Panda videos and lots of AV comment opportunities, reports, events

All those months when nothing came from the Federal Register about autonomous vehicles (AVs) are in the rear view mirror and a few weeks ago the outgoing US Department of Transportation (USDOT) leadership released a flurry of documents - and thereby opened comment periods - charting a course for a road to accessible AVs. 

My small brain has been having a hard time keeping this all straight, so I am making the virtual effort of straightening out the piles, the dates, and the entities involved. To keep sane and smiling, enjoy the three panda cub videos sprinkled among the AV info.

Best in-a-nutshell AV resource 

Before we get to all that good stuff that has popped up in the Federal Register, here is a big treat: Eric Dennis of the Center for Automotive Research has just updated his excellent table of AV state laws. Warning - Not all of the laws within each category are the same, so this is not a deep dive, but it is a fabulous snapshot and an excellent resource. Also note that sources of regulations for a given state might be a law or an executive order of a governor. Dennis also maintains maps of state laws. Follow him on Twitter @EricPaulDennis for notices of his updates.

A database of state AV legislation and laws is available from the National Conference of State Legislatures. Dennis also maintains his own resource.

You didn't have to - lots of AV comment opportunities

Really, Elaine (Chao), you did not have to feel the need to leave so many parting gifts and all with open comment periods. I am sure this work will be helpful to USDOT staff, and I mean that sincerely, but it is also a gift to all of us who care about expanding transportation access and equity because the Chao USDOT made clear where exactly we are and how much we can expect if we do not alter the current public-private transportation divide. Of course, the staff who will be tasked with reading, interpreting, classifying, and preparing a document in response to each document might not be so happy.

• Framework for Automated Driving System Safety - The National Highway Transportation Safety Administration (NHTSA) seeks comments about various aspects of AV safety, testing, and standards development in terms of NHTSA's role. There are over 20 specific questions posed. The comment deadline has been extended to Apr. 1, 2021. This is an Advance Notice of Proposed Rule Making (ANPRM). I have several posts about comments submitted, though, as of today the number is well north of 613 and I am just at the beginning of reading all of those. 😟  Now well over 500 behind. 🤔 Maybe time to clone myself.
• Request for Information: Inclusive Design Reference Hub - The Office of the Secretary (OST) at the USDOT issued this request for information (RFI), which seeks ideas for collating inclusive design research with the goal to "establish a library of resources for accessibility in automation, and work with outside experts to study voluntary best practices for ensuring accessibility in automated vehicles." An RFI is not a commitment; it's a much less formal counterpart to a request for proposals. The comment period ends Feb. 19, 2021. The original comment period, which ended on Jan. 20, 2021, was officially extended. Thus far, there are seven comments and these are summarized in previous posts.*
• Draft Strategic Plan on Accessible Transportation - The USDOT is seeking comments on its draft plan, which aims toward "mak[ing] America's transportation system accessible to all travelers." That is a tall order and I am just beginning to read this document. (Nothing thus far about requirements or legislation that mandate production of accessible vehicles.) Comments are due on or before Feb. 16, 2021. Six comments submitted so far.
• See safety and cybersecurity section below for one more open comment period.

* Please note that as of the publication date that the USDOT website is not making available an OST page.

Events

Inclusive Design of Autonomous Vehicles - Mar. 10 - Apr. 21, 2021, every two weeks. Hosted by the US Access Board.

A four-part series of public forums to discuss different aspects of accessibility and the transportation needs posed by particular groups of disabilities. Links to the forum are not posted yet.

African American Conference on Disabilities - Sessions throughout February 2021. Hosted by the  Arizona Center for Disability Law and the Arizona Center for African American Resources.

This is an event with speakers from across the US. There are no transportation panels; the conference focuses on housing, accommodations, education and the effects of the pandemic. 

Plea to AV report writers: Take a vacation

To make it worse, on top of trying to keep abreast of AV work at the USDOT, I am also trying to keep track of and read all of the excellent AV reports that have been issued recently. There's a list below. I have to admit a certain personal conundrum of figuring out what exactly I want to read and focus on these days. I am supposed to be starting a podcast and a book, but, instead, I am treading through virtual piles of AV reading just to remain up to date. 🏊  (That's a swimmer emoji, in case it's not obvious. No frantic, treading water emojis were available.)

• Inspiring Autonomy: How Auto Insurers Will Lead Through Changing Risks - This is an updated 2018 report from Travelers Insurance about AV developments, how the auto insurance industry should continue as AVs roll out, and the best strategy for quickly compensating crash victims. 
• Autonomous Vehicles and the Future of Auto Insurance - This is a report from RAND Corporation, which has done excellent research and reports on AVs. It explores different AV ownership and insurance regulation possibilities, with recommendations to investigate international models and public-private collaboration.
• Low-Speed Automated Vehicles (LSAVs) in Public Transportation - This report is from the Transit Cooperative Research Program (TCRP) (within the Transportation Research Board (TRB)). It provides an overview of slow-speed AV shuttles, where they have been used, and factors that contribute to success. This is a practical report, with checklists for procurement, evaluation, and monitoring, among others. There are also a few detailed case studies provided.
• Automated Vehicle and Shared Mobility Forum (AVSM Forum) - This TRB website hosts a library of brief reports of research summaries and discussion workshops with invited speakers and forum members, an A-list of AV and shared-use mobility thinkers (with professionals from state, local, and federal agencies, the private and non-profit sectors, and academia). The issues covered are wide ranging, but often in the form of articulating research needs and concerns around data, equity, and accessibility, among others. 

Goodies for safety and cybersecurity experts

• Cybersecurity Best Practices for the Safety of Modern Vehicles - This is NHTSA's draft update of its 2016 (Obama administration) cybersecurity document. Comments are due on or before Mar. 15, 2021.
• Notice Regarding the Applicability of NHTSA FMVSS Test Procedures to Certifying Manufacturers - The comment period is closed. This document essentially reverses (using judicial terminology) the 2016 statement of the Obama-era USDOT that required AV compliance with the NHTSA-issued federal motor vehicle safety standards (FMVSS). This document basically declares that FMVSS are not themselves performance standards. I am not a safety engineer, so I will offer a quote here. "While the manufacturer of a motor vehicle must produce vehicles that comply with all applicable FMVSS and must exercise reasonable care in certifying compliance, the Safety Act does not require that a manufacturer ensure that NHTSA can validate the manufacturer's certification through the FMVSS test conditions and procedures when it certifies the vehicle." This document has nothing directly to do with accessibility. There were 12 comments submitted and it will be interesting to read these as major organizations and businesses are among those who responded to the notice.
• Safe Enough: Approaches to Assessing Acceptable Safety for Automated Vehicles - This RAND report is a dive into different ways to measure safety. 

For more panda time, visit the Giant Panda Cam. 

Request to Congress: Please concentrate on other topics until I am up to date, maybe in four months, before you all circle back to AVs. Thank you. 

Since I am not on the top of anyone's list for that magical vaccine, I can stay home and read official documents and comments.

#2 Comments in Response to USDOT OST RFI

Acronyms for today

Americans with Disabilities Act - ADA

Office of the Secretary - OST, located at the USDOT (see acronym in this list)

Request for Information - RFI

US Department of Transportation - USDOT

Which comment opportunity are we talking about?

This comment opportunity should not be confused with the embarrassment of riches of other open comment periods concerning documents related to AVs and/or accessibility. I am covering those as well. I keep getting the image in my head of very busy, almost frenzied workdays at USDOT in the weeks preceding the change in presidential administrations. 

In the next few days I will post a current list of the AV-related requests for comments and recent AV resources. Right now, I need to look at the sweet, formerly-outdoor cat sleeping next to me. He is one cute officemate.

Information hub that addresses broad range of different disabilities.  

In this next set of comments submitted in response to the late release (in the tenure of Secretary of Transportation Elaine Chao) from the USDOT OST, of an RFI for an Inclusive Design Reference Hub, we continue to see comments that emphasize the diversity of disability challenges by type of disability and accessibility accommodation.

The comment period open for another 24 days, or until about Feb. 18, 2021. Please do your own counting because my calculation could be slightly off.

1. Comment of Jenny Anonymous: This commenter self identifies as an ADA coordinator and the comment speaks briefly, but wisely, about ensuring that accessibility for all types of disabilities, be they physical, sensory, or cognitive, are included under the accessibility umbrella. This person points out the lack of accessible infrastructure (such as curb cuts and sidewalks) that impede travel for many persons with disabilities. The comment also calls for more accessible shared-use vehicles, which is especially limited for those who are unable to transfer out of their wheelchairs into a seat.

[I]t makes sense that auto manufacturers would have to have a certain percentage of their line designed with ramps, which can be deployed when the vehicle arrives at the destination. That way, individuals with mobility disabilities wouldn't need to worry about whether there is an access ramp where they are going.

2. Comment of Brad Dicianno - This commenter is, if a Google search has landed on the correct person, a doctor of rehabilitative medicine at the University of Pittsburgh School of Medicine. He requests that the information hub be established and maintained with an inclusive notion of what the person with a disability deals with when traveling. He envisions an information hub with materials about the "entire trip experience to include planning, communication, vehicle design, system design, standards, and ideally data. The Hub should include peer-reviewed publications, industry reports, government reports, technical standards, conceptual models/designs, and forums for stakeholders." This comment also advocates for high standards in terms of hosting, managing, and disseminating the information, "a place for stakeholders to provide feedback.," "[s]patial and geographic mapping, and "using natural language processing" as a possible "component to analyze consumer feedback."

3. Comment of Anonymous (submitted Jan. 13, 2021) - This commenter is pleased that information will be collected about the many variables involved with providing accessible AV transportation and the comment argues in favor of frequent updating once the hub has been created. Like a few other comments, this one calls for a classification system to organize the information. The comment also suggests that further research be conducted related to different disabilities.

4. Comment of John Kazanchy - This commenter, if that Google machine is correct, is a consultant who provides services related to wheelchair accessible vehicles. The comment argues that individuals with real-world experience providing transportation to people with disabilities should be included somehow in the research and that not all research be university based. 

Some simple examples are as follows:
1. Is there anybody on the chosen teams that has had to go and rescue a stranded physically disabled person in the snow at 1 am when their equipment failed?
2. Is there anyone who has installed and modified vehicle for the disabled that is aware of the complexities that are involved.
3. Has anyone had to investigate the charred remains of a disabled consumer that died while their vehicle burned?
4. Has anyone had hands on interaction with training disabled users on the proper usage of adaptive equipment in vehicles and understands the challenges?

The comment proceeds to discuss briefly the complexities, dangers, and profit motives involved in retrofitting vehicles so that they become accessible.

I am up to date on these comments, for the moment, but far behind on others. 

Jan. 26 List of Comments in Response to NHTSA ANPRM I Have Yet to Read

This post is only a list of names of people who have submitted comments to the Advance Notice of Proposed Rule Making (ANPRM) from the National Highway Transportation Safety Administration (NHTSA) to the Framework for Automated Driving System Safety whose comments I have not covered yet. It is a long list and not the only autonomous vehicle (AV) comments I am covering. Rome wasn't built in a day and it will take a good while before I read and digest all of these. 

The end of the USDOT Secretary Elaine Chao's tenure was marked by the release of lots of AV-related documents and then there's other AV legal discussions ongoing as well. Lots of activity on the issue of AV accessibility that I want to delve into.

Please be aware that although mostly individual names are listed, some of these people might have submitted comments on behalf of a company or an organization. This list is through mid-day of Jan. 26, 2021. Only well over 100 comments to read and that doesn't count the rush of comments yet to be submitted in this last week of the comment period.

The comment period ends in six days. 

1. Aerospace Engineer anonymous
2. Humanetics
3. David DeVeau
4. Car ReFormat comment from Ralph Panhuyzen - listed as a document rather than a comment
5. Gary Schifmiller
6. Alan Kailer
7. Anna Walters
8. James Hooper
9. Dave Simmons
10. Richard Millsap
11. Allison Burson
12. Lance Jacobs
13. Michael Kelley
14. Champe Burnley (Two comments, both posted Jan. 21, 2021)
15. Rob Eckmann
16. Mark Dehanke
17. Jay Ellis
18. Robert Nelson
19. Steve Betts
20. Ira Josephs
21. Sean Hunt
22. Stephen Minster
23. Gina Simpson
24. Kristin Firth
25. Erica Stanojevic
26. Kira Gillette
27. David Kaufmann
28. Fred Story
29. Michael Colucci
30. A-D Riley
31. Alexander Van Duyne
32. Shawn Aldridge
33. Larry Riley
34. Jack Rinaldo
35. Daniel Frey
36. Heidi Perry
37. Frank Blake
38. Ian Frederick-Rothwell
39. Lawrence Anson
40. Steven Gliva
41. Mary Karimi
42. Anna Karimi
43. James Dickson
44. Wendy Foley
45. Aaron Buckley
46. Zeke Smith
47. Wendy Byrne
48. Vince Mendieta
49. Sharon Piekarski
50. Roger McVeigh
51. Thomas Polk
52. Carol Ireland
53. David Gurney
54. James Linderholm
55. Sylvia Star-Lack
56. Wallace West
57. Lisa Hart
58. Robert McBride
59. Tobias Boyd
60. Sara Schroedl
61. Katherine Curtis
62. Tracy McIntosh
63. Thomas Sinacore
64. Kristopher Griffen
65. Sean Long
66. Sarah Clark
67. Jed Lane
68. Lynette O
69. Don Burrier
70. Paul Tucci
71. Michael Duclos 
72. Tim Blagden
73. Joshua Griset
74. Charlotte Black
75. Harold Mann
76. Steven Goodridge
77. Hector Chang
78. Dusty Szarell
79. Robert Havrilla
80. Jacki Bick
81. Steven Shladover
82. Walt Brown
83. David Phillips
84. Eric Schonenberg
85. RC Grimsley
86. Nicholas Paladino
87. David Cardarella
88. Claudia Nix
89. Diane Schultz
90. George Hamilton (probably not the actor)
91. Christopher Quint
92. Kristina Keogh
93. Thomas Spellman
94. John Neller
95. Catina Passmore
96. Stephan Vance
97. Tina Brenza
98. James Castellan
99. Doogie Roux
100. Matt Braun
101. Robert Burkhardt
102. John Hall
103. Richard Holbrook
104. Deborah Rhodes
105. Thomas Wald
106. Steven Ruder
107. Anonymous Anonymous (Yes, that's how it's listed and I don't know whether that is for emphasis)
108. Mark Magree
109. Ben Ferris
110. T. Roman
111. Ty Weatherby
112. Nancy Cousins
113. Chris Crecelius
114. Ben Payment
115. Ben Oberjohn
116. Glen Worrell
117. George Mason
118. Tom Alexander
119. Ron Hirsch
120. Maria Rosales
121. Jay Whipple
122. Stefan Cameron
123. Lizabeth Bourret

#8 Comments in Response to NHTSA ANPRM - Two Organizations Offer Well-Informed Perspectives

 Reader beware: It's a long post, so skip whatever. 

Acronyms for today

ADS - Automated Driver System (sometimes referred to as ADAS for Advanced Driver Assistance System), which requires a human driver to monitor and at points take over operation of the vehicle

ANPRM - Advanced Notice of Proposed Rule Making

AV - Autonomous Vehicle

GAO - Government Accountability Office

GAO is a legislative branch government agency that provides auditing, evaluation, and investigative services for the United States Congress. It is the supreme audit institution of the federal government of the United States.

NCAP - New Car Assessment Program

NCSL - National Conference of State Legislatures

NHTSA - National Highway Transportation Safety Administration (an agency within the US Department of Transportation)

NTSB - National Transportation Safety Board

SUV - Sport Utility Vehicle

USDOT - US Department of Transportation

Comments tally

Disclaimer/Explanation: Please note that anonymous comments and ones where the author's background is undeclared or not easily discovered are counted as "regular people" unless it becomes apparent that the commenter has professional expertise, which then shifts the comment into that category. Also note that the comments tally includes those comments summarized below in this blog post. All categorizations are my own and might seem random or wrong to someone else.  I am not an engineer, an automotive geek, or a software expert.

Comments are due by Feb. 1, 2021. 

Total comments to the Framework for Automated Driving System Safety (Framework) Advance Notice of Proposed Rule Making (ANPRM) issued by NHTSA that I have studied - 18 

Total comments as of Jan. 22, 2021 - 155  - Many comments have flowed in since Jan. 19 and those I have not yet mentioned in my summaries are listed below.  More than 20 were submitted on Jan. 22 alone and almost 100 thus far today. 😲

Anonymous - 2

Companies or Organizations - 6

Individuals with professional expertise - 6

Cybersecurity -2  

Regular people - 4 

Regular people who want increased safety - 3

Regular people who do not believe AVs will be safer than human drivers - 1

Regular people who do not want regulation to constrain innovation - 1

Spam comments - 1

Instructions for submitting comments can be found in the ANPRM.

Please note that these comments are not necessarily representative of the opinions of the US population; rather they come from corporate or non-profit entities or professionals with an interest in AVs, or people with the time, energy, and space in their lives attend public meetings - in this case to devote attention to Federal Register notices. The regulation-making process is, if not hidden, then placed out of the way in the bowels of federal agencies, and is oft forgotten when we vote or choose where we participate in our democracy.  

Two organizations, two perspectives

In this post, I am looking closely at the comments of the American League of Bicyclists (the League) and the National Conference of State Legislatures (NCSL), both organizations that do a lot of informed work in transportation generally and related to autonomous vehicles (AVs).  Whereas the League challenges us, or NHTSA specifically, to reimagine US roads as serving people, however they travel, using various modes of transportation, NCSL proclaims that there is no reason to rethink the ancient  - or since 1966 - balance of power between states and the federal government over regulation of vehicle safety. In contrast to studies of transportation it has done with respect to other modes, here NCSL conceives of AVs as simply replacing the human-driven vehicles we now utilize and declares that we should protect the separation of state versus federal responsibilities in perpetuity.

Complete and equitable streets: Safety for those outside of the vehicle

The comment of the League of American Bicyclists focuses on the safety of all of those who use our road space, not only people inside vehicles. The League did not begin with spandex clad weekend cyclists or commuter bikers who seek separated bike lanes; it actually dates back to 1880 when biking became an American craze. Though founded as a male-dominated organization to promote and build safe roads for a new sport, the League prominently pays homage to women, whose fashions and social independence in the early twentieth century were greatly influenced by biking as a transportation mode. (There are lots of interesting materials to read and podcasts to listen to on this subject.) 

Responding to the specific questions in the NHTSA ANPRM, the League declares that we expand our view of vehicle safety and of the roadway itself.

[T]he League believes that the framework should include: 

• A process that is inclusive of people biking and walking, people with disabilities, people from Black and Brown communities, people young and old; and 

• Engineering measures that include public testing of ADS for efficacy in sensing people of all races and ethnicities and modes of transportation, perceiving people of all types outside of vehicles, and planning to avoid and mitigate harm to people of all types outside of vehicles.

The League's comment points to the numbers, in particular the rising numbers of pedestrians and bikers killed and the increase in their share of road fatalities in contrast to the decrease in fatalities of those who ride inside vehicles. "NHTSA must act to stop that trend and ensure that ADS do not lead to further suppression and danger of active travel, which is critical to public health, environmental goals, and economic sustainability." (ADS is Automated Driving System). In this way, the League's comment ties safety engineering to broad social goals instead of the status quo prism of vehicle occupant safety and a presumption of travel in automobiles.

What is federal regulation for?

This is a comprehensive comment in terms of policy and the only comment, thus far, to mention roadway users outside of vehicles, broader societal goals, and the importance of research of design and technology on roadway interaction with people walking and biking. It is also the only comment at this point that has called upon NHTSA to consider particular transportation-challenged populations. Though the comment does not explicitly condemn the auto industry's production of and marketing mania to sell larger and larger SUVs and light trucks, the League is clearly apoplectic (in a rational, written way) about NHTSA's neglect of the deaths and injuries that these vehicles have wrought and continue to pose on US streets and highways. 

Specific recommendations

• Vision test for AVs "to ensure that ADS are safe for people biking and walking of all sizes, shapes, races, and ethnicities." In the details provided of what a vision test should encompass, the League emphasizes its theme that all types of people be seen. The vision test, in my opinion, is a good example of a performance standard that does not restrict the type of technology developed and implemented.
• Regulation to prevent further technological development that increases risks or limiting the mobility of people biking and walking due to implementation of ADS. The League highlights the "GAO report, “NHTSA Needs to Decide Whether to IncludePedestrian Safety Tests in Its New Car Assessment Program” [(NCAP) which] shows the effects of postponing and avoiding regulation that can save the lives of people biking and walking through NHTSA’s inaction on NCAP and crashworthiness standards." 
• Either comparative tests or performance standards are acceptable, but not testing or standards that ignore pedestrian and biker safety.
• Additional research should include safe walking and biking. "NHTSA should support research on the interaction of roadway designs and ADS so that Federal, state, and local governments can ensure they are building roadways that support the safe mobility of people biking, walking, and using ADS-equipped vehicles." The League also argues in favor of research on "human-machine interaction and what best builds confidence and understanding for people biking and walking interacting with ADS-equipped vehicles." 
• "[I]mmediate action to modernize the New Car Assessment Program (NCAP) to include tests for the safety of people biking and walking. NHTSA should consider testing that is similar to the testing conducted by EuroNCAP for vulnerable road users, including testing of automated emergency braking systems for their efficacy in responding to people biking and walking in multiple contexts. NHTSA should also consider additional testing to account for vulnerable road users of different sizes, shapes, races, and ethnicities to understand the efficacy of systems given the diverse populations of the United States." 

The briefest way to describe the League's comments is that this organization is seeking to reframe the vehicle safety conversation to equally prioritize the safety of pedestrians and bikers, and not merely to relegate them as afterthoughts in a process geared toward vehicle passenger safety. Read about the NTSB's recommendations to include pedestrians and bikers in NCAP, which are referred to in the League's comment. 

The League takes to heart the famous Robert F. Kennedy quote: “Some men see things as they are, and ask why. I dream of things that never were, and ask why not.” (Yes, it's a slightly changed quote from George Bernard Shaw, but more poetic.) Kennedy, a Senator from New York and the former Attorney General and brother of President Kennedy, often used the quote at campaign events and his younger brother, Sen. Edward Kennedy, included it in his eulogy. (Bobby Kennedy was the most inspirational candidate of my lifetime, but I was a very little girl who was absorbing the excitement in my Brooklyn household.)

Photo of Robert Kennedy campaigning for president 
in 1968 from Getty Images, posted on Daily Kos
(Mar. 3, 2020).

Why change at all?

NCSL takes a different attitude. As a bipartisan organization that supports state legislatures across the country, NCSL is arguably not in a position to make waves. It has a braintrust of knowledge about issues that state governments regulate, such as ones at issue with road safety: driver's licenses, automobile insurance, speed limits, and vehicle codes. It also maintains a fabulous AV library of state legislative activity, legislation, executive orders, and regulations. 

The federal government, on the other hand, by a 1966 statute, regulates vehicle safety standards and, via federal funding, sometimes "encourages" particular speed limits. 

NCSL's comment, in keeping with its institutional position to respect the expertise of state legislatures, seemingly seeks to protect this over-50-year tradition of split of authority. Using the word "encroach," NCSL warns against alteration to the federal/state balance, and especially against expansion of federal authority. "This federal authority related to the safety aspects of the design, construction, and performance of a motor vehicle does not include compliance with the traffic laws, rules of the road, or the operation of motor vehicles of a state or political subdivision of a state."

Though NCSL has a point and there has been an ongoing dialectic going back to the drafting of the US Constitution about the proper federal state balance of powers, there is nothing inherently sacrosanct about a town, a city, a county, a state, or a nation being the appropriate decision maker about how difficult to make a driving license test, the enforcement of speed limits, or the speed limit itself.

Constitutional law lesson

From Inauguration Day 2021 celebration, 
participants socially-distanced and masked.

In terms of the US Constitution, NCSL and state governments have the power of persuasion, but not a leg to stand on because the Commerce Clause in Article 1, Section 8, generally interpreted broadly by the US Supreme Court, grants Congress the authority to regulate interstate commerce. Certainly, the importance of transportation and road safety to commerce is a pretty easy reach. 

This does not mean that Congress will extend its reach beyond the balance set in current law, but it could. Likewise, NHTSA has broad jurisdiction over vehicle safety that it arguably has never fully exercised.

What NCSL has, in my opinion, is the power of the status quo - and that status quo is the familiar separation of authority discussed above. The question that remains, most likely for Congress, is whether that balance will be retained when the driver and the vehicle become one.

Posted comments not yet covered - list as of Jan. 22, 2021

This list takes us to 62 comments and a peak a moment ago shows we are now at 155 comments.

1. Aerospace Engineer anonymous
2. Humanetics
3. David DeVeau
4. Car ReFormat comment from Ralph Panhuyzen - listed as a document rather than a comment
5. Gary Schifmiller
6. Alan Kailer
7. Anna Walters
8. James Hooper
9. Dave Simmons
10. Richard Millsap
11. Allison Burson
12. Lance Jacobs
13. Michael Kelley
14. Champe Burnley (Two comments, both posted Jan. 21, 2021)
15. Rob Eckmann
16. Mark Dehanke
17. Jay Ellis
18. Robert Nelson
19. Steve Betts
20. Ira Josephs
21. Sean Hunt
22. Stephen Minster
23. Gina Simpson
24. Kristin Firth
25. Erica Stanojevic
26. Kira Gillette
27. David Kaufmann
28. Fred Story
29. Michael Colucci
30. A-D Riley
31. Alexander Van Duyne
32. Shawn Aldridge
33. Anna Karimi
34. Larry Riley
35. Jack Rinaldo
36. Daniel Frey
37. Heidi Perry
38. Frank Blake
39. Ian Frederick-Rothwell
40. Lawrence Anson

The math does not quite add up because I have examined 18 comments and this list offers 42 more (because there is one person who posted two comments), whereas the regulations.gov page gives the number at 62. 16 + 42 ≠ 62, 16 + 42 = 60. No guess whether I have missed a few. I will keep going over the posted list, which is necessary because the commenters are not listed in order of date of submission or in alphabetical order. Annoying.

Again, there's a whole bunch, taking the current number of 155, that I have not looked at, nor even skimmed the now much-expanded list.

#7 Comments in Response to NHTSA ANPRM

Comments tally

Disclaimer/Explanation: Please note that anonymous comments and ones where the author's background is undeclared or not easily discovered are counted as "regular people" unless it becomes apparent that the commenter has professional expertise, which then shifts the comment into that category. Also note that the comments tally includes those comments summarized below in this blog post. All categorizations are my own and might seem random or wrong to someone else.  I am not an engineer, an automotive geek, or a software expert.

Comments are due by Feb. 1, 2021. 

The following is a tally as of Jan. 14, 2020: Total comments to the Framework for Automated Driving System Safety Advance Notice of Proposed Rule Making (ANPRM) issued by NHTSA - 16 

Note: Many comments have flowed in since Jan. 19 and those are listed below. I have not yet read or classified them.

Anonymous - 2

Companies or Organizations - 4

Safety standards or framework - 2 

Training for human in-vehicle or remote operators - 1 

Individuals with professional expertise - 6

Safety - 5

Cybersecurity -2  

Regular people - 4 

Regular people who want increased safety - 3

Regular people who do not believe AVs will be safer than human drivers - 1

Regular people who do not want regulation to constrain innovation - 1

Spam comments - 1

Instructions for submitting comments can be found in the ANPRM.

Please note that these comments are not necessarily representative of the opinions of the US population; rather they come from corporate or non-profit entities or professionals with an interest in AVs, or people with the time, energy, and space in their lives attend public meetings - in this case to devote attention to Federal Register notices. The regulation-making process is, if not hidden, then placed out of the way in the bowels of federal agencies, and is oft forgotten when we vote or choose where we participate in our democracy.  

I need an extension!

Comment of the Consumer Technology Association (CTA), submitted by Michael Petricone, Senior Vice President, Government Affairs: 

The comment is listed under Mr. Petricone's name in the comment list. According to its polished website, CTA is the "trade association representing the $422 billion U.S. consumer technology industry, which supports more than 18 million U.S. jobs." Its members include Adobe, 3D printing companies, battery companies, helicopter companies, Blackberry, Boingo - and I am only up to the Bs. Some AV companies that are members are Cruise, Lyft, Beep, Mobileye, Ford, Toyota, Aurora and Velodyne, as examples. Not Waymo, Tesla, Easy Mile, or May Mobility. CTA is also a standards organization across many fields. In terms of the many areas of expertise among its members, it includes accessibility and sustainability. advocacy, In its advocacy on Capitol Hill and in state capitols, CTA is generally pro-innovation and anti-regulation. This is the association that puts on a major technology conference every year, CES (Consumer Electronics Show).

CTA's comment is merely a request to extend the response time for 30 days. CTA only mentions the importance of the topic to CTA's members and the significance that a NHTSA framework would mean to the AV industry. No specific reason for the 30-day extension request is given.

We have classes available

Comment of Driving School Association of the Americas (DSAA):

Are you thinking what I'm thinking? It is not only human drivers who will lose their jobs when AVs come along, but also those in the industries surrounding driving, such as driving school owners and instructors. DSAA offers trainings and educational materials to its members - "driving school owners, including entrepreneurs, public and private school teachers, former examiners, transportation and safety experts."

The DSAA comment, however, does not concern itself with highly automated vehicles, or what I term AVs, but with driver assistance systems, such as the Tesla Auto-Pilot and, inappropriately named, the Tesla Self-Driving Package. DSAA declares that additional driver training and consumer education are necessary for the safe operation of vehicles with driver assistance systems, which partially automate many vehicles today. This is a good point and I will add to DSAA's comment by saying that airline pilots receive training that deals with the special dangers of partial automation, which can cause complacence and lack of appropriate monitoring by a human operator. But DSAA's comment only addresses driver training. "Given the nature of this evolving technology, appropriate regulation will be necessary to ensure the manufacturers produce and provide these necessary training components along with additional consumer training by professional traffic safety organizations, such as DSAA."

Coming Up  

Comments of: 

1. League of American Bicyclists
2. Aerospace Engineer anonymous
3. Humanetics
4. David DeVeau
5. Car ReFormat comment from Ralph Panhuyzen - listed as a document rather than a comment
6. National Conference of State Legislatures
7. Gary Schifmiller
8. Alan Kailer
9. Anna Walters
10. James Hooper
11. Dave Simmons
12. Richard Millsap
13. Allison Burson
14. Lance Jacobs
15. Michael Kelley
16. Champe Burnley
17. Rob Eckmann
18. Mark Dehanke
19. Jay Ellis
20. Robert Nelson
21. Steve Betts
22. Ira Josephs
23. Sean Hunt
24. Stephen Minster

Chao's Ciao - USDOT AV Plan More of a Summary

USDOT Secretary Elaine Chao gave the incoming Buttigieg USDOT team a parting gift with the release of the AV Comprehensive Plan, which is a summary of Chao's departmental AV work during the past four years. It's as if Chao wanted to organize the AV-related papers on her desk and file them nicely for her successor to spare him the extra work. Here is the link to the Federal Register notice; comments are due within 60 days. (As of publication time, the regulations.gov page for this docket was not yet posted.)

In Yiddish, this is called being a mensch, though Ms. Chao is neither Jewish nor a man. Mensch may literally mean a man or person, but it actually means someone with integrity who does the right thing. And I'll add that a mensch is very much not a maven, a word that is sometimes translated into English as an expert, but is used in Yiddish and English sprinkled with Yiddish as referring to someone who thinks they know more than everyone else about something, but likely doesn't or by a person who does, but whom others resent. Elaine Chao is very much more a mensch than a maven. She did her job, she didn't point attention to herself unless it was helpful, and, even when she was accused of wrongdoing, she continued focusing on her job. In the Donald years, this was something commendable and remarkable.

Elaine Chao never made herself the conversation.

From Mensch on a Bench at 
https://themenschonabench.com/the-mishpacha-mensch-101/.
The answer given is a person of integrity and honor.

Chao's says bye, bye to the transportation world

In a department that received relatively little attention during the Donald years due to its lack of craziness (in my opinion), Chao steered the course not only as a moderate Republican, one who would have been at home in a Romney Administration, for instance, but as someone who in many ways departed little even from the Obama Administration's course. Once it was clear that Obama was never going to make big inroads on livability and high speed rail, his AV work, in particular, was moderate, nee even prudent, one word say conservative with a small "c." There were efforts to steer funding toward progressive transportation and land use, but no big changes to the structure of transportation funding and policy of the last 40 years. Chao could be said to have kept that tradition despite serving in a radical Administration that sought to overturn established traditions, long-held policies, and democracy itself. 

True, my personal expectations were low, as I tend to favor pedestrians and transit riders over SOV drivers, but Chao surprised me with her prominent statements at every AV event she attended to include accessibility as a theme and declare the significant possibilities for people with disabilities and older adults. One would never call her "Miss Equity," as she did not talk about the full spectrum of transportation-vulnerable populations or the inherent inequities of the status quo, but she tempered her pro-business statements with both her accessibility statements and those from the heads of her modal agencies. Now for Chao, as with most of that lost tribe of moderate Republicans, encouraging innovation was wink-wink language for not increasing regulations. She headed AV efforts that allowed for voluntary puff pieces from companies, for example, but my expectations were of a Republican and I never awaited her rolling over in bed one morning (especially considering that she was sharing a pillow with the Senate Majority Leader) to become an embracer of separated bus and bike lanes, government-approved performance standards for AVs, scramble intersections, or elevator maintenance at rail stations.

Do you need to read this?

The AV Comprehensive Plan lists USDOT work on AVs, specifically the AV documents issued, the partnerships the forged, the research conducted, and the funding initiatives. The summary - I cannot call this a plan - includes mention of AV work of the Obama Administration as well. That was the right thing to do, above what was necessary. A mensch.

If the question is whether you should read the AV Comprehensive Plan, the answer is "yes" if you want to get up to speed quickly on the USDOT's AV work or you wish to provide comments; "no" if you already follow such developments closely, but you don't care to comment. The report is 38 pages and one can skim this easily. This is not a dense document.

The summary appears on regulations.gov, which notes that comments will be due on .

If a plan is defined as "a detailed proposal for doing or achieving something," then this document is not a plan. I don't know why misnaming the document irritates me, but it does. Just call it a comprehensive AV summary because there is no shame in such a title. Rant over; let's move on.

What we did, whom we spoke with ... yada, yada, yada

Yes, there was lots of talking during the past four years with key institutional players in transportation, both in industry and in public-sector-oriented associations. These tended to be players with access and lobbying. As I said earlier, we are not talking equity, if one defines that word as including the broad spectrum of transportation-vulnerable populations.  We're talking car and bus manufacturers, the tech industry as it relates to transportation, and state highway administrators.

Photo taken at Battleground National
Cemetery in Washington, DC. The text is 
the Gettysburg Address.

One should applaud the facilitation, summarized in the summary - not a plan - of AV testing, information sharing, and assessments. It covers, of course, the regulatory activity related to AVs, some coming at the very end of Chao's tenure, one would say when she already had one foot out the door. But unlike her late-Administration peers in history, Chao did not in any way put in screws or make life difficult for her successor with those activities. I would put it otherwise, that in terms of AVs she did her job in a way that will make life easier for the man about to take over her desk.

Where the summary is especially helpful is where it briefly lists and describes activity related to AV testing,  exemptions or waivers to FMVSS (federal vehicle safety standards), advance notices of proposed rule making (ANPRMs), research, funding for pilots, updating of traffic control device standards, and other efforts.

Nice redundant information classification  

What I like is the redundancy in this publication, which not only classifies and lists USDOT AV activities, but then lists AV operations by type - delivery vehicles, slow-speed shared-use and transit, partial automation for private cars, geofenced mobility-on-demand fleets, and AV trucking for freight - with their related USDOT efforts and accomplishments. 

The document goes on to list all of the public engagement activities surrounding AVs during the last four years, followed by its AV research work. 

Subtext: Upholding the status quo of modal balance

Photo from Battleground National
Cemetery.

While not prominently displaying a credo of the Chao years' AV efforts, there is mention that the role of the USDOT is to be technology neutral. What I see in this summary as well is that by not having an agenda to better balance the availability of modal choices, the balance of power in favor of private vehicles remained the same. I do not blame Elaine Chao for this; she was a Republican in a mainly suburban, exurban, and rural political party and in anti-urban Administration. (Pretty funny when you consider that Donald has never lived outside of NYC before he abandoned the city to call Florida home.) Indeed, she is to be applauded for not exclusively catering to those clutching their steering wheels. She quietly allowed multimodal conversations and efforts to move forward. 

Bon voyage to those who worked hard at the USDOT these last four years. I wish you well and I hope that you continue to participate in transportation conversations. We need many viewpoints, we need devil's advocates, and we need intelligent, civil conversations. 

Note on photos: During COVID, when brave men and women have lost their lives while serving their communities and our country in driving transit buses, providing medical care, and even working at grocery stores, I was greatly moved during a visit to Battleground National Cemetery on Georgia Avenue not far from Maryland in Washington, DC. Those young men buried in 1864 in one of the smallest military cemeteries died far from home and alone while fighting to save the Union. With death all around now, hearing about COVID deaths and suicides brought on with social isolation, I hope that we erect memorials to all of those who have and continue to perish during the cataclysmic events of 2020 and 2021, to those who put themselves on our front lines and who give their lives. 

Historical note

According to Wikipedia:

The Battle of Fort Stevens, which took place on July 11–12, 1864, marked the defeat of General Jubal Anderson Early's Confederate campaign to launch an offensive action against the national capital. During the battle, 59 soldiers were killed on the Union side. There were approximately 500 casualties on the Confederate side of the battle.

This was the only Civil War battle to take place in the District of Columbia and President Lincoln himself was present and in danger. The battlefield is now a park. 

#1 Comments in Response to OST RFI

Today's acronyms

ANPRM = Advance Notice of Proposed Rule Making

NHTSA = National Highway Transportation Safety Administration

OST =  Office of the Secretary at the US Department of Transportation

RFI = Request for Information

USDOT =  US Department of Transportation

Update: Still at 14 comments submitted in response to the NHTSA ANPRM. No additional comments have been added since New Year's. I will keep checking and reviewing those. 

RFI Comment Tally

Comments - 3

• Positive response to RFI - 3
• Responses from regular people - 1
• Responses from professionals - 2
• Suggested substantive changes to the RFI - 1
• Suggested organizational elements of Inclusive Design Hub - 1

Comments are due on or before Jan. 20, 2021. Comments to this RFI can be submitted and found at Regulations.gov.  Just as a reminder, the RFI comes from the OST at USDOT.

Now to the RFI Comments

Inclusive Design Reference Hub RFI

Comment #1 was submitted anonymously and, possibly, with the assistance of some type of software program or special equipment because almost every word is capitalized and most are followed by periods. The gist of this one comment, which barely eeks out to be four lines of text, is that we need updated standards or regulations for accessibility and inclusion that will result in a better transportation system. To read something that likely was written from the heart is a privilege and demonstrates why nothing-about-us-without-us is indeed a wise course. Perhaps this is one occasion where grammar rule adherence would get in the way of the message. "To. Better. Services. A. Disability Community. So. People. With. Disabilities. Can be. Involved. In. This. Layout. For. A. Better. Transportation. System." 

Comment #2 was submitted by Steve Yaffe, whom I know through professional transportation circles and whom I respect. Mr. Yaffe has decades of experience providing paratransit, he has participated in related TRB work, and he is currently a consultant. He also has an educated and inclusive perspective when it comes to issues of transit, mobility as a service (MaaS), and shared-use transportation. 

Mr. Yaffe makes four suggestions to improve the RFI:

1. Explicitly discuss the curb cut effect, a term used to mean the benefit of accessibility features for people without disabilities. Think of the thousands of people pulling luggage up a curb cut or ramp where that feature was put in place for the purpose of helping someone in a wheelchair. There are lots of examples, but, Mr. Yaffe states - and I would agree - that infrastructure or other features available to provide accessibility for people with usually also benefit people without disabilities. He points out that the private sector should discover and reap the benefits of the profitability from providing accessibility.
2. Include a question about whether small, shared AVs should have pull-down infant or child seats. Mr. Yaffe specifically mentions very small AVs with only a couple of seats.
3. Include a question about securing one's wheelchair (if one prefers and is able to switch into a provided seat) or luggage if one is unable to do so on one's own.
4. Include an inquiry into "the minimum length and width of a wheelchair-accessible flat-floor passenger compartment that allows the rider to be secured facing-forward." 

I like how Mr. Yaffe goes to those devils in the details because accessibility is not magic; it depends upon whether and what standards are established and then enforced. He does not comment on the library aspect of the RFI.

Comment #3 was submitted by Greg Vanderheiden. He is an engineer, university professor (now at University of Maryland, College Park), and a specialist in assistive technologies for communications and software accessibility. Please note that I am guessing that this is indeed the Greg Vanderheiden who submitted this comment because biographical and professional details have not been submitted in the comment. I also apologize to the professor if I have mischaracterized anything.

Prof. Vanderheiden makes some valuable, practical suggestions for the planned Inclusive Design Reference Hub in terms of how it should be organized and he welcomes the prospect of an AV accessibility knowledge library. The basic theme of this comment is advice for ensuring a good classification system. He also suggests tagging, and, specifically, tagging by date.

Prof. Vanderheiden "suggest[s] that the groups consider organizing the results into:"

>Highlighted Items (documents, standards, videos); 

>Summary Items (things the review or summarize many other documents or sources); 

>Full collection of items (a searchable general collection of everything that might be useful)

Editorial note: I really have to take more photos of our outdoor-turned-halfway-indoor cat. During COVID, he is a welcome distraction. But a panda playing in the snow is a good substitute. 

NJ AV Task Force Report - Maybe Gets a C+

One word to describe the New Jersey AV Task Force Report: Uninspired. Think Route 1 in New Jersey with congestion and strip malls. All of the disadvantages of dense, aging suburbia without any of the charms or convenience of a city. Disclaimer: I am a native New Yorker, but I have spent lots of time in pretty parts of the Garden State.

[Photo of Route 1 in Linden, NJ, from Most-dangerous N.J. roads for pedestrians list is topped by Route 130 in Burlington County, AP (updated Apr. 1, 2019)]

Most state-level autonomous vehicle (AV) study reports are pretty much the same and, therefore are a waste of the money spent on them. Like most, the New Jersey report is part AV primer, part summary of the current legal landscape, and part recommendations, some vague enough to drive an AV truck through. The report does not approach AVs from the perspective that this shift will be an opportunity to solve the transportation problems that plague the Garden State.

Unlike the following opinionated quote from a February 2020 press release by the Amalgamated Transit Union NJ State Council and the New Jersey Work Environment Council, the New Jersey AV report hesitates to offend anyone.

New Jersey suffers from dual problems associated with the same root cause: poor air quality and some of the worst traffic congestion and longest commutes in the country. The cause of this issue can be traced through a mess of policy and cultural phenomena – investments in car travel over public transit paired with America’s unique culture of individualism and self-reliance creates systemic inequity throughout our systems.

[O. Reilly and N. Langweiler, Transit Equity Day - New Jersey Must Create a Transportation System Accessible for All, NJ Insider (Feb., 4 2020).

Note: I will be using the term Department of Motor Vehicles (DMV), but in New Jersey it's called the MVC for Motor Vehicle Commission.

Caveat: What I am not paying much attention to that is discussed in the NJ report

• Freight 
• Delivery
• Enforcement of traffic law details (No one is going to say that traffic laws should not be enforced.)

NJ report - What I like

😎  Good summary of Congressional activity and controversial issues that have kept Congress from passing legislation.

😎  Good summary of state laws and executive orders.

😎  Decent summary of New Jersey regulations that refer to vehicle operators or drivers, which, presumably, would have to be changed at some point were AVs to circulate en masse in the Garden State.

😎  Recommendation for broad stakeholder engagement, but, my big caveat is below in "What I don't like."

😎  Concise explanation of insurance uncertainties and range of opinions as to how liability frameworks could operate.

😎  The New Jersey report spends much of its space repeating what the AAMVA (American Association of Motor Vehicle Administrators) recommends. AAMVA, by the way, has compiled and links to an impressive AV library, available for free on its website.

😎  The report expresses opinions about what is likely to happen when AVs arrive; it predicts for the suburbs greater sprawl, in contrast to its prediction for cities as shared-use smorgasbords. For New Jersey, a state that embraces suburbia, this is a serious concern. Traffic is already a problem in the Garden State.

😎  Summary of research about job loss and displacement that AVs may cause.

😎  Recognizing that how roadways and transportation modal choices play out with AVs will determine who is afforded a healthy and safe environment and who is not. Here the report actually expresses an opinion. 

AVs should be deployed in ways that will reduce transportation-related air emissions and promote healthy living environments for all populations. This implies the need for strong collaborative planning with historically environmentally burdened communities and the prioritization of future transportation investments and land use strategies that will promote active transportation modes such as walking and cycling, and eventually the deployment of zero-emission public transit vehicles. In the future, this may require establishing incentives toward adoption of electric vehicles and shared use of vehicles over private AV ownership, particularly in urbanized areas and congested corridors.

😎  Immediately following this strong declaration in terms of equity and public health, the report again expresses an opinion when it addresses public engagement, calling for "proactive and meaningful involvement processes" that will ensure full and fair participation of "all potentially affected communities."  

NJ report - What I don't like

😣  In the club of states that basically have spent money on a current AV primer. Why did the state legislature authorize to spend the money when there are already good AV primers available for free and the report discusses nothing particular to the state of New Jersey?

😣  Lip service is paid to transportation accessibility needs of people with disabilities. No guarantees are recommended and no details are given about how to achieve equity in transportation (or otherwise) for people with disabilities.

😣  No discussion of state goals - What do we want the New Jersey transportation network as a whole to accomplish for the state and how do we plan for AVs so that the transportation system will achieve those goals? 

😣  Little discussion of equity in terms of how the state should address job loss, the transportation needs of low-income populations, affordability of AV transportation, AV transportation modes available, and land use. However, as noted above, the report does declare strong opinions in terms of equity on the subjects of public health, using that term broadly, and public engagement. In a state with very different populations and a full spectrum of communities from very poor to incredibly wealthy - with all of the separation that we see among these across the US - the report reflects our national hesitance to honestly and fully address equity. The report seems to hesitate to offend anyone.

[Photo: Driving Tips in New Jersey at sixt.com.]

Just watching

The report creates an image of a state that  considers itself a passive bystander to eventual business models for AV passenger services and ownership. Much of the discussion of uncertainties about land use patterns, planning, and AV costs is written in the passive voice as though government has no role unless there is already a strong consensus. The authors of the report seem to have taken the position, or have inferred, that the purpose of the report is not to declare any ultimate goals for an AV transportation network of the future, and certainly not to pick sides in a state where free parking and driving everywhere are the norms.

Even when the report lets itself veer into expressing opinions, in particular what may happen in suburbs versus cities, it does not conceive of the state as having the authority to influence or change land use and transportation regulation and patterns.

Skeptical view of the role recommended for the DMV

The Department of Motor Vehicles (DMV) as the lead agency will limit itself to AV safety and registration, but is not an agency that is accustomed to or bearing the capacity to consider land use or incorporating how non-drivers interact with the roadway. The report does specify pedestrians and people with disabilities.

Again, to underscore my skepticism about a DMV being the lead agency, the report comes out in favor of tasking the DMV with responsibility for broad stakeholder engagement. This is not an agency with a history of relationships with senior, disability, low-income, or transportation-vulnerable communities. New Jersey certainly has not always, or often, done justice for communities of color. There is also nothing to indicate a real commitment to go beyond engaging and listening to active incorporation of concerns and ideas articulated by these communities.

Recommendations read like "We're all in favor of apple pie."

• Safety: Yes, we know that safety is a priority, and this needs to be listed.
• Remain technology neutral. 
• Prepare proactively for AVs.
• Encourage consistent regulation and operating environment. 

Basically, the report recommends trying to get all stakeholders to sing Kumbaya together.

Recommendations with a little more oomph

• Recommendations for two distinct task forces: (1) an interagency advisory committee made up of staff from state agencies, and (2) a stakeholder engagement council. These two bodies have the potential to add lots of value and specifics to how New Jersey proceeds as they are given particular mandates in the report. 
• AV testing and operations regulatory structures that should be in place and what should be required.

🤔 What?

• Recommendation to give a free pass to companies that are already players approved for AV testing in other states. This is surprising given the low bar in certain states.

What is interesting

👀  In some details following the recommendations, the report calls for EITHER a safety risk management plan or a voluntary safety self-assessment approved by NHTSA. Perhaps the authors are providing that leeway as a wait-and-see gesture. But perhaps not, because there is also a recommendation to give a free pass to companies that are already players approved for AV testing in other states, including ones with low standards. Perhaps the state regulators will choose to be more discriminating. 

👀  Recommendation that there always be a human backup driver in an AV that is being tested and recommending a mandate for a training program for backup drivers. 

👀  Recommendations that companies "acknowledge/certify" that an AV, when it is being operated in an automated mode, is incapable of operating outside of its ODD (operational design domain). 

👀  Attention paid to law enforcement and AVs having the capacity to reach a minimal risk condition on the side of the roadway.

👀  For all of the vagueness of the report and its apparent stance that it is too early to make many decisions, the report veers off in a whole different direction when it conceives of passengers on an AV without a backup driver.

For HAVs that do not require a driver, the autonomous vehicle has a communication link with the HAV Operator to provide information on the vehicle’s location and status, and allow two-way communication between the HAV Operator and any passengers (if applicable) and law enforcement or other first responders, should the vehicle experience any failures that would endanger the safety of the vehicle’s passengers or other road users while operating without a driver. 

[Image: Map of New Jersey from Britannica entry about the state.]

My recommendation for a good state AV report - a solid B+

My favorite state-level AV report remains Minnesota's because it conceives of AVs in terms of state goals for equity and accessibility, and environmental sustainability. It separates out legislation around truck platooning as separate from statutes addressing AVs. The report looks at a spectrum of other state frameworks for regulating AVs, and, in addition to other recommendations that are relatively specific for these type of reports, Minnesota's specifically declares:

• The state must ensure that CAV pilot projects are conducted in urban, suburban and rural Minnesota to allow the public equal opportunities to learn about the technology and help guide policy decisions.

• Conduct pilot projects in areas with aging populations, persons with disabilities, low-income communities, in communities of color, and tribal nations.

 To all of you, a happy and healthy 2021!!!