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Legal aspects of autonomous vehicles – an overview*
Viktória Ilková
Faculty of Law
Comenius University in Bratislava
Slovak Republic
viktoria.ilkova1991@gmail.com
Adrian Ilka
Department of Signals and Systems
Chalmers University of Technology
Gothenburg, Sweden
adrian.ilka@chalmers.se
Abstract—The main goal of this article is to provide up-to-
date information about legal regulation of autonomous vehicles
(AVs) in Europe and the United States of America (U.S.). The
legal overview is primarily intended for technical professionals
for the purpose of giving them a holistic approach to AVs. The
authors believe that technical professionals have to be aware of
legal regulation of AVs as well in order to get the opportunity to
discuss the feasibility of different legal statements.
Besides the definition of AVs based on levels of automation,
the article also contains answers to following questions: What are
the greatest benefits of AVs? How does the general road traffic
law need to be changed to allow the use of AVs on public roads?
What are the differences between the current state of AV
regulations in the U.S. and Europe? Finally, the paper draws
attention to the most significant legal challenges that AVs address
to lawmakers, insurance companies, consumers, and last but not
least, car manufacturers.
Keywords—autonomous vehicle; traffic law; legal challenges;
liability
I. INTRODUCTION
Artificial intelligence, robots, 3D tissue printing,
autonomous vehicles. A few years ago we met these modern
technical innovations only in science fiction movies. However,
nowadays these inventions have become reality and in the near
future they will surround us more and more, until they will be
part of our lives [1], [2], [3], [4]. Though, the everyday use of
autonomous vehicles might seem futuristic, prognoses predict
their wide use in the near future [5].
According to the most general definition, an autonomous
vehicle (AV) is such a vehicle that can guide itself without
human conduction [6]. Use of the term “autonomous” in
connection with motor vehicles has sometimes been
misunderstood because in some areas of law the concept of
“autonomy” is associated with broad philosophical concepts.
In contrast, the word “autonomous” in a technical context
simply means (more or less) that it works independently of
human input while driving. An “autonomous system” is
therefore a technical unit which fulfills certain tasks without
being dependent regular human commands [7]. A more
specific definition of AVs is provided by SAE International1
* This work was supported by the Chalmers Area of Advance Transportation,
by Vinnova under the FFI project MultiMEC and by Vinnova under FFI
project VCloud II, which is gratefully acknowledged.
1 SAE International (Society of Automotive Engineers) is a global association
committed to being the ultimate knowledge source for the engineering
profession.
through stating levels of automation. The extent of automation
depends on the human driver’s role in performing the dynamic
driving task (see Chapter II.) [8].
According to statistical information provided by the Police
Force of the Slovak Republic, there are on average 14 000
road traffic accidents in Slovakia per year causing over 7 000
personal injuries, from which ca 300 are fatalities2 [9].
Developers of autonomous technology estimate that autono-
mous vehicles could reduce traffic fatalities by 90%, which
would mean 270 saved lives per year in Slovakia [10]. The
benefits do not stop with safety. Autonomous vehicles have
the potential to transform personal mobility and open doors to
people with disabilities, aging populations, and communities
where car ownership is prohibitively expensive, or those who
prefer not to drive or own a car. Cities will reconsider how
space is utilized and how public transit is provided.
Infrastructure capacity could be increased without pouring a
single new truck load of concrete. Autonomous vehicles may
also have the potential to save energy and reduce air pollution
from transportation through efficiency and by supporting
vehicle electrification [11].
In Europe, cities in Belgium, France, Italy and the UK are
planning to operate transport systems for driverless cars, and
Germany, the Netherlands, and Spain have allowed testing
self-driving cars in traffic [12], [13]. The Swedish car
manufacturer company, Volvo has started to test 100 of its
autonomous cars on public roads driven in normal traffic by
regular clients by 2017. The company announced a
collaboration with Swedish legislators and transport
authorities to test the cars on a 30-mile road section around
Gothenburg by 2017, marking Volvo’s first public pilot of
fully autonomous vehicles. Analysts predict that completely
autonomous cars will be for sale by 2025-2030 [14], [15].
As autonomous technology gradually erodes driver
control, the law must be altered in its code and its
implementation. It is a significant challenge; but not an
insurmountable one. Therefore, any research question related
to the legal regulation of autonomous vehicles is increasingly
necessary and required, especially in Europe. One of the most
important and considerable issues is liability of autonomous
vehicles. The research within this topic is currently ongoing in
U.S. and Europe as well. This has been reported recently in
several publications [16], [17].
2 The average values are calculated based on data from 2011 to 2016.
Statistical information is available online, at the Slovak Ministry of Interior's
webpage.
In a European context, a new project called AdaptIVe
(Automated Driving Applications and Technologies for
Intelligent Vehicles) [18], has been established. The project
has many participants, mainly research institutions, including
some legal research groups. One of the most significant
participants is legal scholar Professor Eric Hilgendorf. At his
research center, called “RobotRecht”, he manages the Europe-
wide research on legal implications of autonomous vehicle
systems. As it is evident from the center's publications, the
research also covers the issue of liability [19].
The significance of this research area is proved by
numerous studies (as it can be seen in the references). Inter
alia, in early 2014, IHS Automotive released “Emerging
Technologies: Autonomous Cars – Not If, But When”, a study
projecting a global total of nearly 54 million autonomous cars
by 2035, and predicting that almost all of the vehicles in use
are likely to be autonomous cars or autonomous commercial
vehicles sometime after 2050 [20]. The result will be a driving
environment that is far safer than what we are accustomed to
today.
II. LEVELS OF AUTOMATION
Before dealing with any further research questions related
to AVs, it is particularly necessary to acquire a sort of
taxonomy stating clear and categorical distinctions between
different modes (levels) of automation.
The mentioned taxonomy can significantly help to easily
differentiate AVs depending on who is responsible for
monitoring the driving environment.
Furthermore, stating clear levels of automation eliminates
confusion and is useful across numerous disciplines
(engineering, legal, media, and public discourse).
As mentioned in the Introduction, a global association of
automotive engineers called SAE International carried out a
report concerning levels of automation for defining driving
automation in on-road motor vehicles (also known as standard
J3016™) [8]. It has been adopted in September 2016 by the
U.S. Department of Transportation in Federal Policy for safe
testing and deployment of AVs [21]. Furthermore, the
organization signed an agreement with the German Institute of
Standardization, which fortifies the acceptance of SAE
automation levels as the global standard [22]. Thus, it has
become “the core reference and a guideline for all
stakeholders in this transformational technology”.3
The report defines six levels of driving automation span
from no automation to full automation. Elements indicate
minimum system capabilities for each level. A key distinction
is between level 2, where the human driver performs part of
the dynamic driving task, and level 3, where the automated
driving system performs the entire dynamic driving task. The
term "dynamic driving task" includes the operational (steering,
braking, accelerating, monitoring the vehicle and roadway)
and tactical (responding to events, determining when to
change lanes, turn, use signals, etc.) aspects of the driving
task, but not the strategic (determining destinations and
waypoints) aspect of the driving task [8].
3 Quoted from David L. Schutt, PhD, Chief Executive Officer of SAE
International.
TABLE 1 SUMMARY TABLE ON LEVELS OF AUTOMATION (Copyright © 2014 SAE International).
SAE
level
Name
Narrative Definition
Execution of
Steering and
Acceleration/
Deceleration
Monitoring
of Driving
Environment
Fallback
Performance
of Dynamic
Driving
Task
System
Capability
(Driving
Modes)
Human driver monitors the driving environment
0
No
Automation
the full-time performance by the human driver of all aspects of the
dynamic driving task, even when enhanced by warning or
intervention systems
Human driver
Human driver
Human
driver
n/a
1
Driver
Assistance
the driving mode-specific execution by a driver assistance system of
either steering or acceleration/deceleration using information about
the driving environment and with the expectation that the human
driver perform all remaining aspects of the dynamic driving task
Human driver
and system
Human driver
Human
driver
Some
driving
modes
2
Partial
Automation
the driving mode-specific execution by one or more driver assistance
systems of both steering and acceleration/deceleration using
information about the driving environment and with the expectation
that the human driver perform all remaining aspects of the dynamic
driving task
System
Human driver
Human
driver
Some
driving
modes
Automated driving system (“system”) monitors the driving environment
3
Conditional
Automation
the driving mode-specific performance by an automated driving
system of all aspects of the dynamic driving task with the expectation
that the human driver will respond appropriately to a request to
intervene
System
System
Human
driver
Some
driving
modes
4
High
Automation
the driving mode-specific performance by an automated driving
system of all aspects of the dynamic driving task, even if a human
driver does not respond appropriately to a request to intervene
System
System
System
Some
driving
modes
5
Full
Automation
the full-time performance by an automated driving system of all
aspects of the dynamic driving task under all roadway and
environmental conditions that can be managed by a human driver
System
System
System
All driving
modes
III. ROAD TRAFFIC LAW IN THE UNITED STATES AND EUROPE
A. United States of America
Foremost, the United States (hereinafter U.S.) dealt with
the issue of legalizing autonomous cars. In June 2011, the
Nevada Legislature passed a law to authorize the use of
autonomous cars. Nevada thus became the first jurisdiction in
the world where autonomous vehicles might be legally
operated on public roads [23], [24]. Nowadays, most of the
U.S. states deal with the basic legal status of autonomous
vehicles [25].
In terms of the form of government, the U.S. is federation;
therefore it is important to distinguish between actions carried
out by the federal government, and those that have been taken
by individual states.
As for the federal road traffic regulation, the National
Highway and Transportation Safety Administration (NHTSA)
issued an updated guidance for the safe development of AVs
in September 2016 [21]. The policy update has four parts:
vehicle performance guidelines, model state policy, NHTSA’s
current regulatory tools and possible new regulatory actions
NHTSA believes could be helpful in ensuring the safe
deployment of AVs. For potential AV manufacturers, the
policy includes a set of 15 best practices regarding the safe
pre-deployment design as well as development and testing of
AVs prior to commercial sale or operation on public roads.
(For more details, the reader is referred to the Appendix).
Regarding state actions since 2012, nine states (California,
Florida, Louisiana, Utah, Michigan, North Dakota, Tennessee,
Nevada, and Virginia) and Washington D.C. have passed
legislation pertaining to AVs. In December 2016, an online
legislative database was created, which provides up-to-date,
real-time information about state AV legislation [27].
September 2016 was a turning point in terms of the state
legislature as well: California transportation authorities made
two major changes in their policy on autonomous vehicles.
The first change, a new bill signed into law, gives the Contra
Costa Transportation Authority permission to test a pilot
project on public roads without having a driver behind the
wheel. Prior to this, the state only allowed public road testing
if a human driver was in the driver’s seat and “capable of
taking immediate manual control of the vehicle in the event of
an autonomous technology failure or other emergency.”
The bill requires the autonomous vehicles to be insured for
$5 million, for the self-driving automobiles to not exceed 35
miles per hour on the road, and for testing data to be shared
with the government and while placing geographic
restrictions. Testing can only take place at two locations: at a
former Concord Naval Weapons Station and current AV
testing facility, and at the San Ramon Bishop Ranch office
park.
The second change, revised draft regulations released by
California’s department of motor vehicles, can potentially
change how all self-driving vehicles are tested in the state by
rolling out the privileges given to the aforementioned pilot
program. If the law were pass (it is still under legislative
procedure) it will allow car manufacturers to test vehicles
deemed safe by the federal government on public roads
without licensed drivers. Instead of having a driver in the
vehicle, the newly proposed regulations require that a test
driver has two-way communication with a vehicle [28].
B. Europe
Concerning Europe, an examination of legislation in
European Union (hereinafter EU) member countries involving
major automotive industry partners – France, Germany, Spain,
Sweden, and the United Kingdom – reveals that none of these
countries currently has pertaining legislation connected to
autonomous vehicles. Tests, however, are being carried out
continuously and are expected to take place in several EU
countries under ad-hoc legal permits [26].
Almost all EU member countries (with the exception of
Spain and the United Kingdom) have signed and ratified the
Convention on Road Traffic, also known as the Vienna
Convention [29]. It is a multilateral international treaty of the
United Nations dealing with general traffic law. Until 23
March 2016, any legislation adopted by a signatory of the
Convention had to require a human driver to be in control of
the moving vehicle at all times (see Article 8 par. 1, 5 and
Article 13 par. 1).4 In 2016, a new paragraph called ‘5bis’ was
added to Article 8.5 As a result, automated vehicles will be
compliant with the Vienna Convention following the
amendment, provided that the system can be overridden by the
driver, or fulfils (future) requirements of the ECE regulations.6
Sweden and Belgium made some further amendment
proposals that are still waiting to be decided upon7 [30].
While Europe has certainly not been left behind in the race
of technical development of advanced autonomous vehicles,
the pressure is now rising for lawmakers, insurance companies
and manufacturers tasked with addressing legal and regulatory
questions which, until recently, have been left unanswered.
4 Article 8 paragraphs 1 and 5 of the Vienna Convention require that “[e]very
moving vehicle or combination of vehicles shall have a [person] driver,” and
“[e]very driver shall at all times be able to control his vehicle.” Article 13
paragraph 1 further requires that “[e]very driver of a vehicle shall in all
circumstances have his vehicle under control so as to be able to exercise due
and proper care and to be at all times in a position to perform all maneuvers
required of him.”
5 It is worded as follows: "Vehicle systems which influence the way vehicles
are driven shall be deemed to be in conformity with paragraph 5 of this Article
and with paragraph 1 of Article 13, when they are in conformity with the
conditions of construction, fitting and utilization according to international
legal instruments concerning wheeled vehicles, equipment and parts which
can be fitted and/or be used on wheeled vehicles (a footnote here refers to the
ECE Agreement of 1958 and the GTR Agreement of 1998).
Vehicle systems which influence the way vehicles are driven and are not in
conformity with the aforementioned conditions of construction, fitting and
utilization, shall be deemed to be in conformity with paragraph 5 of this
Article and with paragraph 1 of Article 13, when such systems can be
overridden or switched off by the driver.”
6 ECE (Economics Commission for Europe) 1958 Agreement, and 1998
Agreement on Global Technical Regulations.
7 The proposals call for a redesign of Article 8 paragraph 5bis as well as the
addition of two further paragraphs - “5ter” and “5quater” – to Article 8. They
intend to distinguish between automated driving functions that take over part
of the task of driving, the complete task of driving for a certain section of the
journey or the complete task of driving for the whole journey, from beginning
to end.
IV. LEGAL CHALLENGES IN THE EUROPIAN KONTEXT
A. Administrative Law
Legal issues related to AVs belong to the scope of mainly
three branches of law. One of them is administrative law,
which includes especially road traffic law in general (it covers
among others issues such as certification and licensing,
technical controls, road traffic rules, etc). It deals with stating
technical norms as well. The most important legal challenges
related to autonomous driving in the area of administrative law
are following:
Does autonomous driving have to require special driving
license? If so, shall it be national or international? Shall an
AV driver (“user”) be required to have a driving license at
all? Do there have to be any age requirements for AV
users? (Or a requirement to be sober?)
Should autonomous driving be allowed everywhere (on all
roads and every regions)? Should it be mandatory on
special roads or dedicated lanes?
Does autonomous driving have to follow all traffic rules?
If an AV violates a traffic rule, does it have to self‐report
to authorities?
Should there be an external indicator on the vehicle when
autonomous driving is engaged?
The research focusing on these questions is currently ongoing
as the main object of the first author’s rigorous thesis.
B. Civil Law
Civil law covers a wide range of legal challenges related to
AVs. The most significant challenge is connected with the
issue of civil liability. It includes on the on hand liability for
damage and/or injury, which is further connected with
insurance issues, and on the other hand, there is product
liability (a specific type of liability for damage and/or injury,
caused by a defective product).
In this regard, an article from a German insurance journal
is worth mentioning [5]. In the article, the author outlines two
possible conceptual approaches that would contribute to reach
clear liability rules pertaining to AVs and clear insurance
coverage. Furthermore, it would result in minimization of
litigation. The first approach is based on a compulsory motor
third party liability (MPTL) insurance under the regime of
strict liability by mandating AV manufacturers to contribute a
portion of the insurance for each individual vehicle. However,
manufacturers would be exempted from product liability for
injury and damage that is covered under the compulsory
MPTL insurance regime and that was caused by a product
defect affecting AV functionality, unless the defect is the
result of gross negligence. This approach is rather theoretical
than pragmatic due to possible administration difficulties.
According the second approach, which suggests product
liability to be further sharpened, the requirement of a product
defect should be omitted. Instead, the manufacturer should be
held liable for injury and damage caused by the way goods
acted (i.e. the way of their actions and behavior; their effect;
and the failure of the goods to act or to behave in a particular
way, or to have a particular effect). The main argument for
this approach is the following: while AVs will be much safer
than conventional cars, the technology in the product is so
complex that there is an uncontrollable residual risk of
malfunctioning even when the product is free from defects.
Hence, the legislation should introduce an irrefutable
presumption of a defect in a highly or fully automated vehicle
that causes an accident, unless the manufacturer can prove that
the autonomous vehicle functionality was not the cause of the
accident. The MTPL regime would in this alternative remain
identical to the first approach, except that manufacturers
would not be incorporated into the MTPL system.
C. Criminal Law
Autonomous driving-inspired legal challenges in the area
of criminal law include especially the issue of criminal
responsibility as well as protection against cybercrime and
hackers. In general, research in this area is dealing with the
following questions:
What crimes may be committed in context of autonomous
vehicles?
Who should be held responsible in case when using an AV
a crime is committed (the owner of the vehicle; the person
who is sitting in the driver’s seat – if there is any kind of it;
the vehicle manufacturer; the mechanic who mounted the
autonomous technology to the vehicle or another entity)?
The incidents may happen under various circumstances.
Will the responsible subject change depending on these
circumstances and if so, how? What are basic model
scenarios of incidents related to the use of autonomous
vehicles?
How should the law react, if the criminally responsible
subject is a legal entity?
As for the criminal responsibility for harm caused by an
AV, according to most European states’ criminal codes, the
driver (or vehicle owner) may be charged with negligence
even if the AV was in control (in autonomous mode). If no
negligence is proved, the criminally responsible entity is the
manufacturer. Since in most cases, a vehicle manufacturer is a
legal entity, it is highly important to consider the issue of
corporate criminal responsibility. The European Union
countries do not have an identical legislation in this area.
Some countries' criminal codes (including the Slovak republic
as well) are built on the idea of personal guilt. These codes
would definitely need an amendment. Hence, any research
questions focusing on corporate criminal responsibility are on
high importance.
According to the relevant statements of the Slovak
Criminal Code,8 a vehicle driver (resp. owner) may be held
criminally responsible for causing death, harm (or creating
danger for another) by negligence, even if the autonomous
vehicle was in control [31]. It means that the driver acted
negligently, i.e. failed to exercise reasonable care. But what
constitutes reasonable care for the driver? Checking the
functioning of the elements of the car’s autonomous systems
at regular intervals? If so, the driver may be blamed because
s/he failed to examine properly whether the sensors or the
autonomous technology were functioning correctly before the
car was starting a journey. May the law require the driver to
8 Chapters 149, 157, 285 of Act of the Slovak republic No. 300/2005 Coll.
Criminal Code, as amended.
look under the algorithm hood? This statement results in the
following dilemma: autonomous systems are installed into the
car to relieve the driver of various driving tasks; however, the
driver remains responsible for monitoring that the autonomous
system is performing the driving tasks correctly, and, where
necessary, taking corrective actions. Therefore, the driver is
not allowed to pursue other activities like reading an email or
watching a film, let alone work or sleep at the same time he is
'in control' of the car. The potential utility of the autonomous
system for the driver (but not for road safety in general) is
therefore significantly reduced [7].
As mentioned above, by the use of autonomous vehicles,
the most potential crimes that may arise are mainly crimes
against life and health (especially unintentional offences, such
as causing another's death, causing bodily injury or illness or
creating danger to another). /In context of intention, it is also
an interesting question, whether a fully AV can commit an
intentional crime/. However, it must not be forgotten about a
relatively new phenomenon, the cybercrime. Since AVs are
governed by a kind of software facility, which can be an
object of several hacker attacks, it is specifically important to
ensure an adequate protection to vehicle users. This protection
has two aspects: on the one hand, the criminal aspect –
protection against cybercrime provided by criminal codes, and
on the other hand, it is the development of appropriate security
system regulated by technical norms and standards.
V. CONCLUSION
Legal regulation of autonomous vehicles is a fairly
complex object of research, all the more exciting, though. The
most significant benefit of autonomous vehicles is a much
safer driving environment. Accidents, however, will always be
an aspect of motor vehicle travel and it must be decided who
is to be held responsible in such cases.
European Union countries have a legal framework that will
be well equipped to address and adapt to all the mentioned
challenges in legal regulation of autonomous vehicles that
arise in the coming years. Some (not radical) legislative
adjustments will probably be needed. However, having
considered the massive reduction of injuries and fatalities
caused by road accidents, and the other benefits of the
autonomous technology, it is absolutely worth making those
legal changes that will lead to clearer rules and practical
reality.
This in turn requires a broad cooperation of lawmakers and
technical professionals in order to achieve the most
appropriate solutions. That is exactly what we attend to call
for by the main contribution of the article which is giving a
brief insight to some legal aspects of autonomous vehicles for
technical professionals.
APPENDIX
Federal Automated Vehicles Policy issued by the U.S. National
Highway Traffic Safety Administration (NHTSA)
1. Vehicle Performance Guidance for Automated Vehicles
It is a 15 point “Safety Assessment” for the safe design, testing
and deployment of automated vehicles. The manu-facturer shall
send in a statement addressing the 15 points below. There is no
formal approval process.
• Operational Design Domain: How and where the highly
automated vehicle (HAV) is supposed to function and
operate;
• Object and Event Detection and Response: Perception-
and response functionality of the HAV system;
• Fall Back (Minimal Risk Condition): Response and
robustness of the HAV upon system failure;
• Validation Methods: Testing, validation, and verification
of an HAV system;
• Registration and Certification: Registration and
certification to NHTSA of an HAV system;
• Data Recording and Sharing: The HAV system’s data
recording for information sharing, knowledge building
and for crash reconstruction purposes;
• Post-Crash Behavior: Process for how an HAV should
perform after a crash and how automation functions can
be restored;
• Privacy: Privacy considerations and protections for users;
• System Safety: Engineering safety practices to support
reasonable system safety;
• Vehicle Cybersecurity: Approaches to guard against
vehicle hacking risks;
• Human Machine Interface: Approaches for commu-
nicating information to the driver, occupant and other road
users;
• Crashworthiness: Protection of occupants in crash situ-
ations;
• Consumer Education and Training: Education and
training requirements for users of HAVs;
• Ethical Considerations: How vehicles are programmed to
address conflict dilemmas on the road; and
• Federal, State and Local Laws:
2. Model State Policy
It contains recommended policy areas for states to consider, with
a goal of generating a consistent national framework for the
testing and deployment of HAVs. States can set up the following
administrative structure and processes to administer requirements
regarding the use of public roads for HAV testing and
deployment in their states:
• Application by manufacturers or other entities to test
HAVs on public roads;
• Jurisdictional permission to test;
• Testing by the manufacturer or other entities;
• Drivers of deployed vehicles;
• Registration and titling of deployed vehicles;
• Law enforcement considerations; and
• Liability and insurance.
The federal government is hoping that the states will adopt this
policy. It would avoid a patchwork of state laws.
3. Current Regulatory Tools of the Department of
Transportation (DOT) that can be used to accelerate the safe
development of HAVs. The federal government will explore how
the existing regulatory tools can be applied to the autonomous
driving (AD) development.
• Interpretations;
• Exemptions;
• Rulemakings;
• Enforcements.
4. Modern Regulatory Tools
Considered New Authorities
NHTSA is looking into new ways to regulate the AD development,
such as:
• Safety Assurance: Pre-market testing, data and analyses to
DOT to demonstrate that organization’s design, manufac-
turing and testing processes apply NHTSA’s vehicle
performance guidance.
• Pre-Market Approval: Pre-market approval authority, in
which the government inspects and affirmatively approves
new technologies, would be a departure from NHTSA’s
current self-certification system. The merits and
challenges of implementing some form of a pre-market
approval are discussed.
• Cease and Desist: Require manufacturers to take
immediate action to mitigate safety risks that are so
serious and immediate that they constitute “imminent
hazards.”
• Expanded Exemptions: Raising the cap on the number of
vehicles subject to exemption and/or the length of time of
exemptions, to facilitate the safe testing and introduction
of HAVs.
• Post-sale Regulation of Software Changes: Regulate post-
sale software changes in HAVs.
Considered New Tools
• Variable Test Procedures: Expand vehicle testing
methods to create test environments more reflecting real-
world environments.
• Functional and System Safety: Make mandatory the 15-
point Safety Assessment envisioned in the first section
(Vehicle Performance Guidance).
• Regular Reviews: Regular reviews of standards and
testing protocols to keep current with the development of
technology.
• Additional Recordkeeping and Reporting: Require
additional reporting about HAV testing and deploy-ment.
• Enhanced Data Collection: Enhance data recorders and
greater reporting requirements about the performance of
HAVs.
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