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March 09, 2018


March 9, 2018

Department of Transportation

1200 New Jersey Avenue SE

West Building Ground Floor

Room W12-140

Washington, DC 20590

In 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”) commends

the Department of Transportation (“DOT”) for holding its March 1, 2018 public Automated Vehicle

Policy Summit. Autonomous vehicles (“AVs”) have the potential to revolutionize the American

economy and eliminate many barriers that are hindering growth. C_TEC looks forward to working

with DOT on its planned release of the AV 3.0 guidance for autonomous vehicles.

I. The Promises of Autonomous Vehicles

One major barrier to economic growth and productivity is traffic congestion. For instance, as

the Chamber’s President and CEO Tom Donohue stated, “[b]etween 1990 and 2015, the time

Americans 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 $2.89

trillion in cumulative losses by 2030.2 The use of autonomous vehicles can enable more efficient

commutes and increase productivity.

In addition to the economic toll, tragically over 40,000 lives were lost in motor vehicles

accidents in the United States in 2016.3 According to the National Highway Transportation Safety

Administration (“NHSTA”), nearly 94 percent of auto crashes can be attributed to human error.4

Vehicles guided with technology such as artificial intelligence (“AI”), LIDAR, and other sensors

hold the promise of eliminating human error and foster safer transportation.

Additionally, AVs have the potential to reduce the number of drunk driving incidents5 as

well as give disabled Americans greater mobility.6 With all of these benefits including congestion

alleviation and accident prevention, it is important that federal agencies like DOT promote these

new emerging technologies by striking the right regulatory balance.

II. The Need for Federal Autonomous Vehicle Standards

The promise of AVs will not fully become a reality until use of this new technology

becomes ubiquitous. One of the many hurdles to the widespread use of AVs is consumers

reluctance to adopt the technology. Increasingly, Americans are becoming more comfortable with

the use of AVs as demonstrated by the American Automobile Association which found this year

that 20 million more Americans would trust an AV compared to last year.7

One significant factor that will lead to increased confidence in autonomous transportation is

an effective regulatory environment. Americans overwhelmingly agree that there should be

governmental standards for AVs and most of those people find that federal standards are preferable

to a patchwork of state laws.8

C_TEC maintains that the best approach to spurring innovation in transportation and

autonomous vehicles is to establish a federal standard for safety. It is for this reason that the

Chamber supports the approach taken by two bills currently before Congress—H.R. 3388, the SELF

DRIVE Act, and S. 1885, the AV START Act. These bills provide for a single AV standard that

eliminates 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 will

contribute toward instilling confidence in consumers about the reliability of autonomous


Transportation is inherently an interstate matter and for that reason safety standards should

be determined on the federal level. At the same time, it should be noted that regulators should

understand the rapidly-evolving nature of technological innovation with regard to AVs and not

adopt a default approach that seeks top-down and overly prescriptive regulations. C_TEC applauds

Secretary Elaine L. Chao’s announcement at the March 1 AV Summit that DOT’s approach for AV

3.0 will be performance-based and not top-down.

III. The Best AV Standard and Guidance Approach is Multimodal

C_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 In

order for the benefits of AV to be fully realized, all modes of autonomous surface transportation

should have regulatory parity.

C_TEC believes that autonomy in surface logistics will be necessary to ensure America

leads in digital commerce. According to the U.S. Census Bureau, it is estimated that in the United

States total e-commerce sales amounted to $453.5 billion which was a 16 percent increase from the

year before.10

Trucking is one of the current major forms of transportation to ensure fulfillment of ecommerce

purchases. Unfortunately, the nation is currently experiencing a shortage in the number

of 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 by

Embark which recently conducted a test of an autonomous truck on a 2400-mile trip from California

to Florida.12

There are a number of exciting innovations and proposals being made in autonomous public

and mass transportation as well. Proterra, which is partnering with the Regional Transportation

Commission of Washoe County in coordination with the University of Nevada, Reno is currently

testing electric buses in Washoe County, Nevada.13 The City of Jacksonville currently is going

forward with a plan known as the Ultimate Urban Circulator (“U2C”) to convert its elevated rail

system, the Skyway, into a test track for autonomous shuttles as a mass transit solution.14 Such

programs have the ability to enable greater mobility for economically-disadvantaged residents as

well as the elderly and the disabled.

The inclusion of trucking and public transportation in the federal safety framework will be

essential to providing the regulatory certainty necessary to ensure that America leads in e-commerce

logistics and provides greater mobility through public transportation.

IV. Conclusion

Autonomy in transportation has the ability to fundamentally transform America’s cities and

roadways for the better. AVs promise safer roads, reduced congestion and greater mobility for those

currently left without transportation options such as low-income residents, the disabled, and the

elderly. 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 working

with you on this critical issue in emerging technology.


Tim Day

Senior Vice President

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