AUTOMATED 

VEHICLES

Comprehensive Plan 

Could Help DOT 

Address Challenges

Report to Congressional Committees

November 2017

GAO-18-132

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-132, a report to 

congressional committees

November 2017

AUTOMATED VEHICLES

Comprehensive Plan Could Help DOT Address 

Challenges

What GAO Found

Automated cars and light-duty trucks—from vehicles already on the road 

equipped with driver assistance technologies to fully driverless cars still in 

development—pose safety and infrastructure challenges for 

policymakers, according to literature GAO reviewed and stakeholders

GAO interviewed. For example, policymakers will need to decide if the 

current approach to vehicle testing and standards is sufficient to ensure 

adequate vehicle safety, according to many stakeholders GAO 

interviewed. Further, policymakers may want to address how automated 

vehicles interact with other road users (see figure below). Likewise, 

automated vehicles may require infrastructure changes, and 

policymakers will need to decide what changes to pursue, while also

providing for conventional vehicles since many stakeholders expect 

conventional vehicles to remain on the roads for decades.

Examples of Potential Driving Scenarios That Could Pose Challenges 

The U.S. Department of Transportation (DOT) has made efforts to 

respond to some of these challenges. For example, DOT’s National 

Highway Traffic Safety Administration has conducted defect 

investigations and pursued recalls of some driver-assistance 

technologies. In September 2017, DOT issued new voluntary guidance

that provides technical assistance for states and suggests a framework 

for industry-led safety testing.

However, DOT does not have a comprehensive plan that sets clear 

goals, that establishes when and how it will act, or that indicates how it 

will monitor progress. According to officials, DOT recently formed a group 

to lead policy development in the future, but has not announced a 

detailed timeframe or scope of work. Without a comprehensive plan, it is 

unclear whether DOT’s efforts are adequately tackling automated vehicle 

challenges. DOT has an opportunity to enhance federal leadership on 

automated vehicle challenges and a comprehensive plan could be a first 

step toward doing so.

View GAO-18-132. For more information, 

contact David Wise at (202) 512-2834 or 

wised@gao.gov.

Why GAO Did This Study

Automated vehicles potentially promise 

transformative benefits in safety, 

mobility, and other areas. However, the 

successful development of these 

vehicles and technologies may pose a 

range of challenges for policymakers to 

confront. DOT is the lead federal 

agency for vehicle safety and road 

infrastructure.

Recent legislation included a provision 

for GAO to review automated vehicle 

policy and DOT’s readiness to address 

challenges. This report addresses: (1) 

what selected stakeholders and 

literature identify as potential safety 

and infrastructure challenges 

automated vehicles pose for 

policymakers and (2) DOT’s efforts in 

response to these challenges. GAO 

reviewed selected literature and 

interviewed 27 selected stakeholders 

to identify policy challenges and views 

on DOT’s efforts. GAO judgmentally 

selected these stakeholders—including 

state transportation officials, academic 

experts, and industry representatives—

to obtain a wide-range of perspectives 

and expertise. The results are nongeneralizable. GAO also reviewed 

DOT’s policy and program 

documentation and interviewed agency 

officials. GAO compared DOT’s efforts 

with leading planning principles 

identified in prior GAO work and 

federal internal control standards. 

What GAO Recommends

GAO recommends that DOT develop a 

comprehensive plan to better manage 

departmental initiatives related to 

automated vehicles. DOT concurred 

with the recommendation.
Page i GAO-18-132 Automated Vehicles

Letter 1

Background 5

Selected Stakeholders and Literature Cite Many Challenges 

Automated Vehicles Present for Policymakers 10

DOT Has Made Efforts to Address Challenges Posed by 

Automated Vehicles but Does Not Have a Comprehensive Plan 19

Conclusions 30

Recommendation for Executive Action 30

Agency Comments 30

Appendix I Literature Reviewed and Selected Stakeholders Interviewed 32

Appendix II Comments from the Department of Transportation 37

Appendix III GAO Contact and Staff Acknowledgments 38

Related GAO Products 39

Tables

Table 1: DOT’s Activities to Advance the Deployment of Smart 

Infrastructure and Automated Vehicle Technologies 25

Table 2: Organization, Type, and Description of Selected 

Stakeholders 34

Figures

Figure 1: Levels of Driving Automation Used by Department of 

Transportation 6

Figure 2: Examples of Potential Driving Scenarios That Could 

Pose Policy Challenges Related to Automated Vehicles 14

Figure 3: Comparison of National Highway Traffic Safety 

Administration’s (NHTSA) Federal Automated Vehicle 

Policy (2016) and Vision for Safety (2017) 21

Contents
Page ii GAO-18-132 Automated Vehicles

Abbreviations

ADS automated driving systems 

DOT U.S. Department of Transportation 

FAST Act Fixing America’s Surface Transportation Act 

FAVP Federal Automated Vehicles Policy 

FHWA Federal Highway Administration 

GPS Global Positioning System

JPO Intelligent Transportation Systems–Joint Program Office

LIDAR light detection and ranging (sensors)

NHTSA National Highway Traffic Safety Administration 

V2X vehicle-to-everything

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Page 1 GAO-18-132 Automated Vehicles

441 G St. N.W.

Washington, DC 20548

November 30, 2017

The Honorable John Thune

Chairman

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Bill Shuster

Chairman

The Honorable Peter A. DeFazio

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Lamar S. Smith

Chairman

The Honorable Eddie Bernice Johnson

Ranking Member

Committee on Science, Space, and Technology

House of Representatives

Automated vehicles, from those that assist drivers with some driving tasks 

to fully self-driving cars, promise transformative benefits such as reducing 

crashes and fatalities, easing congestion, and increasing mobility. The 

U.S. Department of Transportation (DOT) has calculated that 94 percent 

of crashes can be tied to a human choice or error, and many observers 

believe that automated vehicle technologies could reduce or eliminate 

these errors.1 For example, technologies that automatically slow or stop a 

vehicle when it predicts a forward collision can mitigate accidents due to 

inattentive driving and save lives. Further, fully self-driving vehicles could 

reduce traffic congestion through more efficient operations or make time 

in the car less onerous by freeing drivers from some or all driving 

responsibilities. Moreover, people with physical limitations that prevent 

them from operating a vehicle may find that driverless vehicles provide 

them with greater mobility. DOT has stated that automated vehicle 

 1

S. Singh, Critical Reasons for Crashes Investigated in the National Motor Vehicle Crash 

Causation Survey Traffic Safety Facts, Crash Stats. Report No. DOT HS 812 115. 

(Washington, D.C.: National Highway Traffic Safety Administration, February 2015). 

Letter
Page 2 GAO-18-132 Automated Vehicles

technologies, including fully self-driving cars, may prove to be the 

greatest personal transportation revolution since the popularization of the 

personal automobile a century ago.2

Automakers and technology firms are investing heavily to develop and 

deploy automated vehicles. Already, automated technologies are 

changing cars and light trucks, as well as other vehicles. For example, 

automated parking and adaptive cruise control are available on cars for 

sale today. However, for these benefits to be realized, policymakers must

confront an array of challenges now, as technologies are developed and 

tested and in the future as vehicles become widely available. Some of 

these challenges include vehicle safety and infrastructure development.

Within DOT, the National Highway Traffic Safety Administration (NHTSA) 

leads federal efforts to improve car and light-duty truck safety, among 

other responsibilities, and the Federal Highway Administration (FHWA) 

governs multiple infrastructure programs. In September 2017, NHTSA 

released Automated Driving Systems 2.0: A Vision for Safety to provide 

manufacturers, state governments, other entities, and stakeholders with 

testing and deployment guidance.3 State and local governments also 

have roles and responsibilities to play in planning, building, and 

maintaining infrastructure; licensing drivers; registering vehicles; and 

enforcement, and more. Industry observers predict initial deployments of 

automated vehicles in limited situations—such as geographically 

constrained areas or only for hired rides—but expect broader usage in the 

future.

The Fixing America’s Surface Transportation Act (FAST Act), signed into 

law in December 2015, includes a provision for GAO to review automated 

vehicle policy and DOT’s readiness to address challenges related to the 

eventual implementation of this technology.4 In this report we examine: 

(1) what selected stakeholders and literature identify as potential safety 

and infrastructure challenges posed by automated cars and light trucks 

 2

NHTSA, Federal Automated Vehicles Policy: Accelerating the Next Revolution in 

Roadway Safety (September 2016).The Federal Automated Vehicles Policy (FAVP)

established an initial foundation and framework for DOT’s actions related to vehicle 

automation.

3

NHTSA, Automated Driving Systems 2.0: A Vision for Safety, (Washington, D.C.: 

September 2017), which replaced the FAVP. 

4

Pub.L. No.114-94, title VI, § 6025, 129 Stat. 1312, 1586 (2015).
Page 3 GAO-18-132 Automated Vehicles

that policymakers face; and (2) DOT’s efforts to respond to these 

challenges.

To identify and describe safety and infrastructure challenges posed by 

vehicle automation, including vehicle safety, roadway operations and 

design, among other areas, we reviewed literature on this topic and 

interviewed 27 selected stakeholders. To identify recent, pertinent 

literature, we searched bibliographic databases, including Transportation 

Research International Documentation and Scopus for literature from 

2014 or later. We identified scholarly and trade citations using search 

terms related to automated vehicle concepts and policies. Books, journal 

articles, government reports, and industry and think-tank publications 

were considered, among other types of literature. We determined that 

selected works were credible based on factors including the 

demonstrated expertise of the author or source and recommendations 

from experts.

We also selected stakeholders to interview, including representatives of 

10 companies and industry groups; 7 governmental organizations (e.g., 

representatives of state governments or national associations); 6 

academics; and 4 safety organizations. We selected these people and 

entities to interview based on considerations such as recent engagement 

with relevant topics (e.g., publication of articles or significant investments 

in automated technology), recognized expertise; and institutional 

relevance to identified challenges (e.g., we interviewed groups that 

represent the automotive industry, state transportation officials, and so 

forth). We conducted these interviews prior to the release of NHTSA’s A 

Vision for Safety in September 2017, so stakeholders were not able to 

comment on it. To cover the wide range of topics pertinent to automated 

vehicles, our selections of literature and interviews reflect a range of 

perspectives, topics, and areas of expertise. We relied on the information 

gathered through these selections collectively to develop categorizations 

and descriptions of automated vehicle challenges. We analyzed the 

content of our interviews and literature review to identify policy challenges 

and themes that could be the basis for these categorizations. When 

appropriate, we indicate whether the challenges we summarize were 

identified by some, many, or most of the interviewees or works of 

literature, but frequency may not necessarily be indicative of the relative 
Page 4 GAO-18-132 Automated Vehicles

importance of a challenge or consensus, or lack thereof.5 The results of 

our literature review and interviews are non-generalizable. However, we 

determined that our selection methodologies were appropriate for our 

design and objectives and that these methodologies would generate valid 

and reliable evidence to support our work. See appendix I for citations of 

literature reviewed and a list of entities we interviewed. Further, to 

describe the extent of state legislative activities related to automated 

vehicles, we used a database maintained by the National Council of State 

Legislatures. We did not independently perform a data reliability 

assessment of these data.

To examine DOT’s efforts to respond to the challenges we identified, we 

reviewed relevant DOT laws, regulations, and agency guidance and 

interviewed DOT officials and the selected stakeholders described above. 

We assessed DOT’s efforts compared to sound-planning practices that 

we identified through a review of relevant literature, prior GAO work, and 

the Standards for Internal Control in the Federal Government.

6 We 

identified prior GAO reports where we defined a number of desirable 

characteristics of an effective, results-oriented plan or components of 

sound-planning practices.7 We selected the specific planning practices 

we used as criteria by determining which were most applicable to DOT’s 

recent efforts to incorporate automated vehicles in its policies and 

programs. We focused on NHTSA, FHWA, and the Office of the 

Secretary of Transportation because they have led many of DOT’s 

automated vehicle efforts to date.

We conducted this performance audit from November 2016 to November 

2017 in accordance with generally accepted government auditing 

 5

To describe the frequency of stakeholder views, we use “some” when 2 to 6 stakeholders 

indicated a shared viewpoint, “several” for 7 to 11, “many” for 12 to 16, and “most” for 17 

to 21 in situations in which all 27 interviews were applicable. 

6

GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014), contains the internal control standards to be 

followed by executive agencies in establishing and maintaining systems of internal control 

as required by 31 U.S.C. § 3512 (c), (d). 

7

In past reports, we have identified best practices in planning. For example, see GAO, 

Executive Guide: Effectively Implementing the Government Performance and Results Act,

GAO/GGD-96-118 (Washington, D.C.: June 1, 1996); GAO, Combating Terrorism: 

Evaluation of Selected Characteristics in National Strategies Related to Terrorism,

GAO-04-408T (Washington, D.C.: Feb. 3, 2004); and GAO, Veterans’ Health Care: Proper 

Plan Needed to Modernize System for Paying Community Providers, GAO-16-353 

(Washington, D.C.: May 11, 2016). 
Page 5 GAO-18-132 Automated Vehicles

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Automated vehicles can perform certain driving tasks without human 

input. They encompass a diverse range of automated technologies 

ranging from relatively simple driver assistance systems to fully selfdriving vehicles. Certain automated features, like adaptive cruise control, 

can adjust vehicle speed in relation to other objects on the road and are 

currently available on various car models. Over the next several years, 

auto makers expect to market vehicles capable of fully operating without 

the aid of a human driver under certain conditions. DOT has adopted a 

framework for automated driving developed by SAE International, which 

categorizes the levels of automation into 6 levels (See fig. 1).

Background

Automated Vehicles
Page 6 GAO-18-132 Automated Vehicles

Figure 1: Levels of Driving Automation Used by Department of Transportation

a

LIDAR is a technology that uses laser remote sensing to map the vehicle’s surroundings.

b

Inertial navigation systems consist of gyroscopes and accelerometers to constantly track the 

vehicle’s position and help improve the accuracy of the GPS

c

V2X encompasses communication between other vehicles or other permanently installed 

infrastructure.

Vehicles with Level 0, 1, and 2 technologies, as outlined in figure 1, are 

already available for private ownership and currently operate on public 

roadways. Level 0 encompasses conventional vehicles where a human 

driver controls all aspects of driving. Systems that warn drivers of safety 

hazards, such as forward collision warning, but do not take control away 

from the driver are not considered automated. Level 1 technologies 
Page 7 GAO-18-132 Automated Vehicles

incorporate automatic control over one major driving function, such as 

steering or speed, and examples include adaptive cruise control and 

technology that provides assistance keeping within a lane. With Level 2 

the automated systems can control both steering and lane positioning in 

certain conditions, though the human driver must maintain situational 

awareness to ensure safe functioning.

In the September 2017 Vision for Safety, NHTSA categorizes vehicles 

with Level 3, 4, and 5 technologies as Automated Driving Systems 

(ADSs).8 Vehicles with ADS are still in development, and automakers and 

technology firms are actively testing them, sometimes on public roads. 

With Level 3 autonomy, the system can take full control of the vehicle in 

certain conditions. However, it may not be able to navigate all driving 

scenarios, in which case it would pass control back to the human driver 

who must maintain situational awareness to ensure safe functioning. With 

Level 4, automation controls all aspects of driving in certain driving 

conditions and environments, and with Level 5 the vehicle can operate 

fully, in any condition or environment, without a human driver or occupant. 

Some automakers have indicated their intention to release Level 4 

vehicles for use in defined scenarios, such as select commuter roads or 

in a ride-sharing platform as early as 2021.9

DOT has long-standing activities aimed at advancing connected vehicle 

technologies. Connected technologies allow vehicles to communicate 

with other vehicles (vehicle-to-vehicle), roadway infrastructure (vehicle-to-

 8

NHTSA’s 2016 FAVP referred to Levels 3–5 vehicles as “Highly-Automated Vehicles.”

Throughout this report, we adopt DOT’s current terminology where appropriate, but use 

the term “automated vehicles” to refer to vehicles at any level of automation. The 2017 

Vision for Safety focuses specifically on Levels 3–5 vehicles, whereas the 2016 FAVP 

applied to Levels 2–5 vehicles. 

9

We did not assess the likelihood to which industry forecasts are accurate.
Page 8 GAO-18-132 Automated Vehicles

infrastructure), and personal communication devices.10 These 

technologies could complement automated technologies, and DOT has 

indicated that connected vehicle technologies could be critical to the 

success of automated vehicles’ safety. For example, connected 

technologies could help automated vehicles maintain or improve 

situational awareness by communicating traffic control messages that 

camera and radar-based crash avoidance technologies may not be able 

to detect because of obstructions such as buildings or fog. DOT’s 

research and other efforts related to connected vehicles historically have 

been largely independent of vehicle automation, but recent departmental 

efforts have sought to study the potential interactions and synergies 

between the two concepts.

As the lead federal department responsible for vehicle safety and 

roadway infrastructure programs, DOT is responsible for coordinating 

automated vehicle policy at the federal level.11 Through its various offices 

and modal administrations, DOT executes a broad range of 

responsibilities for promoting safe and efficient transportation. NHTSA 

and FHWA are the primary operating administrations within DOT that 

oversee vehicle safety and infrastructure issues,12 while the Office of the 

 10See GAO, Intelligent Transportation Systems: Vehicle-to-Infrastructure Technologies 

Expected to Offer Benefits, but Deployment Challenges Exist, GAO-15-775 (Washington, 

D.C.; Sept. 15, 2015) and GAO, Intelligent Transportation Systems: Vehicle-to-Vehicle 

Technologies Expected to Offer Safety Benefits, but a Variety of Deployment Challenges 

Exist, GAO-14-13 (Washington, D.C.: Nov. 1, 2013). Vehicle-to-vehicle systems rely on invehicle equipment that transmits data between vehicles, enabling applications that can 

warn drivers of road conditions and hazards. Vehicle-to-infrastructure systems transmit 

data between vehicles and roadway infrastructure, such as signage and signal lights. 

These technologies typically communicate using Dedicated Short Range 

Communications, a technology similar to Wi-Fi that offers a link through which vehicles 

and infrastructure can transmit messages over a range of about 300 to 500 meters. 

Currently, these technologies are still being tested and are available on select models. 

11Other federal agencies, such as the Federal Communications Commission and National 

Transportation Safety Board have roles that intersect with automated vehicles. For 

example the Federal Communications Commission monitors radiofrequency spectrum, 

which automated or connected vehicles may use for wireless communications. The 

National Transportation Safety Board has authority to investigate major highway 

accidents, and this authority extends to accidents involving automated vehicles. 

12The Federal Motor Carrier Safety Administration, Federal Transit Administration, and 

Federal Railroad Administration are also DOT administrations that have various roles that 

relate to safety and infrastructure. The Federal Motor Carrier Safety Administration also 

has a role on the operations side for commercial vehicles. However, such responsibilities 

are not covered in this report.

Government Roles
Page 9 GAO-18-132 Automated Vehicles

Under Secretary for Policy and the Office of the Assistant Secretary for 

Research and Technology coordinate policy and research efforts, 

respectively.

NHTSA—NHTSA is responsible for enhancing the safety of vehicles, 

including automated vehicles, and does so through several different 

means that include: developing and enforcing Federal Motor Vehicle 

Safety Standards, promoting safety, leading defect and crash 

investigations, and identifying safety trends and countermeasures.

• The Federal Motor Vehicle Safety Standards are minimum safety 

requirements under which manufacturers of motor vehicles and motor 

vehicle equipment self-certify conformance. NHTSA does not preapprove vehicles and equipment before they enter the marketplace.

• NHTSA’s New Car Assessment Program promotes safety through a 

5-star Safety Ratings Program, which evaluates new vehicles for 

crash worthiness and rollover protection beyond what is required by 

the vehicle standards as well as recognizing vehicles equipped with 

certain crash avoidance technologies, such as forward collision 

warning systems.

• NHTSA can require a recall of vehicles or equipment deemed to pose 

an unreasonable risk to motor vehicle safety, and this authority 

extends to automated vehicle technologies. NHTSA identifies possible 

vehicle defects by gathering data from consumer complaints, 

manufacturer information, and other sources to decide whether an 

investigation should be initiated and if a recall is warranted.13

• NHTSA tracks and monitors safety trends by collecting vehicle safety 

data through its administration of the Fatality Analysis Reporting 

System, which records annual statistics on fatal motor vehicle 

crashes. NHTSA’s Special Crash Investigations teams also help 

collect data on unique vehicle crashes and publish summaries of 

incidents to aid the automotive safety community in identifying issues 

and improving the performance of advanced safety systems.

FHWA—FHWA is responsible for improving mobility and ensuring the 

safety of the country’s highways through funding, research, and guidance. 

 13Vehicle manufacturers also have a responsibility to report and conduct recalls of 

defective technologies independent of direction to do so from the federal government. See 

GAO, Auto Safety: NHTSA Has Options to Improve Safety Defect Recall Process, 

GAO-11-603 (Washington, D.C.: June 15, 2011).
Page 10 GAO-18-132 Automated Vehicles

FHWA administers the federal-aid highway program, which distributes 

approximately $40 billion per year to states for infrastructure projects to 

build and maintain highways, roads, and bridges. FHWA also provides 

guidance on transportation planning, roadway design, operations, and 

other areas to support state and local transportation agencies, which own 

most of the nation’s roads. FHWA also has been a proponent of 

advancing vehicle-to-infrastructure and vehicle-to-vehicle communication 

technologies.

Policy and Research—The Office of the Under Secretary for Policy is

the focal point for developing and coordinating DOT’s automated vehicle 

policies. Likewise, the Intelligent Transportation Systems–Joint Program 

Office (JPO) within the Office of Assistant Secretary for Research and 

Technology is responsible for advancing research and other advanced 

technology efforts throughout DOT. NHTSA and FHWA manage 

research, development, and technology programs as well.

State, regional, and local governments also have responsibilities for 

automated vehicles. For example, state departments of transportation 

oversee the construction and maintenance of state and interstate 

highways, while state police departments enforce traffic laws, such as 

speed limits. States are also responsible for registering vehicles, licensing 

drivers, educating drivers, and regulating auto insurance. Regional 

governments have a variety of long-range infrastructure planning 

responsibilities. At the local level, towns and cities are responsible for 

infrastructure planning, construction, and maintenance; enforcement of 

traffic laws; and emergency services.

Challenges policymakers face include assuring that automated vehicles 

are safe and interact with other road users predictably, adapting road and 

other infrastructure to these vehicles, and addressing questions about 

how data generated by automated vehicles can be used. These 

challenges could spur shifts in the roles and responsibilities of different 

levels of government. Also, given the rapid pace at which automated 

technologies are developing, policymakers face uncertainties in timing 

their actions.

Selected 

Stakeholders and 

Literature Cite Many 

Challenges 

Automated Vehicles 

Present for 

Policymakers
Page 11 GAO-18-132 Automated Vehicles

According to literature we reviewed and stakeholders we spoke to, 

automated vehicles pose challenges to federal, state, and local-level 

policymakers across a wide range of areas and addressing these 

challenges will be important if society is to realize the potential benefits of 

these vehicles. Specifically, based on our literature review and 

stakeholder interviews, we found that the challenges facing policymakers 

can be categorized into four major topical areas: vehicle safety 

assurance, vehicle behavior, infrastructure adaptation, and data 

protection and use.

• Safety assurance: Policymakers will need to determine if the current, 

established approach to vehicle safety assurance is sufficient or if 

modifications or changes are needed, according to many stakeholders 

we interviewed and literature we reviewed. Manufacturers have long 

had the primary responsibility for safety testing of their vehicles and, 

according to the companies developing automated vehicles that we 

interviewed, will continue to focus on safety as they develop 

automated technologies.14 Policymakers also have a role in safety 

assurance through activities like crash testing and safety ratings. 

Across the range of different types of stakeholders we interviewed, 

stakeholders consistently indicated that the complexity of automated 

technologies and the difficulties in demonstrating their safety are a 

challenge for existing public-sector safety programs. Some 

stakeholders and literature suggested that policymakers may wish to 

examine alternative approaches, including third-party testing and 

establishing common testing standards. Other stakeholders—notably 

vehicle developers—advocated for maintaining the current structure.

 14Vehicle developers face a host of challenges in testing their technologies, according to 

DOT, stakeholders, and relevant literature. Developers must determine that their 

technologies function properly (e.g., can stay on the road, follow traffic laws, and avoid 

hazards). According to the literature we reviewed, vehicle developers are likely to need a 

combination of on-road testing, simulations, and other techniques to validate their 

technology functions as intended. For example, one study estimates that millions of onroad testing miles could be needed to prove that automated vehicles perform safely; so 

many, in fact, that the study concludes on-road testing alone may not be practical. Of 

particular concern might be situations that are atypical and may not be routinely 

experienced in on-road testing, but may actually be sometimes or commonly experienced 

by drivers (e.g., a child running into the street or a work zone). See Nidhi Kalra and Susan 

Paddock, “Driving to Safety: How many miles of driving would it take to demonstrate 

autonomous vehicle reliability?” Transportation Research Part A 94 (2016) 182-193 and 

Philip Koopman and Michael Wagner, Challenges in Autonomous Vehicle Testing and 

Validation, SAE World Congress, 2016-01-0128/16AE-0265.

Policymakers Face 

Challenges Posed by 

Automated Vehicles 

across a Wide Range of 

Areas
Page 12 GAO-18-132 Automated Vehicles

NHTSA’s Federal Motor Vehicle Safety Standards do not include 

specific requirements for ADS performance.15 Across the range of 

stakeholders we interviewed, there was broad agreement that the 

current vehicle standards are likely to need some modifications to 

allow for automated technologies to be fully incorporated into vehicle 

design. For example, some stakeholders told us that current 

standards could impede vehicle development because, for example, 

the standards assume the presence of a human driver. As reported by 

the Congressional Research Service, revising the Federal Motor 

Vehicle Safety Standards can take years.16 Views differed on what 

approach NHTSA should take to update the standards. For example, 

one safety organization we interviewed advocated the development of 

functional safety standards that explicitly define required aspects of 

vehicle performance. Alternatively, some companies and industry 

groups advocated increasing the number of vehicles NHTSA has 

authority to exempt from these standards to handle situations where 

current standards are not relevant for automated vehicles while 

maintaining the basic approach of the current standards.17

Policymakers have regulatory and enforcement tools to assure that 

vehicles on the road are safe, but these tools may need to be 

modified or enhanced to address automated vehicles, according to 

stakeholders we interviewed and our literature review. For example, 

we have previously found that NHTSA faces challenges in conducting 

defect investigations because of the difficulty in keeping up with 

changing technologies, among other things. Such challenges might 

result in difficulty determining when recalls are warranted.18 As with 

 15All vehicles, including automated vehicles, must meet these standards to be sold in the 

United States.

16Congressional Research Service, Issues with Federal Motor Vehicle Safety Standards, 

7-5700 (Washington, D.C.: March 2017). 

17Vehicle developers can request a temporary exemption from NHTSA from existing 

Federal Motor Vehicle Safety Standards if the manufacturer can make a sufficient showing 

to NHTSA that the exemption is necessary for research, testing, investigations, 

demonstrations, training, competitive racing events, show, or display. Vehicles exempted 

for testing purposes cannot be sold following the conclusion of testing. Currently, the 

Secretary of Transportation may temporarily exempt up to 2,500 vehicles from certain 

motor vehicle standards annually, if he or she deems it appropriate. Exemptions can last 

up to 3 years and renewals up to 2 years.

18GAO, Vehicle Safety: Enhanced Project Management of New Information Technology 

Could Help Improve NHTSA’s Oversight of Safety Defects, GAO-16-312 (Washington, 

D.C.: Feb. 24, 2016). 
Page 13 GAO-18-132 Automated Vehicles

vehicle safety testing, some stakeholders indicated that defect 

investigations may become increasingly challenging given that 

automated technologies are vastly more complex than conventional 

vehicles. A few stakeholders we interviewed mentioned that it could 

be difficult for investigators to inspect increasingly complex 

technologies that, in some cases, “make” decisions that cannot be 

explained after the fact. For example, the underlying basis for a 

specific decision made by some artificial intelligence technologies 

might be unknowable or untraceable, making assignment of fault 

difficult or impossible for investigators.

• Vehicle behavior: Stakeholders and literature we reviewed identified 

challenges with how automated vehicles operate in the world. For 

example, DOT has identified the importance of automated vehicles’

ability to operate in the traffic conditions the vehicles encounter,

including following laws and etiquette in responding to other vehicles 

and other road users such as pedestrians and law enforcement.19 As 

such, policymakers may want to address how developers handle 

these questions. Some stakeholders noted that public input would 

help developers better decide how their vehicles interpret and 

respond to the formal and informal rules of the road and interact with 

other road users, such as conventional vehicles, pedestrians, and 

cyclists. See figure 2. For example, policy decisions could include how 

much, if any, allowance ADSs should be given to selectively break 

traffic laws when the circumstances might call for it (e.g., should an 

automated vehicle speed to keep up with freeway traffic flow or cross 

double yellow lines to avoid a hazard or work zone?). DOT officials 

noted that automated vehicle technologies have a particularly difficult 

time handling work zones, pedestrians, cyclists, and other vulnerable 

road users. Moreover, there may be some situations in which an 

automated system is confronted with a situation in which there is no 

good outcome. However, some stakeholders we interviewed stated 

that moral dilemma questions are likely to be exceedingly rare.

 19In DOT’s 2016 Federal Automated Vehicle Policy, now replaced by A Vision for Safety, 

DOT uses “vehicle behavioral competencies” to refer to the ability of an automated 

vehicles to operate in the traffic conditions that it will regularly encounter, including 

keeping the vehicle in the lane, obeying traffic laws, following reasonable etiquette, and 

responding to other vehicles, road users, or commonly encountered hazards.
Page 14 GAO-18-132 Automated Vehicles

Figure 2: Examples of Potential Driving Scenarios That Could Pose Policy Challenges Related to Automated Vehicles

Policymakers also may have some role in educating the public about 

what behaviors to expect from automated vehicles, according to 

stakeholders and literature. While several stakeholders we 

interviewed agreed that the industry ought to have a sizable role in 

educating the public on the capabilities of the vehicles they sell, there 

could also be a public-sector role. For example, the public sector 

could help passengers understand if a system is not capable of safely 

operating at night or in poor weather conditions—decisions 

traditionally made by human drivers based on their judgment and 

experience and, at times, limited information about changing weather 

and road conditions—before they attempt to use it in those domains.
Page 15 GAO-18-132 Automated Vehicles

Law enforcement and emergency responders will need knowledge 

and procedures for handling automated vehicles on the road and at 

accident scenes. According to some stakeholders we spoke to and 

literature addressing state and local government responsibilities, 

policymakers will have a role in developing these procedures and 

educating public safety personnel. For example, one stakeholder 

commented that law enforcement will need protocols to pull over 

automated vehicles when warranted and, at a crash scene, 

procedures to retrieve vehicle data to aid crash investigations and

analysis. Because these protocols and procedures will need to work 

across a range of vehicle makes and models, some standardization 

will be needed, according to another stakeholder.

• Infrastructure adaptation: Automated vehicles may necessitate 

changes in roadway designs, land use, and other public infrastructure, 

but, based on literature we reviewed, DOT officials, and many 

stakeholders we interviewed, infrastructure will need to continue to 

serve conventional vehicles for decades to come. As a result, some 

stakeholders do not expect that fundamental changes in infrastructure 

design due to automation are likely to be widespread in the near-term. 

The vehicle developers we interviewed all stated that they are 

currently pursuing automation approaches that are designed to work 

on infrastructure as it currently exists, noting that a technology is not 

commercially viable if it requires perfectly designed and maintained 

roads. Nevertheless, several stakeholders highlighted the importance 

of well-maintained roads and consistent lane markings and signage 

for automated and conventional vehicles alike.20 DOT officials added 

that local ownership of the majority of U.S. roads complicates 

implementation of infrastructure changes because of the increased

number of stakeholders involved. 

Though highly uncertain, more substantial infrastructure adaptations 

could be justified in the long-term if ADSs become common, 

according to some stakeholders and literature. For example, highway 

capacity of existing roadways may increase if automated vehicles are 

able to safely follow one another more closely than conventional 

vehicles, according to officials we interviewed representing state 

transportation agencies. Likewise, as postulated in one study we 

reviewed, if driverless ride hailing becomes the norm, fewer on- and 

 20DOT officials added that infrastructure adaptations and challenges may differ in urban 

and rural areas and that rural fatalities comprise about half of all roadway fatalities. 
Page 16 GAO-18-132 Automated Vehicles

off-street parking spaces may be needed, allowing for these spaces to 

be repurposed for other uses. Further, land-use could change in more 

fundamental ways than just parking availability, either by encouraging 

more density (because ride-hailing works best in denser areas) or less 

(because longer trips become less onerous in an automated vehicle, 

increasing people’s willingness to undertake long commutes).21

Additionally, automated vehicles may benefit from complementary 

new technologies including vehicle-to-infrastructure and vehicle-tovehicle communications. For example, these technologies could warn 

drivers and vehicles of potentially dangerous road conditions ahead. 

However, as we have previously reported, for these communication 

technologies to work, public sector regulators and industry will need to 

establish standards, provide wireless spectrum, and deploy 

equipment.22 Officials representing state transportation agencies 

indicated that they are convening multiple groups to address topics 

such as these to facilitate connected- and automated-vehicle 

deployment.

• Data: Automated vehicles also raise questions for policymakers about 

data privacy, ownership, and access that, according to some 

stakeholders we interviewed, will need to be addressed. In each of 

these areas, as we have previously found, the public has needs for 

data to inform crash and defect investigations and safety analysis and 

transparency about consumer privacy protection.23 One academic we 

interviewed noted that state data privacy protections are typically 

based on the type of technology in use, not the nature or sensitivity of 

data, and are regulated by multiple entities. There is no 

comprehensive federal privacy law, but rather federal statutes and 

regulations are generally tailored to specific purposes, situations, and 

 21Automated vehicles could have implications for vehicle registration and other revenue 

streams that support infrastructure. Also, if automation accelerates transitions to electric 

vehicles, as some studies predict, then current revenue challenges for the Highway Trust 

Fund—which is the principle mechanism for funding federal highway and transit programs

—could be exacerbated because the Highway Trust Fund is largely funded through 

federal fuel tax revenues. Furthermore, changes in vehicle ownership and use could have 

workforce and energy implications.

22See GAO-14-13 and GAO-15-775. 

23See GAO-16-312 and GAO, Vehicle Data Privacy, Industry and Federal Efforts Under 

Way, but DOT Needs to Define Its Role, GAO-17-656 (Washington, D.C.: July 28, 2017).
Page 17 GAO-18-132 Automated Vehicles

types of information.24 Data protections are also determined by 

individual disclosure agreements from manufacturers and, where 

applicable, state laws. Furthermore, the large volumes of data 

automated vehicles are expected to collect also raise questions about 

data ownership and access. For example, automated vehicle data 

could provide investigators with new sources of data on facts and 

circumstances of motor vehicle crashes. However, for these uses to 

become a reality, clarification about who owns and who has access to 

these data is needed, according to some of the stakeholders we 

interviewed. DOT officials indicated that they expect existing data 

privacy policies and disclosure agreements to apply to automated 

vehicles. Additionally, data standards may be needed across vehicles 

so information collected from different vehicles can be compared, 

according to a safety organization we interviewed.

In addition to challenges related to specific areas, policymakers at the 

federal, state, and local levels may face challenges related to shifts in 

their traditional roles and responsibilities. According to some stakeholders 

we interviewed, there is a need for each level of government to examine 

current practices and, where necessary, make adjustments. Also, the 

literature we reviewed calls on states, regions, and local governments to 

prepare for automation.25 For example, an official with one state 

transportation agency indicated that there is a grey area about the state’s 

role in regulating Level 4 and Level 5 vehicles which would be controlled 

by software and could theoretically operate without a state licensed driver 

in the vehicle. This official wondered what kind of regulatory framework 

and division of state and federal responsibility is needed to ensure safety. 

An official with another state transportation agency noted that this state’s 

vehicle code is silent on automation and that the state is working to fill this 

gap with new rules that balance state and federal roles. Likewise, as we 

have previously reported, NHTSA has not fully defined its roles and 

 24The Federal Trade Commission is the lead federal agency in the area of consumer data 

privacy and security, providing guidance and education to consumers and industry and 

wielding enforcement authority to ensure that manufacturers and other stakeholders 

adhere to the data privacy and security commitments that they make to consumers.

25Some historical roles may remain relatively constant, but the nature of regulatory 

activities may change. For example, states may continue regulating auto insurance 

markets even as the increased safety of automated vehicles could shrink the industry.

Federal, State, and Local 

Government 

Responsibilities May Shift 

in Response to 

Challenges
Page 18 GAO-18-132 Automated Vehicles

responsibilities in the event of a cyberattack, to which automated vehicles 

could be vulnerable.26

Some states have instituted, or considered, new laws and regulations. 

Several stakeholders we interviewed expressed concerns that meeting 

different state requirements for testing and deployment could hinder 

safety testing and automated vehicle development. Officials with safety 

organizations and state transportation agencies consistently agreed that 

states should avoid enacting conflicting vehicle regulations, but held 

differing views on the best path for regulating automated vehicle safety. 

DOT has indicated that states will retain their traditional responsibilities, 

such as licensing, and stated the department’s vehicle safety objective is 

a shared national framework rather than a “patchwork” of state laws. To 

date, many states have considered automated vehicle legislation.27

According to the National Council of State Legislators, at least 41 states 

have considered some kind of automated vehicle-related legislation, such 

as requiring the state-licensing agency to study if automated vehicle 

regulations are needed, and 21 states passed legislation related to 

automated vehicles. Additionally, Governors of five states have issued 

executive orders related to automated vehicles.28

 26GAO, Vehicle Cybersecurity: DOT and Industry Have Efforts Under Way, but DOT 

Needs to Define Its Role in Responding to a Real-world Attack, GAO-16-350 (Washington, 

D.C.: March 24, 2016). As of May 2017, NHTSA had taken steps to define its roles and 

responsibilities to address cybersecurity and plans to continue to improve its response 

and coordination plan in fiscal year 2018.

27In addition, Congress is considering legislation that would preempt states from 

regulating automated vehicle design and safety. Legislation was passed by the House of 

Representatives on September 6, 2017, that includes a preemption provision. H.R 

3388,.115th Cong. (2017). Another automated vehicle bill, S. 1885, 115th Cong. (2017), 

was passed by the Senate Committee on Commerce, Science, and Transportation on 

October 4, 2017, and it also contains a preemption provision.

28Moreover, according to the National Council of State Legislators, state legislative activity 

in this area has increased in recent years with legislation introduced in 33 states in 2017, 

20 states in 2016, 16 states in 2015, 12 states in 2014, 9 states and Washington, D.C. in 

2013, and 6 states in 2012. See National Council of State Legislatures, Self-Driving 

Vehicles Enacted Legislation, accessed November 16, 2017, 

http://www.ncsl.org/research/transportation/autonomous-vehicles-self-driving-vehiclesenacted-legislation.aspx. We did not independently validate these numbers.
Page 19 GAO-18-132 Automated Vehicles

In addition to determining what policy actions should be taken and by 

whom, policymakers also face challenges in deciding when to do so. 

Automated technologies are rapidly changing, and consequently, it can 

be unclear when policymakers, regulators, or oversight bodies should act. 

For example, many stakeholders agreed that changes to the Federal 

Motor Vehicle Safety Standards are needed, but views differed about 

when such a revision is needed because premature actions could 

potentially hinder innovation. Likewise, regional government officials 

noted that making significant investment to adapt infrastructure for 

automated vehicles was difficult because it is hard to know when such 

investments should be made. For example, uncertainties about vehicleto-infrastructure standards create a risk that early investments by states 

or municipalities could prove to be in the wrong technologies, according 

to state transportation officials we interviewed. DOT officials also 

emphasized the importance of timing actions, noting, for example, that 

imposing vehicle standards too soon could constrain technology 

development and that well-timed standards can provide stability which 

may encourage industry investments.

Pilot programs can provide an incremental approach to addressing these 

uncertainties. For example, the City of Pittsburgh uses information gained 

from pilot programs to better understand emerging automated vehicle 

technologies, how the city should adapt its role in response, and when 

actions are needed to advance public-interest goals, such as equity and 

accessibility. Strategies such as this provide decision makers with a basis 

for decisions today about infrastructure needs decades in the future, but 

represent something of a departure from more traditional infrastructure 

planning approaches, according to some state, regional, and local 

officials we interviewed.

DOT has begun to address the challenges posed by automated vehicles 

by (1) issuing and revising departmental policies and guidance on vehicle 

safety and oversight; (2) revising programs to address automated-vehiclerelated research requirements and to advance new technologies; and (3) 

conducting internal management efforts such as workforce initiatives. 

While these early efforts represent progress, we found that DOT does not 

have a comprehensive plan that sets clear goals related to automated 

vehicles, that establishes when and how it will act to support those goals, 

or that identifies performance measures to monitor and gauge results. In 

the absence of such a comprehensive plan, as DOT, NHTSA, and FHWA 

Policymakers Face 

Challenges in Timing 

Actions

DOT Has Made 

Efforts to Address 

Challenges Posed by 

Automated Vehicles 

but Does Not Have a 

Comprehensive Plan
Page 20 GAO-18-132 Automated Vehicles

undertake these complex efforts, it is not clear that they are wellpositioned to fully address the challenges posed by automation.

Policy, Guidance, and Oversight Efforts

As of October 2017, DOT has developed and published several policies 

that start to address the challenges we previously discussed related to 

vehicle safety assurance and oversight, federal versus state roles, and 

infrastructure adaptation. According to DOT officials, DOT is first seeking 

to identify or determine best practices for automated vehicles as an 

incremental step in order to avoid issuing regulations prematurely that are 

unable to keep pace with rapidly advancing technologies. Thus far, DOTs 

activities include the following:

• Publishing Voluntary Guidance. In 2016, NHTSA issued the Federal 

Automated Vehicles Policy (FAVP), which discussed policy ideas in 

four areas: (1) vehicle safety assurance; (2) model state policy; (3) 

current regulatory tools; and (4) modern regulatory tools (see fig. 3).

DOT officials described the FAVP as an initial step toward 

establishing a regulatory framework for automated vehicle safety 

assurance and performance. The policy stated that the rapid 

development of complex, automated vehicle technologies called on 

DOT to take new approaches to ensure these technologies achieve 

their safety potential and do not introduce new safety risks. 

Stakeholders we spoke to broadly agreed that issuing the FAVP was 

a positive first step for DOT, but most stakeholders said that details in 

the FAVP needed clarification. For example, 7 of the 10 companies 

and industry groups we interviewed indicated that NHTSA’s idea for 

manufacturers to voluntarily submit a 15-point certification, called a 

“Safety Assessment Letter” and a major aspect of the FAVP’s section 

on vehicle safety assurance, needed more detail and a few indicated 

that the lack of detail created uncertainties in their own planning.29

DOT held public meetings on the FAVP and solicited written 

comments.

In September 2017, NHTSA issued A Vision for Safety, which sought 

to address stakeholder comments on the 2016 FAVP and incorporate 

current policy priorities. This document states that DOT’s role is to 

encourage the development of safe automated vehicle technologies 

 29NHTSA did not receive any Safety Assessment Letters following the publication of the 

FAVP and the issuance of A Vision for Safety, which replaced it. 

DOT Has Undertaken a 

Range of Initial Efforts to 

Respond to Various 

Automated Vehicle 

Challenges
Page 21 GAO-18-132 Automated Vehicles

through a flexible, nimble non-regulatory framework. Like the FAVP, 

the new guidance includes a voluntary, manufacturer-led safety selfassessment and addresses the division of federal and state 

responsibilities. For example, it discusses roles and responsibilities of 

states and the federal government (e.g., licensing drivers versus 

setting vehicle standards, respectively) and emphasizes that 

automated vehicles should not change these general areas of 

responsibility. However, DOT officials described it as a new policy 

direction (see fig. 3).

Figure 3: Comparison of National Highway Traffic Safety Administration’s (NHTSA) Federal Automated Vehicle Policy (2016) 

and Vision for Safety (2017)

a

The Safety Assessment Letter suggested by NHTSA would cover the following areas: data recording 

and sharing; privacy; system safety; vehicle cybersecurity; human machine interface; 

crashworthiness; consumer education and training; registration and certification; post-crash behavior; 

federal, state, and local laws; ethical considerations; operational design domain (i.e., the conditions in 

which an automated vehicle is designed to work); object and event detection and response; fall back 

(i.e., what the automated vehicle will do if a system fails); and validation methods.

b

The Vision for Safety focuses on vehicles and technologies that either do not require a driver or in 

which a driver is not required to monitor the driving environment (SAE International Level 3–5), and 

not “partial automation,” which requires constant driver engagement (SAE International Level 2).
Page 22 GAO-18-132 Automated Vehicles

The Vision for Safety also makes some changes in the safety 

assessment by manufacturers, eliminates some sections of the 

original FAVP, and creates a resource document separate from the 

guidance. First, a Voluntary Safety Self-Assessment replaces the 

FAVP’s Safety Assessment Letter as the proposed mechanism for 

motor vehicle and motor vehicle equipment developers to 

demonstrate their approach to ADS safety. This assessment remains 

voluntary and the new guidance more clearly indicates that ADSs are 

not subject to NHTSA approval prior to testing or deployment. Further, 

three topical areas that the FAVP suggested vehicle developers 

discuss in the Safety Assessment Letter—data privacy and sharing, 

ethical considerations, and vehicle registration—are not included in 

the Voluntary Safety Self-Assessment.30 Second, unlike the FAVP, 

the Vision for Safety does not discuss NHTSA’s current regulatory 

tools, options for how new regulatory tools might help address 

challenges, or list specific “next steps” that DOT intends to take in the 

different areas the guidance addresses. According to officials, DOT is 

beginning work on the third version, dubbed the “FAVP 3.0,” that will 

be available in 2018 and include multimodal topics such as transit and 

commercial trucking. However, DOT has not announced specific 

milestones or a detailed scope of work for this effort.

• Exercising Safety Oversight Authority. As discussed earlier, DOT has 

a multi-faceted approach to safety oversight that includes setting 

federal vehicle safety standards, conducting investigations, and 

pursuing recalls of noncompliant or defective equipment. DOT has 

taken some steps to apply this approach to automated vehicles. For 

example, DOT’s 2016 Enforcement Guidance Bulletin reinforced that 

NHTSA’s authority to investigate and require the recall of defective 

equipment extends to automated vehicle technologies. NHTSA has 

exercised that authority and conducted investigations of Level 0, 1, 

and 2 vehicles equipped with features such as automatic emergency 

braking and adaptive cruise control. As a result of these 

investigations, NHTSA has pursued recalls of some Level 1 

 30A Vision for Safety briefly mentions privacy and ethical considerations in an endnote, 

which directs readers to NHTSA’s website for a more thorough discussion. In October 

2017, Waymo released On the Road to Fully Self-Driving, a report that describes the 

company’s processes relevant to the 12 topical areas included in A Vision for Safety.
Page 23 GAO-18-132 Automated Vehicles

automated equipment, but not for Level 2.31 NHTSA also identified 

various potential areas for revision within the Federal Motor Vehicle 

Safety Standards and is continuing to study the needs for changes to 

these standards.32 However, DOT has not specified what changes to 

exemption authorities are needed or established a time table for when 

a new rulemaking proposal will be initiated.

• Exploring Infrastructure Modernization. DOT has begun responding to 

the challenges it faces in adapting both highway and vehicle 

communication infrastructure by drafting guidance and proposing new 

rules, but is still investigating the best ways to execute such 

proposals. For example, FHWA issued draft Vehicle-to-Infrastructure 

Deployment guidance33 designed to assist DOT staff and 

infrastructure owners at the federal,34 state, and local levels in 

planning for and deploying this technology and ensuring its effective 

operation. According to FHWA officials, they are currently working on 

a final version of the guidance, but could not provide a publication 

 31For instance, NHTSA investigated incidents alleging that the adaptive cruise control, a 

Level 1 technology, on 2015 Ford F-150s falsely identified objects in the vehicle’s path, 

causing unwanted severe brake application. This investigation led to a recall of over 

30,000 vehicles. NHTSA has conducted a preliminary evaluation of a fatal crash involving 

a 2015 Tesla Model S categorized as a Level 2 automated vehicle. NHTSA determined 

that a safety-related defect trend had not been identified and closed its preliminary 

evaluation, noting that it was not making a determination that no safety-related defect 

existed. The National Transportation Safety Board also investigated this crash and 

determined that the vehicle’s automation permitted the car driver’s overreliance on the 

automation, noting its design allowed prolonged disengagement from the driving task and 

enabled the driver to use it in ways inconsistent with manufacturer guidance and 

warnings. See National Transportation Safety Board, Collision between a Car Operating 

with Automated Vehicle Control Systems and a Tractor-Semitrailer Truck Near Williston, 

Florida, May 7, 2016, Accident Report, NTSB/HAR-17/02, (Washington, D.C.: Sept. 12, 

2017).

32For instance, DOT’s Volpe Center conducted a study which sought to identify aspects of 

the Federal Motor Vehicle Safety Standards that could be affected by automated vehicles. 

Anita Kim, et al, Review of Federal Motor Vehicle Safety Standards (FMVSS) for 

Automated Vehicles; Identifying potential barriers and challenges for the certification of 

automated vehicles using existing FMVSS, Preliminary Report, Technology Innovation 

and Policy Division, John A. Volpe National Transportation Systems Center, Prepared for 

Intelligent Transportation Systems Joint Program Office; National Highway Traffic Safety 

Administration (Washington, D.C.: March, 2016).

33FHWA’s vehicle-to-infrastructure guidance was originally estimated to be published in 

September 2015. FHWA initially issued it in January 2017, but the new DOT 

administration has decided to review it. 

34FHWA operates the Office of Federal Lands Highway to assist federal infrastructure 

owners which include the National Park Service, Bureau of Indian Affairs, Tribal 

Governments, and the Department of Defense. 
Page 24 GAO-18-132 Automated Vehicles

date. FHWA officials also acknowledged that existing roadway 

signage and traffic control guidance would likely need to be updated. 

As a result, the office responsible for publishing this guidance has 

begun exploring this issue.35 Additionally, in 2016 NHTSA issued a 

Notice of Proposed Rulemaking to require vehicle-to-vehicle 

communications on all new light vehicles models.36 This rulemaking 

seeks to equip all new passenger vehicles with interoperable vehicleto-vehicle communications capability that could facilitate the 

development and deployment of safety applications. However, some 

of the stakeholders we interviewed noted that different forms of 

wireless communication are already available to facilitate vehicle-to 

vehicle communications. Mandating one type of wireless 

communications could create issues if other, more advanced 

communication technologies arise, according to these stakeholders. 

DOT is reviewing comments to the notice, and no communication 

standard has been established.

Research and Technology Efforts

DOT has begun to focus its research more on automated vehicles, has 

revised programs to incorporate automated vehicle technologies, and 

advance its deployment. While JPO has a central role in coordinating 

research across modes, NHTSA and FHWA also lead many research 

efforts. DOT’s research to date has mainly focused on Level 1 and 2 

technologies. For example, many of FHWA’s and JPO’s studies focus on 

things such as adaptive cruise control and speed harmonization, both 

Level 1 technologies. NHTSA’s research includes some studies of Level 2 

crash avoidance technology and related effect on human factors. One of

NHTSA’s more advanced research areas focuses on the challenge of 

how humans and machines interface when operating Level 2 and 3 

automated systems. Moreover, DOT has revised programs aimed at the 

deployment of advanced technologies to include automated vehicle 

technologies and has also begun to include some automated vehicle 

technologies as part of its New Car Assessment Program (see table 1).

 35The Manual on Uniform Traffic Control Devices contains the national standards for all 

roadway signage and traffic control infrastructure. 

36The effective date for manufacturers to implement this requirement would be 2 model 

years after the final rule is adopted, with a 3 year phase-in period to accommodate vehicle 

manufacturer’s production cycles.
Page 25 GAO-18-132 Automated Vehicles

Table 1: DOT’s Activities to Advance the Deployment of Smart Infrastructure and Automated Vehicle Technologies

Program Description

Promoting Smart Infrastructure

Smart City Challenge Competition held by DOT in 2016 for cities to develop smart infrastructure 

projects with the goal of moving people and goods more efficiently. The winner 

received a $40 million federal grant to deploy its ideas.

Advanced Transportation and Congestion 

Management Technologies Deployment Program

A DOT program that collectively offers $60 million worth of competitive grants 

for applicants to deploy infrastructure projects with advanced technologies. 

Projects that include automated technologies or that accommodate automated 

vehicles can be eligible for funding, though it is not a requirement for the 

program.

Promoting Automated Technologies

New Car Assessment Program NHTSA program that develops safety ratings for all vehicle models based on a 

scale of 1 to 5 stars. Automatic emergency braking will become one of the 

program’s recommended safety features, beginning with all 2018 models. 

Other automated features, such as lane-keeping support, are under 

consideration for inclusion.

Source: GAO analysis of Department of Transportation information. | GAO-18-132.

Internal Management Efforts

DOT has made efforts to use existing mechanisms to coordinate 

internally to respond to automation challenges. These efforts include 

considering automated vehicles in strategic and workforce planning, as 

well as using internal workgroups, as follows:

• Starting to Incorporate Automation into Strategic Planning: At the 

departmental level and through its various administrations, DOT has 

taken preliminary steps toward incorporating automated vehicles into 

its strategic planning. At the departmental level, DOT’s 2014-2018 

strategic plan briefly identifies automated vehicles as a safety 

research area and includes as a priority “leading the conversation on 

vehicle-to-vehicle technology,” which reflects the department’s focus 

thus far on vehicle communication technologies.37 NHTSA’s 2016-

 37The plan includes additional strategies including: (1) encouraging the deployment of 

effective advanced vehicle automation technologies such as advanced braking systems, 

and (2) continuing research and implementation of vehicle-to-vehicle and vehicle-toinfrastructure technologies. See U.S. Department of Transportation, Transportation for a 

New Generation, Strategic Plan Fiscal Years 2014–18. DOT’s draft strategic plan for 

2018-22, circulated for public comment in October 2017 and expected to be finalized by 

February 2018, indicates the department will work with public and private stakeholders to 

advance the development and adoption of automated technologies and ensure their 

safety. See U.S. Department of Transportation Strategic Plan for FY 2018-2022, Draft for 

Public Comment, October 19, 2017.
Page 26 GAO-18-132 Automated Vehicles

2020 strategic plan includes objectives related to ADSs, such as 

providing leadership for the safe deployment of automated vehicles. 

The plan discusses how these vehicles could reinforce NHTSA’s 

overall mission of saving lives, preventing injury, and reducing 

economic costs due to traffic crashes. FHWA’s and JPO’s strategic 

plans also acknowledge how automation could fit into their overall 

visions and missions. Conversely, FHWA issued a 2016 plan 

identifying priorities for the department’s pedestrian and bicycle 

initiatives and investments, but it does not discuss how the risks 

posed to pedestrians and cyclists by automated vehicle technologies 

would be addressed.38

• Beginning to Explore Workforce Adaptations: DOT officials and some 

stakeholders we interviewed described the difficulty DOT faces in 

reshaping its workforce in light of emergent demands on the 

department as automated vehicles become more prevalent. One 

reason, they said, is that DOT competes with high-paying technology 

firms to acquire new talent. For example, some stakeholders 

expressed concern that NHTSA does not have the resources 

necessary to meet the challenges it faces in regulating the safety of 

and overseeing automated vehicles because, in part, it is difficult for 

DOT to find and hire staff with the right software and automotive 

expertise. DOT officials also said that, while recruiting budgets were 

small, they have—on a limited basis—attempted to reach more 

potential college recruits by sponsoring a symposium designed to 

increase potential candidates’ awareness of DOT. In addition, in 2016 

DOT brought in its first Chief Innovation Officer on detail to help foster 

a culture of innovation. This individual was a member of the team that 

developed the FAVP, but is no longer with DOT, and other NHTSA 

staff led the development of A Vision for Safety.

• Establishing Internal Working Groups: DOT has created and used 

different internal working groups to help address automation 

challenges. For example, JPO facilitates weekly executive-level 

meetings to coordinate automated vehicle projects and policy 

initiatives across the department and a bi-weekly meeting to 

coordinate automation research. Likewise, to coordinate all ongoing 

research efforts internally, FHWA’s Research Oversight Committee 

holds monthly meetings among the various offices within the 

administration. In addition, FHWA has established an automated 

vehicle working group that is taking steps to develop a vision 

 38See U.S. Department of Transportation, Federal Highway Administration, Strategic 

Agenda for Pedestrian and Bicycle Transportation (Washington, D.C.: September 2016).
Page 27 GAO-18-132 Automated Vehicles

statement to guide FHWA’s role related to automated vehicles. In 

other instances, DOT created working groups for specific projects; 

however, the working groups end when the project is finished. For 

instance, NHTSA created the Vehicle Innovation Team to support the 

development of the FAVP. According to DOT officials, the team 

stopped meeting formally following the 2016 release of the FAVP, 

though individuals continue to work together on implementation and 

next steps. According to NHTSA officials, NHTSA has created another 

team to review key policy issues stakeholders raised in public 

comments headed by the Associate Administrator for Vehicle Safety 

Research. DOT officials also indicated that after the appointment of a 

new Deputy Assistant Secretary of Transportation Policy in the 

summer of 2017, the Office of the Under Secretary for Policy formed 

an Automation Policy Working Group to develop and coordinate 

automated vehicle policy department-wide, including the “FAVP 3.0”

mentioned previously.

While DOT has made initial efforts to issue or update policies, revise 

programs, and coordinate its research related to automated vehicles, it 

has done so without the benefit of a comprehensive plan to guide these 

efforts. This lack of comprehensive planning is inconsistent with leading 

principles on sound planning we have identified in our prior work; these 

principles call for developing robust, comprehensive plans to achieve 

agency goals.39 When facing major challenges similar to those posed by 

automated vehicles, leading practices call for agencies to develop robust, 

comprehensive plans.40 Successful comprehensive plans include 

principles that progress logically from conception to implementation, such 

as: (1) what the plan is trying to achieve and how it will achieve those 

results, with goals and objectives linked to prioritized activities; and (2) 

milestones and performance measures to monitor and gauge those 

results.41 Comprehensive planning is also consistent with federal internal 

 39For example, see GAO/GGD-96-118 and GAO, Veterans’ Health Care: Proper Plan 

Needed to Modernize System for Paying Community Providers, GAO-16-353 

(Washington, D.C.: May 11, 2016).

40GAO-16-353.

41For key characteristics of sound planning that reflect a comprehensive approach to 

program management, see GAO, Combating Terrorism: Evaluation of Selected 

Characteristics in National Strategies Related to Terrorism, GAO-04-408T (Washington, 

D.C.: Feb. 3, 2004) and GAO, Health Care Quality: HHS Should Set Priorities and 

Comprehensively Plan Its Efforts to Better Align Health Quality Measures, GAO-17-5 

(Washington, D.C.: Oct. 13, 2016).

DOT Does Not Have a 

Comprehensive Plan to 

Further Address 

Challenges
Page 28 GAO-18-132 Automated Vehicles

control standards, which call for agencies to identify timeframes for 

achieving defined objectives and to assess their progress toward meeting 

their objectives.42

As described previously, strategic plans for DOT, NHTSA, and FHWA 

include automation in discussions of vehicle safety, but these plans do 

not have the details that would be found in a comprehensive plan. 

Specifically, DOT issued a departmental strategic plan that calls for 

encouraging automated vehicle technologies and continuing research and 

implementation of vehicle-to-vehicle and vehicle- to-infrastructure 

technologies.43 Likewise, NHTSA, FHWA, and JPO have strategic plans 

that contain high-level goals and objectives, some of which include 

automated vehicles. However, as expected of strategic plans, these are 

broad frameworks for accountability and oversight rather than 

comprehensive plans that systematically outline and prioritize the specific 

efforts needed to achieve the department’s goals and objectives. For 

example, NHTSA’s 2016–2020 strategic plan includes five high-level 

strategic goals, one of which is automated vehicles.44 To achieve this 

goal, the plan calls for NHTSA to “provide national leadership for the safe 

deployment of automated vehicles,” among other objectives. However, 

the plan does not define what national leadership would entail nor 

delineate priorities, implementation details, or a method to monitor 

results. Moreover, while DOT officials indicated that automated vehicles 

could pose a particular risk for pedestrians and cyclists, FHWA does not 

include automation in its plan for pedestrian and cyclist safety, even 

though the plan sets priorities, outlines efforts FHWA will make to achieve 

its goals, and establishes timelines that can be used to monitor progress.

The automation policy and guidance documents DOT has issued, such as 

the FAVP and A Vision for Safety, are also not comprehensive plans that 

explain how DOT will prioritize its efforts in this area and monitor results. 

The FAVP was meant to speed the delivery of an initial regulatory 

 42GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: September 2014). 

43DOT’s Strategic Plan for fiscal years 2014-2018 includes a strategic goal aimed at 

improving safety by reducing transportation-related fatalities and injuries. The draft 

strategic plan for 2018-2022 indicates that automation is a part of the department’s 

strategy to improve safety and encourage innovation.

44U.S. Department of Transportation, The Road Ahead: National Highway Traffic Safety 

Administration Strategic Plan 2016-2020, DOT HS 812 343 (Washington, D.C.: October 

2016).
Page 29 GAO-18-132 Automated Vehicles

framework and best practices and was a first step towards making some 

elements of the guidance mandatory and binding through future 

regulatory actions. The Vision for Safety articulates DOT’s new nonregulatory policy direction which emphasizes voluntary industry actions 

and promoting best practices. However, neither document specified how 

NHTSA would prioritize its efforts, when various internal working groups 

would meet milestones, or what performance measures would be used to 

track progress. For example, the FAVP’s next steps included “Publish 

Safety Assessment Template” and “Mandate Safety Assessment,” but the 

steps were not prioritized and did not include milestones.45 Moreover, A 

Vision for Safety did not include any next steps. Without a comprehensive 

plan, DOT also lacks a mechanism to monitor the results of its efforts. For 

example, as discussed earlier, NHTSA has identified various potential 

areas for revision within the Federal Motor Vehicle Safety Standards. 

Such changes involve numerous steps and could take many years to 

accomplish. However, as NHTSA continues to study the need for 

changes to these standards, it has not specified milestones or 

performance measures for the efforts it would need to complete to make 

such a determination about the standards.

DOT has changed its policy direction under new leadership and is in the 

early stages of detailing this new, non-regulatory and voluntary vision, 

according to officials, and does not have a comprehensive plan for its 

current efforts. After releasing the FAVP in September 2016, NHTSA 

solicited and reviewed public comments and developed potential 

responses to the comments through the first half of 2017. However, 

following the change in administrations, DOT was without some 

permanent key senior leadership, including a NHTSA administrator, and 

NHTSA did not take any public steps to further clarify the guidance after 

January 2017. Many of the stakeholders we interviewed said that the 

absence of senior leaders or NHTSA clarifications created uncertainty 

about the direction of DOT’s automated vehicle policy. As noted above, in 

June 2017, DOT’s policy efforts coalesced under the leadership of the 

new Automation Policy Working Group, according to DOT officials, to 

start work on DOT’s next policy. This effort is just beginning and not fully 

detailed, but DOT documentation describing this effort indicates it will 

result in a “coordinated, comprehensive plan” to support safe automated 

vehicle development and deployment. However, this documentation does 

 45NHTSA did not complete either of these steps prior to issuing A Vision for Safety, which 

replaced the FAVP. 
Page 30 GAO-18-132 Automated Vehicles

not indicate that it will include goals, milestones, or monitoring, key 

principles of comprehensive planning that have been lacking from DOT’s 

recent guidance and strategic plans.

At present, it is unclear whether DOT’s initial efforts are appropriately 

tackling automated vehicle challenges and making sufficient progress 

toward achieving high-priority goals. This could lead to delays in the 

deployment of life-saving technologies or, conversely, unsafe 

technologies making it into vehicles. A comprehensive plan would also 

help provide industry, governmental, and safety stakeholders with details 

about DOT’s efforts so they can appropriately plan their own efforts.

Automated vehicle technologies are quickly evolving, and as a result, 

DOT has been and likely will continue to face emerging safety and 

infrastructure challenges. It is too soon to know if DOT’s current efforts, 

as articulated in A Vision for Safety, will successfully address the 

challenges automated vehicles pose. As DOT refines and advances its 

efforts, it has the opportunity to incorporate leading principles of 

comprehensive planning. A comprehensive plan would help DOT manage 

its efforts to oversee and advance the safe development, testing, and 

deployment of automated vehicle technology. In addition, a 

comprehensive plan could help DOT make decisions about whether and 

how to respond to different automated vehicle technology challenges as 

they arise. Without a comprehensive plan, DOT may miss the opportunity 

to organize, prioritize, and clearly monitor the progress of its many efforts 

across NHTSA, FHWA, and the Office of the Secretary, and other 

administrations as appropriate.

The Secretary of Transportation should develop and implement a 

comprehensive plan to better manage departmental initiatives related to 

automated vehicles. This plan should include leading principles such as 

goals, priorities, steps to achieve results, milestones, and performance 

measures to track progress. (Recommendation 1)

We provided a draft of this report to DOT for review and comment. In its 

comments, reproduced in appendix II, DOT concurred with the 

recommendation and indicated that it would be premature to publish a 

comprehensive plan at this time, but would pursue an iterative framework 

to manage DOT’s activities to address automated vehicle challenges. We 

believe this approach could address our recommendation provided this 

Conclusions

Recommendation for 

Executive Action

Agency Comments
Page 31 GAO-18-132 Automated Vehicles

framework incorporates leading principles of comprehensive planning.

DOT also provided technical comments which we incorporated as 

appropriate.

We are sending copies of this report to the Secretary of the Department 

of Transportation, and interested congressional requesters. In addition, 

the report will be available at no charge on the GAO website at 

http://www.gao.gov. If you or your staff have any questions about this 

report, please contact me at (202) 512-2834 or wised@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. GAO staff who made major 

contributions to this report are listed in appendix III.

David Wise

Director, Physical Infrastructure Issues
Appendix I: Literature Reviewed and Selected 

Stakeholders Interviewed

Page 32 GAO-18-132 Automated Vehicles

Anderson, James, et al. Autonomous Vehicle Technology, A Guide for 

Policymakers. Santa Monica, CA: RAND Corporation, 2016.

DiClemente, Jonathan, et al., Autonomous Car Policy Report. Pittsburgh, 

PA: Carnegie Mellon University, May 2014.

Glancy, Dorthy J., et al. “A Look at the Legal Environment for Driverless 

Vehicles.” Legal Research Digest 69. Washington, D.C.: National 

Cooperative Highway Research Program, Feb. 2016.

Goodall, Noah. “Ethical Decision Making During Automated Vehicle 

Crashes,” Transportation Research Board of the National Academies,

Transportation Research Record: Journal of the Transportation Research 

Board, No. 2424. Washington, D.C.: 2014: 58–65.

Harper, Corey, et al. “Cost and benefit estimates of partially-automated 

vehicle collision avoidance technologies.” Accident Analysis and 

Prevention, July 2016.

Kalra, Nidhi and Susan Paddock. “Driving to Safety: How many miles of 

driving would it take to demonstrate autonomous vehicle reliability?”

Transportation Research Part A 94 (2016): 182-193.

Kockelman, Kara, et al. Implications of Connected and Automated 

Vehicles on the Safety and Operations of Roadway Networks: A Final 

Report, 0-6849-1. Austin, TX: Center for Transportation Research at the 

University of Texas at Austin, October 2016.

Kockelman, Kara, et al. Best Practices Guidebook for Preparing Texas for 

Connected and Automated Vehicles, 0-6849-P1. Austin, TX: Center for 

Transportation Research at the University of Texas at Austin, October 

2016.

Kockelman, Kara, et al. Bringing Smart Transport to Texans: Ensuring the 

Benefits of a Connected and Autonomous Transport System in Texas—

Final Report, 0-6838-2. Austin, TX: Center for Transportation Research at 

the University of Texas at Austin, November 2016.

Koopman, Philip and Michael Wagner, Challenges in Autonomous 

Vehicle Testing and Validation, SAE World Congress, 2016-01-

0128/16AE-0265.

Appendix I: Literature Reviewed and 

Selected Stakeholders Interviewed

Literature Reviewed
Appendix I: Literature Reviewed and Selected 

Stakeholders Interviewed

Page 33 GAO-18-132 Automated Vehicles

Paul Lewis, et al. Beyond Speculation: Automated Vehicles and Public 

Policy, An Action Plan for Federal, State, and Local Policymakers. 

Washington, D.C.: Eno Center for Transportation, May 2017.

Paul Lewis, et al. Adopting and Adapting: States and Automated Vehicle 

Policy. Washington, D.C.: Eno Center for Transportation, June 2017.

McGehee, Daniel, et al. Review of Automated Vehicle Technology: Policy 

and Implementation Implications. Iowa City, IA: University of Iowa, Public 

Policy Center, March 2016.

Milakis, Dimitris, et al. Policy and society related implications of 

automated driving: a review of the literature and directions for future 

research. working paper, Delft University of Technology, Infrastructures 

and Mobility Initiative. Delft, The Netherlands: October 2015.

National League of Cities, Center for City Solutions, Autonomous 

Vehicles: A Policy Preparation Guide. 2017.

Robertson, Robyn, et al. Automated Vehicles: Driver Knowledge, 

Attitudes, and Practices. Ottawa, Ontario: Traffic Injury Research 

Foundation, September 2016.

Shladover, Steven E. and Douglas Gettman, Connected/Automated 

Vehicle Research Roadmap for AASHTO, NCHRP-20-24(98), 

(Washington, D.C.: June 2015).

Smith, Bryant Walker, How Governments Can Promote Automated 

Driving, 47 N.M.L. Review 99, (2017).

Smith, Bryant Walker and Joakim Svensson, Automated and Autonomous 

Driving: Regulation under uncertainty, International Transport Forum, 

Organization for Economic Cooperation and Development (2015).

Richards, Dale and Alex Stedmon. “To delegate or not to delegate: A 

review of control frameworks for autonomous cars.” Applied Ergonomics, 

53 (2016): 383–388.

Vishnubhatla, Sravya and Jessica Li. Self-Driving Cars: The Drive Behind 

a New Transparency and Liability Framework. Cambridge, MA: 

Massachusetts Institute of Technology, December 2016.
Appendix I: Literature Reviewed and Selected 

Stakeholders Interviewed

Page 34 GAO-18-132 Automated Vehicles

Volpe National Transportation Systems Center. 2014 TRB Automated 

Vehicles Symposium Proceedings—Final, FHWA-JPO-14-176. 

Cambridge, MA: December 2014.

Volpe National Transportation Systems Center. 2013 TRB Workshop on 

the Opportunities and Challenges of Road Vehicle Automation: Synopsis 

of Proceedings. Cambridge, MA: November 2013.

Table 2 lists the stakeholders we interviewed for this work.

Table 2: Organization, Type, and Description of Selected Stakeholders

Organization Description

Companies and industry groups

Alliance of Automobile Manufacturers An advocacy group for the auto industry representing 12 companies that account for 

70 percent of all car and light truck sales in the U.S. 

Automotive Information Sharing and Analysis 

Center

Created by the auto industry to promote collaborative cyber-security efforts, the group 

has established and maintained a set of best practices. 

Delphi Automotive High-technology company that develops and sells automated and connected vehicle 

technologies.

Ford Motor Company Plans to design and operate Level 4 automated vehicles without steering wheels, or 

gas or brake pedals for use in commercial mobility services such as ride sharing and 

ride hailing within limited areas. 

General Motors Has been testing Chevrolet Bolt EV automated vehicles equipped with self-driving 

technology on public roads in San Francisco, CA and Scottsdale, AZ, since June 2016 

and in Warren, MI. since Jan. 2017.

Mercedes-Benz Developing software and algorithms for an automated driving system through a

partnership designed to bring Level 4 and 5 cars to urban roads. 

QNX Software Systems Subsidiary of Blackberry, developing a software platform for automotive safety 

applications such as digital instrument clusters, heads-up displays, and advanced 

driver-assistance systems.

SAE International International standards organization that defined automated driving terms and 

identified six levels of driving automation, from no automation to full automation, later 

adapted by the National Highway Traffic Safety Administration.

Tesla Auto maker all of whose electric vehicles come standard with automated features that 

are updated through over-the-air software upgrades.

Waymo Technology company working to commercialize self-driving technology, currently 

testing nearly 60 automated vehicles on public roads in 4 U.S. cities.

State, regional, and local governmental organizations or associations

American Association of Motor Vehicle 

Administrators

Nonprofit organization developing model programs in motor vehicle administration, law 

enforcement, and highway safety.

Selected Stakeholders 

Interviewed
Appendix I: Literature Reviewed and Selected 

Stakeholders Interviewed

Page 35 GAO-18-132 Automated Vehicles

Organization Description

State, regional, and local governmental organizations or associations

American Association of State Highway and 

Transportation Officials

Nonprofit organization working to foster the development, operation, and maintenance 

of an integrated national transportation system.

California Department of Motor Vehicles California Vehicle Code Section 38750 requires the department to adopt regulations 

governing both the testing and public use of automated vehicles on California 

roadways.

City of Pittsburgh, Mayor’s Office City plans to use self-driving technology and adaptive traffic signals to improve safety 

and increase mobility. 

City of San Francisco

• Mayor’s Office

• Municipal Transportation Agency 

(SFMTA)

City plans to use shared, electric vehicles—eventually fully automated ones—as well 

as collision avoidance technology and connected vehicles to enhance safety.

Pennsylvania Department of Transportation 

(PennDOT) 

Convened an Autonomous Vehicle Policy Task Force to promote the advancement of 

technology while ensuring public safety. 

• Regional Transportation Commission of 

Southern Nevada

• Nevada Department of Transportation

• The commission is a regional entity that oversees public transportation, traffic 

management, roadway design and construction funding, and transportation 

planning for Southern Nevada.

• The department works to provide, operate, and preserve a transportation system 

that enhances safety, quality of life and economic development through

innovation, environmental stewardship, and a dedicated workforce. 

Safety organizations 

Governors Highway Safety Association Nonprofit organization representing state and territorial highway safety offices that 

implement federal grant programs to address behavioral highway safety issues. 

Insurance Institute for Highway Safety Independent, nonprofit scientific and educational organization dedicated to reducing 

the losses—deaths, injuries and property damage—from crashes on the nation’s 

roads.

National Transportation Safety Board Independent federal agency that investigates accidents, determines their

probable cause, and recommends ways to prevent them from happening again. 

Safety Research and Strategies Provides fact-based research and analysis on injuries associated with product hazards 

ranging from motor vehicles to consumer and industrial products to medical devices. 

Academics

California Partners for Advanced 

Transportation Technology (University of 

California, Berkeley) 

We interviewed Steven Shladover, Program Manager and Research Engineer at 

Partners for Advanced Transportation Technology, a research and development 

program that has been a leader in intelligent transportation systems research since its 

founding in 1986.

Center for Automotive Research (Stanford 

University) 

We interviewed Chris Gerdes, Professor of Mechanical Engineering, who studies how 

cars move, how humans drive, and how to design automated vehicles. He served as 

the U.S. Dept. of Transportation’s first Chief Innovation Officer from Feb. 2016 to Jan. 

2017 and was part of the team that developed the Federal Automated Vehicles Policy.

Santa Clara University School of Law We interviewed Dorothy Glancy, a Law Professor at SCU since 1975, who is nationally 

known for her extensive work in the area of privacy and transportation law.

Technologies for Safe and Efficient 

Transportation (Carnegie Mellon University) 

We interviewed Raj Rajkumar, Technologies for Safe and Efficient Transportation 

Director and Electrical and Computer Engineering Professor. His work is primarily in 

cyber-physical systems, such as automated driving and vehicular networks, and 

wireless/sensor networks.
Appendix I: Literature Reviewed and Selected 

Stakeholders Interviewed

Page 36 GAO-18-132 Automated Vehicles

Organization Description

Academics

Traffic21 (Carnegie Mellon University) We interviewed Chris Hendrickson, Engineering Professor and Director of Traffic 21, 

which was founded to identify, refine, and deploy intelligent transportation system 

projects to Pittsburgh.

University of South Carolina School of Law We interviewed Bryant Walker Smith, Law Professor at the University of South 

Carolina, and Affiliate Scholar at Stanford Law School’s Center for Internet and 

Society. 

Source: GAO. | GAO-18-132.
Appendix II: Comments from the Department 

of Transportation

Page 37 GAO-18-132 Automated Vehicles

Appendix II: Comments from the Department 

of Transportation
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 38 GAO-18-132 Automated Vehicles

David Wise, (202) 512-2834 or wised@gao.gov

In addition to the individual named above, Cathy Colwell (Assistant 

Director); John Stambaugh (Analyst in Charge); Jenny Chanley; Leia 

Dickerson; Gary Guggolz; Terence Lam; Josh Ormond; Cheryl Peterson; 

Patrick Tierney; and Michelle Weathers made key contributions to this 

report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 39 GAO-18-132 Automated Vehicles

Intelligent Transportation Systems: Urban and Rural Transit Providers 

Reported Benefits but Face Deployment Challenges. GAO-16-638. 

Washington, D.C.: June 21, 2016.

Intelligent Transportation Systems: Vehicle-to-Infrastructure Technologies 

Expected to Offer Benefits, but Deployment Challenges Exist. 

GAO-15-775. Washington, D.C.: September 15, 2015.

Intelligent Transportation Systems: Vehicle-to-Vehicle Technologies 

Expected to Offer Safety Benefits, but a Variety of Deployment 

Challenges Exist. GAO-14-13. Washington, D.C.: November 1, 2013.

Intelligent Transportation Systems: Improved DOT Collaboration and 

Communication Could Enhance the Use of Technology to Manage 

Congestion. GAO-12-308. Washington, D.C.: March 19, 2012.

Vehicle Cybersecurity: DOT and Industry Have Efforts Under Way, but 

DOT Needs to Define Its Role in Responding to a Real-world Attack. 

GAO-16-350. Washington, D.C.: March 24, 2016.

Vehicle Safety: Enhanced Project Management of New Information 

Technology Could Help Improve NHTSA’s Oversight of Safety Defects. 

GAO-16-312. Washington, D.C.: February 24, 2016.

Vehicle Safety Inspections: Improved DOT Communication Could Better 

Inform State Programs. GAO-15-705. Washington, D.C.: August 25, 

2015.

Auto Safety: NHTSA Has Options to Improve the Safety Defect Recall 

Process. GAO-11-603. Washington, D.C.: June 15, 2011.

Vehicle Data Privacy: Industry and Federal Efforts Under Way but 

NHTSA Needs to Define Its Role. GAO-17-656. Washington, D.C.: July 

28, 2017.

Pedestrians and Cyclists: Cities, States, and DOT Are Implementing 

Actions to Improve Safety. GAO-16-66. Washington, D.C.: November 19, 

2015.

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