Inside Unmanned Systems

AUG-SEP 2017

Inside Unmanned Systems provides actionable business intelligence to decision-makers and influencers operating within the global UAS community. Features include analysis of key technologies, policy/regulatory developments and new product design.

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LETTER 47 unmanned systems inside August/September 2017 rapidly, and we can put vehicles on roadways now and in the near future that will help save lives while regulators develop the necessary policy framework. So the question is: What do we do in this interim period?" There are already provisions to allow exemp- tions from some regulations for up to 2,500 ve- hicles so they can be driven in real-world con- ditions. The industry wants that number lifted dramatically to allow each company the latitude to deploy tens of thousands of vehicles, learning along the way and demonstrating their safety. The current limit on exemptions of 2,500 is too strict to allow the industry to move quickly, explained John Strickland, who is counsel to the Self-Driving Coalition for Safer Streets. "The numerical and temporal limitations on exemptions under current law present a con- crete obstacle to achieve the goal of rapid, safe, and robust deployment necessary to attain the safety and mobility benefits we believe the fully self-driving vehicles promise." This Is Not A Test The bill, which was passed by the full committee July 27, would allow exemptions for 25,000 HAVs per manufacturer for the first year, 50,0000 the second year and 100,000 during the third and fourth years with a possibility of renewal. These exemptions are not aimed at testing but at estab- lishing a broad base of on-the-road experience to be used to frame both the technology and the rules that eventually regulate it. " The National Highway Traf f ic Safet y Administration makes its decisions based upon data—whether or not they are going to take a rule-making posture, whether they're going to think about creating a change to the new car as- sessment program," Strickland said, "…all those things need data. The only way you get data, frankly, is deployment and usage—and that generates those necessary components." Under the 2,500-vehicle limit, he said, "there is no way you're going to be able to generate the type of data information needed for, frankly, the companies to be able to innovate thought- fully and, frankly, the agency to learn about those technologies." Given the number of automakers, the number of automated vehicles on U.S. roads could surge into the millions in a few short years—some- thing that gives safety advocates pause. There are "30-something" manufacturers who could eventually be making up to 100,000 cars a year that would operate under these exemptions, Alan Morrison told the hearing. Morrison is the Lerner Family Associate Dean for Public Interest and Public Service Law at George Washington University Law School in Washington, DC. " THE ONLY WAY YOU GET DATA, FRANKLY, IS DEPLOYMENT AND USAGE." John Strickland, counsel to the Self-Driving Coalition for Safer Streets "Currently, when a company needs an exemp- tion from a safety standard, they're limited to 2,500 vehicles and it's basically to test the new concept—to see if it's going to work on the road," said Henry Jasny, vice president and general counsel for Advocates for Highway and Auto Safety. The (National Highway Traffic Safety Administration or NHTSA) reviews their re- quest and may ask the company to do certain things. But we're talking about a drop in the bucket in terms of volume of vehicles when you're talking about 2,500. So to up that to 100,000 per manufacturer per year—and to ex- tend these (exemptions) from two, I think they extend it to four or five years—is a big change. Here we're talking about mass production of vehicles with exemptions from current safety standards, and when you're not sure exactly how those exemptions are going to work." Morrison pointed out that such "deployed" vehicles could be driven by anyone, including rental car customers, whereas only the auto

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