171003 s1885 avstartact thune nelson


October 04, 2017


Dear Chairman Thune and Ranking Member Nelson:

The U.S. Chamber of Commerce thanks the Committee for its leadership on S. 1885, the

“AV START Act,” and for its recognition of the safety and mobility benefits of autonomous


Self-driving vehicles present tremendous opportunities for consumers, businesses, and

the U.S. economy by making travel safer, enhancing productivity, and increasing transportation

efficiency. However, regulatory and other barriers can impede the development of self-driving


The Chamber created the Technology Engagement Center (C_TEC) to promote the role

of technology in the economy and to advocate for rational policies that drive economic growth,

spur innovation, and create jobs. The Institute for Legal Reform (ILR) is an affiliate of the

Chamber dedicated to making the civil legal system simpler, faster, and fairer for all


C_TEC convenes an autonomous vehicle working group representing sectors across the

economy to help guide policymakers, regulators, the public at large, and the business community

on the benefits of self-driving vehicle technologies. This group represents a diverse membership,

including Original Equipment Manufacturers, software, and insurance companies among others.

We appreciate the legislation’s provisions for a single national framework for vehicle

safety and performance standards, and we urge the Senate Commerce Committee to ensure that

such a framework applies to all types of motor vehicles including commercial vehicles. We also

believe that the legislation requires effective preemption provisions; while there is always room

for improvement, we support the text currently in the legislation.

To be competitive in the global autonomous vehicle market, legislators must strike the

critical, yet challenging, balance between innovation, safety, and privacy when developing

standards for autonomous vehicles. Innovators need a single set of federal standards as opposed

to a patchwork of state laws, rules and regulations. We encourage the Committee to ensure that

the legislation’s preemption provisions protect innovation and development from inconsistent

state liability rules, potentially expansive litigation and entrepreneurial plaintiffs’

lawyers. Without effective and appropriate preemption, we risk impeding our innovators and

ceding our leadership in this industry.

As S. 1885 moves through the legislative process, the Chamber looks forward to working

with the Committee to further refine and improve the bill.


Tim Day

Senior Vice President

C_TEC U.S. Chamber of Commerce

Lisa Rickard


U.S. Chamber Institute for Legal Reform

cc: Members of the Committee on Commerce, Science, and Transportation

171003 s1885 avstartact thune nelson