Newly Issued Federal Autonomous Vehicle Guidelines Fail to Address Major Safety Implications, NSPE Urges Revisions

Recognizing the promise of autonomous vehicles, the National Society of Professional Engineers has been a leading advocate on the need to place the public health, safety, and welfare first, and require a licensed professional engineer to play a key role in the development, testing, and safety certification of autonomous vehicles. NSPE is disappointed that several major safety implications are still not addressed in the National Highway Traffic Safety Administration’s recently released Federal Automated Vehicles Policy. These guidelines, while not binding, will play a key role in the development and deployment of autonomous vehicles. NSPE and the professional engineers it represents have a foremost responsibility to protect the public health, safety, and welfare—and to make others aware of ways that safety may be jeopardized.

Given the unique technical and ethical expertise that professional engineers possess, NSPE strongly believes professional engineers can play a key role in addressing the ethical and technological challenges raised by autonomous vehicles, and strongly urges NHTSA to reconsider and revise its policy to address the following key issues:

• There is no requirement for a third-party certification of autonomous vehicles and technologies by someone in the decision chain who has a duty that puts public safety first and overrides competitive pressures– i.e., a professional engineer. These guidelines allow manufacturers and suppliers to self-certify, eliminating a critical third-party safety check.

• Despite encouraging results of autonomous vehicle deployments in controlled environments, there is still significant work to be done before the achievement of human-operated and autonomous vehicles safely sharing public roadways. Many factors—weather, pedestrians, road conditions—are common, rapidly changing, and highly unpredictable. The guidelines assume these hurdles will be easily overcome and do not provide for adequate safety protections.

• The enormous ethical implications of deploying autonomous vehicles are simply not addressed. While the guidelines acknowledge there are major ethical issues, no proposed methods for addressing them are provided, leaving these critical considerations up to manufacturers and interested stakeholders. Professional engineers should play a key role in this evaluation as their oath in holding the license is to place the public health, safety, and welfare above all other considerations.

There is no reason that these steps should slow or delay the introduction of this promising new technology. However, the risks posed by failing to adequately address public safety protections are too great to ignore. In the absence of NHTSA revising its policy, NSPE urges states to incorporate such requirements in rulemaking and manufacturers to incorporate these steps in their deployment of the various iterations of this technological advancement.