#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