The Motor & Equipment Manufacturers Association (MEMA) presented oral comments before the National Highway Traffic Safety Administration (NHTSA) during a Dec. 12 public meeting regarding a section of the Federal Automated Vehicle Policy (FAVP) dedicated to model state policy. This is the second public meeting the agency has held on the FAVP; the first was on Nov. 17.
To create a national framework, “Federal and state governments must work together to establish policies that accelerate deployment of these technologies while also balancing public safety and building trust,” said Leigh Merino, MEMA senior director of regulatory affairs, during the hearing. “Federal leadership working closely with the states is essential to avoid a potential patchwork of varying state laws and requirements.”
In its statement, MEMA once again urged for broad-based clarity and requested that NHTSA ensure that its policy clearly treat test vehicles separately from production vehicles. As it relates to the State model policy, NHTSA’s FAVP proposed a framework of requirements for the states among which is the assertion that each test vehicle follows the Performance Guidance “set forth by NHTSA” and “meets all applicable” federal motor vehicle safety standards.
MEMA strongly believes that a state should not codify the NHTSA vehicle performance guidance by way of its own laws, policies and/or application requirements for automated vehicle testing. “Doing so will avoid the impact of unintended consequences that may hinder supplier development and innovation of automated systems and prevent opportunities for real-world testing experiences in various states,” Merino said.
MEMA’s testimony represents just one step in a multi-pronged effort to communicate concerns about the policy to regulators and legislators to advance members’ business interests. On Nov. 22, MEMA submitted comments to NHTSA regarding its FAVP, and MEMA also testified on Nov. 15 at the House Energy and Commerce Subcommittee on Commerce, Manufacturing and Trade during a hearing on self-driving vehicles.
MEMA and its four specialized divisions comprise the leading international trade association in the fast-changing mobility industry, and legislators and regulators rely on MEMA’s input for a wide range of policies that affect MEMA membership. Testifying before Congress is one way MEMA represents the industry in Washington, D.C. For more information on NHTSA’s AV Policy, contact Leigh Merino.
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