A letter to regulators: Prioritizing safety and a technology-neutral approach

At Aurora, we’re committed to working with our partners in the industry and the government to make sure self-driving vehicle guidelines and regulations prioritize safety, are technology-neutral, and ensure a level playing field for all self-driving developers. It’s unacceptable that tens of thousands of people die annually on our roadways and self-driving technology can usher in a new era of safety.

Recently the National Highway Traffic Safety Administration (NHTSA) asked the public to comment on how the agency should begin developing a framework for regulating the safety of self-driving vehicles, also called automated driving systems or ADS. We appreciate the opportunity to offer our perspective. And because a key part of our holistic safety approach is operating with transparency, we want to share the key points of our letter more broadly, which can be found in full here.

Develop technology-neutral guidance and regulations

We strongly support NHTSA’s continued efforts to develop a technology-neutral approach to guiding and regulating self-driving technology and to ensure a level playing field for all self-driving technology developers. We recommend that NHTSA continue developing a performance-based regulatory framework for ADS safety by considering a variety of approaches to objectively test and evaluate ADSs at the vehicle level.

Support and guide current industry standards activities

While many of the industry voluntary standards are helpful for developers, a fair amount of interpretation is needed by each ADS developer in order to apply these standards to their specific ADS use case, like goods delivery or ride-hailing. NHTSA could provide more direction on the potential utility of these standards and whether they could be used as part of a framework for ADS safety.

Partner with companies to build public trust and transparency

We are committed to sharing our safety case framework with NHTSA, the industry, and the general public, and intend to continue to engage in technical discussions with the agency and its other federal partners. Public trust is an important aspect of developing and deploying self-driving technology and NHTSA is a key partner in supporting the public's understanding and acceptance of the technology.

Develop a comprehensive roadmap on ADS safety

Developing a framework for ADS safety would benefit from a coordinated approach between industry and the federal government. Given its convening power, NHTSA should consider collaboratively developing, with ADS developers and industry stakeholders, a roadmap that captures and helps coordinate the multitude of concurrent activities underway, including ADS emerging standards, ADS developers’ internal safety frameworks, federal-led research, and federal-led voluntary initiatives.

Complement regulatory approach with other ADS safety initiatives

Aurora appreciates and supports NHTSA’s continued regulatory work on ADS safety. However, regulations can take years to develop and implement. In the interim, we believe there are several ways the agency can continue supporting the safe deployment of ADS technology. These include strengthening the Voluntary Safety Self Assessment (VSSA), facilitating collaboration externally with ADS developers and internally with its partner agencies, and promoting and coordinating a national effort to standardize road rules.

We look forward to a future where our roads are safer, goods get where they need to go efficiently, and everyone has access to better modes of transportation. Partnership and collaboration with our government partners are critical to how we will get there.