C_TEC Submits Comments to DOT following the Autonomous Vehicle Policy Summit

March 9, 2018Department of Transportation1200 New Jersey Avenue SEWest Building Ground FloorRoom W12-140Washington, DC 20590In the matter of Automated Vehicle Policy Summit (DOT-OST-2018-0017)To Whom It May Concern:The U.S. Chamber of Commerce’s Technology Engagement Center (“C_TEC”) commendsthe Department of Transportation (“DOT”) for holding its March 1, 2018 public Automated VehiclePolicy Summit. Autonomous vehicles (“AVs”) have the potential to revolutionize the Americaneconomy and eliminate many barriers that are hindering growth. C_TEC looks forward to workingwith DOT on its planned release of the AV 3.0 guidance for autonomous vehicles.I. The Promises of Autonomous VehiclesOne major barrier to economic growth and productivity is traffic congestion. For instance, asthe Chamber’s President and CEO Tom Donohue stated, “[b]etween 1990 and 2015, the timeAmericans spend commuting has increased by about 35 minutes a week.”1 According to one study,traffic congestion cost the US economy nearly $124 billion in 2013 and could add up to $2.89trillion in cumulative losses by 2030.2 The use of autonomous vehicles can enable more efficientcommutes and increase productivity.In addition to the economic toll, tragically over 40,000 lives were lost in motor vehiclesaccidents in the United States in 2016.3 According to the National Highway Transportation SafetyAdministration (“NHSTA”), nearly 94 percent of auto crashes can be attributed to human error.4Vehicles guided with technology such as artificial intelligence (“AI”), LIDAR, and other sensorshold the promise of eliminating human error and foster safer transportation.Additionally, AVs have the potential to reduce the number of drunk driving incidents5 aswell as give disabled Americans greater mobility.6 With all of these benefits including congestionalleviation and accident prevention, it is important that federal agencies like DOT promote thesenew emerging technologies by striking the right regulatory balance.II. The Need for Federal Autonomous Vehicle StandardsThe promise of AVs will not fully become a reality until use of this new technologybecomes ubiquitous. One of the many hurdles to the widespread use of AVs is consumersreluctance to adopt the technology. Increasingly, Americans are becoming more comfortable withthe use of AVs as demonstrated by the American Automobile Association which found this yearthat 20 million more Americans would trust an AV compared to last year.7One significant factor that will lead to increased confidence in autonomous transportation isan effective regulatory environment. Americans overwhelmingly agree that there should begovernmental standards for AVs and most of those people find that federal standards are preferableto a patchwork of state laws.8C_TEC maintains that the best approach to spurring innovation in transportation andautonomous vehicles is to establish a federal standard for safety. It is for this reason that theChamber supports the approach taken by two bills currently before Congress—H.R. 3388, the SELFDRIVE Act, and S. 1885, the AV START Act. These bills provide for a single AV standard thateliminates the patchwork of 50 state laws which create regulatory uncertainty and hinder testing,innovation, and deployment of potentially life-saving AVs. A federal AV safety standard willcontribute toward instilling confidence in consumers about the reliability of autonomoustransportation.Transportation is inherently an interstate matter and for that reason safety standards shouldbe determined on the federal level. At the same time, it should be noted that regulators shouldunderstand the rapidly-evolving nature of technological innovation with regard to AVs and notadopt a default approach that seeks top-down and overly prescriptive regulations. C_TEC applaudsSecretary Elaine L. Chao’s announcement at the March 1 AV Summit that DOT’s approach for AV3.0 will be performance-based and not top-down.III. The Best AV Standard and Guidance Approach is MultimodalC_TEC strongly endorses the Secretary’s announcement that AV 3.0 “will be multimodal,and include various surface transportation systems, such as mass transit, rail, and trucking.”9 Inorder for the benefits of AV to be fully realized, all modes of autonomous surface transportationshould have regulatory parity.C_TEC believes that autonomy in surface logistics will be necessary to ensure Americaleads in digital commerce. According to the U.S. Census Bureau, it is estimated that in the UnitedStates total e-commerce sales amounted to $453.5 billion which was a 16 percent increase from theyear before.10Trucking is one of the current major forms of transportation to ensure fulfillment of ecommercepurchases. Unfortunately, the nation is currently experiencing a shortage in the numberof truck drivers.11 One of the many solutions to this shortage in the future will be autonomy.Fortunately, testing has shown that autonomous commercial trucking is viable as demonstrated byEmbark which recently conducted a test of an autonomous truck on a 2400-mile trip from Californiato Florida.12There are a number of exciting innovations and proposals being made in autonomous publicand mass transportation as well. Proterra, which is partnering with the Regional TransportationCommission of Washoe County in coordination with the University of Nevada, Reno is currentlytesting electric buses in Washoe County, Nevada.13 The City of Jacksonville currently is goingforward with a plan known as the Ultimate Urban Circulator (“U2C”) to convert its elevated railsystem, the Skyway, into a test track for autonomous shuttles as a mass transit solution.14 Suchprograms have the ability to enable greater mobility for economically-disadvantaged residents aswell as the elderly and the disabled.The inclusion of trucking and public transportation in the federal safety framework will beessential to providing the regulatory certainty necessary to ensure that America leads in e-commercelogistics and provides greater mobility through public transportation.IV. ConclusionAutonomy in transportation has the ability to fundamentally transform America’s cities androadways for the better. AVs promise safer roads, reduced congestion and greater mobility for thosecurrently left without transportation options such as low-income residents, the disabled, and theelderly. C_TEC believes that in order to facilitate the widespread deployment of this technology,policymakers, including DOT, should embrace a multimodal, federal safety approach.C_TEC thanks the Secretary and DOT for your leadership and looks forward to workingwith you on this critical issue in emerging technology.Sincerely,Tim DaySenior Vice President