and we expect that legislation to protect safety and mobility for people who bicycle and walk as well.

MoBikeFed recently signed onto to a letter to Congress asking for significant changes to current autonomous vehicle legislation to improve safety for people who walk and bicycle.

Full text of our comments in support of regulations to support safety for people who walk and bicycle

Below is the full text of our submitted comments to the USDOT and NHTSA:

I am writing today on behalf of the Missouri Bicycle & Pedestrian Federation.

We are very concerned about the development of vehicles with Automated Driving Systems as it relates to safety and access for people who walk and bicycle. In Missouri, millions of citizens depend on walking and bicycling for basic transportation and millions more choose to walk and bicycle for transportation, recreation, and health.

All of these vital transportation trips involve interaction with motorized vehicles, and for that reason it is very important that any system of regulation of these motorized vehicles prioritize safety of people who walk and bicycle at the highest possible level.

In general, we strongly support the comments and recommendations of the League of American Bicyclists about the proposed ADS regulations.

We would like to emphasize these points:

  • Recent reports show that ADS have a hard time recognizing bicyclists and pedestrian, and we believe more research needs to be done specifically on bicycling, until ADS reaches a high level of success in recognizing and responding to bicyclists and pedestrians. We support research and publicly available information on how ADS recognizes and responds to bicycling and pedestrian users. ADS systems that do not properly and consistently recognize bicyclists and pedestrians should not be allowed to operate on public roadways. All liability for injuries, deaths, and property damage under such systems must be the responsibility of the ADS creator or operator.
  • Federal-aid Highway programs should be changed to emphasize and incentivize fix it first policies that repair and update existing infrastructure to be enable ADS to perform at safe and effective levels. Repairing and updating infrastructure to serve all users will also enable ADS to detect and avoid bicyclists and pedestrians.
  • We also have concerns that preparing for ADS could result in additional restrictions on the mobility of non-motorized users.

    For instance, we caution strongly against laws or regulations that may require bicycles be outfitted with expensive equipment to allow cars to connect with them. While we support development of this technology as an optional upgrade, we worry that the technology will make bikes too expensive for many bike owners. The vast majority of bikes sold in the United States cost under $100 dollars. Technology that may only be a tiny fraction of the cost of a car would create a cost barrier for a bicycle. People who bicycle using these inexpensive bicycles depend on those bicycles for basic, everyday transportation--for example, to school, work, shopping, and medical appointments.

    Regulations or laws that make it more dangerous or more expensive for these people who depend on bicycling for basic transportation are eliminating or make far more dangerous basic, everyday transportation for these citizens.

    Additionally, because such requirements will have far greater impact on transportation system users who are in low income and minority population brackets, any such requirements will have disproportionate impact on underserved populations.

    Any such proposed laws or regulations must be evaluated with the impact on these underserved populations in mind.

ADS technology has the potential to greatly improve safety in our transportation system as a whole, and for people who walk and bicycle particularly. However, the exact laws, regulations, and manner of rolling out these new rules and regulations will have a decisive impact on whether that potential for improved access and safety for nonmotorized is completely realized or squandered.

We strongly encourage the greatest attention to access and safety for those of us who access the national transportation system using nonmotorized means. 


Improving safety for all road users is one of the four primary goals of MoBikeFed's Vision for Bicycling and Walking in Missouri. Ensuring that self-driving automobile systems are safe for all road users, including those who walk and bicycle, is one of the ways we work towards that goal.

Your ongoing membership and generous financial support helps turn our Vision into reality!

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