A letter to Congress: Rules to keep citizens safe and encourage rapid innovation

At Aurora, our mission is to deliver the benefits of self-driving technology safely, quickly, and broadly. Much of our work is focused on building the most advanced technology, the Aurora Driver, and doing it in a way that always puts safety first. We’re also partnering with the government and industry groups to ensure we have the right rules in place when it comes to developing and deploying this new, life-saving technology.

This year, we helped found PAVE (Partners for Automated Vehicle Education), released our first-ever safety report, “The New Era of Mobility,” and have begun to work with federal and state regulators to identify ways to bring states and communities together to standardize the conflicting road rules that currently exist.

Recently, the U.S. Senate Committee on Commerce, Science, and Transportation and the U.S. House Committee on Energy and Commerce—who are working to develop a self-driving car bill—sought feedback from the industry. Our feedback, included below, focused on two main requests:

1. Ensure that NHTSA (National Highway Traffic Safety Administration) retains its primary safety authority vis-a-vis the states
2. Expand the ability of all companies to take advantage of critical exemptions in the development of their self-driving system

Aurora will continue to put safety first in everything we do and advocate for rules that keep citizens safe and encourage rapid innovation for this life-saving technology.

Below is the letter we sent the U.S. Senate Committee on Commerce, Science, and Transportation and the U.S. House Committee on Energy and Commerce:

Dear Members,

On behalf of Aurora, I would like to express my gratitude to you and your staff for helping to address the policy challenges and opportunities that exist for the self-driving vehicles industry.

Aurora’s mission is to deliver the benefits of self-driving technology safely, quickly, and broadly. We are focused on building the Aurora Driver, a platform that combines hardware, software, and data services that allows vehicles to move people and goods safely through the world. When complete, the Aurora Driver will enable a transportation ecosystem, bringing together automakers, logistics services, mobility services, and fleet management providers to deliver the benefits of this technology broadly.

Safety is our first priority, and primary motivation for, developing the Aurora Driver. We put safety top of mind with everything that we do, from the people that we hire to our development and decision-making process. As an industry, as we collectively bring self-driving vehicles to our roads, it is vital that we partner closely to prepare our communities and our cities for this transformative moment.

In response to your staffs’ recent request for feedback, I would like to offer a few perspectives. Aurora’s primary concerns for any federal legislation are to, first, ensure that NHTSA retains its primary safety authority vis-a-vis the states and, second, expand the ability of all companies to take advantage of critical exemptions in the development of their self-driving systems. While these two issues are critical to the development of self-driving cars, there will be additional issue areas where Aurora can offer expertise and insight to the committees’ future work on legislation addressing Level 3 automation and above.

NHTSA Authority

We are supportive of the federal government maintaining its regulatory authority over the design, construction, or performance of automotive vehicles and applying that same authority to the regulation of highly automated vehicles. States can, and should, continue to regulate the testing and deployment of self-driving vehicles on their roads. In the current regulatory landscape, the ability to successfully deploy self-driving vehicles varies greatly from state to state. If states were to expand their domain and begin regulating the design, construction and performance of highly automated vehicles, it would create an unnavigable patchwork of rules and regulations that would cause the United States to cede its leadership in developing and deploying this important, life-saving technology.

In addition, we believe that there is an opportunity for the federal government to provide leadership to encourage uniformity of existing state rules of the road. For example, in some jurisdictions it is required by law to use a bike lane to make a right hand turn while in others it is prohibited. We do not have a position on what is the safest option, but we do believe that more uniformity could be beneficial to the self-driving vehicle industry. While traffic law is clearly within state jurisdiction, Congress could provide valuable guidance on tackling this entrenched patchwork of laws that affects all drivers, regardless of whether they are human or autonomous.

Federal Motor Vehicle Safety Standards (FMVSS) and Exemptions

We support NHTSA’s efforts to modernize the Federal Motor Vehicle Safety Standards (FMVSS) to encourage the development of new and innovative technologies. As you know, the FMVSS were not created with self-driving technology in mind. As such, the FMVSS do not currently contemplate the integration of self-driving technology, like the Aurora Driver, into vehicles, and should be updated to account for this new technology.

Aurora believes that the opportunity to provide additional industry guidance to Congress and regulatory agencies would speed up regulatory process, which would in turn permit industry to make meaningful investments in self-driving technology. We would welcome the opportunity to be included in a broad cross-section of stakeholders on Advisory Committees and in consultations on any legislation or rulemakings.

As your committees approach legislation, we encourage you to level the playing field for all developers of self-driving technology and ensure that innovative, job-creating companies like Aurora are not disadvantaged versus incumbents. With a level playing field in place, we are supportive of language that would increase the number of vehicles that could qualify for an exemption and lifting the current cap of two years for each exemption. We believe that the current low vehicle number threshold disincentivizes both manufacturers and technology developers from continuing to make significant investments to develop new and safer vehicles.

I look forward to continuing this conversation and reviewing language as your committees go through the legislative process. If we can be helpful, my team and I are happy to serve as a resource as you consider various policy proposals. Thank you for your leadership and your willingness to include us.

Sincerely,

Chris Urmson

Chief Executive Officer