The Motor & Equipment Manufacturers Association (MEMA) submitted comments to the National Highway Traffic Safety Administration (NHTSA) on Nov. 22 regarding the recently released “Federal Automated Vehicles Policy.”
During this important comment phase, MEMA praised NHTSA for providing proactive guidance at a time when technologies are just emerging. However, MEMA also outlined several issues and concerns and urged NHTSA to not risk impeding technological development and listen to industry voices as they develop their policy.
In its comments, MEMA urged for broad-based clarity. For example, MEMA requested that NHTSA ensure that its policy clearly treat test vehicles separately from production vehicles and that testing documentation requirements are clear, fair, and achievable in order to facilitate innovation. MEMA’s comments also emphasized a need to clearly identify the roles and responsibilities of vehicle manufacturers and their suppliers and outlined concerns about intellectual property protections. Finally, MEMA encouraged NHTSA to coordinate policymaking efforts with the global community to increase chances of alignment for all stakeholders, including consumers, government, industry, and safety advocates.
“We are committed to reducing or eliminating fatalities on our roads, and automated vehicles will be critical to reach that goal,” said MEMA President and CEO Steve Handschuh. “We are encouraged by the inclusion of the state policy recommendations in NHTSA’s guidelines, but we do have concerns that the guidelines as currently drafted risk inhibiting life-saving innovations. As the leading trade association representing more than 1,000 companies in the mobility industry, we sincerely hope NHTSA will carefully review our concerns and make appropriate adjustments to improve the policy and lay the groundwork for technological advances.”
Three key takeaways addressed in MEMA's comments:
- Support of NHTSA’s approach to establish policy guidance versus regulations through a transparent, iterative process involving all stakeholders and that does not impede innovation;
- Urge NHTSA to treat systems and vehicles for testing and production separately in the context of the AV Policy – particularly with regards to the Safety Assessment Letters, roles and responsibilities of entities, data recording and sharing, model state policy and, NHTSA exemptions; and,
- Request that NHTSA issue an immediate update of the AV Policy, which is critically important to provide fundamental clarifications and to make appropriate changes based on stakeholders’ input.
MEMA’s comments represent just one step in a multi-pronged effort to communicate concerns about the policy to regulators and legislators to advance members’ business interests. Most recently, on November 17, MEMA testified before members of Congress at the House Energy and Commerce Subcommittee on Commerce, Manufacturing and Trade during a hearing on self-driving vehicles.
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