Is the NHTSA Model Right for AV Regulation?

Remember:
I am not an engineer or a computer scientist; nor am I a planner. I am a lawyer by education and, worse, I was trained as a criminal defense appellate attorney, which means I was taught to be skeptical and wary of large institutions that believe the public should trust them.

When leaders and attendees at this week's NHTSA autonomous vehicle (AV) gathering referred endlessly to various federal motor vehicle safety standards (FMVSS) that proscribe equipment rather than performance, my brain did not process well the nerdy details. Plus, we are talking about a world of professionals mostly from automobiles, SUVs, and light trucks, with a smattering of trucking people.

We had a very small group, or so it seemed, representing other modes and transportation-challenged populations. I am grateful that this was an articulate and outspoken bunch.

Themes of my non-auto-oriented brain takeaways

Do we need FMVSS or better to require performance standards? Maybe concentrate on driving and other tests that are technology neutral. I would have to go to NHTSA's authorizing legislation for that.

Note to regulators: We can NOT assume at least one able-bodied occupant will be present in every AV whenever it is in operation. The AV might be picking up groceries, the kids, or anyone from a parking space or even moving across town without any passengers.

We should NOT assume that there will be any occupants! This thought kept repeating in my brain.

Another constant thought: OMG these FMVSS NHTSA people are so car oriented. To them transit examples - like Detroit driverless People Mover - is out of the box thinking. Thank you to the person from Michigan whose name I did not catch. He kept raising the point that transit already has examples - decades old in some instances - of driverless vehicles and "unconventional" seating design. He wisely said a few times, essentially, that we do not need to reinvent the wheel, as it were.

Good thing that people with disabilities and people of different sizes and abilities were acknowledged.

Good thinking about people with luggage. No mention of strollers at this event. We need more women in AV planning.

How to handle unbelted side facing occupants. Has anyone heard of transit? This happens every day for thousands of people.

Just a bit cranky here. These engineers from the auto and trucking industries mean well and really they, more than me, represent an America where an overwhelming percentage of people do not walk, bike, or take transit to their destinations.