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NHTSA seeking public comment on automated driving system safety principles

The US Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) is seeking public comment on the potential development of a framework of principles to govern the safe behavior of automated driving systems (ADS) in the future. The advance notice of proposed rulemaking (ANPRM) was submitted to the Federal Register on 19 November.

NHTSA defines an ADS as the hardware and software that are, collectively, capable of performing the entire dynamic driving task on a sustained basis, regardless of whether it is limited to a specific operational design domain (ODD).

ADS technologies are different from more conventional automotive equipment, and it is necessary and appropriate to consider how ADS standards can and should be articulated. The framework of principles would objectively define, assess, and manage the safety of ADS, while ensuring the flexibility to enable further innovation. NHTSA seeks feedback on the approaches described in the ANPRM.

—NHTSA Deputy Administrator James Owens

While no ADS-equipped vehicle is available for sale to the public today and widescale deployment of ADS-equipped vehicles is likely years away, NHTSA and others have identified elements of a framework necessary for objectively defining and assessing ADS competence.

This ANPRM seeks public comment on these elements and how they could most appropriately form a framework that provides for motor vehicle safety while also providing flexibility to develop more effective safety innovations.

The development of an FMVSS [Federal Motor Vehicle Safety Standard] typically requires significant engineering research, the development of an objective metric (i.e., knowing what aspect or aspects of performance to measure), and the establishment of an appropriate standard based upon that metric (i.e., specifying the minimum required level of performance). Premature establishment of an FMVSS without the appropriate knowledge base could result in unintended consequences. For example, a premature standard might focus on the wrong metric, potentially placing constraints on the wrong performance factors, while missing other critical safety factors. Such a standard could inadvertently provide an unreliable sense of security, potentially lead to negative safety results, or potentially hinder the development of new ADS technology.

Although the establishment of an FMVSS for ADS may be premature, it is appropriate to begin to consider how NHTSA may properly use its regulatory authority to encourage a focus on safety as ADS technology continues to develop. This Notice, thus, marks a significant departure from the regulatory notices NHTSA has previously issued on ADS because NHTSA is looking beyond the existing FMVSS and their application to novel vehicle designs and is considering the creation of a governmental safety framework specifically tailored to ADS.

… This Notice focuses on ways the Agency could approach the performance evaluation of ADS through a safety framework, containing a variety of approaches and mechanisms that, together, would allow NHTSA to identify and manage safety risks related to ADS in an appropriate manner. NHTSA anticipates focusing this framework on the functions of an ADS that are most critical for safe operation.

At this stage, NHTSA believes there are four primary functions of the ADS that should be the focus of the Agency’s attention. First, how the ADS receives information about its environment through sensors (“sensing”). Second, how the ADS detects and categorizes other road users (vehicles, motorcyclists, pedestrians, etc.), infrastructure (traffic signs, signals, etc.), and conditions (weather events, road construction, etc.) (“perception”). Third, how the ADS analyzes the situation, plans the route it will take on the way to its intended destination, and makes decisions on how to respond appropriately to the road users, infrastructure, and conditions detected and categorized (“planning”). Fourth, how the ADS executes the driving functions necessary to carry out that plan (“control”) through interaction with other parts of the vehicle. While other elements of ADS safety are discussed throughout this Notice, these four primary functions serve as the core elements NHTSA is considering.

—ANPRM

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