The Alliance of Automobile Manufacturers (Auto Alliance or Alliance) appreciates this opportunity to provide input to the U.S. Department of Transportations (DoT or Department) request for public comment on the Preparing for the Future of Transportation: Automated Vehicles 3.0 document (AV 3.0). The Auto Alliance is the leading advocacy group for the auto industry. Its members include BMW Group, FCA US LLC, Ford Motor Company, General Motors Company, Jaguar Land Rover, Mazda, Mercedes-Benz USA, Mitsubishi Motors, Porsche, Toyota, Volkswagen Group of America and Volvo Cars North America, and represent approximately 70 percent of all car and light truck sales in the United States. We commend you and the Department of Transportation for continuing to spur the development of innovative safety technologies, including self-driving vehicle technologies that hold great promise for our nation. AV 3.0 builds on the previous guidance the National Highway Traffic Safety Administration (NHTSA) released last September which provided greater clarity to auto manufacturers and technology providers working to develop cutting-edge technologies that can enhance roadway safety, expand mobility, and ensure that the U.S. continues to lead the development, testing, and deployment of life saving technologies. The actions that the Department and NHTSA have taken with AV 3.0 will help to reduce the barriers for Automated Driving Systems (ADS) technologies and lead to profound societal benefits. ADS-equipped vehicles and related safety technologies have the potential to significantly improve overall safety on our nations roadways. In 2017, 37,133 people died in motor vehicle crashes on our nations roads. Given that 94 percent (94%) of vehicles crashes are caused by human error , ADS-equipped vehicles have tremendous potential to reduce roadway fatalities, injuries and property damage. Additionally, ADS-equipped vehicles could provide numerous economic and societal benefits, such as decreased congestion and fuel consumption, and increased access and mobility for the elderly and disabled that would have additional positive benefits on the labor market. We look forward to working with the Department on the workforce study to address concerns about the potential labor market effects of AVs. Additionally, the AV Pilot Program outlined in the Advance Notice of Proposed Rulemaking (ANPRM) , released alongside AV 3.0 has the potential to provide a path to significant deployment of automated technologies and will ultimately could save many injuries and lives. The proposed program also will provide for a system where industry and DoT could exchange critical data that will allow for smart new policy by DoT and the acceleration of testing and deployment. We will be separately submitting a detailed response to the ANPRM. (See attached for full comment)
DOTNonrulemakingDOT-OST-2018-0149
Preparing for the future of Transportation: Automated Vehicles 3.0 (AV 3.0) [ISBN 978-0-16-094944-9]
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Alliance of Automobile Manufacturers filed 1 comment on this docket between Dec 4, 2018 and Dec 4, 2018. 54 other organizations filed here. The comment window closed 2794d ago.
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Dec 4, 2018· Comment from Alliance of Automobile Manufacturers· DOT-OST-2018-0149-0081
Abstract
Preparing for the future of Transportation: Automated Vehicles 3.0 (AV 3.0) [ISBN 978-0-16-094944-9]
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