National Society of Professional Engineers - #1 Comment in Response to NHTSA's ANPRM

 

For a recap from my last post - While comments submitted in response to an advance notice of proposed rulemaking (ANPRM) are public, they do not tend to receive much media coverage. Because the current  NHTSA ANPRM about autonomous vehicles (AVs) is important, I will be summarizing the comments one-by-one in this blog.

Comment of National Society of Professional Engineers:

Let's place ourselves where NSPE has stood on AV issues. NPSE has been troubled by AV legislation in Congress over the past few years. 

This legislation would allow automakers to deploy autonomous vehicles without first properly addressing the major safety, technological, and ethical implications. NSPE is working to ensure that these issues, particularly the need for independent certifications, recognition of the limits of the current technologies, and the ethical considerations in deploying such vehicles, are incorporated into legislation and regulations and considered as part of the next federal review of the guidelines.

What the submitted comment does and does not do

In response to the current ANPRM, NSPE is not calling for development or use of particular technology. We are not talking about LIDAR versus cameras or a combination thereof. Rather NPSE is advocating for ensuring AV safety through diligent implementation of a thorough and ethical process. NPSE's comment directs the reader to its recommendation of uniform AV testing and development procedures and standards that address risk assessment, standards development and implementation, transparency, accountability, and third party verification. 

My translation: If one considers how Tesla has proceeded with its automation software, NPSE seems to be recommending the opposite.

One piece of wisdom: According to one of my close family engineers (and there's a bunch), who works in aerospace, when you study the history of crashes and explosions it is always the same story - a decision to not heed warnings gleaned from routine following of procedures designed to ensure safe operations. 

What NHTSA is requesting - and will the agency receive that?

The ANPRM that NHTSA released is a detailed request for comments, which specifically lists 25 questions. NPSE did not provide a similarly detailed response, but chose to respond with comments about a framework - or really a philosophy - for a solid regulatory process and continued assessment of data as AV technology develops.

Deadline for submitting comments: Feb. 1, 2021