Diverse Coalition--including MoBikeFed, League, many bike/ped organizations across the U.S.--asks Senate to hit pause on Driverless Car Bill until NTSB completes critical Uber, Tesla crash investigations

Leading state and national stakeholders representing safety, public health, bicyclists, pedestrians, smart growth, consumer and environmental organizations, law enforcement and first responders, disability communities, and individuals affected by motor vehicle crashes asked the U.S. Senate to back off plans to move the AV START Act (S. 1885) that could set driverless car policy for decades to come until the National Transportation Safety Board (NTSB) completes important investigations into recent crashes involving automated driving systems that have killed at least two people – including a pedestrian walking a bicycle.  NTSB’s expert analysis of the recent crashes and the agency’s subsequent recommendations will likely have a direct bearing on issues included in the AV START Act.

Self-driving cars have the potential to greatly increase safety--in the future
Self-driving cars have the potential to greatly increase safety, but currently fall short when it comes to detecting and reacting to people who walk and bicycle, and many other day-to-day driving situations

The Senate returns from recess on Monday and during the next couple of weeks is expected to consider S. 1405, reauthorization of the Federal Aviation Administration (FAA).  It is possible that the AV START Act might get attached to that bill, potentially precluding any debate or amendments to the AV START Act. Attempts to advance the bill and bypass the legislative process especially before having crucial information from the NTSB would be reckless at best and deadly at worst.

Driverless car technology has the potential to greatly increase road safety in the future.  But right now, driverless vehicle technology is in its infancy.  Some company's systems are more advanced than others; other companies are rushing to market. Some companies value safety highly; others will value profitability and convenience over safety.

We need to be very careful as this new technology launches, that we set parameters that ensure safety and respect for all road users.

This technology will set the tone for use of our streets and roads for many decades and centuries to come.

We need to make sure this promising technology gets off on the right foot, right from the start. Waiting to analyze results of recent serious fatality situations before moving forward with sweeping legislation is a good first step.

May 4, 2018

Dear Senator:

As representatives of a diverse group of safety, public health, bicyclists, pedestrians, smart growth, consumer and environmental groups, law enforcement and first responders, disability communities and families affected by motor vehicle crashes, we write urging you to support sensible and needed safety and consumer improvements to legislation pending in the U.S. Senate, S. 1885, the AV START Act.  This bill, which addresses the development and deployment of autonomous vehicle (AV) technology or driverless cars, lacks critical public safeguards.

Just this year, at least two people have been killed in crashes involving driving automation systems – including a pedestrian walking a bicycle.  The National Transportation Safety Board (NTSB) is investigating those crashes.  As the findings from those investigations are likely to have a direct bearing on the AV START Act, we ask that it not move forward until those investigations are complete.  While we are hopeful that in the future driverless cars may result in significant reductions in motor vehicle crashes, deaths and injuries, we are very concerned that provisions in the bill put others sharing the road with AVs at unnecessary and unacceptable risk.

We urge you to adopt reasonable and responsible improvements including:

  • Requirements for safety standards such as a “vision test” for driverless technologies, cybersecurity and electronics system protections, and distracted driving requirements when a human needs to take back control of a vehicle from a computer;
  • Adequate data collection and consumer information;
  • Crash analysis data recording that includes parameters designed to aid investigators such as NTSB and the National Highway Traffic Safety Administration (NHTSA);
  • Reducing the size and scope of exemptions from federal safety standards;
  • Ensuring access for all disability communities, including wheelchair users;
  • Subjecting Level 2 vehicles to all safety critical provisions, without blocking state protections for these vehicles;
  • Eliminating a section that would allow manufacturers to unilaterally “turn off” vehicle systems;
  • Removing provisions that prohibit states and localities from protecting their citizens by regulating the AV system even when it is functioning as the driver of the vehicle; and,
  • Providing the U.S. Department of Transportation (DOT) and NHTSA with sufficient resources and authorities.

These changes would protect innovation and technological progress from consumer fears of self-driving technology that have only grown after the recent fatalities.  And, they would ensure that AVs are developed and deployed in a way that provides proper government oversight and industry accountability while prioritizing public safety.

Concern about AV safety and support for improvements is widespread.  For instance, a CARAVAN public opinion poll released earlier this year found that 64 percent of respondents expressed concern about sharing the roads with driverless cars and 73 percent of respondents support the U.S. DOT developing safety standards for new features related to the operation of driverless cars.  These sentiments have been echoed by numerous editorials and opinion pieces including:

  • The New York Times (3/31/18): “the technology that powers these vehicles could introduce new risks that few people appreciate or understand”;
  • Automotive News (3/26/18): “If it takes time to figure how to develop and test vehicles responsibly without posing an undue risk to the public, that’s time well spent”; and,
  • Los Angeles Times (3/23/18): “So far, there’s no comprehensive data on how driverless cars are performing on tests or whether the vehicles are ready for commercial use. There are no federal rules governing the deployment and performance of autonomous technology. There are no standardized tests the cars are required to pass before using public roads.”

Moreover, recent reports have suggested the bill could be attached to unrelated legislation moving through the Senate.  The AV START Act will set AV policy for decades to come and should not bypass the regular legislative process.  It is essential that the legislation be given the opportunity for discussion, debate and transparent consideration before the Senate votes.  Considering predictions by numerous auto and tech industry executives state that it will likely be many years until AVs are rolled out, it would be prudent to be deliberate in legislating our Nation’s AV policy and not rush through the AV START Act.

The Senate stands poised at a critical juncture in surface transportation policy.  We urge you to allow for the completion of NTSB’s expert analysis of the recent crashes and their subsequent recommendations before any further legislative action is taken.  It is crucial that necessary and commonsense safety improvements to ensure the safe development and deployment of AVs for all roads users are included in this legislation.

Thank you for your consideration.


Jeff Solheim, 2018 President
Emergency Nurses Association

Bill Nesper, Executive Director
The League of American Bicyclists

Christopher Michetti, MD, President
American Trauma Society

Dominick Stokes, Vice President for Legislative Affairs
Federal Law Enforcement Officers Association

Catherine Chase, President
Advocates for Highway and Auto Safety

David Friedman
Director of Cars an d Product Policy and AnalysisConsumers Union and
Former Deputy and Acting Administrator, NHTSA

Georges C. Benjamin, MD, Executive Director
American Public Health Association

Joan Claybrook, President Emeritus
Public Citizen, and Former NHTSA Administrator

Ralf Hotchkiss, Co-Founder
Whirlwind Wheelchair International

Amy Colberg, Director of Government Affairs
Brain Injury Association of America

Leah Shahum, Founder and Director
Vision Zero Network

Dave Snyder, Executive Director
California Bicycle Coalition

Cara Spencer, Executive Director
Consumers Council of Missouri

Paul Steely White, Executive Director
Transportation Alternatives

Jack Gillis, Director of Public Affairs
Consumer Federation of America

Jason Levine, Executive Director
Center for Auto Safety

Robert Weissman, President
Public Citizen

Bill Newton, Deputy Director
Florida Consumer Action Network

Cathy DeLuca, Policy & Program Director
Walk San Francisco

Paul Winkeller, Executive Director
New York Bicycling Coalition

Dan Becker, Director
Safe Climate Campaign

Jackie Martin, President
Tempe Bicycle Action Group

John M. Simpson, Privacy and Technology
Project Director, Consumer Watchdog

Linda Sherry, Director of National Priorities
Consumer Action

Stephen W. Hargarten, M.D., MPH
Society for the Advancement of Violence and Injury Research

Sally Greenberg, Executive Director
National Consumers League

Irene E. Leech, President
Virginia Citizens Consumer Council

Brent Hugh, Executive Director
Missouri Bicycle & Pedestrian Federation

Scott Bricker, Executive Director
Bike Pittsburgh

Melissa Wandall, President
National Coalition for Safer Roads
Founder, The Mark Wandall Foundation

Rosemary Shahan, President
Consumers for Auto Reliability and Safety

Steve Owings, Co-Founder
Road Safe America

Dawn King, President
Truck Safety Coalition

Elliott Caldwell, Executive Director
Georgia Bikes

Andrew McGuire, Executive Director
Trauma Foundation

Champe Burnley
VA Bicycling Federation

Tom Francis, Interim Executive Director

Dennis Strawn, President
West Virginia Connecting Communities

Ted Silver, Chair
Banner Elk NC Bike/Ped Committee
Program Coordinator, Cycling Studies Minor Program
Lees-McRae College

Anne Rugg, Vice President
Seacoast Area Bicycle Riders

Karin Weisburgh, Member
League of American Bicyclists Board of Directors

Ivan Vamos AICP, Retired Urban Planner
Steven Hardy-Braz
North Carolina

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.

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