The release of the newly proposed guidelines kicked off a 45-day public comment period during which industry representatives, advocacy groups and local governments were able to make their views known in order to influence the final product. On April 25, DMV Director Jean Shiomoto, DMV Chief Counsel Brian Soublet and DMV Deputy Director Bernard Soriano held another public hearing in Sacramento to conclude the public comment period.
Startups, automotive giants, transportation network companies, several California cities and individual residents provided their views on the proposed regulations.
Local Government Input
Four cities sent representatives to the Capitol: Los Angeles, San Francisco, San José and Beverly Hills. “Cities are where the costs of automation are born. We are building the infrastructure, installing the signals and responding to the crashes,” said Jennifer Cohen, director of government affairs for the Los Angeles Transportation Department. “However, with a carefully regulated policy, we will also be reaping the benefits of safer streets, cleaner air, increased mobility and decreased congestion.”In order to fully realize the benefits of AVs, the technology must be able to fit into the existing system of infrastructure and mobility. “Autonomous vehicles need to support our efforts to build safe streets and achieve our Vision Zero traffic goals,” said San Francisco Municipal Transportation Agency Director of Sustainable Streets Tom Maguire. One suggestion to ensure safety offered at the hearing was to limit the speed for AVs to 25 mph on city streets.
Both Los Angeles and San Francisco argued that there are two main factors that will help cities maximize the benefits of AVs. “Cities have an obligation to provide safe, well-run infrastructure and cannot do that without access to data and street management,” said Cohen.
Due to the ability of AVs to constantly measure congestion and any potholes they encounter, this data is invaluable for local governments. With it, they would be able to plan more efficient infrastructure projects and be alerted to necessary maintenance.
The information is also crucial in designing safer streets. “Cities need comprehensive data on disengagements and collisions in a standardized format on a regular basis,” said Cohen. Armed with the data on where AVs are forced to forfeit controls back to a human driver, cities could examine why it may be happening. And although AV permitholders are required to log any disengagements and provide that data to the DMV, it is only done annually, which is too infrequent to be useful to cities, argued Maguire.
AV Manufacturers Weigh In
Several representatives from the auto industry appeared at the hearing, and their message, not surprisingly, was that some regulations go too far. One issue brought up by Ford’s Andre Welch was the suggestion that all types of vehicles adhere to the same AV permitting process.Truly recognizing the benefits of AVs, Welch explained, means exploring the possibilities for “autonomous multi-passenger shuttles.” Last fall, the company acquired Chariot, a Bay Area-based startup that specializes in on-demand shuttles.
Matthew Burton, legal director for Uber, requested a similar action from the DMV. The company bought Otto, a self-driving freight truck company, in August 2016. “We believe testing permit regulations are adequate for all motor vehicles,” he said. "There is no need for a separate permitting process for freight vehicles."
Soublet responded to the request by stating that the DMV intends to work on a separate permitting process for freight trucks and vehicles over 10,000 pounds after the smaller vehicle regulations are complete.
One issue brought up by several auto manufacturers involved reporting regulations for replacement parts that may improve the design or safety of the vehicle. Paul Hemmersbaugh of General Motors, who previously worked as chief counsel for the National Highway Safety Traffic Administration, said, “Our suggested changes would ensure that technology improvements would not be unduly delayed by amendment applications and the accompanying 180-day administrative review process.”
In order to get this life-saving technology to the public as quickly as possible, safety improvements need to be made rapidly, with an explanation provided to the DMV at a later date, said Hemmersbaugh.
Ron Medford of Waymo, the spin-off from Google’s self-driving car project, iterated some of the same concerns as other automakers, but added one unique request.
In the proposed regulations, a remote operator must be able to take over an AV in case of an extreme emergency. This can either be a communication link for someone to guide a user on how to bring the vehicle to a safe stop, or a remote controller of the vehicle. Medford requested that the "remote operator" functions can be performed by multiple persons within a single entity.
