#10 Comments in Response to NHTSA ANPRM - Campaign of Cyclist Organization

Write-In Campaign

Love this! We have a write-in campaign from the League of American Bicyclists. Identical comments, very brief, from avid bikers. Nice. This is a wonderful exercise in participatory democracy available to any organization whose membership or constituency has a minimum of computer skills, a minute of free time, and a device to post with. Comment after comment is the same - a brief message with a link that allows for easy posting on the webpage for the Framework for Automated Driving System Safety  announcement of proposed rule making (ANPRM).

Photo of turtles in the sun.

Any organization can do this, but for this ANPRM only the League took the time to ask its members to sign on to the generic support of the League's full comment and to thus push for a shift in direction of the great big ship of federal transportation policy on which autonomous vehicle (AV) policy will be based. The generic comment basically states that the comment submitter agrees with the League's position about the ANPRM. No details, no engineering-talk, just an indication of support for an organization they trust and one with a simple goal.

The generic comment reads as follows: 

I am writing to support the comments of the League of American Bicyclists' on NHTSA's Proposed Rule for a Framework for Automated Driving System (ADS) Safety.

 
In the last 15 years people biking and walking have made up an increasing portion of traffic deaths and currently make up 20% of all traffic deaths. It is critical that NHTSA's Framework for ADS Safety prioritize the safety of people biking and walking to stop this increase and realize the potential of ADS for all people.

Through a "vision test," robust public testing of existing automated safety technologies, and research NHTSA can lead the way to safer roadways for all. Now is the time to make the safety of people outside of vehicles a priority in ADS safety.

So far, I have looked at over 200 of these identical comments from League members and a mere handful from individuals who added some text to emphasize their hope that we can protect users of other transportation modes, particularly pedestrians, but also transit.

I have not gotten to the bottom of the pile from League members and surely there will also be more comments from organizations as I reach the comments submitted at or near the deadline.

Why no one else?

Hand lettering of "contemplation."

I could list at least 10 organizations off the top of my head that provides or promotes a transportation option other than private vehicles, or that represents a transportation-challenged population - but none of these has enlisted its share of the public to inform NHTSA of their priorities regarding AV safety and regulation. Think of the possibilities for an explosion of public sentiment from older adults, people of color, transit riders, pedestrians, and people with disabilities.

At some point, I will tally these up and post the numbers. I am sure that the League did this as well with the opportunity to comment on the draft Manual on Uniform Traffic Control Devices for Streets and Highways (MUTCD). So far, over 900 comments have been submitted in response to that draft and the deadline is not until May 14, 2021. America Walks and others have enlisted their constituencies to comment on that very important document.