Current Federal Motor Vehicle Safety Standards (FMVSS) do not explicitly address automated vehicle technology and often assume the presence of a human driver. As a result, existing language may create certification challenges for manufacturers of automated vehicles that choose to pursue certain vehicle concepts. The purpose of this work is to identify instances where the existing FMVSS may pose challenges to the introduction of automated vehicles. It identifies standards requiring further review - both to ensure that existing regulations do not unduly stifle innovation and to help ensure that automated vehicles perform their functions safely. The review highlighted standards in the FMVSS that may create certification challenges for automated vehicle concepts with particular characteristics, including situations in which those characteristics could introduce ambiguity into the interpretation of existing standards. The review team’s approach was meant to be as inclusive as possible, with the intent to identify standards that would require further review or discussion. This is a preliminary report summarizing the review of FMVSS and includes a discussion on approach, findings, and analysis. As a preliminary review, the contents of this report reflect the results of an initial analysis and may be modified based on stakeholder input and future discussion. The Volpe team conducted two reviews of the FMVSS: a driver reference scan to identify which standards include an explicit or implicit reference to a human driver and an automated vehicle concepts scan to identify which standards could pose a challenge for a wide range of automated vehicle capabilities and concepts. o The driver reference scan revealed references in numerous standards to a driver (defined in §571.3 as “…the occupant of the motor vehicle seated immediately behind the steering control system”), a driver’s seating position, or controls and displays that must be visible to or operable by a driver, or actuated by a driver’s hands or feet. o In order to conduct the automated vehicle concepts scan, the Volpe team developed 13 different automated vehicle concepts, ranging from limited levels of automation (and near-term applications) to highly automated, driverless concepts with innovative vehicle designs. The idea was to evaluate the FMVSS against these different automated vehicle concepts. In summary, the review revealed that there are few barriers for automated vehicles to comply with FMVSS, as long as the vehicle does not significantly diverge from a conventional vehicle design. Two standards: theft protection and rollaway prevention (§571.114) and light vehicle brake systems (§571.135) were identified as having potential issues for automated vehicles with conventional designs. Automated vehicles that begin to push the boundaries of conventional design (e.g., alternative cabin layouts, omission of manual controls) would be constrained by the current FMVSS or may conflict with policy objectives of the FMVSS. Many standards, as currently written, are based on assumptions of conventional vehicle designs and thus pose challenges for certain design concepts, particularly for ‘driverless’ concepts where human occupants have no way of driving the vehicle (e.g., §571.101, controls and displays, §571.111, rear visibility, §571.208, occupant crash protection represent a few examples). Subsequent to the Volpe Center’s review of the FMVSS, but prior to the publication of this report, NHTSA released interpretations to BMW of North America and Google, Inc. in response to questions regarding how to interpret certain FMVSS requirements in the context of automated vehicles. As a result, the review does not reflect this subsequent development. The full text of these interpretations are available in NHTSA’s repository of interpretation files at the website: http://isearch.nhtsa.gov. (Author/publisher)
Abstract