I.   Transparent interactions with government officials and the public

Commitment to Transparency

Transparency in interactions with government officials and the public is critically important to the AV industry. AVIA supports AV companies:

• responding in a timely manner to appropriate questions and data requests from lawmakers and regulators about AV deployments, 

• making experts available to hear and address potential concerns from government officials, 

• sharing incident information with regulatory officials as required under state and federal regulatory frameworks, and  

• disclosing crash-related information as required by law and fully participating in formal crash investigations conducted by government officials. 

The following specific examples aim to build on the trust and transparency that must be achieved:

Safety Evaluation Reports

AVIA encourages its members to publish industry safety self-assessment reports to educate the public and relevant government agencies about the SAE Level 4 or 5 technology being tested or deployed. AVIA will provide a public forum for these documents on its website.

Transparency of Operations

AVIA will continue to serve as a member of the National Highway Traffic Safety Administration’s (NHTSA) voluntary “Automated Vehicle Transparency and Engagement for Safe Testing (AV TEST) Initiative” that provides the public with direct and easy access to information about testing of AVs to increase public awareness of on-road testing, safety precautions, and principles guiding the testing. AVIA encourages participation in the AV TEST Initiative within its membership, as applicable.

Community Engagement

AVIA supports industry engagement with relevant communities prior to commencing AV operations and on an ongoing basis. Engagement should aim to include state and local officials, including policymakers and regulators, public safety officials, law enforcement agencies, first responders, community groups, and populations that have been historically underserved by the existing transportation infrastructure to learn how AVs can best meet their needs.

Public Education

AVIA commits to providing public education about the safety of AVs through multiple channels, including making information about the technology available to consumers and customers. AVIA will continue to work with policymakers and other relevant stakeholders to educate consumers about the difference between autonomous vehicles and driver-assist technology. 

II.   Responsible integration into communities and deep engagement with law enforcement and first responders

Engagement with Public Safety Officials

AVIA supports engagement with relevant law enforcement and first responders in the jurisdictions in which an AV operates prior to operating on public roads. These engagements should provide a forum to discuss any additional incidents of concern to law enforcement and first responders. AVIA also supports AV companies providing opportunities for discussion with appropriate law enforcement for reportable incidents under NHTSA’s “Standing General Order” or other state reportable events. 

Law Enforcement Interaction Plan

AVIA will continue to work closely with appropriate law enforcement and first responders to educate them about how to interact with AVs and to understand and address concerns or issues they may have. As discussed below, AVIA has strongly supported – and will continue to support – state AV statutes that include a requirement that AV companies develop and submit a Law Enforcement Interaction Plan to relevant state agencies.

Law Enforcement and First Responder Engagement Council

AVIA will create and support a national council of law enforcement officials, first responders, and industry representatives to further develop and enhance law enforcement cooperation and dialogue as described in the AVIA TRUST Principles.

III.   Upholding the highest cybersecurity and privacy standards

AVIA supports AV companies reviewing and implementing relevant cybersecurity and privacy best practices and standards for autonomous vehicle design, testing, and deployment, including conducting regular risk assessments, as appropriate. AVIA commits to continuing robust engagement with policymakers at the federal and state levels on the cybersecurity and privacy practices of AV operators.

IV.   Safety-first culture and governance

The safety of AVs is of paramount importance. AVIA supports the establishment of a strong safety culture within AV companies through governance, policy, oversight, practices, and procedures.

V.   Transportation policies that will increase safety and public trust of  AVs

AVIA strongly supports policies that will increase safety and public trust in AVs. AVIA will continue to advocate for the following policy recommendations:

• State legislation

• Requiring that an AV is capable of complying with all applicable traffic and motor vehicle safety laws and regulations of a given state, county, or city;

• Providing a meaningful role for state transportation regulators with respect to AV deployment oversight within a given state.

• Requiring that an AV operator submit a Law Enforcement Interaction Plan with relevant state agencies prior to operating an autonomous vehicle on public roads without a human driver. Such a plan should include: 

• How to communicate with a representative of an AV operator who is available during the times the vehicle is in operation;

• How to safely remove the AV from the roadway and steps to safely tow the vehicle if necessary;

• Instructions on how law enforcement can determine whether a given AV is in autonomous mode; and

• Any additional information the manufacturer or owner deems necessary regarding hazardous conditions or public safety risks associated with the operation of the AV.

• Requiring that an AV is able to achieve a “minimal risk condition” (i.e. the ability of an AV to perform a fallback in case of any system fault);

• Requiring that before operating an AV on public roads without a human driver, the operator must submit proof of financial responsibility satisfactory to the applicable agency that the AV is covered by insurance or proof of self-insurance that satisfies law.

• Crash Reporting

• Enactment of federal requirements included in the NHTSA’s Second Amended Standing General Order 2021-01 for AV operators to report incidents that involve AVs to NHTSA, and for those reports to be made publicly available by NHTSA, subject to confidential and trade secret protections.

• Additional Resources for NHTSA 

• Increased funding for NHTSA and the Federal Motor Carrier Safety Administration (FMCSA) to reinforce the leadership role the U.S. Department of Transportation (USDOT) plays to promote the safe deployment of AV technology, and to help ensure that the agencies can resolve rulemakings and exemption petitions in a timely fashion. 

• Continuing Study of AV Impact

• USDOT undertaking a study to inform policymakers and the public about how AVs will impact existing transportation systems. This includes how AVs can enhance safety, expand mobility, address supply chain challenges, create jobs, and increase electrification of the vehicle fleet. NHTSA, FMCSA, and USDOT should receive additional research funding to study AV technology and understand broader impacts on infrastructure.

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