Tom Brewer, CEO/President of Intelligent Mobility Planning, LLC and long-time expert in automotive matters in Tennessee, offers the below thoughts on the status of vehicle testing. Baker Donelson has been fortunate to work on a project with Mr. Brewer, and we are very impressed with the depth of his knowledge.
As connected and automated vehicle (CAV) technology races toward reality, there is an equal (if not greater) number of issues to address concerning safety, liability, infrastructure and cybersecurity. These issues are beginning to be defined and developed through testing, validation and certification (TV&C) protocols by numerous entities (Academic / Industry / Government Agencies) in the U.S. and worldwide.
However, the current dichotomy is that technological advancement (vehicle and systems) is happening at warp-speed, while the TV&C updated CAV requirements from the U.S. National Highway Traffic Safety Administration’s Federal Motor Vehicle Safety Standards is moving at a snail’s pace – not an uncommon divide – but a deliberate approach is certainly reasonable and acceptable.
A 2017 report by the Governor’s Highway Safety Association provided five recommendations to state leaders:
- Be informed.
- Be a player.
- Understand your state role.
- Don’t rush in to enacting laws and regulations.
- Be flexible. THIS IS A NEW GAME!
This advice is invaluable because many agencies, industry inventors / innovators, and legislators are still struggling with definitions:
- operator versus driver (driverless);
- autonomous versus automated;
- pilot versus development;
- state versus federal authority;
- testing requirements (systems infrastructure versus vehicle);
- testing data management / storage; and
- testing protocols (OEM vs. third-party independent).
There are 58 documented mobility / vehicle proving grounds (U.S. 32 / Europe 14 / Asia 12; mostly OEM/supplier owned) globally that are currently preparing their facilities and processes for the immense and unprecedented change in the next 10 to 15 to 20 years, but they are preparing without the completed “playbook.” There is much more to come.
So remember recommendation #5 above. Be flexible. THIS IS A NEW GAME!