C_TEC Letter of Support to Senate Commerce Committee on AV Legislation

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 autonomoustechnology.Self-driving vehicles present tremendous opportunities for consumers, businesses, andthe U.S. economy by making travel safer, enhancing productivity, and increasing transportationefficiency. However, regulatory and other barriers can impede the development of self-drivingvehicles.The Chamber created the Technology Engagement Center (C_TEC) to promote the roleof 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 theChamber dedicated to making the civil legal system simpler, faster, and fairer for allparticipants.C_TEC convenes an autonomous vehicle working group representing sectors across theeconomy to help guide policymakers, regulators, the public at large, and the business communityon 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 vehiclesafety and performance standards, and we urge the Senate Commerce Committee to ensure thatsuch a framework applies to all types of motor vehicles including commercial vehicles. We alsobelieve that the legislation requires effective preemption provisions; while there is always roomfor improvement, we support the text currently in the legislation.To be competitive in the global autonomous vehicle market, legislators must strike thecritical, yet challenging, balance between innovation, safety, and privacy when developingstandards for autonomous vehicles. Innovators need a single set of federal standards as opposedto a patchwork of state laws, rules and regulations. We encourage the Committee to ensure thatthe legislation’s preemption provisions protect innovation and development from inconsistentstate liability rules, potentially expansive litigation and entrepreneurial plaintiffs’lawyers. Without effective and appropriate preemption, we risk impeding our innovators andceding our leadership in this industry.As S. 1885 moves through the legislative process, the Chamber looks forward to workingwith the Committee to further refine and improve the bill.Sincerely,Tim DaySenior Vice PresidentC_TEC U.S. Chamber of CommerceLisa RickardPresidentU.S. Chamber Institute for Legal Reformcc: Members of the Committee on Commerce, Science, and Transportation