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SELF-DRIVING CARS: LEVELS OF AUTOMATION 

HEARING 

BEFORE THE

SUBCOMMITTEE ON DIGITAL COMMERCE AND 

CONSUMER PROTECTION 

OF THE

COMMITTEE ON ENERGY AND 

COMMERCE 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

MARCH 28, 2017 

Serial No. 115–19 

( 

Printed for the use of the Committee on Energy and Commerce 

energycommerce.house.gov 

COMMITTEE ON ENERGY AND COMMERCE 

GREG WALDEN, Oregon 

Chairman 

JOE BARTON, Texas 

Vice Chairman 

FRED UPTON, Michigan 

JOHN SHIMKUS, Illinois 

TIM MURPHY, Pennsylvania 

MICHAEL C. BURGESS, Texas 

MARSHA BLACKBURN, Tennessee 

STEVE SCALISE, Louisiana 

ROBERT E. LATTA, Ohio 

CATHY MCMORRIS RODGERS, Washington 

GREGG HARPER, Mississippi 

LEONARD LANCE, New Jersey 

BRETT GUTHRIE, Kentucky 

PETE OLSON, Texas 

DAVID B. MCKINLEY, West Virginia 

ADAM KINZINGER, Illinois 

H. MORGAN GRIFFITH, Virginia 

GUS M. BILIRAKIS, Florida 

BILL JOHNSON, Ohio 

BILLY LONG, Missouri 

LARRY BUCSHON, Indiana 

BILL FLORES, Texas 

SUSAN W. BROOKS, Indiana 

MARKWAYNE MULLIN, Oklahoma 

RICHARD HUDSON, North Carolina 

CHRIS COLLINS, New York 

KEVIN CRAMER, North Dakota 

TIM WALBERG, Michigan 

MIMI WALTERS, California 

RYAN A. COSTELLO, Pennsylvania 

EARL L. ‘‘BUDDY’’ CARTER, Georgia 

FRANK PALLONE, JR., New Jersey 

Ranking Member 

BOBBY L. RUSH, Illinois 

ANNA G. ESHOO, California 

ELIOT L. ENGEL, New York 

GENE GREEN, Texas 

DIANA DEGETTE, Colorado 

MICHAEL F. DOYLE, Pennsylvania 

JANICE D. SCHAKOWSKY, Illinois 

G.K. BUTTERFIELD, North Carolina 

DORIS O. MATSUI, California 

KATHY CASTOR, Florida 

JOHN P. SARBANES, Maryland 

JERRY MCNERNEY, California 

PETER WELCH, Vermont 

BEN RAY LUJA ́ N, New Mexico 

PAUL TONKO, New York 

YVETTE D. CLARKE, New York 

DAVID LOEBSACK, Iowa 

KURT SCHRADER, Oregon 

JOSEPH P. KENNEDY, III, Massachusetts 

TONY CA ́ RDENAS, California 

RAUL RUIZ, California 

SCOTT H. PETERS, California 

DEBBIE DINGELL, Michigan 

SUBCOMMITTEE ON DIGITAL COMMERCE AND CONSUMER PROTECTION

ROBERT E. LATTA, Ohio 

Chairman 

GREGG HARPER, Mississippi 

Vice Chairman 

FRED UPTON, Michigan 

MICHAEL C. BURGESS, Texas 

LEONARD LANCE, New Jersey 

BRETT GUTHRIE, Kentucky 

DAVID B. MCKINLEY, West Virgina 

ADAM KINZINGER, Illinois 

GUS M. BILIRAKIS, Florida 

LARRY BUCSHON, Indiana 

MARKWAYNE MULLIN, Oklahoma 

MIMI WALTERS, California 

RYAN A. COSTELLO, Pennsylvania 

GREG WALDEN, Oregon (ex officio) 

JANICE D. SCHAKOWSKY, Illinois 

Ranking Member 

BEN RAY LUJA ́ N, New Mexico 

YVETTE D. CLARKE, New York 

TONY CA ́ RDENAS, California 

DEBBIE DINGELL, Michigan 

DORIS O. MATSUI, California 

PETER WELCH, Vermont 

JOSEPH P. KENNEDY, III, Massachusetts 

GENE GREEN, Texas 

FRANK PALLONE, JR., New Jersey (ex 

officio) 

(II) 

(III) 

C O N T E N T S 

Page 

Hon. Robert E. Latta, a Representative in Congress from the State of Ohio, 

opening statement ................................................................................................ 1 

Prepared statement .......................................................................................... 3 

Hon. Janice D. Schakowsky, a Representative in Congress from the State 

of Illinois, opening statement .............................................................................. 4 

Hon. Greg Walden, a Representative in Congress from the State of Oregon, 

opening statement ................................................................................................ 5 

Prepared statement .......................................................................................... 6 

Hon. Frank Pallone, Jr., a Representative in Congress from the State of 

New Jersey, opening statement .......................................................................... 7 

Prepared statement .......................................................................................... 8 

WITNESSES

Jeff Klei, President, North America Automotive Divisions, Continental AG ..... 9 

Prepared statement .......................................................................................... 12 

S. William Gouse, Diretor, Federal Programs Development, SAE International ................................................................................................................. 15 

Prepared statement .......................................................................................... 18 

David S. Zuby, Executive Vice President and Chief Research Officer, Insurance Institute for Highway Safety ...................................................................... 24 

Prepared statement .......................................................................................... 25 

Kay Stepper, Ph.D., Vice President for Automated Driving and Driver Assistance Systems, Robert Bosch LLC ....................................................................... 34 

Prepared statement .......................................................................................... 36 

SUBMITTED MATERIAL

Report, ‘‘A Roadmap to Safer Driving Through Advanced Driver Assistance 

Systems,’’ Motor & Equipment Manufacturers Association, 1 submitted by 

Mr. Costello 

Letter of March 27, 2017, from Jacqueline S. Gillan, President, and Catherine 

Chase, Vice President of Governmental Affairs, Advocates for Highway 

& Auto Safety, to Mr. Latta and Ms. Schakowsky, submitted by Mr. Costello ........................................................................................................................ 70 

Response to Request for Comment, DOT Docket No. NHTSA 092016 090090, 

Advocates for Highway & Auto Safety, December 2, 2016, 2 submitted by 

Mr. Costello 

Statement of National Safety Council, March 28, 2017, submitted by Mr. 

Costello .................................................................................................................. 74 

Statement of John Bozzella, President and Chief Executive Officer, Global 

Automakers, March 28, 2017, submitted by Mr. Costello ................................ 83 

Response to Request for Comment, DOT Docket No. NHTSA 092016 090090, 

U.S. Chamber of Commerce, November 22, 2016, submitted by Mr. Costello 87 

1The information has been retained in committee files and also is available at http:// 

docs.house.gov/meetings/IF/IF17/20170328/105790/HHRG-115-IF17-20170328-SD011.pdf. 2The information has been retained in committee files and also is available at http:// 

docs.house.gov/meetings/IF/IF17/20170328/105790/HHRG-115-IF17-20170328-SD004.pdf. 

Page

IV 

Statement of American Car Rental Association, March 28, 2017, submitted 

by Mr. Costello ..................................................................................................... 97 

Statement of Dan Galves, Senior Vice President, Chief Communications Officer, Mobileye, March 28, 2017, submitted by Mr. Costello ............................... 100 

Letter of March 27, 2017, from Marc Rotenberg, President, et al., Electronic 

Privacy Information Center, to Mr. Latta and Ms. Schakowsky, submitted 

by Mr. Costello ..................................................................................................... 105 

Letter of March 28, 2017, from Honda North America, Inc., to Mr. Latta 

and Ms. Schakowsky, submitted by Mr. Costello .............................................. 108 

(1) 

SELF-DRIVING CARS: LEVELS OF 

AUTOMATION 

TUESDAY, MARCH 28, 2017 

HOUSE OF REPRESENTATIVES, SUBCOMMITTEE ON DIGITAL COMMERCE AND CONSUMER

PROTECTION, COMMITTEE ON ENERGY AND COMMERCE, Washington, DC. 

The subcommittee met, pursuant to call, at 10:05 a.m., in Room 

2322 Rayburn House Office Building, Hon. Robert E. Latta (chairman of the subcommittee) presiding. 

Members present: Representatives Latta, Harper, Lance, McKinley, Kinzinger, Bilirakis, Mullin, Walters, Costello, Walden (ex officio), Schakowsky, Clarke, Ca ́ rdenas, Dingell, Matsui, Welch, Kennedy, Green, and Pallone (ex officio). 

Staff present: Ray Baum, Staff Director; Blair Ellis, Press Secretary/Digital Coordinator; Melissa Froelich, Counsel, Digital Commerce and Consumer Protection; Adam Fromm, Director of Outreach and Coalitions; Giulia Giannangeli, Legislative Clerk, Digital 

Commerce and Consumer Protection/Communications and Technology; Paul Nagle, Chief Counsel, Digital Commerce and Consumer Protection; Olivia Trusty, Professional Staff Member, Digital 

Commerce and Consumer Protection; Madeline Vey, Policy Coordinator, Digital Commerce and Consumer Protection; Hamlin Wade, 

Special Advisor for External Affairs; Michelle Ash, Minority Chief 

Counsel, Digital Commerce and Consumer Protection; Jeff Carroll, 

Minority Staff Director; Lisa Goldman, Minority Counsel; Caroline 

Paris-Behr, Minority Policy Analyst; Matt Schumacher, Minority 

Press Assistant; Andrew Souvall, Minority Director of Communications, Member Services, and Outreach. 

Mr. LATTA. Well, good morning. I would like to welcome you all 

to our subcommittee meeting of the Digital Commerce and Consumer Protection this morning. I really appreciate our witnesses 

being here. We are going to have members coming in. There is a 

meeting going on downstairs, and so more folks will be coming in. 

We see a couple more coming in right now. But I really again appreciate you so for being here, and to get started I would like to 

recognize myself for 5 minutes for an opening statement. 

OPENING STATEMENT OF HON. ROBERT E. LATTA, A 

REPRESENTATIVE IN CONGRESS FROM THE STATE OF OHIO 

Again, good morning. And last month, this subcommittee examined how automakers and other entities are testing self-driving vehicles and preparing for the development of this lifesaving techVerDate Mar 15 2010 15:09 Jun 07, 2017 Jkt 037690 PO 00000 Frm 00005 Fmt 6633 Sfmt 6633 I:\115THCONGRESS\115X17SELFDRIVINGCARS\115X17SELFDRIVINGCARSWORKING
2 

nology. While projections for the development of self-driving vehicles remains years out, advanced driver assistance systems that 

offer self semi-autonomous driving capabilities are entering the 

marketplace today. 

Advanced driver assistance systems are crash avoidance technologies that can protect drivers, reduce crashes, and enhance the 

convenience of driving. Forward collision warning, blind spot detection, and lane departure warnings are examples of advanced driver 

assistance systems. These systems help drivers make safer decisions on the road by providing real-time information about surrounding roadway activity. The driver can receive this information 

through audible tones, steering wheel vibrations, or small flashing 

lights on side mirrors alerting the driver of potential safety hazards on the road. 

Increasingly, advanced driver assistance systems now entering 

the market are capable of taking a more active role in the driving 

task. Innovative systems such as automatic emergency braking and 

lane departure prevention can temporarily take control over parts 

of the vehicle’s critical safety functions such as braking or steering. 

This can occur by the system either applying the brakes without 

input from the driver or steering the vehicle back into marked 

lanes following unintended drifting. 

Automakers and equipment suppliers have announced additional 

innovative driver assistance systems that are currently in line for 

deployment. Traffic jam assist can take control of a vehicle’s functions in low speed, stop and go traffic. Autonomous valet parking 

can park itself and retrieve itself when summoned by the owner. 

And highway autopilot with lane changing is being developed to 

change lanes and pass other vehicles without the input of the 

human driver. 

The deployment of the advanced driver assistance systems is 

demonstrating significant safety benefits across the country. Studies are showing that advanced driver assistance systems and crash 

avoidance technologies are reducing crashes, roadway injuries, and 

insurance claims. Advanced driver assistance systems are also an 

essential part in laying the groundwork for the deployment of fully 

self-driving vehicles. 

Through technological advances by manufacturers and equipment suppliers, basic driver assistance systems are taking on more 

advanced capabilities that assume greater control of the vehicle’s 

critical safety functions throughout a driving trip. The progression 

of these technologies is incrementally removing the human driver 

from the driving task and paving the way to full autonomy. 

To provide consistency in the development of driver assistance 

safety technologies, standards-setting organization SAE International developed a classification system to define six different 

levels of driving automation. SAE levels of automation establish 

the general scope of the driver assistance system and the role of 

the human driver in vehicles taking on increasing autonomous 

driving capabilities. 

The levels span from a vehicle with no automation all the way 

to a vehicle with full automation or a fully self-driving vehicle. Last 

September, the National Highway Traffic Safety Administration 

3 

adopted SAE’s levels of automation for its own use in its Federal 

Automated Vehicles Policy. 

As we discuss the levels of vehicle automation today, I look forward to learning more about the capabilities of advanced driver assistance systems currently on the market and how these technologies are increasing vehicle safety and protecting America’s motorists. I look forward to examining how these systems are informing the development of fully self-driving vehicles and how the auto 

industry is working to make these systems available across all 

models and fleets. 

I also look forward to hearing from witnesses about how consumers are adopting these technologies and how they are helping 

to build consumers’ confidence in automated driving systems. And 

with that I will end my opening statement. 

[The prepared statement of Mr. Latta follows:] 

PREPARED STATEMENT OF HON. ROBERT E. LATTA

Good morning. Last month, this subcommittee examined how automakers and 

other entities are testing self-driving vehicles and preparing for the deployment of 

this life-saving technology. While projections for the deployment of self-driving vehicles remain years out, advanced driver assistance systems that offer semiautonomous driving capabilities are entering the marketplace today. 

Advanced driver assistance systems are crash avoidance technologies that can 

protect drivers, reduce crashes, and enhance the convenience of driving. ‘‘Forward 

Collision Warning,’’ ‘‘Blind Spot Detection,’’ and ‘‘Lane Departure Warning’’ are examples of advanced driver assistance systems. These systems help drivers make 

safer decisions on the road by providing real-time information about surrounding 

roadway activity. The driver can receive this information through audible tones, 

steering wheel vibrations, or small flashing lights on side mirrors, alerting the driver to potential safety hazards on the road. 

Increasingly, advanced driver assistance systems now entering the market are capable of taking a more active role in the driving task. Innovative systems such as 

‘‘Automatic Emergency Braking’’ and ‘‘Lane Departure Prevention’’ can temporarily 

take control over parts of the vehicle’s critical safety functions such as braking or 

steering. This can occur by the system either applying the brakes without input 

from the driver or steering the vehicle back into marked lanes following unintended 

drifting. 

Automakers and equipment suppliers have announced additional innovative driver assistance systems that are currently in line for deployment. ‘‘Traffic jam assist’’ 

can take control of a vehicle’s functions in low-speed, stop and go traffic. ‘‘Autonomous valet parking’’ can park itself and retrieve itself when summoned by the 

owner. And, ‘‘highway autopilot with lane changing’’ is being developed to change 

lanes and pass other vehicles without the input of a human driver. 

The deployment of advanced driver assistance systems is demonstrating significant safety benefits across the country. Studies are showing that advanced driver 

assistance systems and crash avoidance technologies are reducing crashes, roadway 

injuries, and insurance claims. 

Advanced driver assistance systems are also an essential part in laying the 

groundwork for the deployment of fully self-driving vehicles. Through technological 

advancements by manufacturers and equipment suppliers, basic driver assistance 

systems are taking on more advanced capabilities that assume greater control of the 

vehicle’s critical safety functions throughout a driving trip. The progression of these 

technologies is incrementally removing the human driver from the driving task and 

paving the way to full autonomy. 

To provide consistency in the development of driver assistance safety technologies, 

standards-setting organization, SAE (S–A-E) International, developed a classification system that defines six different levels of driving automation. SAE’s levels of 

automation establish the general scope of the driver assistance system and the role 

of the human driver in vehicles taking on increasing autonomous driving capabilities. The levels span from a vehicle with no automation all the way to a vehicle with 

full automation or a fully self-driving vehicle. Last September, the National Highway Traffic Safety Administration adopted SAE’s levels of automation for its own 

use in its Federal Automated Vehicles Policy. 

4 

As we discuss the levels of vehicle automation today, I look forward to learning 

more about the capabilities of advanced driver assistance systems currently on the 

market and how these technologies are increasing vehicle safety and protecting 

America’s motorists. I look forward to examining how these systems are informing 

the development of fully self-driving vehicles and how the auto industry is working 

to make these systems available across all models and fleets. I also look forward 

to hearing from witnesses about how consumers are adopting these technologies and 

how they are helping to build consumers’ confidence in automated driving systems. 

Mr. LATTA. I would like to recognize for 5 minutes the gentlelady 

from Illinois, the ranking member, for 5 minutes. Good morning. 

OPENING STATEMENT OF HON. JANICE D. SCHAKOWSKY, A 

REPRESENTATIVE IN CONGRESS FROM THE STATE OF ILLINOIS 

Ms. SCHAKOWSKY. Good morning and thank you, Mr. Chairman 

and our witnesses. Today’s hearing continues our subcommittee’s 

series on autonomous vehicles. In last month’s hearing, several of 

our witnesses referenced different levels of automation and today 

we will better define those levels and we will also ask about the 

effectiveness of existing safety technologies. 

Self-driving cars are part of a long-term vision to minimize accidents due to human error. Automated features are becoming increasingly common in our cars, but we still have a long way to go 

to reach full automation, Level 5, as SAE would call it. Technology 

must be sufficiently tested and ensure that we don’t replace human 

error with system error. In addition, the Takata and Volkswagen 

scandals raised serious questions about how much we can trust industry to do the right thing on safety. 

Volkswagen ordered its supplier to write software to cheat on 

emissions testing. With software increasingly integral to our vehicles, proper oversight becomes that much more challenging. Ultimately, the success of autonomous features and self-driving cars relies on consumers trusting the technology. Trust must be earned. 

Once technologies are put in new vehicles it takes decades for technology to become widespread among all vehicles on the road. 

Just look at backup cameras. I worked to require backup cameras after I met and talked to parents who were devastated after 

their children were injured or killed in backover accidents. We 

passed that law in 2008. Parents and advocates came to DC regularly during the rulemaking process, and NHTSA finally established the standard in 2014. And backup cameras will now be required in all vehicles starting in model year 2018, 10 years after 

the bill passed. 

It will still be years before the passenger vehicles without backup 

cameras cycle out of use. A car sold today may be on the road for 

another 2 decades. That is why it is critical we look not only at 

safety improvements in the long term, but also at which technologies can be effectively deployed right now to save lives. 

A lot of safety technologies are out there. However, some are 

more effective than others. Automatic braking for instance has 

proven very effective in reducing accidents. The evidence on lane 

departures systems is more mixed. Today we will hear from the 

suppliers that develop safety technologies. We will hear about the 

testing data that is essential to lawmakers as we consider what 

should be standard, and we will learn about classifying levels of 

5 

automation, a useful framework as we think about how we move 

from today’s cars to the self-driving cars of the future. 

It is a long road ahead, but as I have seen in my years on the 

subcommittee we have to push forward at every step in the process 

to make safety improvements a reality. I thank all of our witnesses 

for being here today, and I look forward to your testimony. And 

now I would like to yield the remaining time to Representative 

Matsui. 

Ms. MATSUI. Thank you very much, Ranking Member Schakowsky. Innovation and AV vehicle technology is moving at an 

ever-accelerating pace. We are seeing major investments from traditional auto manufacturers, suppliers like our witnesses from 

Bosch and Continental, and new entrants like technology companies and ride-sharing platforms. I believe we will make big leaps 

forward in this space sooner than any of us would have anticipated. 

Different companies are pursuing different levels of automation 

and we know that they do not need to move sequentially through 

each level of automation. Some companies are choosing to incorporate certain individual features of automation while others are 

investing in a more integrated Level 4 automation systems today. 

In my district in Sacramento we are looking aggressively to the 

future to lay the foundation for fully autonomous vehicles to be 

tested on our roads. We are rapidly moving towards a time when 

truly driverless cars will be on our roads and will coexist with 

human drivers and other vehicles with different levels of automation. 

I look forward to hearing more from our witnesses today and 

working with all of you to accelerate the testing and deployment 

of this exciting technology which holds so much promise for improving safety on our roads. I thank you and I yield back. 

Ms. SCHAKOWSKY. And I yield back. 

Mr. LATTA. Thank you very much. The gentlelady yields back the 

balance of her time, and at this time the Chair recognizes the gentleman from Oregon, the chairman of the full committee, for 5 minutes for an opening statement. 

OPENING STATEMENT OF HON. GREG WALDEN, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF OREGON 

Mr. WALDEN. I thank the chairman and I welcome our witnesses 

and look forward to your delivery of your testimony which I have 

read and appreciate. 

Following years of declining traffic fatalities, we have seen tragically a sharp rise in vehicle-related deaths over the past 2 years. 

According to early estimates, more than 40,000 Americans, 40,000 

people, lost their lives on our Nation’s roads last year. That marks 

a 6 percent increase from 2015. And in my own State of Oregon, 

2016 was the deadliest year on the roads in more than a decade, 

up 20 percent from the year before. 

These are sobering numbers. The development of self-driving 

cars could be a solution to this uptick in danger facing the driving 

public, the main question is how do we get there? Last month, this 

subcommittee examined how automakers and other entities are 

testing self-driving cars and that we are still years away from getting them into hands of consumers. 

6 

But that has not stopped the automotive industry from laying 

the foundation for a complete vehicle autonomy. Today, many cars 

on the market, including one that my wife owns, are equipped with 

active safety features or semi-autonomous driving systems. It is 

pretty impressive to see them in action. These systems have the potential to keep a vehicle within its designated lane; accelerate to 

pass another vehicle; change lanes, brake, and park all without the 

input of a human driver. 

These advanced driver assistance systems or crash avoidance 

technologies represent the building blocks to a fully self-driving 

car. Gradually allowing the vehicle to perform parts of the driving 

task absent human control means that vehicles are steadily learning how to operate alone and consumers are progressively becoming 

more familiar and more comfortable with automated driving systems. The advancement of driver assistance systems over the last 

decade, it is already demonstrating this progression as this technology is minimizing crashes, reducing injuries, and decreasing insurance claims. 

In recognition of the safety benefits provided by these systems, 

the National Highway Traffic Safety Administration has begun to 

formally incorporate many of these technologies in its 5–Star safety 

ratings program. Today’s hearing will look more closely at many of 

the advanced driver assistance systems and crash avoidance technologies that are on the road. Our witnesses will also help us to 

understand the different levels of driving automation, how these 

technologies are improving safety, and how the development of 

driver assistance systems and technologies is paving the way for 

fully self-driving cars. 

We often say the development of self-driving cars is a lifesaving 

endeavor. Following a devastating year on our Nation’s roads this 

could not be any more true. I look forward to a thoughtful and engaging discussion on the levels of driving automation and how advanced driver assistance systems can lead us to the future of a full 

vehicle autonomy on our road systems. 

So thanks for the work you all are doing, thanks for sharing your 

comments with us. We want to make sure to advance this innovation and technology and save lives on our roads and in our communities. 

[The prepared statement of Mr. Walden follows:] 

PREPARED STATEMENT OF HON. GREG WALDEN

Following years of declining traffic fatalities, there has been a sharp rise in vehicle-related deaths over the past 2 years. According to early estimates, over 40,000 

people lost their lives on our Nation’s roads last year, marking a six percent increase from 2015. In Oregon, 2016 was the deadliest year on the roads in more than 

a decade, up 20 percent from the year before. These are sobering numbers. 

The development of self-driving cars could be a solution to this uptick in danger 

facing the driving public. The main question is: how do we get there? 

Last month, this subcommittee examined how automakers and other entities are 

testing self-driving cars and preparing this innovative safety technology for commercial deployment. Just about everyone concedes that fully self-driving cars are still 

years away from getting into the hands of consumers; but, that has not stopped the 

automotive industry from laying the foundation for complete vehicle autonomy. 

Today, many cars on the market are equipped with active safety features or semiautonomous driving systems. These systems have the potential to keep a vehicle 

within its designated lane; accelerate to pass another vehicle; change lanes; brake; 

and park—all without the input of a human driver. These advanced driver -assistVerDate Mar 15 2010 15:09 Jun 07, 2017 Jkt 037690 PO 00000 Frm 00010 Fmt 6633 Sfmt 6633 I:\115THCONGRESS\115X17SELFDRIVINGCARS\115X17SELFDRIVINGCARSWORKING
7 

ance systems or crash-avoidance technologies represent the building blocks to a fully 

self-driving car. 

Gradually allowing the vehicle to perform parts of the driving task absent human 

control means that vehicles are steadily learning how to operate alone and consumers are progressively becoming more familiar and more comfortable with automated driving systems. 

The advancement of driver assistance systems over the last decade is already 

demonstrating this progression, as this technology is minimizing crashes, reducing 

injuries, and decreasing insurance claims. In recognition of the safety benefits provided by these systems, the National Highway Traffic Safety Administration has 

begun work to formally incorporate many of these technologies into its 5–Star Safety Ratings program. 

Today’s hearing will look more closely at many of the advanced driver assistance 

systems and crash avoidance technologies on the road. Our witnesses will also help 

us to understand the different levels of driving automation; how these technologies 

are improving safety; and how the development of driver assistance systems and 

technologies is paving the way for fully self-driving cars. 

We often say that the development of self-driving cars is a life-saving endeavor. 

Following a devastating year on our Nation’s roads, this could not be truer now. I 

look forward to a thoughtful and engaging discussion on the levels of driving automation and how advanced driver assistance systems can lead us to a future of full 

vehicle autonomy. 

Mr. WALDEN. With that Mr. Chairman, I don’t know if anybody 

else on our side—I would yield to the gentleman from Mississippi 

for the remainder of my time. 

Mr. HARPER. Thank you, Mr. Chairman. Thank you, Chairman 

Latta, for calling this hearing today to continue the subcommittee’s 

efforts to explore the world of self-driving cars. As I have mentioned at our previous hearings, this topic is of particular interest 

to me because of the potential opportunities that self-driving cars 

would provide to Americans with disabilities, including those with 

intellectual disabilities. 

In the disability community lack of transportation is widely 

viewed as the top impediment to advancement and success in society. Self-driving cars could offer the disability community a new 

method of transportation to potentially remove this roadblock and 

provide them additional independence that would open the doors to 

access new job markets and opportunities to have an even more active role in our society, which benefits us all. 

I am looking forward to learning more about the capabilities of 

advanced driver assistance systems and crash avoidance technologies that are currently on the market and how these capabilities will advance the future of self-driving cars. And with that I 

yield back. 

Mr. LATTA. Thank you. The gentleman yields back, and the 

Chair now recognizes for a 5-minute opening statement the gentleman from New Jersey, the ranking member of the full committee. 

OPENING STATEMENT OF HON. FRANK PALLONE, JR., A REPRESENTATIVE IN CONGRESS FROM THE STATE OF NEW JERSEY 

Mr. PALLONE. Thank you, Chairman Latta. Today’s hearing gives 

us a our first true opportunity to talk about what is happening now 

in automated technology. While learning about the potential technologies of the future is exciting, understanding that there are 

products currently available that are saving lives and reducing injuries is paramount. 

8 

For the foreseeable future, human drivers are going to be driving 

vehicles on our roads and so efforts to prevent crashes or protect 

drivers and passengers in a crash are vital. For example, advances 

such as the addition of airbags and electronic stability control to 

our cars have saved thousands of lives. As I mentioned at this subcommittee’s November hearing on self-driving cars, we see technologies in today’s marketplace such as automatic braking that 

have enormous benefits. 

So today I urge all automakers to expedite the deployment of 

these braking systems into all new vehicles. According to the Highway Loss Data Institute it takes 25 years for a new feature to be 

on 95 percent of cars on our roads. Therefore, when we see something that works we need to get it on vehicles quickly and it needs 

to be made standard on all models and makes, not just the most 

expensive ones. 

Witnesses today will discuss other advances such as in lighting 

and blind spot detection that have promise, and I hope these technologies can help prevent injuries and fatalities. And as with automatic braking, I encourage rapid deployment of any new features 

that are proven to be beneficial. I also look forward to hearing 

about research into pedestrian and bicycle rider safety. As we 

learned at last week’s hearing on smart communities, the number 

of people living in urban areas is rising and those areas have 

unique transportation challenges. 

I am also interested in hearing what new technologies can reduce 

injuries to rear seat passengers. While injuries to drivers are still 

the most common, often our most vulnerable passengers are in the 

back. Unfortunately, data on back seat passengers is still limited 

which hampers efforts to determine the effectiveness of features intended to protect them. 

Therefore, I encourage NHTSA and all other stakeholders to collect and share all relevant data on road safety. We need to be able 

to see transit opportunities for safety improvements for people 

riding in the back seats as well as drivers, front seat passengers, 

and others on the road. More information will also encourage innovation of new safety technologies. 

And finally, I will close by continuing my push for security by design and privacy by design where security and privacy are not 

afterthoughts but built into the products from day 1. I don’t think 

anybody else wants my time, so I will yield back, Mr. Chairman. 

[The prepared statement of Mr. Pallone follows:] 

PREPARED STATEMENT OF HON. FRANK PALLONE, JR. 

Today’s hearing gives us our first true opportunity to talk about what is happening now in automotive technology. While learning about the potential technologies of the future is exciting, understanding that there are products currently 

available that are saving lives and reducing injuries is paramount. 

For the foreseeable future, human drivers are going to be driving vehicles on our 

roads, and so efforts to prevent crashes or protect drivers and passengers in a crash 

are vital. For example, advances such as the addition of airbags and electronic stability control to our cars have saved thousands of lives. 

As I mentioned at this subcommittee’s November hearing on self-driving cars, we 

see technologies in today’s marketplace, such as automatic braking, that have enormous benefits. So today, I urge all automakers to expedite the deployment of these 

braking systems into all new vehicles. 

9 

According to the Highway Loss Data Institute, it takes 25 years for a new feature 

to be on 95 percent of cars on our roads. Therefore, when we see something that 

works, we need to get it on vehicles quickly and it needs to be made standard on 

all makes and models, not just the most expensive ones. 

Witnesses today will discuss other advances such as in lighting and blind-spot detection that have promise. I hope these technologies can help prevent injuries and 

fatalities. And as with automatic braking, I encourage rapid deployment of any new 

features that are proven to be beneficial. 

I also look forward to hearing about research into pedestrian and bicycle rider 

safety. As we learned at last week’s hearing on smart communities, the number of 

people living in urban areas is rising, and those areas have unique transportation 

challenges. I am also interested in hearing what new technologies can reduce injuries to rear-seat passengers. While injuries to drivers are still the most common, 

often our most vulnerable passengers are in the back. 

Unfortunately, data on back-seat passengers is still limited, which hampers efforts to determine the effectiveness of features intended to protect them. Therefore, 

I encourage NHTSA, and all other stakeholders, to collect and share all relevant 

data on road safety. We need to be able to see trends and opportunities for safety 

improvements, for people riding in the back seats as well as drivers, front seat passengers, and others on the road. More information will also encourage innovation 

of new safety technologies. 

Finally, I will close by continuing my push for ‘‘security by design’’ and ‘‘privacy 

by design,’’ where security and privacy are not afterthoughts but built into the products from day one. 

Mr. LATTA. Thank you. The gentleman yields back, and that will 

conclude our opening statements from our members. The Chair 

would like to remind Members that, pursuant to committee rules, 

all Members’ opening statements will be made part of the record. 

At this time I also want to again thank our witnesses for being 

with us today. We really appreciate their taking the time to testify 

before the subcommittee. Today’s witnesses will have the opportunity to give opening statements followed by a round of questions 

from our members. 

Our witness panel for today’s hearing will include Mr. Jeff Klei, 

president of Continental Automotive Systems North America at 

Continental AG; Mr. Bill Gouse, director of Federal Programs at 

SAE International; Mr. David Zuby, executive vice president and 

chief research officer at Insurance Institute for Highway Safety; 

and Dr. Kay Stepper, vice president for Automated Driving and 

Driver Assistance Systems at Robert Bosch. 

We appreciate you all being here with us today and I would like 

to just mention that we have another subcommittee so we have 

members coming and out from both subcommittees today. But we 

look forward to your opening statements and, Mr. Klei, you are recognized for 5 minutes. 

STATEMENTS OF JEFF KLEI, PRESIDENT, NORTH AMERICA 

AUTOMOTIVE DIVISIONS, CONTINENTAL AG; S. WILLIAM 

GOUSE, DIRECTOR, FEDERAL PROGRAMS DEVELOPMENT, 

SAE INTERNATIONAL; DAVID S. ZUBY, EXECUTIVE VICE 

PRESIDENT AND CHIEF RESEARCH OFFICER, INSURANCE 

INSTITUTE FOR HIGHWAY SAFETY; AND KAY STEPPER, 

PH.D., VICE PRESIDENT FOR AUTOMATED DRIVING AND 

DRIVER ASSISTANCE SYSTEMS, ROBERT BOSCH LLC 

STATEMENT OF JEFF KLEI 

Mr. KLEI. Thank you very much and good morning, Chairman 

Latta, Ranking Member Schakowsky, and members of the SubVerDate Mar 15 2010 15:09 Jun 07, 2017 Jkt 037690 PO 00000 Frm 00013 Fmt 6633 Sfmt 6633 I:\115THCONGRESS\115X17SELFDRIVINGCARS\115X17SELFDRIVINGCARSWORKING
10 

committee on Digital Commerce and Consumer Protection. I thank 

the committee for the opportunity to testify today on behalf of Continental. My name is Jeff Klei and I am the president of Continental Automotive Systems in North America. 

Continental is a leading tier 1 supplier to develop safe, sustainable, and affordable mobility technology and solutions for our customers. In 2016, we generated more than $43 billion in sales within our automotive tire and specialty rubber groups. Continental 

employs more than 20,000 employees in the U.S. in more than 80 

facilities located in 26 States and has more than 220,000 employees 

in 55 countries worldwide. 

In 2015, there were more than 35,000 lives lost in the U.S. due 

to traffic crashes. Projections for 2016 are the dismal increase to 

more than 40,000 fatalities, a level we haven’t seen in a decade. 

More troubling is that on a global scale, roughly 1.2 million people 

die in roadway crashes and another 50 million are injured each 

year. This is unacceptable and changing this is what motivates 

each and every employee at Continental. 

In the last 45 years, the U.S. has experienced a relatively declining trend in traffic fatalities due in large part to vehicle safety 

technology like seatbelts in the ’70s, the introduction of anti-lock 

brake systems and airbags in the ’80s, and finally electronic stability control in the ’90s. As the auto industry moves towards more 

widespread implementation of advanced driver assistance systems, 

Continental projects these technologies will once again reverse the 

recent increase in fatalities. 

Continental and our dedicated employees are committed to developing safe and dynamic driving technologies that contribute to 

what we call our Vision Zero, a future with zero traffic fatalities, 

zero injuries, and ultimately zero accidents. Such a future can only 

be achieved with the help of innovative active and passive safety, 

advanced driver assistance systems, and automated driving technologies. 

With building block technologies like automatic emergency braking, adaptive cruise control, and rear backup assist that are available in vehicles today, we believe we can continue to pursue our 

Vision Zero and achieve higher levels of automated driving. When 

we ultimately achieve fully automated driving we believe that we 

can reduce the number of fatalities by more than 90 percent, the 

percentage of accidents caused by human error. 

The world and the behavior of drivers within it are ever-changing and the vehicles must adapt to these changing trends. Our children seem to rely more on smart phones to stay connected with one 

another and living in a world of distractions has been commonplace. Automotive technology must develop accordingly. 

That is why Continental has put a great deal of effort into 

human-machine interface technology. We want the driver to be 

aware of their surroundings, be aware of what systems in the vehicle are doing, and be aware of when it is safe to relinquish control 

of the vehicle and when it is necessary to re-engage with the vehicle. In addition, we are heavily focused on securing the systems of 

the vehicle with cybersecurity enhancements as well as the redundancy of safety systems. 

11 

Since 2011, we have continued a pursuit of developing and testing highly automated driving with next generation technologies 

like automated parking, Cruising Chauffeur, and a complete selfdriving vehicle in combination with V2X technology. We were the 

first supplier in the U.S. to be awarded a testing license in the 

State of Nevada for automated vehicles and are currently testing 

our third generation automated vehicle on highways and roads 

throughout the country and around the world. 

But our continued efforts in this direction would benefit greatly 

from an investment in infrastructure that promotes vehicle to X 

communication, a dedicated spectrum communication band that 

can be utilized by current and future safety systems, and harmonization of safety laws that allows for the full real world testing of 

these technologies. The safe commercial deployment of potential 

lifesaving technology depends on the ability to extensively test on 

public roads under all conditions. 

Finally, we need an update of Federal motor vehicle safety standards to accommodate automated driving technology in a legal 

framework that supports a new system of mobility. The world of 

mobility has the capability of expanding to unimaginable independence and personal freedom while enhancing the safety of future 

generations. Continental stands at the ready alongside our industry colleagues to work with the committee and Congress in helping 

construct laws and regulations that foster innovation, enable mobility, and create a safer environment for our public. 

Thank you again, Chairman Latta, Ranking Member Schakowsky, members of the Subcommittee on Digital Commerce and 

Consumer Protection, and staff for the opportunity to testify at today’s hearing. 

[The prepared statement of Mr. Klei follows:] 

12 


Testimony of JeffKiei 

President, North America Automotive Divisions 

Continental AG 

Energy and Commerce Committee 

Digital Commerce and Consumer Protection Subcommittee 

"Self Driving Cars: Levels of Automation" 

March 28,2017 

Good morning Chairman Latta, Ranking Member Schakowsky, and members of the Subcommittee 

on Digital Commerce and Consumer Protection. I thank the Subcommittee for the opportunity to testify 

today on behalf of Continental. My name is JcffKlci, and I am the President of Continental Automotive 

Systems in North America. 

Continental is a leading Tier I supplier that develops intelligent technologies for transp01ting people 

and their goods. We provide our automotive customers with sustainable, safe and atlordable solutions 

that enhance automotive safety. In 2016 we generated more than $43 billion in sales within our five 

divisions, Chassis & Safety, Interior, Powertrain, Tires, and ContiTech. Continental employs more than 

20,000 employees in the U.S at more than 80 facilities located in 26 states and has more than 220,000 

employees in 55 countries worldwide. 

In 2015 there were more than 35,000 lives lost in the U.S. due to traffic crashes. Projections for 2016 

are expected to increase to more than 40,000 fatalities, a level we haven't seen in a decade. While this is 

an alarming number, it is even more stattling at a global level-more than 1.2 million people die in 

roadway crashes and another 50 million arc injured. This is unacceptable and reversing this trend is what 

motivates each and every employee at Continental. 

In the last 45 years the U.S. has experienced a relative declining trend in tralTic fatalities with respect 

to an increased number of vehicles on the road and number of miles driven. This is due in large part to 

improved vehicle safety technologies. In the early 1970s the numberofinjuries and fatalities were at an 

all-time high. The introduction of the seat belt helped to reduce the total number of traffic fatalities by 

10,000 in a few short years. In 1983, the number of fatalities was the lowest in 20 years due to the 

introduction of anti-lock braking systems. As numbers began to rise again, the airbag became standard in 

vehicles reducing injuries and fatalities down to its lowest number in 30 years. The introduction of 

electronic stability control in the mid-1990s helped to reduce traffic accidents to the lowest number in 50 

years. Continental projects new crash-avoidance technologies will once again reverse the recent increase 

in fatalities as the auto industry moves toward a more widespread implementation of Advanced Driver 

Assist Systems (ADAS). 

Innovation has always been at the heart ofthe automotive industry. From the original concept of the 

automobile in the late 1800s, the mass production lines pioneered in Detroit, to today, the automotive 

industry has always invested in research and development to make their products safer, more reliable and 

more affordable. Today, we are witnessing the automotive industry evolve from a crashworthiness 

mindset, where manufacturers try to make the passenger cabin more survivable in the event of an 

accident towards a crash avoidance mindset-aftcr all, the best way to survive a crash is to avoid one in 

the tirst place. 
13 


Continental, and our dedicated employees, arc committed to developing Safe and Dynamic Driving 

technologies tow·ards Vision Zero. Vision Zero means a fbturc with zero traffic fatalities, injuries and 

ultimately zero accidents. Such a future can only be achieved with the help of innovative active and 

passive safety. driver assistance, and automated driving technologies. As Continental brings these 

technologies to market, we exhaustively test products, and subsystems, as part of a larger system of 

advanced driving assistance technologies that will be integrated with a variety of components by original 

equipment manufactmcrs. 

Our Vision Zero philosophy is embedded in each technology we develop as we continue to enable 

automated driving. At Continental, we describe our systems approach through three primary actionssense, plan, and act. Whether the technology simply assists the driver like many systems on the road 

today, or ultimately takes over the driving task completely, it first must SENSE the surrounding 

environment and gather the necessary data that can be interpreted. Sophisticated sensor systems can help 

eliminate human error and distractions by providing 360-degree awareness of the road at all times. The 

data gathered from the sensors is then analyzed to identify obstacles or hazards. Our systems then 

dynamically develop a PLAN to determine how to assist the driver. Once that plan is in place, the 

systems will ACT to execute the plan to safely and comfortably pilot the vehicle and in certain cases 

avoid a hazard or crash situation. Our Sense, Plan. Act approach is the foundation behind Continental's 

active safety and Advanced Driver Assistance System technology, and is a key component to advancing 

automated driving systems. We believe that when fully automated driving is possible, traffic fatalities 

can he reduced by 90 percent because that is the percentage of accidents that are caused by human error. 

Continental has been an active participant globally in policy discussions and initiatives with 

governments, automotive industry partners, trade associations and other standard setting organizations. 

The collaborative efforts to help estahlish consistency within the emerging self-driving market has been 

crucial to the advancement of automated driving technologies. Continental is CutTently engaged with the 

Department ofTransportation 's Smart Cities Program. Several of our divisions are working together to 

develop a highly sophisticated intersection in Columbus, Ohio. with vehicle and integrated infi'astructure 

technologies that will help save the lives of vehicle occupants as well as pedestrians while improving 

transportation efficiency in urban environments. We support the National Highway Traffic Safety 

Administration's recent adoption ofthe SAE International definitions of automation, as we believe it is 

beneficial to helping educate the public in order to distinguish between different automated technologies 

and garner public acceptance. 

Continental is one of the leading suppliers in this market, with a complete p011folio ofteclmologies 

for all defined levels of automation. Each innovative safety feature undergoes an extensive testing 

process before becoming available to the market. As a supplier, we currently develop a multitude of 

innovative technologies that can save lives and enhance the driving experience under the Level 0 to 

Level 2 definitions of automation. These products arc designed based on the needs of our customers to 

assist the driver in interpreting the surrounding environment and control the vehicle in order to prevent 

an accident from occurring. 

Continental has been integral in the deployment of current crash avoidance technologies such as lane 

keep assist, rear back up assist, automatic emergency braking, and adaptive cruise control, to name a few. 

These crash avoidance technologies are the building blocks to higher levels of automated driving and 

need to be embraced as crash avoidance technologies that save lives. All of these technologies can be 

found throughout the fleets of most vehicle manufacturers. 

2 
14 


As the industry moves forward towards Leve13 automation technology and beyond, Continental is 

positioned to supply public and personal transportation needs with the safest and most advanced 

technology available on the market. The world and the behavior of drivers within it are ever changing, 

and the vehicle must adapt to these changing trends. Our children seem to rely on smartphones more so 

than vehicles. Living in a world of distractions has become commonplace. Automotive technology must 

be developed accordingly. That is why Continental has put a great deal of effot1 into Human Machine 

Interface technology. We want the driver to be aware of their surroundings, be aware of what the 

systems in the vehicle arc doing, and be aware of when it is safe to relinquish control ofthc vehicle and 

when to reengage with the vehicle. In addition to informing the occupants, keeping them safe, and 

pedestrians sale, we must also secure the systems within the vehicle. As part of system development t(Jr 

llighly Automated Driving. we focus on redundancy of vehicle safety systems. That is why we are 

developing complimentary systems and technologies that supp011 existing safety systems in the vehicle's 

architecture. 

Since 201!, we have continued a pursuit of testing and developing highly automated driving with 

next generation technologies like automated parking, cruising chauffeur and a complete self-driving 

vehicle in combination with V2VIV2X technology. We were the first supplier in the U.S. to he awarded 

a testing license for antomated vehicles in Nevada and arc currently testing our third generation 

automated vehicle on highways and roads throughout the country and around the world. We are 

currently integrating sophisticated technologies such as high resolution flash lidar, which will expand the 

vehicle's detection capabilities. This is the same technology that has been deployed on space shuttles at 

the most advanced technical level, and we are working to utilize its potentiall(lr road applications. But, 

our continued ctforts in this direction would benefit greatly ti·om an investment in infrastructure that 

promotes vehicle to X communication, a dedicated spectrum communication band that can be utilized by 

current and f\tture safety systems, and harmonization of safety laws that allows for the fhll real world 

testing of these technologies. 

The challenges in broadly testing this new and innovative safety technology across the country are 

great. The indnstry currently faces considerable uncertainty on state and federal requirements that would 

require clarification from the federal government's exclusive authority to regulate all motor vehicles. 

The sale commercial deployment of potential life saving technology depends on the ability to extensively 

test on public roads under all conditions. In order to envision a future of full automation, the government 

must review federal motor vehicle safety standards that would allow for vehicles that may not be under 

the Jl.tll control of a driver at all times. Similar to the need of improved road conditions as automobiles 

transitioned from rural landscapes to metropolitan areas in the early 1900s, we need a road infrastructure 

that complements automotive advancements, and a legal framework that supports a new system of 

mobility. 

The automotive world is one of excitement. Software developers are becoming automotive suppliers, 

automotive companies are becoming software developers, and our vehicles are becoming our smartdevice. The world of mobility has the capability of expanding to unimaginable independence and 

personal freedom without sacrificing the safety of future generations. Continental stands at the ready, 

alongside our industry colleagues, to work with the Committee and Congress in helping construct laws 

that foster innovation, enable mobility, and create a sater environment tor the public. 

Thank you again, Chairman Latta, Ranking Member Sehakowsky, members of the Subcommittee on 

Digital Commerce and Consumer protection and staff, for the opportunity to testify at today's hearing. 

3 
15 

Mr. LATTA. Well, thank you very much for your testimony today 

and the Chair recognizes Mr. Gouse for 5 minutes. Thanks again 

for being here. 

STATEMENT OF S. WILLIAM GOUSE 

Mr. GOUSE. Thank you, Chairman Latta, Ranking Member Schakowsky, and distinguished members of the subcommittee. SAE 

International thanks you for the opportunity to participate in this 

hearing, Self-Driving Cars: Levels of Automation. SAE International is a global society founded in 1905 with more than 140,000 

engineers, scientists, related technical experts, and students in 

over a hundred countries in the aerospace, automotive, motorcycle, 

commercial, construction, agricultural, and specialized vehicle industries. 

Some notable members were aviation and automotive pioneers 

Orville Wright, Henry Ford, Amelia Earhart and Ransom Olds, 

motor sports legends such as Andy Granatelli and Dan Gurney, 

along with celebrities like Jay Leno. SAE members from Government, academia, and industry have testified at this subcommittee 

or at previous hearings in both chambers. All four of us on this 

panel today testifying are SAE members, as I see are many of my 

colleagues in the audience. 

My SAE experience began even before I was a freshman mechanical engineering student at Georgia Tech when my professor and 

SAE Student Chapter advisor Professor Williams signed me up as 

a student member and gave me this membership pin. My initial exposure to SAE was before college because my father was or actually 

still is an SAE member. 

SAE’s core competencies are voluntary consensus standards development with nearly 30,000 experts across the globe contributing 

to a continually growing standards portfolio of over 10,000 active 

and 25,000 historical standards. These are used to increase safety, 

performance, quality and productivity of personal commercial 

transportation services while optimizing cost of products and product life cycles. This is an important point as this standard I will 

discuss in more detail in a moment is a product, as all standards 

are, of our members and other volunteers’ efforts. 

In addition to the standards activities SAE holds dozen of conferences and symposia, including the Government/industry meeting 

held in January in conjunction with the Washington Auto Show 

Mobility Talks, and next week is the SAE World Congress in Detroit where my colleagues are also presenting and participating. 

These events plus other mutually beneficial Government/industry 

academic networking opportunities provide information for the formation of sound public policy positions and affiliated programs, 

products, and services that add value and encourage innovation. 

SAE standards are referenced in Government regulations, procurement documents, recommendations, and guidelines issued by 

the U.S. DOT, the U.S. EPA, Department of Energy, the NTSB, in 

regulations in our States, Commonwealths, inhabited territories, 

and local jurisdictions. In addition, SAE standards are used internationally, Canada, elsewhere in the Americas, overseas, and by 

the UNECE. 

16 

SAE believes that incorporating voluntary consensus standards 

by reference as directed in the National Technology Transfer Advancement Act and the Office of Management and Budget CircularA119 improves the efficiency and effectiveness of Government, 

whether a Federal, State, municipal body, or global harmonization 

activity, it saves time and money while increasing the efficacy of 

policy, legislation, and/or regulation. This is critical in order to respond to the policy or regulatory needs brought about by the rapid 

technology developments we are witnessing. 

These developments are progressing significantly faster, potentially orders of magnitude faster, than the regulatory process. In 

addition, the competitiveness of products and services increased in 

the global marketplace because of the higher quality, value, and 

customer confidence achieved through conformity with SAE standards. SAE has several standards published and many documents in 

development by a variety of car, motorcycle, pedestrian, and truck 

and bus committees relating to increasing the safety and efficiency 

of transport. 

While work continues to improve passive safety and crashworthiness of vehicles, the potential of implementing technological 

solutions to avoid or reduce the severity of crashes is a major focus 

of our SAE committee activities. Details of these efforts, standards 

and documents, and progress were submitted to the subcommittee 

in written testimony. In summary, they encompass active safety 

systems, driver assistance systems, cybersecurity, vehicle 

connectivity and communications, measurement and test devices, 

vehicle testing including safe on-road testing of automated driving 

systems, and specific to today’s hearing, title SAE International 

Standard J3016: Taxonomy and Definitions for Terms Related to 

Automated Driving. I believe there is a flyer in front of all of you 

of this standard. 

This recommended practice originally published in 2014 and revised last September and referenced in the Federal Automated Vehicles Policy provides stakeholders including Federal, State, and 

local/municipal regulators, policy makers with a taxonomy describing the full range of six levels, SAE 0 through 5, of driving automation in on-road motor vehicles. These six levels span from no automation to full automation. 

I want to point out the key distinction. You see a dark green 

break in the handout here is between Level 2 where the human 

driver performs part of the dynamic driving task and Level 3 where 

the automated driving system performs the entire dynamic driving 

task under various conditions. The document, J3016, also contains 

functional definitions for advanced levels of driving automation and 

over a dozen related terms and definitions. 

Additional terms and definitions of active safety systems are contained in another standard, J3063 that was published in November 

of 2015. Importantly, what these standards do not provide are specifications or otherwise imposed requirements on driving automation 

systems or active safety systems, nor does it imply any particular 

order of market introduction or adoption. One vehicle might have 

multiple driving automation features such that it could operate at 

or different levels depending upon the features that are engaged or 

other consideration. 

17 

Standardizing levels of driving automation and supporting terms 

serve several purposes particularly clarifying the role of the human 

driver, if any, during driving automation system engagement; providing a useful framework for driving automation specifications 

and technical requirements; providing clarity, consistency, and stability in communications on the topic of driving automation, as well 

as a useful shorthand that saves considerable effort and time. The 

document is designed to be useful to many beyond the engineering 

community, such as legislators, regulators, others in the legal profession, the general and trade media, and consumers and the public 

that are buying, riding in, or having freight delivered in a vehicle 

with some level of driver assistance or automation. 

The levels I will go through very briefly are 0, with no automation; 1, a driver assistance system to a specific mode such as keeping steering or accelerating/decelerating; Level 2, partial automation, one or more driver assistance systems, both steering and acceleration/deceleration using information about the driving environment. The human driver is still expected to perform all remaining 

aspects. 

That break down to automated driving systems that monitor the 

driving environment for Level 3 conditional automation, driving 

mode-specific performed by an automated driving system in all aspects of the dynamic driving task which define the standard, with 

the expectation that the human driver will respond appropriately 

with a request to intervene; 4, high automation, the driving modespecific performance by an automated driving system of all aspects 

of the driving task even if a human driver does not respond appropriately to a request to intervene; and 5, full automation, full-time 

performance by an automated driving system of all aspects of the 

dynamic driving task under all roadway and environmental conditions that can be managed by a human driver. 

SAE has been and will continue to work with organizations and 

entities to reference SAE standards as we learn of their policy, regulatory, and legislative activities regarding both the public on-road 

testing, and the deployment of vehicles with driver assistance and 

automation systems. We are members of the Commonwealth of 

Pennsylvania—— 

Mr. LATTA. Pardon me, Mr. Gouse, if you could just wrap up, 

please. 

Mr. GOUSE. All right. We are members of the Pennsylvania Department of Transportation Task Force; we work with the associated motor vehicle manufacturers and other groups. SAE levels of 

automation were adopted in the Declaration of Amsterdam and 

they are used as we spoke earlier of the U.S. DOT and the Federal 

Automated Vehicles Policy. Prior to this, the Government used separate terms and retired their classification so now we have this 

consistent usage. 

Driving assistance and automated driving systems have the potential to provide substantial benefits to all customers of road 

transport. And I thank you very much for this opportunity to provide this statement and answer any questions. 

[The prepared statement of Mr. Gouse follows:] 

18 


United States House of Representatives 

Committee on Energy and Commerce 

Subcommittee on Digital Commerce and Consumer Protection 

Self-Driving Cars: Levels of Automation Hearing 

March 28, 2017 

Statement of SAE International· 

S. William Gouse, Director, Federal Program Development 

Chairman Latta, Ranking Member Schakowsky, and distinguished members of the subcommittee, SAE 

International thanks you for the opportunity to submit this statement for the hearing: "Self-Driving Cars: 

Levels of Automation". 

SAE International is a global society founded in 1905 with more than 140,000 engineers, scientists, 

related technical experts, and students, in over 100 countries, in the aerospace, automotive, motorcycle, 

commercial, construction, agricultural and specialized vehicles industries. Some notable members were 

aviation and automotive pioneers Orville Wright, Henry Ford, Amelia Earhart, and Ransom Olds, and 

celebrities such as Andy Granatelli and Jay Leno. SAE members from government, academia, and 

industry have testified to this subcommittee at previous hearings. 

SAE's core competencies are voluntary consensus standards development with nearly 30,000 experts 

across the globe contributing to a continually growing standards portfolio of over I 0,000 active and 

25,000 historical standards used to increase safety, performance, quality, productivity of personal 

commercial transportation services while optimizing cost of products and product-life cycles. SAE holds 

1 
19 


dozens of conferences and symposia, including the Government Industry meeting held in January in 

conjunction with the Washington Auto Show and our World Congress next month in Detroit. These 

events, plus other mutually beneficial government/industry academic networking opportunities provide 

information for the formation of sound public policy positions and affiliated programs, products and 

services that add value and encourage innovation. 

SAE standards are referenced in government procurement documents, recommendations, guidelines, and 

in regulations issued by the US Department of Transportation (US DOT), US Environmental Protection 

Agency, US Department of Energy, the National Transportation Safety Board, in regulations in our 

states, commonwealths, and inhabited territories. In addition, SAE standards are used internationally, in 

Canada, elsewhere in the Americas, overseas and by the United Nations Economic Commission for 

Europe. SAE believes that incorporating voluntary consensus standards by reference as directed in the 

National Technology Transfer Advancement Act and in Office of Management and Budget CircularA 119 improves the efficiency and effectiveness of government (whether a Federal, state, municipal 

body, or global harmonization activity), saving time and money, while increasing the efficacy of policy, 

legislation, and/or regulation. This is critical in order to respond to the policy or regulatory needs 

brought about by rapid technology developments. These developments are progressing significantly 

faster, potentially orders of magnitude faster, than the regulatory process. In addition, the 

competitiveness of adopting organizations' products and services is increased in the global marketplace 

because of the higher quality, value, and customer confidence achieved through conformity with SAE 

standards. 

SAE has several standards published and many documents in development by a variety of car, 

motorcycle, pedestrian, and truck and bus committees relating to increasing safety and efficiency of 

transport. While work continues to improve passive safety and crash worthiness of vehicles, the potential 

2 
20 


of implementing technological solutions to avoid or reduce the severity of crashes is a major focus of 

our members' committee activities. These efforts encompass active safety systems, driver assistances 

systems, cybersecurity, vehicle connectivity and communications, measurement and test devices, vehicle 

testing including safe on-road testing of automated driving systems, and specific to today's hearing's 

title, SAE International's standard J3016: Taxonomy and Definitions for Terms Related to On-Road 

Motor Vehicle Automated Driving Systems. 

This Recommended Practice originally published in 2014 and revised last September, and referenced in 

the Federal Automated Vehicles Policy provides stakeholders including Federal, state, and 

local/municipal legislators, regulators and policy-makers with a taxonomy describing the full range of 

levels (SAE 0 through 5) of driving automation in on-road motor vehicles. This includes functional 

definitions for advanced levels of driving automation and related terms and definitions. This 

Recommended Practice does not provide specifications, or otherwise impose requirements on, driving 

automation systems. Standardizing levels of driving automation and supporting terms serves several 

purposes, including: 

• Clarifying the role of the (human) driver, if any, during driving automation system engagement. 

• Answering questions of scope when it comes to developing laws, policies, regulations, and standards. 

• Providing a useful framework for driving automation specifications and technical requirements. 

• Providing clarity and stability in communications on the topic of driving automation, as well as a 

useful short-hand that saves considerable time and effort. 

This document was developed per the following guiding principles: 

• Be descriptive and informative rather than normative. 

3 
21 


• Be consistent with current industry practice. 

• Be consistent \Vith prior art to the extent practicable. 

• Be useful acmss disciplines. including engineering. law, media. public discourse. 

• Be clear and cogent. provide functional definitions and avoid or define ambiguous terms, 

SAE International's Lewis Of Automated Driving Automation for On-Road Vehicles: 

4 
22 


SAE has been and will continue to work with states and commonwealths as we learn of their policy, 

regulatory, and legislative activities regarding both the public on-road testing and the deployment of 

vehicles with driver assistance and automated driving systems. For example, we have been working the 

American Association of Motor Vehicle Administrators members and staff, and participate and 

contribute to their "Automated Vehicles Information Sharing Group". We're also members ofthe 

Commonwealth of Pennsylvania's Department of Transportation Autonomous Vehicle Testing Policy 

Task Force and continue to work with several states regarding policy and regulations for testing of 

automated driving systems on public roads. SAE staff and members have been involved with efforts in 

California and Michigan, but many more states, commonwealths, and municipalities in the US are 

developing policy, regulations and legislation in their departments of transportation, motor vehicle 

administrations, and legislative bodies. 

SAE was pleased that the US DOT and the National Highway Traffic and Safety Administration 

(NHTSA) adopted the SAE levels of automation in their September· 2016 "Federal Automated Vehicles 

Policy". Government entities, media, trade and consumer associations and the transportation/vehicle 

industry were using SAE levels of automation or the differing NHTSA classification and some, both. 

This incongruent usage has been one of the difficulties with communicating with stakeholders and 

harmonizing policy efforts. An ongoing challenge is to expand the use of consistent terms, definitions, 

and procedures via increasing the awareness ofSAE's resources, such as SAE J3016, SAE J3018: 

Guidelines for Safe On-Road Testing of SAE Level 3, 4, and 5 Prototype Automated Driving Systems 

(ADS), and other SAE International's enabling standards and recommended practices to all levels and 

branches of government. 

Driver assistance and automated driving systems have the potential to provide substantial benefits to all 

customers of road transport. SAE International's wealth of knowledge and experience with existing and 

5 
23 


developing standards in this area should be used by government, industry and academia to assist in the 

technology and policy solutions necessary for the adoption ofthese life and property saving advances. 

SAE International thanks the Subcommittee for this opportunity to provide a statement and welcomes 

questions and requests for additional information. 

Supplementing this statement, SAE International submits the following documents for the record: 

Surface Vehicle Recommended Practice, SAE 13016, Taxonomy and Definitions for Terms Related to 

Automated Driving Systems, issued January 2014, revised September 2016. 

Automated & Connected Transportation Standards, An infographic from SAE International 

Automated Driving, Levels of Driving Automation are Defined in New SAE International Standard 

J3016 

SAE International Global Ground Vehicle Standards Organization Chart 

6 
24 

Mr. LATTA. Well, thank you very much. And Mr. Zuby you are 

recognized for 5 minutes and thank you very much for being here. 

STATEMENT OF DAVID S. ZUBY 

Mr. ZUBY. Good morning, Chairman Latta, Ranking Member 

Schakowsky, and distinguished members of the subcommittee. On 

behalf of the Insurance Institute for Highway Safety, thank you for 

the opportunity to testify today on vehicle automation and crash 

avoidance technologies. 

The Insurance Institute for Highway Safety and its sister organization, the Highway Loss Data Institute, are nonprofit research institutes that identify ways to reduce deaths, injuries, and property 

damage on our highways. We are wholly supported by voluntary 

contributions from companies that sell automobile insurance in the 

United States and Canada. 

The United States has made enormous progress in reducing the 

toll from motor vehicle crashes. The death rate per billion vehicle 

miles traveled is one quarter of what it was in 1973 when crash 

deaths peaked at 54,589. While changes in traffic laws and their 

enforcement combined with changes in road and vehicle designs all 

contributed to that decline, our research has shown that improvements in vehicle safety have been the largest contributor to road 

safety since the 1990s. We are convinced that further improvement 

in vehicle safety will remain an important strategy to make travel 

on U.S. roads even more safe in the future. 

Past improvements in vehicle safety largely focused on mitigating and preventing injuries when crashes occurred. The newest 

tool in the vehicle safety toolbox is automation of the vehicle controls that can prevent crashes in the first place and reduce the severity of those that aren’t prevented. Electronic stability control 

which helps prevent sideways skidding and loss of control, reduces 

the risk of a fatal single vehicle crash by 49 percent and cuts the 

risk of a fatal multiple vehicle crash by 20 percent. 

More recently, front crash prevention systems which help drivers 

avoid front to rear crashes with warnings or automatic braking reduce these crashes by 26 percent for warnings by itself and by 50 

percent for warnings combined with auto braking. Reductions for 

crashes with injuries are even larger. 

These are large reductions and count as wins for automation of 

vehicle control, but neither ESC nor front crash prevention systems 

prevent all the crashes they target. In addition, there are other 

new crash avoidance technologies like those that aim to prevent 

crashes precipitated by inadvertent lane drifts for which we have 

not yet found definitive benefits. There are reasons to be skeptical 

of the claims that driving automation will eliminate all crashes 

currently caused by human error. This is especially true in the 

near term technologies which will continue to involve human driver 

to a large extent. 

The design of these technologies and how drivers interact with 

them will be an important factor in their success. For example, we 

have found that on average across multiple implementations from 

various automakers, lane departure warning and other lane maintenance systems are used by only 50 percent of drivers whose cars 

25 

have them. There is a wide variation in the use rate and that 

seems to be influenced by system design. 

As technology allows further automation of the driving task, we 

are concerned that some human drivers will fail to understand the 

limitations of these systems on their vehicles and crash because 

they are overly reliant on them. The design of driving automation 

systems will be key to helping drivers understand how systems 

work including the limitations of the technology. It will be important to continually monitor the effects of safety on new technologies 

entering the market. 

The studies mentioned above were only possible with close cooperation of a few automakers who helped us identify by vehicle 

identification number the specific vehicles that were equipped with 

a range of optional features. Unfortunately, there was no comprehensive database linking VINs to information about what features are present on a given vehicle. Government policies aimed at 

ensuring the availability of such highway safety data are important 

to enhance highway safety research on the effectiveness of these 

emerging technologies. 

Thank you again to the members of the subcommittee for inviting me to share what IIHS and HLDI have learned about the effectiveness of crash avoidance technologies. I would be happy to answer any questions. 

[The prepared statement of Mr. Zuby follows:] 

26 


Statement before the United States House of 

Representatives Committee on Energy and Commerce; 

Subcommittee on Digital Commerce and Consumer 

Protection 

What today's advanced driver assistance systems can 

tell us about the self-driving future 

David S. Zuby 

Insurance Institute for Highway Safety 
27 


Summary 

The United States has made enormous progress in reducing the toll from motor vehicle crashes, 

thanks to safer vehicles, better laws and enforcement, and traffic engineering improvements. Of those 

factors, vehicle improvements have played the biggest role in recent years. In contrast, efforts to 

reduce crashes by changing driver behavior have largely stalled. 

Automation is the next frontier in vehicle improvements and could one day address the problem of 

human behavior by taking it out of the equation completely. That day remains far in the future, 

however. 

Experiences with existing crash avoidance technologies can give us some clues regarding the 

potential benefits and pitfalls of emerging automation technologies. IIHS research has documented 

safety benefits from some features, including electronic stability control and automatic braking. On the 

other hand, studies of insurance claims have not found consistent benefits from lane departure 

warning systems. These results show how crucial it will be to monitor new technologies to see if they 

deliver on their promise. Policies to help ensure the availability of information about which specific 

vehicles are equipped with which features would help researchers track the effectiveness of driver 

assistance systems. 

Driver attitudes toward technologies will be key to ensuring new features reach their potential. Our 

research has shown that driver acceptance of technology varies. 

We expect driving automation to enter the market gradually. During these years of technical evolution, 

some drivers may fail to understand the limitations of the systems and become overly reliant on them. 

New features should be designed in such a way as to make their limitations clear. 

While automation has the potential to greatly reduce the toll from crashes, it would be a mistake to 

focus on it to the exclusion of proven countermeasures. Things like lower speed limits and strict 

enforcement of seat belt laws can provide benefits now, while we await the self-driving future. 

Insurance Institute for Highway Safety 

1005 North Glebe Road. Arlington. VA 22201 

March 28. 2017 
28 


Introduction 

The Insurance Institute for Highway Safety (IIHS) and its sister organization, the Highway Loss Data 

Institute (HLDI), are nonprofit research institutes that identify ways to reduce deaths, injuries, and 

property damage on our highways. We are wholly supported by voluntary contributions from companies 

that sell automobile insurance in the U.S. and Canada. Thank you for the opportunity to testify on 

emerging automated driving technologies. 

The United States has made enormous progress in reducing motor vehicle crash deaths over the past 

half a century. A combination of safer vehicles, better laws and enforcement of those laws, and traffic 

engineering improvements have cut the rate of crash deaths per population to nearly half of what it was in 

1975.1 The rate of crash fatalities per 100 million vehicle miles traveled is one-third the rate in 1980. 

Out of all these types of countermeasures, it is vehicle improvements - including more crashworthy 

structures, front and side airbags and electronic stability control (ESC)- that have driven most of the 

decline in driver death rates since the mid-1990s. 2 In contrast, efforts to reduce crashes by changing 

driver behavior have largely stalled. Speeding, alcohol-impaired driving and lack of safety belt use all 

remain persistent problems. 

Automation is the next frontier in vehicle improvements and could also address the problem of driver 

behavior. Full automation has the potential to make the human propensity to make poor decisions and 

errors irrelevant. In a study of police-reported crashes occurring during 2005-07 where at least one 

vehicle was towed from the scene, researchers found that a driver's error or physical state had Jed to 94 

percent of the crashes. 3 If automation can eliminate all crashes involving driver-related factors, then 

thousands of lives will be saved each year. 

At the moment and for the foreseeable future, however, human drivers are still a key part of the equation. 

The safety potential of partial automation will be limited in large part by the way human drivers interact 

with driver assistance systems on their own vehicles and with fully automated vehicles with which they 

may share the road. 

Insurance Institute for Highway Safety 

1005 North Glebe Road, Arlington, VA 22201 

March 28, 2017 
29 


What we can learn from existing crash avoidance features 

Although full driving automation for most vehicles remains far in the future, crash avoidance features that 

automatically assume control over vehicle motion when drivers fail to adequately respond to crash 

hazards aren't new. These include ESC and automatic braking systems. Our research has already 

documented injury-preventing benefits of these features. 

ESC, which has been required on all new passenger vehicles since the 2012 model year, helps prevents 

sideways skidding and loss of control. The technology reduces the risk of a fatal single-vehicle crash by 

49 percent and cuts the risk of a fatal multiple-vehicle crash by 20 percent for cars and SUVs 4 Its 

effectiveness in preventing rollover crashes is even more dramatic. Years ago, SUVs were considered 

dangerous vehicles because their high centers of gravity made them prone to rolling over. That is no 

longer the case, thanks to ESC, which reducing the risk of fatal single-vehicle rollover crashes by 75 

percent for SUVs and by 72 percent for cars. 4 

More recently, automatic control of vehicle brakes has proven to be an effective countermeasure against 

front-to-rear crashes. Front crash prevention is our name for systems that can detect an impending 

collision with the vehicle in front and warns the driver to brake, automatically brakes on its own or 

performs a combination of these functions. In a study of police-reported front-to-rear crashes, we found 

that systems with automatic braking reduce rear-end crashes by about 50 percent.5 Studies by HLDI of 

insurance claim rates have also shown benefits for front crash prevention systems with and without 

automatic braking6 •

7·

8•

9•

10·

11 · 

Despite these success stories, not all crash avoidance features have been shown to be effective. For 

example, HLDI examined the effectiveness of lane departure warning systems from six manufacturers 

and did not find any consistent changes in rates of insurance claims covering damage to at-fault vehicles, 

which is the type of claim that would likely follow a single-vehicle run-off-road crash. 7•

9•

12·

13 

The disparate results for the effects of crash avoidance technologies point to one of our concerns about 

driving automation- namely, that there is no guarantee that the technology will deliver on its promise. 

Consequently, it will be important to continually monitor the effects on safety of new technologies entering 

Insurance Institute for Highway Safety 

1005 North Glebe Road. Arlington, VA 22201 

March 28, 2017 
30 


the market The studies mentioned above were only possible with the close cooperation of a few 

automakers who helped us identify by Vehicle Identification Number (VIN) the specific vehicles that were 

equipped with a range of optional features. Unfortunately, there is no comprehensive database linking 

VINs to information about what features are present on a given vehicle. Government policies aimed at 

ensuring the availability of such data for highway safety research would greatly enhance our ability to 

study the effectiveness of emerging technologies. 

Driver attitudes 

Collision avoidance and driving automation systems can't reach their crash-reduction potential if drivers 

don't use or respond appropriately to them. A recent IIHS observational study illustrates how driver 

attitudes toward advanced driver assistance systems can vary depending on how the feature is 

implemented. 14 We observed vehicles from eight manufacturers brought to dealership service centers to 

see if their front crash prevention and lane-maintenance systems (i.e., lane-departure warning, lanedeparture prevention or active lane-keeping) were turned on. While front crash prevention was activated 

in 93 percent of vehicles we observed, lane-maintenance systems were turned on in only 51 percent of 

vehicles. 

We also studied driver trust in advanced technologies in a more direct way by inviting our own employees 

to drive vehicles equipped with adaptive cruise control, forward collision warning, lane-departure warning, 

active lane-keeping and side-view assist systems. Fifty-four employees took part in this study, using the 

vehicles for days or weeks at a time for both commuting and longer trips. Overall, drivers did not express 

strong trust in any of the technologies. 15 Trust was highest for side-view assist and lowest for active lanekeeping. Trust in adaptive cruise control and side-view assist varied among vehicles. 

Pitfalls of partial automation 

No matter how quickly technology develops, it will take at least 25 years before nearly all vehicles on U.S. 

roads have Ieday's latest technology. This estimate is based on a HLDI study that examined how long it 

takes for new features to be present in 95 percent of registered vehicles. 16 Thus, if the government were 

Insurance Institute for Highway Safety 

1005 North Glebe Road. Arlington, VA 22201 

March 28, 2017 
31 


to require that all new vehicles sold in the U.S. be fully automated starting tomorrow, it would still be 2042 

before nearly all vehicles on the roads were fully automated. 

More realistically, we think driving automation will enter the market in a piecemeal fashion. Over time 

more and more of the driving task will be able to be automated. During these years of technical evolution, 

we are concerned that some human drivers will fail to understand the limitations of the systems on their 

vehicles and crash because they are overly reliant on them. Driving automation systems should be 

designed in ways that make their limitations clear to human operators. 

It is also worth noting that partial automation may be of limited benefit in many kinds of crashes. We 

recently examined records of crashes caused by drivers drifting from their lanes. We found that 34 

percent of drivers in lane-drift crashes were asleep or otherwise incapacitated because of a medical issue 

or alcohol or drug use. 17 For those drivers, lane-maintenance systems would have little relevance. Even if 

these vehicles had been brought back into their lanes, they likely would have crashed ultimately. To be 

effective in such cases, a crash avoidance system would have to bring the vehicle to a stop on the side of 

the road. 

Finally, there is the issue of autonomous vehicles sharing the road with human drivers. Our study of 

crashes on public roads involving Google's self-driving cars shows that even high-performing self-driving 

vehicles will still be struck by vehicles driven by humans. 18 We reviewed 19 crashes involving Google selfdriving cars traveling in autonomous mode. In most of the incidents, the Google car was rear-ended by 

another vehicle. 

Other opportunities to reduce crash deaths and injuries 

Our work at IIHS and HLDI is guided by a rubric known as the Haddon matrix. Developed by William 

Haddon Jr., the nation's first highway safety chief and president of IIHS from 1969 to 1985, the matrix 

reminds public health practitioners and policymakers that there are often multiple opportunities to treat a 

public health problem such as motor vehicle crashes. 

Improvements in vehicle safety have been effective in reducing crash deaths in recent decades, and 

increasing automation is the next logical step in those efforts. However, it would be a mistake to focus on 

Insurance Institute for Highway Safety 

1005 North Glebe Road, Arlington, VA 22201 

March 28,2017 
32 


those opportunities to the exclusion of proven countermeasures. Lower speed limits, strict enforcement of 

seat belt laws and prohibitions on alcohol-impaired driving, and safer road designs are just some of the 

tools that could be used to reduce the toll from crashes while we wait for the benefits of driving 

automation. 

Insurance Institute for Highway Safety 

1005 North Glebe Road, Arlington, VA 22201 

March 28, 2017 
33 


References 

1. Insurance Institute for Highway Safety. Yearly snapshot 2015. http:llwww.iihs.org/iihs/topics/t/generalstatistics/fatalityfacts/overview-of-fatality-facts. Accessed on March 23, 2017. 

2. Farmer, C. M.; Lund, A.K. 2015. The effects of vehicle redesign on the risk of driver death. Traffic 

Injury Prevention 16(7): 684-690. 

3. Singh, S. 2015. Critical reasons for crashes investigated in the National Motor Vehicle Crash 

Causation Survey. Traffic Safety Facts, Report no. DOT HS 812 115. Washington, DC: National 

Highway Traffic Safety Administration. 

4. Farmer, C. M. 2010. Effects of electronic stability control on fatal crash risk. Arlington, VA: Insurance 

Institute for Highway Safety. 

5. Cicchino, J. B. 2017. Effectiveness of forward collision warning and autonomous emergency braking 

systems in reducing front-to-rear crash rates. Accident Analysis and Prevention 99(Part A): 142-152. 

6. Highway Loss Data Institute. 2016. Fiat Chrysler collision avoidance features: initial results. Loss 

Bulletin 33(2). Arlington, VA. 

7. Highway Loss Data Institute. 2016. 2013-15 Honda Accord collision avoidance features. Loss Bulletin 

33(32). Arlington, VA. 

8. Highway Loss Data Institute. 2016. Mercedes-Benz collision avoidance features - a 2016 update. 

Loss Bulletin 33(23). Arlington, VA. 

9. Highway Loss Data Institute. 2012. Volvo collision avoidance features: initial results. Loss Bulletin 

29(5). Arlington, VA. 

10. Highway Loss Data Institute. 2016. Acura collision avoidance features- a 2016 update. Loss Bulletin 

33(19). Arlington, VA. 

11. Highway Loss Data Institute. 2016. 2013-15 Subaru collision avoidance features. Loss Bulletin 33(30). 

Arlington, VA. 

12. Highway Loss Data Institute. 2012. Mercedes-Benz collision avoidance features: initial results. HLDI 

Bulletin 29(7). Arlington, VA. 

13. Highway Loss Data Institute. 2016. Mazda collision avoidance features: an update. HLDI Bulletin 

33(3). Arlington, VA. 

14. Reagan, I.J.; Cicchino, J.B.; Kerfoot, L. B.; and Weast, R.A. 2017. Crash avoidance and driver 

assistance system technologies- are they used? Arlington, VA: Insurance Institute for Highway 

Safety. 

15. Kidd, D.G.; Cicchino, J.B.; Reagan; I.J.; and Kerfoot, LB. In press. Driver trust in five driver assistance 

technologies following real-world use in four production vehicles. Traffic Injury Prevention. 

16. Highway Loss Data Institute. 2015. Predicted availability of safety features on registered vehicles- a 

2015 update. HLDI Bulletin 32(16). Arlington, VA. 

17. Cicchino, J. B.; Zuby, D.S. In press. Prevalence of driver physical factors leading to unintentional lane 

departure crashes. Traffic Injury Prevention. 

18. Insurance Institute for Highway Safety. 2016. Special issue: autonomous vehicles. Status Report 

51(8). Arlington, VA. 

Insurance Institute for Highway Safety 

1005 North Glebe Road, Arlington, VA 22201 

March 28, 2017 
34 

Mr. LATTA. Well, thank you very much. And Dr. Stepper, you are 

recognized for 5 minutes for your opening remarks. Thank you very 

much for being here. 

STATEMENT OF KAY STEPPER 

Dr. STEPPER. Thank you Chairman Latta, Ranking Member 

Schakowsky, and members of the committee for the opportunity to 

testify before you today. My name is Kay Stepper, vice president 

with responsibility for the Driver Assistance and Automated Driving Systems for Bosch in the United States. At Bosch we are proud 

to be inventive for life, and I am honored to discuss an issue that 

is one of the pillars of our everyday work at Bosch: to save lives. 

Bosch has a long history in the United States. Robert Bosch himself established the first office in the United States in New York 

City in 1906. Now in 2017, Bosch companies operate more than 100 

sites across the country. Bosch believes that automated driving is 

the future of mobility, and leading the way to safe, agile, and automated driving is our guiding principle. Worldwide, Bosch has more 

than 2,500 engineers and researchers working on the topics of 

automated driving and advanced driver assistance in our autonomous driving tests that is conducted in the United States, Germany, Japan, and Australia. 

Preliminary 2016 data from the National Safety Council projects 

that as many as 40,000 people died in motor vehicle crashes last 

year. The magnitude of the safety crisis is such that we must seek 

active means to increase deployment of technologies that can support drivers and reduce accidents and injury rates. Driver assistance systems such as automatic emergency braking and blind spot 

detection can assist in reducing the rising fatality and injury numbers that we are facing in the United States today. 

In the near term, it is critical that Government and industry continue to work together to help increase consumer access to and understanding of these advanced technologies. I commend the committee for calling this hearing and for focusing its attention on two 

topics that lie at the heart of this transformation in vehicle mobility: the levels of automation and the importance of the deployment 

of driver assistance systems as a foundation for automated driving. 

Unfortunately, these topics are often overlooked in the overall 

dialogue about automated driving. The truth is that many drivers 

and passengers are already experiencing the benefits of vehicle automation every single day. The active safety system electronic stability control is integrated into every new light-duty vehicle sold in 

the United States today. This revolutionary technology invented by 

Bosch engineer Dr. Anton van Zanten has saved thousands of lives. 

A 2014 report from NHTSA found that ESC saved close to 4,000 

lives during the 5-year period from 2008 to 2012. 

Automated driving will bring great benefits and pave the paths 

forward a new vision of personal and collective transportation. 

However, it will take time to achieve fully automated driving and 

it will be an evolutionary process, building up on the stepping 

stones of active safety, driver assistance, and crash avoidance system. 

In discussing the evolution toward automated driving I want to 

emphasis that Bosch strongly supports NHTSA’s decision to adopt 

35 

the SAE J3016 framework for levels of automation as part of the 

Federal Automated Vehicle Policy. This is a major step toward harmonizing and establishing a common set of definitions across the 

various stakeholders involved in these efforts. Bosch wishes to 

highlight automatic emergency braking as one clear example of 

how drivers are being introduced to automation in a gradual manner, and also of how automation intervention by the vehicle can 

provide the greatest benefit in terms of accident reduction. 

Suppliers play an important role in the innovation cycle and 

many suppliers such as Bosch conduct extensive testing in the lab 

on test tracks and on public roads. Suppliers presently face several 

obstacles in carrying out this testing on public roads, and we respectfully request that the committee consider extending the FAST 

Act exemption to include suppliers with active and established research and development programs in the United States. 

Bosch position on the need for improved consumer education is 

well known. We have urged NHTSA and the U.S. Department of 

Transportation for many years to include crash avoidance system 

as a key component of the vehicle 5–Star rating and to provide additional information to consumers through the Monroney label. 

Bosch believes that displaying crash avoidance systems as part of 

the official safety portion of the Monroney label and particular in 

the form of 5–Star rating, as the most effective means to help driver consumer awareness and eventually consumer demand for such 

technologies. Without the clear presence of crash avoidance and 

mitigation technologies on the most recognizable feature for consumers, the physical Monroney label as affixed to the vehicle, consumer education will continue to lag. 

The adaption of crash avoidance technologies into NCAP would 

be a very significant improvement and one which we believe will 

bring about immediate benefits as well as paving the path toward 

the attainment of automated driving in the future. Bosch encourages Congress and NHTSA to cooperate a path forward for the U.S. 

NCAP to become an effective means of encouraging the enhanced 

adoption of these lifesaving systems. Bosch truly believes that a 5– 

Star rating is the most effective means to translate the presence 

and performance of crash avoidance technologies into an easy-tounderstand indicator for consumers. 

Thank you again for the opportunity to speak before the committee. I welcome any questions you may have. 

[The prepared statement of Dr. Stepper follows:] 

36 


Testimony of Dr. Kay Stepper 

Vice President for Automated Driving and Driver Assistance 

Systems 

Chassis Systems Control 

Robert Bosch LLC 

BOSCH 

Hearing on 

Self-Driving Cars: Levels of Automation 

House Energy & Commerce Committee 

Subcommittee on Digital Commerce and Consumer Protection 

United State House of Representatives 

March 28, 2017 
37 


Robert Bosch LLC 

Testimony before the House Energy and Commerce 

Subcommittee on Digital Commerce and Consumer Protection 

March 28,2017 

Background 

As a global Tier One supplier, Bosch is working diligently to make Automated Driving 

a reality. We currently employ more than 2,500 engineers working worldwide on the 

topics of automated driving and advanced driver assistance. 

Key Areas 

Automated Driving and Innovation: Continued federal collaboration and support for 

research and testing is vital to keeping the U.S. and the automotive industry at the 

forefront of technological innovation. Lawmakers and regulators should permit the 

safe and responsible testing of advanced safety and automated technologies on 

public roads. The Federal Automated Vehicles Policy, issued by NHTSA in 2016, 

represents an important step forward but critical issues must still be addressed. 

Driver Assistance I Crash Avoidance Systems: The automotive industry continues 

to develop and bring to market innovative safety technologies that have made a 

significant difference in reducing fatality and injury rates. Adoption rates, however, 

remain low and additional actions must be taken to encourage the installation of 

these technologies. 

Consumer Education and NCAP: The U.S. New Car Assessment Program (NCAP) 

is the leading mechanism through which the federal government communicates 

vehicle safety information to consumers. Although the NHTSA has proposed an 

update to NCAP, the current NCAP model, which is focused solely on 

crashworthiness and rollover propensity, is outdated and should be modernized. 
38 


Chairman Latta, Ranking Member Schakowsky, members of the 

Committee, thank you for the opportunity to testify before you today. 

My name is Kay Stepper, Vice President with responsibility for the 

Driver Assistance and Automated Driving Systems for Bosch in the United 

States. At Bosch we are proud to be "Invented for Life" and I am honored 

to discuss an issue that is one of the pillars of our everyday work at Bosch: 

to save lives. 

Robert Bosch founded the company in 1886, when he opened the 

"Workshop for Precision Mechanics and Electrical Engineering" in 

Stuttgart, Germany. Today, the Bosch group of companies employ more 

than 390,000 associates around the globe, including nearly 18,000 in the 

United States. 

Bosch has a long history in the United States. In fact, the U.S. played 

a pivotal role in the history of Robert Bosch himself. At the age of just 23, 

he ventured across the Atlantic, traveling to the U.S. to work with Edison 

and gain insights into electrical engineering. He subsequently established 

an office in New York City in 1906. Now, in 2017, Bosch companies 

operate more than 100 manufacturing, development, sales, service and 

administrative sites across the country with a significant presence in 

Michigan, South Carolina, Illinois, California, Wisconsin, and Kentucky. 

We also have three dedicated Research and Development Centers in the 

U.S.; they are located in Pittsburgh, PA; Cambridge, MA and Palo Alto, 

CA. 

Bosch has four business sectors - Mobility Solutions, Energy and 

Building Technology; Consumer Goods; and Industrial Technology. 

Mobility solutions is our largest sector, comprising approximately 60 

percent of our business and representing 217,000 associates. 
39 


Bosch is very active at every level of autonomous driving. As a Tier 

One full systems supplier, Bosch understands the entire automated driving 

system from requirements derivation to turn-key solutions. Ranging from 

individual components such as sensors, electronic control units, brake 

systems, steering, to the overall system, we develop and supply almost 

every element required for automated driving. Bosch is the world's largest 

manufacturer of MEMS and radar sensors and a leading global 

manufacturer of mono- and stereo-vision cameras, ultrasonic sensors, 

braking and steering systems. With this broad product reach, combined 

with our expertise in cybersecurity protection, Bosch is uniquely positioned 

to help drive the creation of a full system approach for our customers. 

Bosch is advancing artificial intelligence. At the Bosch 

Connected World 2017 conference in Berlin, Bosch presented an onboard 

computer for automated vehicles. Thanks to artificial intelligence (AI), the 

computer can apply machine learning methods. The AI onboard computer 

is expected to guide self-driving cars through even complex traffic 

situations, or ones that are new to the car. 

Bosch believes that automated driving is the future of mobility and 

"Leading the way to safe, agile and automated driving" is our guiding 

principle. Bosch has more than 2,500 engineers working worldwide on the 

topics of automated driving and advanced driver assistance in order to 

achieve this goal and our autonomous driving testing is conducted in the 

U.S., Germany, Japan, and Australia. 

Accident statistics indicate that more than 90 percent of all crashes 

are caused by human error. A forward-thinking vehicle which takes over 

dedicated driving tasks could make the vision of injury and collision-free 

driving a reality. NHTSA's preliminary numbers for the first nine months of 

2016 show that an estimated 27,875 people died in crashes - an eight 
40 


percent increase over the first 9 months of 2015.1 Preliminary 2016 data 

from the National Safety Council projects that as many as 40,000 people 

died in motor vehicle crashes last year.2 

The magnitude of this safety crisis is such that we must seek active 

means to increase deployment of technologies that can support drivers 

and reduce accident and injury rates. Driver assistance systems such as 

Automatic Emergency Braking (AEB) and Blind Spot Detection (BSD) can 

assist in reducing the rising fatality and injury numbers that we are facing 

in the United States today. In the near term, it is critical that government 

and industry continue to work together to help increase consumer access 

to and understanding of these advanced technologies. 

In January 2017, Bosch released a study "Connected Car Effect 

2025"3 which investigated what mobility technology will mean specifically 

for the US, Germany and the major cities of China. The result: safety 

systems and cloud-based functions can prevent around 260,000 injury 

accidents, save 390,000 tons of C02 emissions and offer drivers many 

hours of more time for other activities. Over 260,000 accidents involving 

personal injuries (US: 210,000, China: 20,000, Germany: 30,000) will be 

avoided annually - as many accidents as occur within two years in 

Germany's capital city of Berlin. The Study predicted that 350,000 fewer 

people would be injured by traffic accidents- the same as 12 years without 

traffic injuries in Los Angeles. In the US alone, there will be 290,000 fewer 

(China: 25,000, Germany: 37,000). 

I commend the Committee for calling this hearing and for focusing 

its attention on two topics that lie at the heart of this transformation in 

1 DOT HS 812 358: A Brief Statistical Summary- Early Estimate of Motor Vehicle Traffic Fatalities 

For the First 9 Months of 2016; January 2017 

2 National Safety Council Press Release. February 15,2017. "Motor Vehicle Deaths in 2016 Estimated 

to be Highest in Nine Years" 

'"Connected Car Effect 2025" conducted by Bosch and the consulting finm Prognos, January 2017 
41 


vehicle mobility: the levels of automation and the importance of the 

deployment of driver assistance systems as a foundation for automated 

driving. Unfortunately, these topics are often overlooked within the overall 

dialogue about Automated Driving. The truth is that many drivers and 

passengers are already experiencing the benefits of vehicle automation 

every day. The active safety system Electronic Stability Control (ESC) is 

integrated into every new passenger car sold in the United States. This 

revolutionary technology, invented by Bosch engineer Dr. Anton van 

Zanten, has saved thousands of lives. A 2014 report from NHTSA found 

that ESC saved close to 4,000 lives during the 5-year period from 2008 to 

20124. The technology works by monitoring driver intent and vehicle 

direction and by automatically applying braking force as needed to prevent 

a loss of control. Most drivers are not even aware of its support. This 

intervention is communicated to the driver as a mere flash of the indicator 

light on the dash. but the real world result is often a life saved or a serious 

injury mitigated. 

Automated driving will bring great benefits and pave the path toward 

a new vision of personal and collective transportation. However, it will take 

time to achieve fully automated driving and it will be an evolutionary 

process, building upon the stepping stones of active safety, driver 

assistance and crash avoidance systems. The first wave is already here 

in the form of driver assistance systems that utilize automation to increase 

safety. The next phase will consist of partially-automated functions. such 

as traffic jam assist. which are available in the market but not deployed in 

great numbers. 

In discussing the evolution toward Automated Driving, I want to 

emphasize that Bosch strongly supports NHTSA's decision to adopt the 

'DOT HS 812 042, June 2014, Estimating Lives Saved by Electronic Stability Control, 2008-2012 
42 


SAE International (SAE) J3016 framework for levels of automation as part 

of the Federal Automated Vehicles Policy. This is a major step toward 

harmonizing and establishing a common set of definitions across the 

various stakeholders involved in these efforts. Without a common 

taxonomy and understanding of the different levels of automation, it will be 

considerably more difficult to make the necessary strides toward full 

automation. In fact, the lack of a common "language" and standardized 

descriptions is one of the obstacles that has hindered the understanding 

and adoption of Advanced Driver Assistance Systems (ADAS). 

A 2015 study conducted by the Boston Consulting Group (BCG), on 

behalf of the Motor & Equipment Manufacturers Association (MEMA}, 

determined that the widespread installation of ADAS technologies could 

prevent about 9,900 fatalities each year and save more than $250 billion 

annually in societal costss in the United States. The BCG found that, at 

that time, ADAS features were not present in a high number of vehicles 

and that their share of the U.S. market was growing at only 2 to 5 percent 

annually. 

Bosch wishes to highlight Automatic Emergency Braking as one 

clear example of how drivers are being introduced to automation in a 

gradual manner and also of how automation and intervention by the 

vehicle can provide the greatest benefit in terms of accident reduction. The 

full suite of AEB, also known as Crash Imminent Braking, consists of three 

technologies. The first is Forward Collision Warning which simply alerts 

the driver to the fact that he/she is getting very close to the vehicle in front 

of them. The next stage technology, termed by NHTSA as Dynamic Brake 

Support, actually prepares the brakes and pre-fills them so that the driver 

will immediately have full braking power when he/she engages the brakes 

'A Roadmap to Safer Driving Through Advanced Driver Assistance Systems (ADAS), Boston 

Consulting Group, September 2015 
43 


to slow or stop the vehicle. The driver does not feel a demonstrable 

difference in the brake but he/she receives enhanced braking power to 

reduce the stopping distance. AEB is the last technology in this cascade. 

If the driver takes no action, then the system engages the brakes on its 

own and stops the vehicle to prevent or mitigate the crash. 

These types of crashes remain a leading safety concern in the 

United States. Bosch's internal analysis of NHTSA's 2013 NASSe data 

indicated that approximately 33 percent of collisions with injuries and 

fatalities were rear-end crashes. Most drivers believe that they are 

observant and fully aware of their surroundings, but Bosch's research 

found that drivers often fail to detect the obstacle in rear end crashes. In 

cases where the driver did detect the obstacle, approximately 49 percent 

of the drivers failed to apply adequate braking force in order to avoid the 

collision. Further, 31 percent of drivers failed to even apply the brakes at 

all. This cascade approach optimizes the system's ability to support and 

assist the driver. It exemplifies the manner in which increasing levels of 

automation can help to supplement the driver's own abilities. 

Bosch, together with its customers and other suppliers, has also 

devoted considerable resources to tackling the growing safety problem of 

pedestrian fatalities and injuries. Technology, in the form of advanced 

pedestrian detection and braking technologies, offers us the opportunity to 

notably mitigate and, in some cases, prevent crashes involving vulnerable 

road users. In 2015 there were 5,376 pedestrians killed in traffic crashes 

in the U.S., a 9.5 percent increase from the 4,910 pedestrian fatalities in 

2014. This figure represents the highest number of pedestrians killed 

annually since 1996. On average, a pedestrian was killed nearly every 1.6 

hours and injured more than every 7.5 minutes in traffic crashes in 2015.7 

s National Highway Traffic Safety Administration, National Automotive Sampling System (NASS} 

'DOT HS 812 375, NHTSA Traffic Safety Facts, February 2017 
44 


Bosch has developed forward pedestrian Automatic Emergency Braking 

systems as well as rear Automatic Braking systems to address these types 

of crashes. We are applying the same strategies utilized in AEB, 

cascading from a driver warning to a full automatic intervention. Also, as 

mentioned before, Bosch has been developing Artificial Intelligence for 

use in vehicle automation. Bosch's AI onboard computer can recognize 

pedestrians or cyclists. 

Suppliers play an important role in the innovation cycle and many 

established suppliers, such as Bosch, conduct extensive testing in the lab, 

on test tracks, and on public roads. These activities are integral to the 

development and maturity of the technology needed for automated driving. 

Our engineers conduct extensive track testing and simulation work; but 

nothing can replace the importance of on the road testing and validation. 

In addition, these efforts are intrinsic to enabling suppliers to develop their 

own robust and comprehensive offerings for OEMs and support the 

competitive challenge to deliver the most effective and cost-sensitive 

software options for automakers. Prohibitions and delays that impede onroad testing will slow this process at the supplier level and; thereby, inhibit 

the overall progression of automated driving technology. For Bosch, 

reliability and robustness are the top priorities when it comes to safety 

systems. This requires the use of thoroughly tested and approved software. 

Bosch emphasizes that these development vehicles are driven exclusively 

by trained test drivers at Bosch and equipped with special safety concepts 

to enable the driver to reassert control at any time. After a successful 

release procedure on test tracks, we take the system on public roads to 

conduct evaluations in a real environment but always under supervision of 

a trained driver accompanied by a test engineer monitoring the system. 

Suppliers presently face several obstacles in carrying out this testing 

on public roads and we respectfully request that the Committee consider 
45 


extending the FAST Act exemption to include suppliers with active and 

established research and development programs in the U.S. 

Bosch has been a passionate advocate for the deployment of driver 

assistance systems. We continue to view these technologies as the most 

effective and immediate means to reducing fatalities and injuries. We have 

worked diligently as a company to make these systems more accessible 

to all consumers. By developing cost effective components, such as 

Bosch's mid-range radar sensor, we have sought to support the 

distribution of these systems to all makes and models of passenger 

vehicles. Series production of Bosch radar sensors began in 2000. In 2016, 

Bosch delivered its ten-millionth radar sensor. 

Bosch's position on the need for improved consumer education is 

well known. We have urged NHTSA and the U.S. Department of 

Transportation for many years to include crash avoidance systems as a 

key component of the vehicle 5-star rating and to provide additional 

information to consumers through the Monroney Label. Bosch believes 

that displaying crash avoidance systems as part of the official safety 

portion of the Monroney Label, and particularly in the form a five star rating, 

is the most effective means to help drive consumer awareness and 

eventually consumer demand for such technologies. Without the clear 

presence of crash avoidance and mitigation technologies on the most 

recognizable feature for consumers - the physical Monroney Label as 

affixed to the vehicle - consumer education will continue to lag. 

Support for the proposed inclusion of crash avoidance technologies 

was also confirmed by prominent groups such as the National Safety 

Council and the Insurance Institute for Highway Safety in their formal 

responses to the NHTSA proposed NCAP update, issued in December 

2015. 
46 


The adoption of crash avoidance technologies into NCAP would be 

a very significant improvement and one which we believe will help bring 

about immediate benefits, as well as paving the path toward the attainment 

of automated driving in the future. Based on Bosch's analysis of the 2013 

NASS data, crash avoidance technologies such as forward collision 

warning, automatic emergency braking, lane departure warning, lane 

keeping systems, blind spot detection, lane change assist and pedestrian 

crash avoidance systems have the potential to avoid or mitigate up to 64 

percent of passenger car and light-duty truck collisions resulting in injuries 

and fatalities in the United States. 

As part of the proposed NCAP update issued in December 2015, 

NHTSA had proposed separate ratings for crash avoidance and 

pedestrian protection, as well as a combined overall vehicle rating. Bosch 

acknowledges that there were many issues that still need to be addressed 

and fleshed out as part of the proposals and we are aware that many 

entities raised legitimate concerns relative to the proposed changes to the 

crashworthiness section of the proposal. Our intent is simply to encourage 

Congress and NHTSA to cooperate and find a path forward for the U.S. 

NCAP to become an effective means of encouraging the enhanced 

adoption of these life-saving systems. Bosch truly believes that a five star 

rating is the most effective means to translate the presence and 

performance of crash avoidance technologies into an easy-to-understand 

indicator for consumers. 

Thank you again for the opportunity to speak before the 

Committee. I welcome any questions you may have. 
47 

Mr. LATTA. Well, thank you very much for your testimony and 

that will conclude our opening statements from our witnesses. 

Again we appreciate you being here, and I will begin the questions 

if I may. 

And if I could, Mr. Zuby, I would like to just follow up what you 

said what you said. A lot of the drivers out there driving the vehicles that have a lot of this technology are not using it. Is it because, you know, is it too difficult for them to understand maybe 

from reading the instructions in the manual or they just don’t want 

to bother with doing it, or what are you finding out there why people aren’t using that technology? 

Mr. ZUBY. Right. So we think that one of the reasons that people 

aren’t using lane departure warning technology is because they 

find it annoying. The way that technology works today is that it 

basically gives you a warning which may be an audible beeping or 

a vibrating of the steering wheel or vibrating of the seat when you 

transgress a lane line without signaling your intention to do so. 

So one way to think of the current technology is it is sort of a 

turn signal nanny rather than warning the driver about an imminent danger. And when we interview, or rather survey drivers with 

the technology that is one of the things that they tell us is the lane 

departure warning is very annoying. Systems that interact with 

the driver less frequently like front crash prevention are much 

more likely to be left turned on. In the studies that we have done 

we find that AEB and front crash warnings are left on in 90 percent or more of the vehicles, whereas we only see about 50 percent 

of lane departure systems left on. 

The other thing that our research is finding is that the design 

of the lane departure warning seems to have an influence. So people don’t like the audible alerts, but when the system alerts them 

about crossing the lane line with a vibrating steering wheel or a 

vibrating seat they are much more likely to leave it on. And we 

also find that if the car takes some steering action in response to, 

you know, transgressing the line that too leads to higher use rates 

than the original systems which only warned the driver with an 

audible warning. 

Mr. LATTA. Well, thank you very much. 

Mr. Klei, if I could ask you a little bit about especially on the 

cyber side, in your testimony you mentioned how driver assistance 

systems will require sensors to gather data about a vehicle’s surrounding environment in order to adequately assist that driver. 

How is Continental thinking about the privacy and security of the 

advanced driver assistance systems and crash avoidance systems, 

and what is Continental doing to secure those systems against 

cyber threats? 

Mr. KLEI. Thanks for the question, Chairman Latta, and it is a 

great question and it is something that at Continental we have 

been thinking about for many years. Cybersecurity is not new with 

automated driving or the advanced driver assistance systems. It 

has been a discussion point and a key development area for us for 

many, many years ever since, really, electronics started to come 

into the car. 

I would say the connection to the cloud, the connection with all 

the 4G connections that are now available open up a new opporVerDate Mar 15 2010 15:09 Jun 07, 2017 Jkt 037690 PO 00000 Frm 00051 Fmt 6633 Sfmt 6633 I:\115THCONGRESS\115X17SELFDRIVINGCARS\115X17SELFDRIVINGCARSWORKING
48 

tunity for those cybersecurity threats. We have developed an entire 

competency center in our company that is used extensively for cybersecurity and we are trying to install all the different protections 

that we can from known cybersecurity attacks. 

But many people say should we have a cybersecurity specification it is dynamic. Every day there is new threats. Every day there 

is new opportunities that emerge. So we have to work together 

with our OEM partners, suppliers, and the Government to look at 

ways we can work together to identify and eliminate those cybersecurity attacks. But we clearly have a competency center, we think 

very much about it, and it is clearly a challenge as we bring many 

of these technologies into market. But it is not new. It has been 

thought about and developed for many, many years. 

Mr. LATTA. Well, if I could also, Dr. Stepper, would you like to 

comment on that on what Bosch is doing in this area on the cyber 

side? 

Dr. STEPPER. Yes. Thank you, Chairman, for the question. Bosch 

has been very active on this topic for cybersecurity protection. We 

believe very much in a layered approach, layered in a sense that 

there is hardware layer, software layers, and architectural layers 

that need to be introduced. We actually established a center of 

competency for cybersecurity back in 2010, and we already established additional units within Bosch that work specifically on software solution to help our OEM partners to protect against cybersecurity threats. 

Mr. LATTA. Well, thank you very much. 

And also, Dr. Klei, could I ask a real quick question because my 

time is running out here, commenting on SAE levels of automation 

and why they are important to the industry standard of fully selfdriving cars. 

Mr. KLEI. Certainly we very much support the adoption of the 

SAE standards. We think a standard that clearly defines what the 

levels of automation are, are very useful as we start to develop and 

deploy these technologies. The consumers are often confused by the 

various naming and the various levels. And I think we as an industry have a lot of work to do to improve that communication and 

education of the consumers. 

Suppliers have a role in this. The OEMs have probably the largest role because they are the ultimate touch point with consumers. 

And then of course any assistance from the Government and other 

outside agencies are very, very beneficial. So we very much support 

it and we think everyone has a role in educating so that the naming of these technologies really describe what it can do and people 

don’t get confused. 

Mr. LATTA. Well, thank you very much. And my time is expired 

and I will now recognize the gentlelady from Illinois, the ranking 

member of the subcommittee, for 5 minutes. 

Ms. SCHAKOWSKY. Thank you, Mr. Chairman. 

Dr. Stepper, your testimony mentions rear automatic emergency 

braking systems and I am wondering if you could discuss how that 

could help prevent backover accidents. 

Dr. STEPPER. Yes. Thank you, Ranking Member Schakowsky, for 

the question. The rear automated emergency braking is a relatively 

recent addition to the automatic emergency brake suite of functions 

49 

that we have. We already have a mandate in the United States 

starting in 2018 for backover legislation to have a rearview camera 

installed in each and every vehicle. 

So we have already a basis of the technology in there, and we 

also see that especially with pedestrian incidents that we see in 

rear backover situations this technology could really help not only 

to protect from material damage but saves lives and prevent injuries. 

Ms. SCHAKOWSKY. And is this feature available today in any 

makes or models? 

Dr. STEPPER. It is available today but still in very, very small 

numbers. There are a few select vehicles in the United States today 

sold with this. The installation rate overall is less than five percent, in contrast to forward-looking automatic emergency braking 

where you look more between a 20 to 25 percent installation rate 

today already. 

Ms. SCHAKOWSKY. You also mentioned pedestrian automatic 

emergency braking. Is that any different from AEB when another 

car is in front of the vehicle? 

Dr. STEPPER. It is another progression and another step in the 

full AEB suite. The automatic emergency braking for vehicles was 

invented first and brought to market. Pedestrian automatic emergency braking has a little bit of a different requirement in the 

sense that you need to have a very wide field of view to recognize 

crossing pedestrians and not only at higher speeds, but especially 

in urban scenarios at lower speeds. So and therefore it is different 

in the sense that the requirements on the technology are different 

and it is already part of Euro NCAP in the European Union as a 

requirement moving forward. 

Ms. SCHAKOWSKY. Thank you. Mr. Zuby, I wonder if you have 

looked into these technologies and if you have any comments on 

that. 

Mr. ZUBY. Yes. We have been looking into these technologies and 

we have worked up a series of tests that we intend to start using 

to promote the idea of reversing automatic braking. We think that 

that may be an additional thing that is needed to address backover 

crashes because the experiments that have been run using cameras 

show that while they definitely improve the situation and help 

drivers avoid running into things that are behind their vehicle that 

they don’t expect to be behind their vehicle, they are not a hundred 

percent effective because the driver needs to be looking at the camera at the same time that the person or object behind them is in 

the view of the camera. 

So automatic braking, I think, can augment the benefits that we 

get from the technology looking rearward in the camera during reversing maneuvers. We are also looking at pedestrian—by the way, 

my guys have identified, I think, 14 models of cars sold in the current model year that are equipped with reversing AEB. We are also 

looking at pedestrian detection. And it is a slightly more difficult 

problem for the technology to solve because of the field-of-view 

issue and the fact that pedestrians can change direction and 

change their movement very quickly. 

Ms. SCHAKOWSKY. Because I have been so involved in the issue 

of the cameras and you say it is not a hundred percent, have you 

50 

estimated how effective it is or how many times it does fail to prevent an accident? 

Mr. ZUBY. Well, so in experiments we find that it reduces the 

likelihood that you are going to back over something that is in your 

path by about two thirds. 

Ms. SCHAKOWSKY. OK. So you have done years of research on 

AEB systems. Can you give us more details on how these systems 

work and why they save lives? 

Mr. ZUBY. So the current AEB systems mainly prevent front-torear crashes. They are effective at preventing those kinds of crashes, and even when they don’t prevent the crash they reduce the 

risk of injury. Front-to-rear crashes don’t result in a lot of fatalities. It is in the neighborhood of about 800, 900 people a year out 

of the nearly 40,000 die in front-to-rear crashes. So even if a technology were to prevent all of the rear crashes, it would have a 

small dent on fatalities. 

But the sensors that are needed for AEB are sensors that will 

be needed to address other types of crashes, you know, leverage the 

technology to address other kinds of crashes that do account for 

more fatalities. 

Ms. SCHAKOWSKY. Thank you. I see I am out of time, I yield 

back. Thank you. 

Mr. LATTA. Well, thank you very much. The gentlelady yields 

back, and the Chair now recognizes the gentleman from Illinois for 

5 minutes. 

Mr. KINZINGER. Thank you, Mr. Chairman. Thank you all for 

being here and taking some time with us today. It is an important 

hearing on the future of self-driving cars and specifically the opportunity to learn more about the advanced driver assistance systems 

that is saving lives today and it is also paving the way to fully autonomous vehicles. 

Dr. Stepper, in your testimony you highlighted the importance of 

the SAE framework for the various stakeholders in autonomous vehicles and the lack of common language for advanced driver assistance systems. How has this lack of a voluntary standard impacted 

Bosch’s ability to bring technology to the market? 

Dr. STEPPER. Thank you for the question, Congressman. Very 

clearly, the lack of clear language and common taxonomy has resulted in some confusion at the consumer side: What is really my 

car doing with the different technologies that we have? So as Mr. 

Gouse has very graphically illustrated in his chart, there is well defined levels of 0 to 5 for automation, and coupled with a very active 

consumer education campaign we can really educate consumers 

what they can expect. 

Is it just a warning that my vehicle will provide or is it actually 

an actual intervention like an active braking situation or can I take 

my hands and my feet off the controls and the car will drive by 

itself? And what we have found clearly is that the lack of such common language really has led to confusion on the consumer end, and 

we really commend the National Safety Council together with the 

University of Iowa joining the Road to Zero campaign and actually 

establishing a Web site that is called mycardoeswhat.org to educate 

consumers of what is actually in their vehicles today because it can 

be so confusing. 

51 

Mr. KINZINGER. We should do a my-congressman-does-what. Mr. 

Gouse, what are the challenges to adopting a voluntary consensus 

standard and what efforts are underway to provide a common language for advanced driver assistance systems? 

Mr. GOUSE. Thank you, Congressman, for the question. It is an 

emotional question internally, because it is very difficult to raise 

awareness that our documents even exist to a variety of stakeholders that don’t traditionally know that they even use this. We 

were working with the American Association of Motor Vehicle Administrators and they didn’t even know that the license plate geometry was our standard. So that was our beginning point. And we 

told them we had this document in works at the same time NHTSA 

had their levels of automation in works, and with differing vocabulary and differing levels it confused the issue a lot. Fortunately, 

NHTSA decided to adopt the SAE language, and then AAMVA and 

through the States that proliferated. That is one example. 

The same thing is happening all over the world. For the driver 

assistance systems, same thing, we have a standard that is called 

Active Safety Systems Terms and Definitions. It is a fairly easy 

read. It is not really riveting like a novel, but it is a fairly easy 

read and we are trying to get that language adopted too. And as 

you hear today, we even use different terms ourselves and I agree 

it is confusing. 

Mr. KINZINGER. Let me add on. Are there any policies, developing 

policies that you are concerned with as you are seeing them right 

now? 

Mr. GOUSE. The States that are unaware or choosing not to use 

a common terminology and the common taxonomy, I believe, will 

result in a patchwork of very difficult to understand and operate 

in environments. This is happening now at the testing level where 

they are passing regulations permitting testing of various levels of 

automation in nonsalable vehicles. So it is a concern. 

Mr. KINZINGER. And then we will go with Dr. Stepper on this 

one. When you look at educating the public about the benefits and 

the limitations of various systems, especially for systems like automatic emergency braking that provides a lot of value to the customer, but the customer, the consumer may not be aware that the 

technology is assisting the driver. Mr. Zuby mentioned that lane 

maintenance systems were only turned on in 51 percent of the vehicles that IHS observed. How do your companies, how does your 

company work with the consumers to build confidence in the technology so it is being fully utilized? 

Dr. STEPPER. So thank you for the question, Congressman. Clearly we work with activities like the Road to Zero and the activities 

from the National Safety Council as well as the University of Iowa. 

We work very closely with our OEM customers, for example, in 

joined co-marketing campaigns to educate dealers, because at the 

end of the day new vehicles are being bought from dealerships and 

consumers are being consulted by dealership personnel and that is 

really your first touch point of a new vehicle purchase and understanding of what this vehicle really has on board in terms of technology. 

So we work very actively with several OEM customers on this 

topic to make tours to make joint marketing campaigns around the 

52 

country to educate dealerships on this topic so they can explain 

what is installed on the vehicle. Again I want to emphasize an additional mention of these crash avoidance technologies. In a 5–Star 

rating, incorporating crash avoidance technologies could also very 

much help in that regard because now the dealership personnel 

would have the Monroney label right in front of them to help them 

guide the consumer through the purchase. 

Mr. KINZINGER. Thank you. And I have some more questions; I 

will submit them for the record. Mr. Chairman, I yield back. 

Mr. LATTA. Thank you very much. The gentleman yields back, 

and the Chair now recognizes the gentlelady from Michigan for 5 

minutes. 

Mrs. DINGELL. Thank you for the recognition, Mr. Chairman, and 

for your continued interest in the automated vehicles. As you all 

know it is a subject that I really care a great deal about. As I stated in the last hearing on this issue, I believe it is critical that the 

Congress, the administration, the industry, and safety advocates 

all come together on a common framework for automated vehicles. 

Too much is at stake and we have got to get it right. 

Legislation will be needed to facilitate the deployment of higher 

level automated vehicles, and I support raising the statutory exemption caps as an interim solution while directing NHTSA to 

amend existing vehicle safety standards as they relate to human 

operated controls. And I think a lot of people don’t understand 

what some of the regulations are because they have been there for 

so long. 

Great strides in vehicle automation are being made. Proud of it 

that a lot of it is in my district in developing safety technologies 

that have the potential to reduce roadway deaths, and I believe 

helping them get to market could have a significant impact on public safety, and I have got some questions to help the committee examine these issues. 

My first questions are for Mr. Gouse of SAE, and if you could 

just do yes or no, please. Is it correct that SAE Levels 0 to 2 contemplate that a human driver will perform all or some aspects of 

what is known as the dynamic driving task? 

Mr. GOUSE. Yes. 

Mrs. DINGELL. Is it correct that SAE Level 3 contemplates that 

a human driver must be in the loop and prepared to respond to a 

request by the vehicle to take over the dynamic driving task? 

Mr. GOUSE. Yes. 

Mrs. DINGELL. Now is it true that an SAE Level 4 vehicle is one 

that is capable of performing all aspects of the dynamic driving 

task in a given situation also known as the operational design domain? 

Mr. GOUSE. Yes. 

Mrs. DINGELL. And a Level 5 vehicle can handle all aspects of 

driving under all conditions? 

Mr. GOUSE. Yes. 

Mrs. DINGELL. Thank you. Now these questions are for all four 

witnesses. Is it true that companies like FCA, Ford, and GM in 

Michigan are developing and currently deploying SAE Levels 1 and 

2 systems? Anyone can say yes or no. 

[Chorus of yeses.] 

53 

Mrs. DINGELL. Thank you. Is it true that these traditional automakers and others like Waymo are developing Level 4 systems at 

the same time? 

Mr. KLEI. Yes. 

Mrs. DINGELL. In other words, these companies aren’t necessarily 

pursuing a sequential progression through the SAE Levels to full 

vehicle automation; is that correct? 

Mr. KLEI. No. 

Mrs. DINGELL. That is not correct. So you think they are going 

1, 2, 3, 4 or are they going from 2 to 4? 

Dr. STEPPER. If I may jump on this one, Congresswoman Dingell, 

it depends on the automaker. Some absolutely proceed along the 

path, Level 0, 1, 2, 3, 4, and 5; some other ones may skip Level 

3. There is no common answer. But some of them that you mentioned are indeed following exactly along the path of what Mr. 

Gouse has presented. 

Mrs. DINGELL. And others are skipping. Is it true that a number 

of existing NHTSA safety standards require human operation of vehicle controls that may not be necessary if there is no human driver, such in Level 4 or 5? 

Mr. ZUBY. Yes. 

Mr. GOUSE. Yes. 

Mrs. DINGELL. Do you all have good—I don’t know if I am—my 

staff wants me to keep moving. But I think people don’t know that 

a NHTSA requirement requires a foot on a brake and it is not necessary at 4 or 5, so—— 

Dr. STEPPER. That is correct. 

Mrs. DINGELL. Thank you. Should NHTSA amend existing safety 

standards to clarify how they apply to higher level automated vehicles without drivers? 

[Chorus of yeses.] 

Mrs. DINGELL. Do all of you agree on that? 

Mr. GOUSE. Yes. 

Mrs. DINGELL. Well, I am running out of time, so I am going to— 

I have lots of questions but—and, for the record, I may submit 

some more, Mr. Chairman. But I want to commend the chairman 

for holding this important hearing to help educate members on the 

issues because it is really important that we get it right. Automated vehicles are going to be developed and they are going to be 

developed internationally if we don’t take the lead on making sure 

we do it, develop them here and that these technologies are developed in the United States of America. So I look forward to working 

with my colleagues on both sides of the aisle in a bipartisan manner to achieve this goal. 

Thank you all for being here today. Thank you, Mr. Chairman. 

I yield back my 15 seconds. 

Mr. LATTA. Thank you very much. The gentlelady yields back the 

balance of her time and the Chair now recognizes for 5 minutes the 

gentleman from Mississippi, the vice chairman of the subcommittee. 

Mr. HARPER. Thank you, Mr. Chairman. And again thanks to 

each of you. This is, you know, it is just mind boggling the possibilities and we have just barely scratched the surface. And, you 

know, I can’t imagine what it will be like we come back in 5 years 

54 

and just discuss what we are doing next. I mean this is really remarkable. So thanks for the involvement that each of you and each 

of your companies have. 

And Mr. Klei, thank you very much. We are excited about the 

presence of the new Continental Tires facility that will be opening 

in Mississippi. I think that was a great decision. We are honored 

to have a part of your company that will be there, and I wanted 

to talk to you for just a minute. 

Obviously, the intellectual disabilities issue is important. My 

wife and I have a son who is 27 years old who has Fragile X syndrome. He graduated from a special program at Mississippi State 

University. He works Monday through Friday. My wife has to drive 

him every day and drop him off and pick him up. So it is something 

for many families, this is an important issue. So are advanced driver assistance systems at a point where they are able to provide new 

transportation opportunities to the disabled community? 

Mr. KLEI. Certainly is it an important topic, and thank you for 

the question, Congressman. It is something that I think, as an industry we are working very hard, and it is not just for the automated driving technologies in general. We are trying to make mobility more available and safer for all, and I think the advancements in automated driving are clearly going to move that forward. 

Are they ready today to take over all driving tasks for someone 

that can’t drive today? Not necessarily; over time, absolutely. We 

believe when we get to Level 4 and Level 5, absolutely it is going 

to provide mobility for many people that today don’t have that mobility. The Waymo development, their first example that they 

showed was someone that was blind. And that is a huge statement 

for the potential mobility promise for the elderly, the blind, and 

every disabled person in the United States will have mobility, and 

it is an important step for them, but also for society. 

Mr. HARPER. Well, we are excited that Continental is taking that 

into consideration in the development of this. 

Dr. Stepper, will you also comment on that as well? 

Dr. STEPPER. Yes. Thank you for the question, Congressman. We 

are actually working very, very intensively on the aspect of human 

factors because as we have learned before, on some of the levels of 

automation the interaction of the human being is still very, very 

important and part of the requirement for both SAE all the way 

to Level 3 as we heard earlier. 

So in human factors we have done a number of research for user, 

human-machine interaction perspective, but we have also worked 

in augmented reality experiences. And that is a topic I just want 

to make the comment that we are actually going to show a demonstration of augmented reality for automated driving. It is an upcoming experience here on the Hill as the event that is CES on the 

Hill on April 5th, where all of you of course are invited to experience some of the human factors aspect and how important it is as 

part of the automated driving equation. 

Mr. HARPER. We are expecting self-driving cars to be at Level 5 

tomorrow, when most drivers are not Level 5 drivers. Mr. Klei, 

what do you think Congress should do to facilitate this development in deployment of advanced driver assistance systems at a 

55 

point where we can assist and not be, let’s say, a roadblock to that 

development? 

Mr. KLEI. Thank you, Congressman, a very important question 

and one that I think we look at a couple different areas. One is the 

Federal Automated Vehicles Policy that was issued last September. 

While we commend the NHTSA organization and all the work that 

they did we think there is a lot more to do. 

First of all, when it comes to that policy it really more talks 

about deployment rather than development, and we think development is an important part of bringing these technologies to market 

safely and with real world testing.And only through an improvement in that policy can we get there. For example, the policy requires for every software change or every change that we make we 

have to submit a new exemption. The time to develop those and the 

time to get the approvals will significantly delay the implementation of this. 

I think the other thing is the model State policy. To have a 

patchwork of State regulations is clearly hindering our ability to 

test and develop and ultimately commercially deploy these technologies. So there is two examples. I could go on and on about 

other examples, but clearly there is opportunity to work closer together between ourselves as suppliers, the OEMs, and the Government to really bring these forward in a safe and effective way. 

Mr. HARPER. Thanks to each of you. I yield back. 

Mr. LATTA. Well, thank you very much. The gentleman yields 

back, and the Chair now recognizes the gentlelady from California 

for 5 minutes. 

Ms. MATSUI. Thank you very much, Mr. Chairman, and thank 

you very much for the witnesses for being here today. As many of 

you know, the FAST Act mandated that self-driving cars could be 

introduced into commerce solely for the purposes of testing, but 

only by companies that had at the time of the law’s enactment already manufactured and distributed motor vehicles in the United 

States. 

In addition, legislation has been proposed in some States that 

would allow only traditional car manufacturers to test and deploy 

AVs. Some have even speculated that NHTSA’s deployment exemptions also could be limited to car manufacturers that already build 

and distribute motor vehicles in the United States, and I believe 

we started down this path already. 

But Dr. Stepper and Mr. Klei, I know that you have been working with AV components that could benefit from direct testing. 

What are the barriers to your companies doing testing on your 

own? 

Mr. KLEI. From the Continental side certainly we have talked a 

little bit about some of those barriers with the ability to test without concern for all the different State regulations. I mean, since the 

Federal Automated Vehicles Policy came out there has been 48 different bills in 20 States that complicate our development of these 

technologies. We believe that as suppliers we also need to have the 

ability to test and develop these. It can’t be just the OEMs that in 

fact do certify vehicles for FMVSS. We as suppliers don’t certify vehicles. We develop technologies, we work with our OEM partners 

to bring them in safely, but we need the ability to develop and test 

56 

those ourselves, not as a certifying FMVSS body but as one that 

really looks to develop those. 

Ms. MATSUI. Certainly. Dr. Stepper? 

Dr. STEPPER. Congresswoman Matsui, thank you for the question. As I mentioned earlier in my testimony, suppliers play a very 

important role in the innovation cycle. And as a matter of fact, 

often innovations like electronic stability control, the required sensors like radars, video cameras, ultrasonic sensors, and many of the 

other active systems, for example, the braking and the steering in 

the vehicle, is actually coming from the suppliers. 

So we do our utmost of course to develop and test and verify 

these components and systems in the lab with artificial methods 

like modeling and simulation, but there comes the point where we 

suppliers need to take these technologies on the road to ensure that 

they are fully verified and validated before they ever go into consumers’ hands. So it is really limiting our ability to test on public 

roads. 

And we understand very clearly that the expansion of the exemption must be handled very carefully and cautiously, but we are very 

happy to engage actively with the committee on this point. 

Ms. MATSUI. Thank you. I understand that different companies 

are pursuing different strategies in terms of the level of automation 

in the vehicles they plan to deploy. And as we have been reminded, 

often it is human drivers that can cause and contribute to accidents with automated vehicles. 

Mr. Zuby, are there particular concerns we should consider during a transition when vehicles from all different levels of automation will be on the roads? 

Mr. ZUBY. Yes. I think we are already seeing in studying work 

that Waymo are doing and other automakers that even when the 

automated cars are driving at a very high level of competency they 

often are involved in crashes caused by human drivers. And so I 

think as the testing develop it is important to make sure that there 

are safeguards that the testing be done in safe ways and not endanger other people and the public, but it will be absolutely necessary to test these things in the real situation because that is 

where they need to work. 

Ms. MATSUI. Right. As companies continue to expand testing of 

autonomous vehicles, they are all gathering an enormous amount 

of data about these vehicles. Mr. Gouse, are there any efforts in 

place to standardize the data that is being collected so that we can 

learn best practices regardless of where the autonomous vehicles is 

being tested? 

Mr. GOUSE. Ma’am, there are very early efforts going on. You 

have to understand that it is a very proprietary environment. 

While these gentlemen are cordial here, they probably want to kill 

each other sometime over a product. 

Ms. MATSUI. I hope not. 

Mr. GOUSE. No, no, no. So there are discussions going underway 

with the associations that they belong to on this and how to collect 

the data and use it. 

Ms. MATSUI. So we are at the very early stages of that right now 

but it would be very helpful to have the data. So anyway I will 

yield back my remaining time. 

57 

Mr. LATTA. Thank you very much. The gentlelady yields back, 

and the Chair now recognizes the gentleman from West Virginia 

for 5 minutes. 

Mr. MCKINLEY. Thank you, Mr. Chairman. And last month when 

we met I said then that I think this is, this whole process is probably inevitable. And as one of just two licensed engineers in Congress, I am intrigued with the problem-solving possibilities that we 

have with this. I am fascinated with the developments that have 

occurred so far in lane movement as you referred to it or the braking. 

But I am a huge skeptic of driverless cars and I am not buying 

this one iota yet. I will go with all the others. I can see the possibilities of that. But at the last meeting I raised some questions 

about IV&V and everyone on the panel had no idea what we were 

talking about, so I ask you because you are four different people. 

Are you using IV&V for confirmation of the various steps that we 

are going through so far? 

I am seeing a no all the way around again. If we send a ship to 

Mars or when we send a satellite into space we run through all the 

steps to test it for individual verification and validation and make 

sure that it is going to work because we don’t want to rely on competitive peer pressure without having some third party validate 

what we are doing. And that is what we are looking for, I am going 

to looking for is third party, because I know companies are going 

to be under a lot of pressure to skip steps 2 and 3 and go right 

to 4 if possible or skip 1 and go to 3, whatever that might be they 

are going to move that because of competitive pressures. 

We talked a little bit when one of the things since that time— 

because I am fascinated with this. Again, it is the engineering. I 

know this is inevitable. How can we work with this thing to do everything but driverless? So when I have asked the question when 

I have been back in my district, it is wherever it is we are excited. 

In fact we are going to have a summit meeting about this, about 

driverless cars. 

But when I have raised the question, Would you put your 6-yearold granddaughter in the car and let her go 40 miles to meet her 

brother, perhaps, every one of them says no. Now, I know it is 

going to be evolutionary. They will develop more confidence with it. 

But when I was hearing about if something goes wrong they are 

going to transfer operation back over to the person in the car, what 

happens if it is indeed someone that is intellectually impaired or 

is inebriated and we have allowed them to get in that car to be 

able to get home, and then they are turning the transportation over 

to them when they are doing 60 miles an hour, and they say, ‘‘OK, 

driver, it is your car’’? 

I have a series of questions about it. I am going to remain a 

skeptic on this. I want to follow the money. I don’t understand 

other than insurance companies who is really going to benefit for 

this, but as an engineer let me skip to my last, so ask a question 

of this. If when we get to steps 4 and 5, because I have designed 

a lot of bridges, a lot of highways, culverts, I don’t know how this 

is functioning yet, so is there something I should be working in in 

my old company in engineering that starts to get ready so the cars 

when we are at steps 4 and 5 there is something, is there a wire 

58 

in the road, is there something along the guardrail, or is this something merely sensing it? Is this all GPS driven? 

I need to have a lot more information before we get anywhere 

close to that. Because if we are designing all these roads, why 

aren’t we taking those things into consideration now especially 

with this infrastructure bill that it is going to have? So with that 

can you tell me what should we be doing in our highways to be 

ready for steps 4 and 5? 

Mr. KLEI. In terms of the highways themselves we have to adapt 

to the highways, we can’t expect the highways to adapt to these 

systems. That is why real world testing around the world has to 

happen. 

Mr. MCKINLEY. So in that case, Mr. Klei, is it GPS driven or is 

it sensing the side of the highway? 

Mr. KLEI. It is both. It is GPS, it is sensing. 

Mr. MCKINLEY. It goes through a tunnel, and in West Virginia, 

where we have almost 50 percent of the State does not have service, I lose my signal constantly and no one knows where we are. 

And I don’t know what happens at that point, so you are going to 

have to rely on a lot better control if you are going to use GPS. So 

if it is going to be sensing how do we do that? 

Mr. KLEI. Obviously, the sensory development is a key part of 

that. But it is not just sensing it is also GPS. It is also vehicle-tovehicle, vehicle-to-infrastructure, DSRC, all of that coming together 

will unable that Level 4 and Level 5. 

Mr. MCKINLEY. Thank you very much, I have run out of my time. 

But I want some engineering answers on this, not the 90 percent 

savings of accidents, because I think it is BS. It is not going to happen, just like we have had the debates here over my 7 years in 

Congress that, if we stop using coal, we would eliminate 80 percent 

of the asthma attacks in this country. We know that is false. So 

I don’t want to use a technique or a topic that says we are going 

to save 90 percent of accidents if we adopt this, I want to have 

more facts. The engineer in me says I need more facts. So thank 

you, and I yield back. 

Mr. LATTA. Thank you very much. The gentleman yields back 

and the gentleman from Texas is now recognized for 5 minutes. 

Mr. GREEN. Thank you, Mr. Chairman, for both you and our 

ranking member, Ms. Schakowsky, for having the hearing today. 

While the technology behind autonomous vehicles continues to 

evolve at a rapid pace it is important that industry and Congress 

continue to examine safety standards to ensure consumer safety. 

Not all the safety innovations are willingly accepted by the public 

with the history of airbags and seatbelts has shown. Continued 

open discussion on these new technologies are essential moving forward so that consumers can be familiar with both benefits and the 

limits of autonomous features. Frankly, my wife is probably the 

most supporter of me not being in an autonomous vehicle when I 

am driving. She complains all the time about my driving. 

Mr. Zuby, in your testimony you state that your research has 

shown that the driver acceptance of technology varies. Can you tell 

us more about the varying level of acceptance of new technology 

and what can be done to increase the public’s acceptance? 

59 

Mr. ZUBY. Yes. For one of the things that we found for lane departure warning systems, the mode of the warning made a big difference in whether or not the drivers accepted them. When we 

interview drivers what we find is they complain about audible 

warnings being annoying. Another important aspect of lane departure warning and lane maintenance is that the systems respond to 

truly dangerous situations and not be perceived by the driver as 

simply being a nanny about use of the turn signal. 

So I think the technology needs to go a ways beyond where it is 

today in order to sort out what are the real dangerous situations 

that we need to inform the driver about versus those things that 

might be dangerous, but a lot of drivers aren’t going to perceive 

them as such. 

Mr. GREEN. OK. At this point, is it known why one warning system is so effective and another ineffective? 

Mr. ZUBY. One of the issues is if the warning system can be 

heard by other people in the vehicle drivers tend not to like it. So 

the vibrating steering wheels, the vibrating seats tend to have 

higher levels of acceptance than audible warnings themselves. 

Mr. GREEN. Thank you. How can we better study the effectiveness of these safety claims to ensure technology is living up to its 

promise? 

Mr. ZUBY. It is super important I think that we work out ways 

to make sure that data about which cars have which systems and 

how the systems are working is available to independent researchers. Obviously, the companies who are developing the systems are 

going to want to make claims about their high levels of effectiveness, but I think people in Government and independent evaluators 

need to be able to verify those claims. 

Mr. GREEN. I would like to ask this question of the entire panel. 

Would enhanced Government regulation on the collection of the 

crash data with specific regard to what autonomous technologies 

were in each vehicle improve both public safety and efficiency, the 

AV technology? I will start with Mr. Klei. 

Mr. KLEI. Yes. Certainly when you look at things like the Auto 

ISAC, which has been developed as an industry coalition to really 

share data on cybersecurity, it is a good example where data sharing can really benefit. We think there is an opportunity as well to 

do something similar for some of the crash data and some of the 

activity around autonomous, automated driving vehicles. We think 

that the sharing is very powerful, but it needs to be the edge cases 

and it needs to be things that can help all of us develop and deploy 

these technologies. 

Mr. GREEN. Mr. Gouse. 

Mr. GOUSE. In our committees, sir, there is quite a bit of sharing 

going on of technical information that is not proprietary to build 

the standards to design test specifications, test devices, and what 

not to build good product, so there is a quite a bit ongoing already 

at that level. 

Mr. GREEN. OK. Mr. Zuby. 

Mr. ZUBY. Definitely, I think regulations prescribing what kind 

of data needs to be saved and under what kind of circumstances 

and with whom that data can be shared will help all of us achieve 

60 

a greater level of comfort that the technology is being developed in 

a safe way. 

Mr. GREEN. Dr. Stepper. 

Dr. STEPPER. Definitely a yes, Congressman. Bosch has been 

working very adequately to actually get NHTSA more resources for 

data for crash reconstruction. Why, because we have used NHTSA’s 

NASS database for our own research in understanding how many 

percent of collisions with injuries and fatalities with rear-end 

crashes, how many drivers failed to, for example, even after they 

received the warning to even apply the brakes in the first place. 

So it is very valuable data for us for our development purposes. 

Mr. GREEN. OK. Thank you, Mr. Chairman. I yield back. 

Mr. LATTA. Thank you. The gentleman yields back, and the 

Chair now recognizes the gentleman from Florida for 5 minutes. 

Mr. BILIRAKIS. Thank you, Mr. Chairman. I appreciate it. Dr. 

Stepper, some driver assistance systems on the market use audible 

tones, steering wheel vibrations, and flashing lights to alert the 

drivers to impending hazards. We are also facing high levels of 

driver distraction as you know. As Bosch works to develop these 

technologies how are you working with automakers to ensure that 

these technologies aren’t pulling drivers’ attention away from the 

task of driving and causing more distraction? 

Dr. STEPPER. Thank you, Congressman, for the question. 

Mr. BILIRAKIS. Sure. 

Dr. STEPPER. We work very intensively with our OEM partners 

on the human factors element. For example, evaluating what is a 

really effective and efficient means of alerting the driver of getting 

the attention from the driver back? Is it audible, is it visual, is it 

maybe haptic? 

As Mr. Zuby has answered before what we have found is that 

haptic feedback is actually very, very efficient when it is related to 

a specific action that is wanted. For example, if there is a hazard 

approaching from the rear left, if your seat vibrates on the left side 

of the driver’s seat there is a haptic feedback that alerts you that 

something is happening to the left of the vehicle. Or if it is intended that you are, for example, departing your road lane, the vibration of the steering wheel is directly related to something that 

is going on with the steering system that the driver should pay attention to. 

We have formed our own group to work on human factors to specifically look at the human-machine in action and we work very intensively not only with our OEM customers but also with academia 

on this topic. 

Mr. BILIRAKIS. Mr. Klei, do you want to comment on that as 

well? 

Mr. KLEI. Yes, I think similar to the Bosch development we also 

have a very significant investment in the human-machine interface 

technologies. We have been one of the leaders in displays, in clusters, and in warning systems for vehicles for many, many years. 

We think that is an important part of bringing these technologies 

to market safely. 

Clearly, when it comes to the audible versus haptic, we have 

done a lot of research as well. We actually have driver monitoring 

cameras that we are looking where the driver is seeing, or looking, 

61 

where the driving task should be. And we sometimes use LED 

lights or other ways to try and bring the driver’s attention back to 

the driving task. That is a big question. 

As you talk about Level 3 technologies that is the biggest question and the biggest area of development is how do you get the 

driver disengaged and then re-engaged fast enough to resume the 

driving task. And I think that is a challenge for the industry. That 

is why you see some developing from Level 2 to Level 4, some are 

going to go through Level 3. But that is probably one of the biggest 

challenges and we are investing heavily in this area. 

Mr. BILIRAKIS. OK. As a follow-up, are consumers able to manually turn off these alerts or warnings or customize them to their 

individual preferences? 

Mr. KLEI. So that is really a question for the OEM to determine 

what they would like to do. And it happened as well with ABS and 

electronic stability control and the various traction control systems, 

the OEMs for many years could determine which could be turned 

on and off. So it is something that some allow, some don’t. We believe that ultimately when it is proven that the safety technologies 

are really going to save lives that it shouldn’t be turned off. It 

should be developed over time to be very easy to understand, very 

easy to use, and will ultimately save lives. 

Mr. BILIRAKIS. OK. I have a question with regard to actually a 

follow-up on the gentleman from West Virginia. I mean, we want 

to help a lot of the elderly, maybe physically disabled people get 

around. We don’t have in my area, in the Tampa Bay area we really don’t have a mass transit system, so this could be extremely beneficial to people getting to doctors’ appointments, what have you, 

these automated cars. 

But you anticipate them having a standard driver’s license; is 

that correct? I mean they have to qualify for this. For example, if 

you have a visual disability, if you are visually impaired and you 

don’t qualify. I am visually impaired but I qualify at this particular 

time. I have a standard driver’s license. I don’t drive at night, but 

5 years from now, who knows? Will I be able to drive one of these 

cars even though I am visually impaired? That is just an example 

there. Can I hear from one of you? What do you anticipate? 

Mr. KLEI. Certainly we believe like we have talked a lot about 

the improvements in mobility for disabled and then certainly we 

think these technologies will offer significant improvements here. 

But it takes time and it takes really more, the systems that are 

developed with that in mind. And that is why we are working hard 

as a company with our OEM partners to make sure that these systems are developed with all considerations in mind. It is not just 

for the driver that has, you know, zero disabilities. It is to provide 

mobility for everyone. And we think there is a clear promise and 

they are being developed with this in mind. 

Mr. BILIRAKIS. Anyone else? 

Mr. GOUSE. May I, please. We have been working with AAMVA, 

the American Association of Motor Vehicles Administrators, on that 

exact topic for both cars and trucks. And a simple example would 

be some States require that parallel parking is required to get your 

initial driver’s license, but in some vehicles the vehicle itself can 

parallel park without the assistance, with the assistance—— 

62 

Mr. BILIRAKIS. If you could put the mike a little closer. 

Mr. GOUSE. So we have been working with them trying to define 

what features are in place or are possibly in place in the future and 

they can design their driving tests and their ratings or perhaps certification levels like a commercial driving license has or something 

that says you can operate a Level 3 vehicle with these features, but 

you can’t do a completely manual one. You can’t drive a manual 

transmission anymore. So it is a complicated question, but it is 

being worked on. 

Mr. BILIRAKIS. And there will be a State issue, obviously, as far 

as that is concerned. OK, well, that is important. I mean, we have 

got to know that ,because we want to help out our constituents. 

But again, you know, if you have a standard driver’s license you 

qualify. And the gentleman asked about someone that is intellectually impaired. You know, would that person qualify? More than 

likely they couldn’t get a license. So anyway that is something we 

have to resolve, so I appreciate that. I have one more question if 

I have time. I don’t have time. 

Mr. LATTA. Yes. If you would like to submit it in writing that 

would be great. 

Mr. BILIRAKIS. Yes, I will submit it. Thank you very much. I 

yield back. Thank you. 

Mr. LATTA. Thank you very much. The gentleman yields back, 

and the Chair now recognizes the gentlelady from New York for 5 

minutes. 

Ms. CLARKE. Thank you, Mr. Chairman, and I thank our ranking 

member. I thank our expert panelists for a very important and 

stimulating examination of autonomous cars. 

Some experts have raised particular concerns regarding Level 3 

automation and you have discussed it here today where a vehicle 

can drive itself but the driver must be ready to take over at a moment’s notice. There is some evidence that Level 3 may lead to an 

increase in traffic collisions. During recent test drives, Ford reportedly noticed that even their engineers trained to monitor autonomous vehicles had trouble staying alert at the wheel while the car 

was driving. Volvo’s autonomous vehicle program is skipping Level 

3 altogether and planning to go straight from Level 2 to Level 4. 

Mr. Zuby and Mr. Gouse, do you agree that complications of 

Level 3 automation are an example of why it is important to monitor autonomous technology to make sure that it is actually making 

driving safer? 

Mr. ZUBY. Yes. Thank you for the question. Absolutely, I think 

the important thing will be to be able to monitor these developments as they are put out into the fleet. There is a long history 

of human factors research that says things like Level 3 are potential problems for human monitors, and I think that is why you find 

some automakers and some technology developers deciding that 

they aren’t going to mess around with Level 3. 

I am not expert enough to know that Level 3 is impossible to do 

successfully, but definitely there is a concern that if the car is too 

highly capable at the dynamic driving task that the driver will discontinue his monitoring activities and not be able to resume control 

when it is necessary because the system is no longer capable handling a situation. 

63 

Mr. GOUSE. I would just second what David said, but I would 

like to caveat with, bear in mind that people working on this—I am 

just awed when I go to committee meetings and listen in at the experts, the level of knowledge that is behind all this and the amount 

of consideration that is going on for all the aspects. Whether it be 

taking over control immediately or changes in weather conditions 

or road issues or anything at all these levels, it is very impressive 

the level of expertise and the care that is going into this. 

Ms. CLARKE. The only factor that I guess is challenging to sort 

of pin down is human error, right? 

Mr. GOUSE. Well, there are other challenges too, just like in our 

normal driving that we have unexpected issues that arise. The deer 

jumps out that you never saw before and how do you react to that? 

Or there is some sort of a failure in the vehicle or in the infrastructure that is unanticipated and how do you react to that? Or someone else who has not got automation or not got assistance and 

makes a grave error and how do you react to that? 

Ms. CLARKE. But the reaction is the human being, right, not necessarily the vehicle? Or is it that the vehicle would be programmed 

to react to the jumping deer or the change in weather conditions? 

Mr. GOUSE. Well, that goes back to the level of automation, 

whose job it is, who is it assigned and—— 

Ms. CLARKE. So Level 3 then becomes the challenge in terms of 

what the standard would be for automation versus human participation. 

Mr. GOUSE. The expectations between Level 2 and 3, it is a big 

step. 

Ms. CLARKE. OK. As we have heard, semi-autonomous features 

can have significant safety benefits but they may also be confusing, 

especially to drivers who are unfamiliar with the technology or fail 

to use it correctly. Consumer education will be essential to ensuring that the full advantages of these technologies are realized. 

Mr. Zuby, why is it so important that drivers understand that 

limits of semi-autonomous features and are aware of what exactly 

their cars can and cannot do? 

Mr. ZUBY. Yes, for exactly the issues that we have been discussing about Level 3. I mean it will be important for drivers to 

understand how close attention they need to pay to the driving situation in order to be ready to take over and wonder what situations the system is likely to hand control back to them. 

But we would say that I think it is important to try to figure out 

how to design these things so that the limitations and the way they 

work is as intuitive as possible because I don’t think we can rely 

on people to spend extra time to learn how to drive their cars. I 

mean how many people in this room have read their owner’s manual from front to start? There is a lot of really important information in there, but I for one have not read the owner’s manual from 

start to finish for any of the vehicles I have ever owned. 

Ms. CLARKE. Very well. Mr. Chairman, I yield back. 

Mr. COSTELLO [presiding]. Mrs. Walters. 

Mrs. WALTERS. Thank you, Mr. Chair. 

Mr. Gouse, we know that many States and localities have developed legislation aimed at regulating self-driving cars. Can you go 

64 

into further detail on the State localities implementing SAE’s level 

of driving automation into their laws? 

Mr. GOUSE. I am most familiar as a staff person with Pennsylvania and Michigan and California. But there are, as Jeff said earlier, there are two or three dozen States, and at each State or Commonwealth there is an upper chamber and a lower chamber and 

also there may be a regulatory agency, or two of them that are 

working in concert or in parallel paths. So there are quite a few 

going on. 

And our members who are active are picking up things. I know 

New Jersey is talking about it. I heard that from a member yesterday. North Dakota is a State, I believe. So it is not our main business as SAE to monitor State activities, but we want them to adopt 

the SAE language so there is consistency across all the States and 

territories. 

Mrs. WALTERS. Yes. I think that is going to be an issue. The consistency is going to be obviously very, very important. And then the 

same question for you again is a number of groups have developed 

classification systems to define automated driving systems, and can 

you discuss why SAE determined the J3016 standard to be the 

most optimal way of defining the different automated driving systems? 

Mr. GOUSE. I would just like to say probably that the committee 

leadership and members worked very hard on this over quite a bit 

of time with a tremendous amount of input from various different 

stakeholders. And it is not just a committee of technology developers, there are policy folks in there, NHTSA was part of it, motor 

carriers, Federal Motor Carriers was part of it. 

So it was an ongoing process. It was in fact adopted internationally before NHTSA did even at the Amsterdam convention in April 

of ’16, I believe. So it is becoming a global standard and it is being 

validated that way across the globe and in the States as being the 

preferred choice. It is also a living document. It has been revised 

already once since it was issued. In fact, the name was even 

changed a little bit to clarify it. So it will go through revisions and 

additional references to discuss some of the issues that were 

brought up here in questions to add to it. 

Mrs. WALTERS. OK, all right. Thank you very much, and I yield 

back the balance of my time. 

Mr. COSTELLO. Mr. Ca ́ rdenas, you are now recognized for 5 minutes. 

Mr. CA ́ RDENAS. Thank you very much, Mr. Chairman. Something 

just occurred to me. Are we likely going to see in the near future— 

I grew up learning how to drive on a stick shift. A lot of today most 

drivers in America probably don’t know how to use a manual or a 

stick shift vehicle, these automatic gear shifting vehicles. Are we 

looking at possibly in the near future where people get in their car 

and they push a button, today I am going to use automation 1, 2, 

or 3 Level, and maybe that is the new gear shifting or shifting of 

the vehicle that we are going to be driving in the future? Does that 

make any sense, or is that probably likely what we are going to be 

looking at? 

Mr. KLEI. I think one of the things that we look at when we are 

looking into development is you never take the fun away from drivVerDate Mar 15 2010 15:09 Jun 07, 2017 Jkt 037690 PO 00000 Frm 00068 Fmt 6633 Sfmt 6633 I:\115THCONGRESS\115X17SELFDRIVINGCARS\115X17SELFDRIVINGCARSWORKING
65 

ing your car. We still like the ability for people to drive their cars 

when they want to drive their cars. But there is many driving 

tasks, there is many opportunities for disabled to provide mobility, 

and that is where we think the big benefit will be. We never want 

to take the fun away though. 

So it could be someone gets in a car and says yes, I want to go 

from point A to point B in an automated way or it could be that 

I want to drive myself on the windy country roads. So I think there 

is going to be some opportunities there over time for people to still 

have fun, but in certain circumstances still get the mobility that 

they need and they want and to be able to do other things in the 

car. 

Mr. CA ́ RDENAS. Well, speaking of taking the fun away driving, I 

can envision if we are going to be appropriate as a Government, 

and maybe in the future what we have is a speed limit technology 

where if you are going to be driving an automated vehicle then the 

speed limit is 35 miles an hour. Your car is not going to be allowed 

to go over 35 miles an hour on that piece of the road. 

Mr. KLEI. Yes. I mean, I think these are things that we need to 

consider, but quite frankly we believe that if you do that you could 

actually introduce more challenges because everyone will try and 

go around the car. You want the car to flow naturally with traffic 

with other automated vehicles as well as nonautomated vehicles, so 

you want it to be very natural, and through testing and development that is what we are developing for. So to limit a car and limit 

the mobility and limit the functionality is going to limit the testing 

and deployment of such technologies and potentially lifesaving benefits. 

Mr. CA ́ RDENAS. For those of you who are on the panel from private industry, I mean how do you feel about your relationship right 

now with Federal departments when it comes to reporting and expectations of, you know, obviously nonproprietary progress and letting them know what you are looking for as long as timing of introducing products, et cetera? 

Mr. KLEI. I think, Congressman, it is a great question. It is one 

that through the Federal Automated Vehicles Policy that was 

rolled out last September from NHTSA it is a great start to bringing the collaboration together between industry and Government. 

And we think it is a big step forward but there is more work to 

do. 

In that policy it requires significant reporting between the industry and NHTSA and that reporting needs to be better defined, it 

needs to be more expedited, and the exemption rules that we are 

all looking for especially in the development side need to be improved. And so we are working closely with that agency, with 

NHTSA to try and improve that and make sure that when it is officially rolled out and deployed that really it is, in fact, usable and 

it is going to drive this technology forward and potentially save 

lives when deployed. 

Mr. CA ́ RDENAS. What country right now seems to be more, I don’t 

want to use the word advanced, but more ready and willing to 

allow their constituents to drive the highest class of automated vehicle right now? 

66 

Mr. KLEI. Every country has certain limitations and certain regulations and there is no one country that is easy. Every country has 

different—— 

Mr. CA ́ RDENAS. I mean, is there a particular country right now 

that—I am thinking of Germany. I am wondering if they are allowing a little bit more than we are so far. 

Mr. KLEI. I don’t know that there is one country that says it is 

easy to do. Every country has certain limitations and for good reason. 

Mr. CA ́ RDENAS. Anybody know what is going on around the 

world? 

Dr. STEPPER. The same as Mr. Klei said, from my side sometimes 

it is not even regulated by a specific country law. You know, also 

in Germany, you mentioned Germany as an example, the different 

States have different laws and different regulations and the regards of allowing or not allowing different levels of automation. 

There may be some States that are really fostering the rollout so 

that companies like Bosch can go on public roads and test and validate the systems which is very helpful for our development to be 

allowed to do that. 

Mr. CA ́ RDENAS. OK. Thank you, Mr. Chairman. 

Mr. COSTELLO. Mr. Mullin, you are now recognized for 5 minutes. 

Mr. MULLIN. Thank you, Mr. Chairman. 

Doctor, is it Stepper? 

Dr. STEPPER. Yes. 

Mr. MULLIN. Thank you for being here. You talk about the technology and moving forward with the technology of going out and 

testing the vehicles. But can you explain a little bit more how that 

works with the technology of the vehicle versus the GPS—— 

Dr. STEPPER. Yes. 

Mr. MULLIN [continuing]. That the vehicle I am assuming has to 

be programmed into a GPS and it has got to take you from point 

A to point B; is that correct? 

Dr. STEPPER. So it depends on the level of automation, Congressman. So if you would go all the way to a Level 5 automated driving, for example, which really takes the driver out of the loop and 

there is no longer a driver required to operate the machine that it 

would exactly the scenario that you would dial in a particular destination and the vehicle will take you there, for example, door to 

door. 

Mr. MULLIN. Well, what is Level 1? 

Dr. STEPPER. In Level 1, this is what we call today’s driver assistance systems where there is—— 

Mr. MULLIN. Where your seat vibrates and it tells you and does 

all that stuff? 

Dr. STEPPER. For example, there would be a warning that there 

is an impending front-to-rear-end collision or there is a lane departure that is about to happen. 

Mr. MULLIN. And 2? 

Dr. STEPPER. Two combines the longitudinal and lateral control 

of the vehicle so, for example, we still call it the assistance functions. It is functions like a traffic jam assist where the vehicle in 

that particular scenario in a traffic jam would automatically take 

the control for the longitudinal and the lateral perspective of the 

67 

vehicles but the driver is still fully responsible and fully in the 

loop, whereas in Level 3, for example, you take that as one example to a traffic jam pilot where you can take your hands and your 

feet off for a well-defined scenario. 

You need to be on a Class 1 road. On a traffic jam pilot, for example, you need to have preceding traffic, and then for this stop 

and go traffic the machine would take over the control of the vehicle until it handles it back to the human being. 

Mr. MULLIN. And 5 is what we started the conversation with. Do 

we see the advancement of the vehicles catching up or going to surpass the GPS? Because everybody uses their road maps and their 

GPSs on their phones and I am sure I am not the only one that 

it takes me to the wrong place all the time. 

Dr. STEPPER. Yes, yes. 

Mr. MULLIN. So they would have to work simultaneously, 

wouldn’t they? 

Dr. STEPPER. Yes, so they actually, Congressman, there is additional technology that is required. So what we know today as GPS, 

also standard definition maps, for Level 4, Level 5 automated driving to a certain extent even for Level 3, we have the need for high 

resolution, highly dynamic maps that really exceed the requirements that we see from the map requirements from today’s navigation system. And that is actually coupled in a process called data 

fusion with onboard sensing via radio cameras, your radars, your 

other sensing technology you may have on board on the vehicle 

that will recognize certain landmarks like a fire hydrant, like a 

bridge, like a certain exit, and it combines the GPS information—— 

Mr. MULLIN. That is more of an eyesight on it. 

Dr. STEPPER. As well as nonvisible electromagnetic base like 

radar, for example, or LiDAR technology which uses laser light. 

Mr. MULLIN. So would this be one entity or would each company 

be responsible for their own technology for the GPS to which their 

vehicle is going to be operating by? 

Dr. STEPPER. It really comes together at the end at the vehicle 

manufacturer. There may be different suppliers for certain sensing 

technologies or GPS technology. What really is the trick to have 

the competency in bringing all this data together in this data fusion process and derive driving policy decisions out of that. 

Mr. MULLIN. What I am talking about is somebody working on 

this end of the GPS as you guys are working up with the vehicle, 

are they going to meet? Or when the technology for the vehicle gets 

to that point, then we start diving into the precise GPS? 

Dr. STEPPER. Yes, so that is already available today in a system 

that is called differential GPS systems that increases the resolution. Most companies, actually, out there testing and validating 

automated driving today use differential GPS system to get them 

to the resolution that they need, which in essence is a centimeter 

resolution as opposed to a couple meters that we see today. So that 

technology is already available today. The challenge in the development is going to be to bring the prices down and the costs down 

of such an advanced GPS system for use in every vehicle. 

Mr. MULLIN. Is there one company that is leading that? 

68 

Dr. STEPPER. There are several companies that are working on 

that exact topic. There is not one company that stands out. 

Mr. MULLIN. Do you have one particular one that you are working with? 

Dr. STEPPER. We work really with all of them at the moment. 

There is no particular one that I can point out at the moment, Congressman. 

Mr. MULLIN. All right, thank you. Thank you for your time. Mr. 

Chairman, I yield back. 

Mr. COSTELLO. Thank you. I will now recognize myself for 5 minutes and ask a question to all panelists, two-part question: One, 

how is the development and testing of these systems different from 

the development and testing of fully self-driving technologies; and 

second, how much can be learned from the development and testing 

of advanced driver assistance systems? 

Mr. KLEI. So first, what is different, I don’t really think there is 

so much difference in the way we develop and we test technologies, 

everything from ABS through electronic stability control and all 

the way to fully automated driving. It is a very rigorous, long testing process. It starts with the technology itself. It starts with bench 

testing, then in contained track environments, and we evolve all 

the way to, ultimately, the real road and real world testing. 

So the process is very similar. Obviously, the conditions by which 

we test are going to be different depending on the technology. But 

in terms of the rigorous, you know, Six Sigma, continuous improvement mindset that we have to make sure the products are safe is 

no different regardless of what the technology is. The challenges 

are bigger the higher levels of automation you go to, but the testing 

process itself is always very much the same, safety first. 

When it comes to the implementation of these and across the 

various product portfolio again everyone is going to be different, 

and ultimately it is the OEM that decides when it is safe to deploy 

in the vehicle. We work with OEM customers and they ultimately 

are the ones that certify for FMVSS. 

Mr. GOUSE. I would like to just briefly add a couple things. Prior 

to the beginning of testing, there are some tools you put in place, 

what are called a design failure mode effects analysis and failure 

mode effects analysis, where you look at all different ways a system 

might fail and then you design a test procedure to encompass that 

and then you look at when something fails, whether it is part of 

the system or something external or you are testing an automated 

vehicle, but the engine conks out or something or you get a flat 

tire, you have to build all of that into your test procedures. And 

so you have got a complete, very comprehensive, and carefully designed program to execute as part of the process. 

Mr. ZUBY. Yes. I would agree with Mr. Klei and Mr. Gouse that 

the process is similar. But I think one of the things that we need 

to keep in mind that as we deploy increasingly evolving technologies we do need to watch them very carefully and see how they 

perform in the real world. And when they fail to perform try to understand whether or not they are failing to perform because of a 

deficiency in the technology, a deficiency in the logic behind the 

technology, or because the circumstance in which they failed is just 

outside the design domain of that particular technology. 

69 

Again, consequently, I think information about what is happening in the real world as these technologies deploy is going to be 

vitally important to making sure that this stuff is developed in a 

safe way. 

Dr. STEPPER. And if I just may add a few points. Number one is 

what we didn’t have available in the past when we started developing ABS or ESP, for example stability control, was an international standard specifically designed for the different safety assessments and different safety levels. And that standard is called 

ISO 26262 which was specifically developed for use in the automotive space to define different safety levels and also define how 

to get to and what you have to meet in order to get to the different 

levels of this safety. 

Number two, what we didn’t have available when we are deploying ABS or electronic stability control or early in driver assistance 

is the vehicle being connected to the rest of the world, being connected to servers. If we would just proceed with conventional validation as we have in all these decades it would really be cost and 

time prohibitive. We would; literally, in order to fully validate a 

fully automated vehicle we would have to drive a distance that 

equals the average distance between the sun and the earth which 

is not feasible from a cost and time perspective. 

So what we continue to deploy is the advantages of being connected and having vehicles deployed in the field that collect for us 

very valuable data of real world traffic situations that we then can 

take back to analyze and develop and adjust our software, for example, accordingly. 

Mr. COSTELLO. Thank you. Seeing there are no further members 

seeking to ask questions for the first panel, I would like to thank 

all of our witnesses again for being here today. 

Before we conclude, I would like to include the following documents to be submitted for the record by unanimous consent: a report from MEMA; Advocates for Highway and Auto Safety’s FAVP 

comments in a March 27th letter to Chairman Latta and Ms. Schakowsky; a statement from the National Safety Council; a statement 

from Global Automakers; a letter from the U.S. Chamber of Commerce, Technology; a statement from American Car Rental Association; a statement from Mobileye; a statement from EPIC; and a letter from Honda. 

[The information appears at the conclusion of the hearing and at 

http://docs.house.gov/Committee/Calendar/ 

ByEvent.aspx?EventID=105790.] 

Mr. COSTELLO. In pursuant to committee rules, I remind members they have 10 business days to submit additional questions for 

the record and I ask that witnesses submit their response within 

10 business days upon receipt of the questions. Without objection, 

the subcommittee is adjourned. 

[Whereupon, at 12:00 p.m., the subcommittee was adjourned.] 

[Material submitted for inclusion in the record follows:] 

70 


ADVOCATES 

FOR H1GHWAY 

~~ Atl'10 S,AfC!Y 

March 27, 2017 

The Honorable Robert Latta 

Chairman 

Committee on Energy and Commerce 

Subcommittee on Digital Commerce and 

Consumer Protection 

2125 Rayburn House Office Building 

Washington, D.C. 20515 

The Honorable Jan Schakowsky 

Ranking Member 

Committee on Energy and Commerce 

Subcommittee on Digital Commerce and 

Consumer Protection 

2125 Rayburn House Office Building 

Washington, D.C. 20515 

Dear Chairman Latta and Ranking Member Schakowsky: 

As you prepare for tomorrow's hearing, "Self-Driving Cars: Levels of Automation," Advocates 

for Highway and Auto Safety (Advocates) would like to submit our position on the safety 

implications presented by autonomous vehicles (AVs). Advocates is a coalition of public health, 

safety, and consumer organizations, insurers and insurance agents that promotes highway and 

auto safety through the adoption of safety laws, policies and regulations. We respectfully request 

that this letter and the comments Advocates submitted to the public docket in response to the 

National Highway Traffic Safety Administration (NHTSA) "Federal Automated Vehicles 

Policy" (A V Guidelines) Notice and Request for Comments (81 Federal Register 65703, 

September 23, 2016, DOT Docket No. NHTSA-20 16-0090), which are attached, be included in 

the hearing record. 

Advocates Has Consistently Pushed for Advanced Technologies in Vehicles to Save Lives 

and Prevent Injuries. With Fatalities on the Rise, Action is Needed. 

Advocates has been a long-standing leading supporter of technological solutions to advance 

safety, reduce crashes, save lives, mitigate injuries and contain crash costs. These efforts include 

promoting requirements for airbags, electronic stability control, anti-lock brakes, rearview 

cameras and other important safety features as standard equipment on cars, trucks and 

motorcoaches. In fact, NHTSA has estimated that since 1960, over 600,000 lives have been 

saved by motor vehicle safety technologies.' Autonomous vehicle technology presents a similar 

possibility of accomplishing significant reductions in preventable motor vehicle deaths and 

injuries at a time when fatalities are on the rise. 

According to NHTSA, 2015 experienced the largest percentage increase of motor vehicle deaths 

in nearly fifty years.2 More than 35,000 people were killed on our nation's roads, representing a 

7 .2-percent upturn? Preliminary information for the first half of 2016 appears to be even worse, 

indicating an 8 percent rise in fatalities compared to the same time period in 2015.4 Advocates is 

optimistic that A V technologies can help reverse this recent trend. 

1 Lives Saved by Vehicle Safety Technologies and Associated Federal Motor Vehicle Safety Standards, 1960 to 

2012, DOT HS 812 069 (NHTSA, 2015); See also, NHTSA AV Policy, Executive Summary, p. 5 endnote l. 2 National Center for Statistics and Analysis, 2015 motor vehicle crashes: Overview, Report No. DOT HS 812 318, 

National Highway Traffic Safety Administration (Aug. 20 16). 

3 !d. 4 National Center for Statistics and Analysis, Early Estimate of Motor Vehicle Traffic Fatalities for the First Half 

(Jan-Jun) oj2016, Report No. DOT HS 812 332 (Oct. 2016). 
71 


Yet, some experts forecast that 15-20 years may transpire before A V s comprise a major portion 

of the vehicles on public roads. In the interim it is unacceptable to complacently allow more 

than 500,000 people to be killed and more than 36 million to be injured in crashes. In the short 

term, we urge NHTSA to use its authority to require that available and effective crash avoidance 

technologies be required as standard equipment on all motor vehicles. These include automatic 

emergency braking (AEB) and lane departure warning systems for trucks, buses and cars. To 

encourage these advances, Advocates, along with other safety groups and families of victims and 

survivors of crashes, filed a Petition for Rulemaking with NHTSA in 20 15 requesting the agency 

issue a rule to require automatic braking systems to prevent frontal crashes involving large 

trucks. The agency granted the petition and Advocates urges NHTSA to commence rulemaking 

this year, particularly because of the urgency in addressing the unacceptable and dramatic 

increases in truck crash deaths these past five years. 

Semi-Autonomous Vehicles that Share Control with the Human.Driver Pose Serious Safety 

Challenges. 

Regarding the specific focus of the Subcommittee's hearing, the levels of autonomous operation 

of A V s, the Society of Automotive Engineers (SAE) and NHTSA in its A V policy5 have adopted 

a range oflevels, 1 through 5. Levels l through 3 involve some form of safety-oriented 

technology or A V system that may only alert the driver by providing a warning, assist the driver 

in taking evasive action, control a particular safety system in order to prevent a crash, or operate 

the vehicle in certain circumstances while the driver is supposed to monitor the vehicle. These 

three levels represent varying degrees of reliance on independent automated technology systems 

but can also involve shared control of the vehicle by the driver and the A V operating system at 

different points in a trip. At each level of autonomous or semi-autonomous operation through 

level 3 the driver must remain completely engaged in the driving task. The driver must remain 

alert, monitor the vehicle operation and driving task, and either maintain control of the operation 

of the vehicle or be prepared to take control of vehicle operation (re-engage) in the event the AV 

system fails to function properly or cannot respond (shuts off) under the circumstances 

prevailing at the time. This shared control poses serious safety challenges as drivers may 

become overconfident and allow themselves to be distracted and/or lulled into a false sense of 

security by the A V system. 

An example of the consequences that can occur when an AV system is not properly vetted and 

tested was the May 2016 crash in Florida of a Tesla Model S using the Autopilot A V system that 

resulted in the death of the vehicle owner. First, while the Autopilot system was designed to 

have the driver constantly monitor the operation of the vehicle, the A V system method for 

maintaining driver engagement was insufficient. Reminders to the driver to keep his hands on 

the steering wheel were inadequate and too far apart in time sequence to ensure driver reengagement during a critical safety event. Second, the vehicle visual sensors for the AEB 

system did not identifY that a large truck had crossed the path of the Tesla and presented an 

immediate danger. The radar may have detected the truck but dismissed it. The conflicting 

inputs from the camera and radar sensors did not trigger any safety action by the Autopilot A V 

system, such as switching off the vehicle cruise control or applying the AEB system. Despite the 

conflict in sensor information, and the lack of response by the driver to any driver engagement 

warnings, the autopilot remained engaged and drove the vehicle under the truck killing the 

driver. This example of a shared responsibility for vehicle operation by the driver and the A V 

system, and the hand-off that needs to occur between the A V system and the driver, clearly show 

that Level 2/3 A V systems present a particularly high degree of safety risk to the public. This is 

the reason adequate testing of the A V operating system is essential in order to ensure that drivers 

5 The NHTSA A V policy identifies levels 3-5 as highly autonomous vehicle (HA V) operation. 
72 


remain engaged in the driving task and that the transition from autonomous operation to driver 

re-engagement works perfectly every time. 

Fully Autonomous Vehicles Present Unique Safety Concerns. 

A V operation levels 4 and 5, which represent fully autonomous operation controlled by the A V 

system, present a different set of safety concerns. Level 4 and 5 vehicles must be able to 

complete a trip entirely based on A V system control, without driver input. To do so, the A V 

system must undergo rigorous and thorough testing to ensure it is capable of operating 

flawlessly. In the event of a mechanical or software problem, defect or failure, the A V system 

must be able to put the vehicle in a safe mode that takes it out of harm's way. 

A Functional Safety Approach is Needed to Provide the Framework for the Design, 

Development, and Deployment of Autonomous Vehicle Technology. 

Advocates' comments to the docket on the AV Guidelines urged NHTSA to require a functional 

safety process for new A V technologies which are rapidly entering the marketplace. The 

command and control software of these vehicles is not addressed by current Federal Motor 

Vehicle Safety Standards (FMVSS). Furthermore, it is expected that there will be efforts by 

industry to seek and obtain exemptions for AVs from some or all of the existing FMVSS. While 

we know there will be crashes, deaths and injuries during the transition between old and new 

cars, human error should not be replaced with computer error. Predictable problems and flaws 

that pose unreasonable risks to public safety before these vehicles are sold to the public and used 

on public roads should be eliminated, and this can be achieved with a mandatory functional 

safety process. 

Additionally, cybersecurity is an important aspect of A V development which must be addressed 

as part of functional safety. NHTSA should identifY problem areas and require specific 

responses from manufacturers as to how those are being addressed. Problem areas could include 

subjects such as GPS signal loss or degradation, spoofing, and off-line and real time hacking of 

single vehicles or fleets of vehicles. As with all other A V performance aspects, the sharing of 

data in terms of cybersecurity will improve overall safety and ensure that all vehicles are 

afforded the same level of security. Data and information about known flaws or problems must 

be shared among manufacturers and with NHTSA and the public to ensure solutions to safety 

problems are readily identified and remedied. The potential risk of a single software error, or 

malevolent computer hack impacting hundreds or thousands of AVs, perhaps whole model runs, 

makes strong cybersecurity protections a crucial and essential element of A V design. 

The Development of Autonomous Vehicles Must Be Transparent or Public Confidence in 

the Technology Will Suffer. 

The development and deployment of AVs as well as NHTSA's role in regulating this technology 

must be open and transparent. All communications and responses between the agency and a 

manufacturer as it relates to any issues involving A V s must be made available for public review 

and scholarly research. All data generated from the testing and deployment of AVs, except for 

trade secrets and private individual information must also be made public. Lack of transparency 

will severely undermine the public's confidence in this new technology and inhibit its 

widespread adoption. 

In fact, a recent national survey commissioned by Kelley Blue Book found that a large portion of 

the public is hesitant to accept A V s. Fifty-one percent of respondents replied that they prefer to 

have full control of their vehicle, even if it's not as safe for other drivers. Additionally, 
73 

[Additional information from AHAS is available at http:// 

docs.house.gov/meetings/IF/IF17/20170328/105790/HHRG-115- 

IF17-20170328-SD004.pdf.] 


awareness of the higher levels of vehicle autonomy is limited, with 6 out of 10 people saying 

they know little or nothing about A V s. For half of the respondents, the perception of safety and 

personal comfort with autonomous technology diminished as the level of autonomy increased. 

In fact 80 percent believed that people should always have the option to drive themselves, and 

nearly one in three respondents said they would never buy a level 5 vehicle.6 

Advocates urges the agency to issue appropriate safety standards for the A V technologies and we 

hope that the industries involved will support this position. Having some basic rules of the road 

that everyone follows, drivers as well as manufacturers, will benefit the auto and tech industries 

as well as public safety. If a lack of transparency or malfunctioning technology leading to 

crashes, deaths and injuries disrupts consumer confidence, it will set back all of our efforts to 

advance these lifesaving technologies. 

Conclusion 

In response to concerns about the death and injury toll on our highways, Congress passed the 

National Traffic and Motor Vehicle Safety Act of 1966.7 The law required the federal 

government to establish the FMVSS to protect the public against "unreasonable risk of accidents 

occurring as a result of the design, construction or performance of motor vehicles."8 While cars 

have changed dramatically over the last half century and will continue to do so in the future, the 

underlying premise of this prescient law has not. Technological advances, including A Vs, offer 

the promise of achieving much-needed safety improvements. However, it is critically important 

that safety and transparency are at the forefront of the process. 

Thank you for your time and consideration of our safety position on this emerging issue. Please 

do not hesitate to contact us if we can provide any additional assistance to the Subcommittee. 

Sincerely, 

Jacqueline S. Gillan 

President 

Catherine Chase 

Vice President of Governmental Affairs 

cc: Members of the Subcommittee on Digital Commerce and Consumer Protection 

6 2016 Kelley Blue Book Future Autonomous Vehicle Driver Study, www.kbb.com. 7 Pub. L. 89-563 (Sept. 9, 1966). 8 Title 49, U.S.C. Sec. 30102. 
74 


Statement of the National Safety Council 

House of Representat.lves 

Committee on Energy & Commer-ce 

Olgit:a! Commerce and Consumer Protection 

Hearing on 

Se!r~Orlving Cars, Levels of Automation 

Tuesday, Macch 28,2017 

Chairman Latta, Ranking Membor Schal<ovvsky and members of the subcommittee, thank you 

for allovving the Natlonal Safety Council (NSC) to submit this statement for the record. NSC Is a 

100-year-old nonprofit based in Itasca, IL, vvith a v1sion to end preventable deaths Jn our Hfet!me 

at vvork, in homes and communities and on the road through !eadersh1p, research, education 

and advocacy, Our more than 13,500 member compan1es represent employees at more than 

5Q,QQO U.S. vvorksites. For decades we have advocated for safer cars, safer drivers and a 

forg1ving environment 1n and around vehicles< We have led large scale public education 

campaigns on the importance of seatbelts and airbags, eliminating distracted driving, and 

helping consumers understand the technologies in their vehicles to reduce deaths and Injuries 

on our roadways, 

Federal leadership on mo'tor vehicle safe'ty is necessary because there should only be one level 

of safety. Consumers need confidence ln veh1cles regardless ofvvhere they reside; 

manufacturers need certainty in order 'to invest.1n design and production, and states do not 

possess the expertise and the resources to repliCate design, testing and reporting programs. 

further, a patchvvork of requirements will result in confusion for consumers and increased cost 

for manufacturers and operators attempting to comply vvit.h a myriad of requirements. F1nal1y, 

the absence of a safe, workable standard vvill drive development, testing and deployment 

ovorseas, resulting in the f!Jght of innovation and the jobs that accompany it to locations outside 

of the US. 

The Lifesaving Potential of Advanced Technology 

NSC believes advanced vehicle technology, up to and including fully automated vehicles, can 

p1·ovlde many benefits to society. The most Important contribution will be the pate.ntial to greatly 

reduce the number of' fatal crashes on our roadways, vvhich are increasing. Every day vve lose 

more than 100 people In motor vehicles crashes, and every year more than 4 million people are 

!njurod. Beyond the human toll, these deaths and injuries cost society over $380 b!11!on, 

tnclud1ng productivity losses, med1ca1 expenses, motor vehtc!e property damages and employer 

I 

NSC preliminary estimates reveal that the 40,200 roadway fatal!ties dunng 2016 are 6% higher 

than the same period last year and 14% higher than the same period tvvo years ago.lfvve aro to 
75 


moke a mean1ngful change 1n this trend, there must be a sense of urgency coupled vvith large, 

near term gains t.o save lives on our roadvvays, 

Motor Vehicle Deaths On the Rise 

Number of Deaths 

47000 

45000 

43000 

41000 

39000 

37000 

35000 

33000 

2005 2010 2015 

Source: NSC ar;alys•s of Nanonal Center for Health Statlstlcs (NCHS) mortality data and NSC a$tlmate for 2016 

while "the absolute numbers of' fatalities change from year to year, many of the same behavioral 

problems remain persistent and have been represon"ted in the data for decades. For example, in 

2015: 

9,306 people vvere kl!led in alcohol-impaired driving crashes 2 

3,477 people ~ece killed ;o difitcac<ioo ccashes 3 

9,874 people vvore killed V11h1le unrestrained, 

T ne National H1 9 hvvay Traffic Sl'lfoty Administration (NHTSA) estimates that 94% of au fatal 

crashes have an element of hurnan error, T her afore, If' we are t.o eliminate or reduce the number 

offat:aHties on our roadvvays, advances in vehicle technology must be part: of tho solut1on. 

Hovvever, it vvilllikely be decades before vve have meaningful fleet penetration of fully automated 

vehicles. 

Last year, the NSC and the National Transportation Safety Board (NTSB) hosted a full day 

event vvith dozens of expert panelists focused on Roaching Zero Crashes: A dialogue on the 

Ro1e of Advanced OnverAssistanco Systems (ADAS). 5 While there 1s a great deal or 

excitement about highly automated vehicles (HAVs), automate-d vehicles and their potential to 

save !lves, it is Important to recognize that many legacy technologies represent the building 
76 


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77 


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78 


ADAS already operate on the roadways today, but more could be done to encourage greater 

fleet penetration. Features !Ike lane departure warning systems, blind spot monitoring, adaptive 

cruise control and others help to prevent or mitigate crashes. The cost of these technologies is 

declining and their impact is measurable. According to the Insurance Institute for Highway 

Safety {II HS), if fa ur current tee h nolo g I e s--fontva rd c otJlslo n vvarn in g/ m it1g at!o n, Ian e departure 

warning/prevention, side vievv assist/blind spot monitoring, and adaptive headlights-were 

deployed In all passenger vehicles, they could or mitigate as many as 1.86 mi!non 

crashes and save more than 10,000 lives per year, Ho\Nevor, front crash prevention, commonly 

referred to as automat1c emergency braking, which was en option In about half new 2015 model 

year cars, vvas ln only 8% of registered cars in 2015. 10 

Crashes relevant to 4 crash avoidance systems 

FARS and GES, 2004-2008 

all injury fatal 

front crash prevention 66,000 879 

lane departure prevention 179,000 37,000 7,529 

side view assist 395,000 20,000 393 

adaptive headlights 142,000 29,000 2,484 

total unique crashes 11,866,000 149,000 10,238 

Source: Insurance lnst1tute for Highway Safety 

Simdar conclusions were reached in a July 2016, Carnegie Mellon study which stated thatjust 

three technologtes--rorward collision warning, lane departure warning and blind spot 

monitOring-could have prevented or reduced as many as 1.3 miHion crashes annually and over 

1Q,QOQ fatal crashes. 11 This study further found that almost one quarter of all crashes could be 

affected by these crash avo•dance systems, butonly2% or2013 model year cars included 

these systems as standard. 

while many of these tochnologies are available on higher value cars or as part of an upgraded 

technology package today, they are not standard equipment an all makes and models. Safety 

should not boJustfor those vvho can afrord it, especially for technologies that will result In 

thousands of nves saved every year. The Carnegie Menon study est!m ated that if all light-duty 

vehicles were equipped vvith the three technologies, they would provtde a lower bound annual 

benefit of about $18 b!Hion. With 2015 prictng, it would cost about $13 billion to equlp a!! lightduty vehicles with the three technologies, resulting tn an annual net benefit of about $4 billion 

a $20 per vehicle net benefit. By assuming all relevant crashes are avoided, the total upper 

9 cmp://o ,, aaLocg/1 Q, 1 016/,,a ap 2010 10.020 

-o a up '//www o"o.oov/oow>/ avo o"/Doo om oo"/2016 

,, hnp://<;lx.dol.oFg/10 1016/;.up 2016.06.017 

RT p 1 p3 moara.pdf 
79 


boun.d annual net benefit from all three technologies combined 1s about $202 billion or an $861 

per vehlcle net benefit, at cun·enttechnology costs. 

NSC recognizes and applauds the voluntary commitment made last March by 20 automakers to 

include automatic emergency braking (AEB) on all vehicles sold in the US ny 2022. Toyota has 

already committed to beatth!s date by several years. Given the slow turnover of the fleet, '.Ne 

encourage other manufacturers to vie'.Nthe 2022 date as a finish J1ne rather than a starting point 

and accelerate the roll out orAEB and other lifesaving technologies. 

Whether mandated or optional, in many cases these systems can perform driving tasks more 

predictably, more conservatively and more safely than a human driver, and may act vvithout 

driver input tf a driver is distracted, impairod or incapacitated. However, because there are no 

minimum standards for many of these technologies, legitimate questions about their 

effectiveness remain. 

Dedicated Short Range Com municatlon (DSRC) 

Another component ofADAS and automated vehicle systems Is dedicated short range 

com municatlon (DSRC), '.Nhich vvould allow vehicles to communicate over dedicated spectrum 

bands vv1th each other, pedestrians, and Infrastructure to prevent collisions. This technology, 

often referred to as V2V (vehicle-to-vehicle), V2! {vehlcle-to-infras"tructure), V2P (vehicle-topedestrian), or V2X (vehicle-to-everything), is pending a rulemak1ng decision by NHTSAto 

establish performance standards. NSC enC()Urages NHTSAto release this standard soon so 

that implementatiOn orV2X can be more '.Nidespread, 

DSRC can create redundant safety systems in motor vehicles, !n other modes of transportation, 

fall-safe designs can support operator error, but in highvvay vehicles that task has fallen solely 

on drivers, DSRC would ai!O'.N a vehicle to communicate with a red light to compensate for a 

fat1gued driver, stop a car to prevent a coll!sion wlth a pedestrian if a driver fails to detect him or 

her, and prevent or mitigate collisions betvveen veh1c1es equipped '.Nith DSRC, DSRC has been 

deployed by some manufacturers, but NSC beliE;Jves it is an important opt1on in a safe systems 

approach to the design of HAVs and anticipates lt will be more 'Nidely deployed if there is more 

regulatory certainty, 

Education and Training 

One component in the National Highway Traffic Safety Administration's Automated Vehicle (AV) 

poncy, released last year, that should be a requirement moving forvvard is the incorporatlOO of 

driver education and training about ncvv technologies. With nearly 17.4 mll!ion nevv 

passenger cars and trucks sold in 2015, understanding tho technology on these vehicles Is 

necessary, yet a University of' Iowa survey found that 40 percent of respondents reported they 

hnd experienced a situation 1n vvhich their vehicle acted in an unexpected vvay.· 3 When thls 

occurs 1n a rea1-11fe driving situation, among multiple drivers, 1t can load to d1sastrous outcomes. 

The National Safety Council and our research partners at tho University or!ovva are focused on 

educating consumers about ln-vchicle safety technology through our MyCarOoesWhat 

12 

University ot loiNa. of Driving Safety T actinologies. July 30, 2015. Accassibl~ at 

http:// p pc. u!OWf.l. e d u/.., ita.,.,/ ct a fa tJit/fii e._/ n at10 n n l_c on sumo~ _s urv a y_tec h n ic al_r e po~t_fln a 1_8. 7 .15. pdf" 
80 


campa1gn. 14 rh!s brand agnostic education campaign Informs drivers about how safety 

technologies work, hovv to best interact with them, and hovv to identtf'y situations vvhen the 

technology may not perform optlmHfly and should not be relied upon. Because of the need for 

continued human Involvement In the operation all vehicles today, the campaign tagline is You 

are your car's best safety feature, 

V,sttors to MyCarOoesWhat.org realize improvement In general knowledge and accurate 

comprehension of vehicle safety features. Drivers cannot effectively use these life-saving 

technologies if they do not understand both their functions and limitations, The AV policy 

proposes that this education be delivered in multiple v.tays, Including computer based, hantjs-on 

and virtual reality tratnlng, and other 1nnovative approaches, The MyCarOoesWhat education 

campa1gn follovvs that approach, and is developing virtual reality modules for release early next 

year. Further, INe recommend ongoing evaluation to determine the effectiveness of the various 

messages, methods of delivery and media so they can be 1m proved over time. 

St.andardized Nomenclature and Performance Outcomos 

Another way to reduce consumer confusion is to standardize the nomenclature or taxonomy for 

advanced technologies. NSC, the State of California, and Consumer Reports have 

recommended that, at the very !east, systems that are not completely a uta mated or Level 5 

should not be described as such. ADAS, with emphasis on driver assist, represents the vahicles 

b eln g sold today and req uiro s drivers to rem a in fully engaged in the driving task, That fact is 

often lost In marketing, media reports and consumer expectations, Labeling a motor vehicle as 

flautonomous" today, or even using terms such as "autopilofl, only confuses consumers and can 

contnbute to losses of situational awareness arC)Und the drivtng task, 

BY establishing standard nomenclature and establishing clear performance outcomes, 

consumers 1Nill better understand what they should expect from these technologies, For 

example, marketed as having AEB vvill not necessarily come to a complete stop before 

a colltsion, Some AEB systems only operate at t11gher speeds, and some are designed to slow 

rather than stop pnort:o a col!tslon. These nuances may not be easily understood by 

consumers. IIHS repon:s that systems vvith a warning only, but no automatic corrective action, 

reduce frontal crash rates by about 25%, but vehicles with automatic brak.1ng reduce crashes by 

more than 40%. Vehicles INith a vvarning and automatic braking reduce crash rates by about 

50%. Establishing a standardized, results-based, understandable definition orAEB and other 

ADAS technologies vvould benefit consumers, manufacturers, and dealers, as well as 

organizations that evaluate vehicles for their safety benof1ts, 

F1na11y, the New Car Assessment Program {NCAP) pr·ogram has operated ror nearly 40 years 

w1th a goal or testing vehicle sarety systems and educating consumers about them. Practically, 

it has created a mechanism to allow consumers to evaluate vehicles on safety systems, NSC 

supports NCAP and be~ieves lt is an important program to Improve the safety or the motor 

vehicle neet, Standardtzed nomenclature and performance outcomes vvill ensure NCAP can 

more effectively compare vehicle safety systems between manufacturers, and even between a 

manufacturer's own models. 

14 

15~~~~~~~~ua 
81 


Amer1can Na.tlonal Standards Institute {ANSI) Standard 

As important as it Is for the average consumer to know and understand the ADAS and 

automated technology, there is also work to be done on this Issue as 1t relates to the technology 

and Its rollout to commercial fleets. As such, NSCis taking a leading role working with the 

American Society of Safety Engineers (ASSE) and a wide array o"f experts in the automotive 

industry, technology sector, academia and f!e<;:ot management, to develop an ANSI standard to 

address policies, procedures and management processes that V\1111 ass1st in the control of risks 

and exposures associated With the operation of autonomous fleet vehicles on public 

thoroughfares. 

Road to Zero 

On October 5, NSC, NHSTA, tho Federal Highway Administration (FHWA), and the Federal 

Motor Carrier Safety Administration (FMCSA) announced the Road to Zero (RTZ) Coalition, 

RTZ is a partnership initiative focused on dramatic reducttons in roadV\Iay fatalities, Over 80 

public and pnvate organizations attended the announcement to !earn more about committing to 

a shared vtsJon of zero fatalit1es on our roadways. The f~rst meeting of the coalltlon V\ll!l be on 

December 15, 

The purpose of the Road to Zero Coalition is to 1) encourage and facilitate widespread 

lmplement<:~tion of countermeasures to reduce motor vehicle crash deaths in the near term; 2) 

develop a scenario-based vtsion for zero US traffiC deaths in the futuro; and 3) provide a 

road map for policymakers and stakeholders to eliminate traffiC deaths. 

NSC is joined on the Steering Group for the Road to Zero Coalition by the following 

organizations: Advocates for HighV\Iay and Auto Safety, American Association of Motor Vehicle 

Ad m1nistrators (AAMV/\), Am eric an Association of Stato Highway and Transportation Orncials 

(AASHTQ), American Automobile Assoc1at10n (AAA), Com mercia I Vehicle Safe"ty Alliance 

(CVSA), Global Automakors, Governors Highway Safety Association (GHSA), Institute of 

Transportation Engineers (JTE), lnsuranco Institute for Highvvay Safety (!IHS), Intelligent Car 

Coali"tlon, International Association of Chiefs of Police (!ACP), Mothers A 9 a!nst Drunk Driving 

(MADD), National Associat1on of State Emergency Medtcal Services Omctals (NASEMSQ), 

National Association of C11:y Transportation OtftCials (NACTQL National Association of County 

Eng1noers {NACE), and the V1sion Zero Network. 

On behalF of the Coalit:ron, "the NSC is adrnlnisterlng a grant program to support national nonprofit organiza"tions committed to roadway sa"fety programs that address the overlaps and gaps 

between roadway users, vehlcles·and infrastructure. Theflrstround of grants were awarded 

earlier th!s month to seven V\linners. In addition, the Coalltion will look at engaging others in near 

term solutions and countermeasures to reduce the death toll on our ro~dways. Frna!ly, vve wJtl 

also provide critical input for the development of a fu"ture community scenariO V\lith zero traffic 

fatallties-an effort to look at the measures, programs and technologies will be necessary to 

reach zero highway fatalities in thirty years and V\lork back from there, NHTSA, FHWA, FMCSA, 

and NSC are sponsoring the development of the scenario-based vlston for zero traffic deaths In 

"the U.S. in a 30-yeartJmeframe, and the RAND Corporation has boon retained to produce the 

scenario over the next 12-18 months. l1ook forV\Iard to briefing this Committee and others 1n 

Congress on the results of these aCtivities and the efforts of the Coalition to roach zero deaths 

on our roadvvays. 
82 


Conclusion 

Today, wo have rni1!1ons of drivers beh1nd the wheel, spend mlll1ons of dollars on education and 

enforcement campaigns, and still recognize billions in economic loses as a result of crashes. In 

spite of sat'er vehicle designs and reco!d*settlng seat belt use rates across the nation, operating 

a motor vehicle remains one of the deadliest things we do on a daily basis. 

It vvill be a long time before HAVs replace our current fleet. The transition vvill Hkely be messy as 

VIle deal with a complex and ever-changing Human-Machlne intort'ace. There 'VVlll be an evolUtiOn 

of the existing technologies and perhaps a revolution when it comes to new and dif"ferent 

tochno!ogtes. We need to be prepared for unantlc1pated consequences and new faHure modes. 

Although we can imagine a future vvith automated vehicles, 1t will be a long and winding road to 

get to the destination of zero fatalities as a result of HAVs. We cannot afford to ignore the 

carnnge on our highways that is a national epidemic today, The US trails other industrialized 

countries 1n addressing highway deaths, Efforts !ike Road to Zero witJ decrease fatalities today, 

tomorrow, and in the futuro ifvve embrace proven countermeasures and accelerate deployment 

of et'fective ADAS technologies. 

NSC apprec1ates thiS Committee'S leadership on vehicle technology and safe roadway 

transportation, If safety for the tr-aveling publ!c is the ultimate goat, advanced technology 

provides the most promising opportunity to achieve that outcome, and vvHI go a long way toward 

reaching the goal of eliminating preventable deaths in our lifetime, 
83 


GlobalAutomakers '0 " Kin 

~ Nissan <> Subaru " Suzuki o Toyota 

Statement for the Record of John Bozzella 

President and CEO, Association of Global Automakers, before the 

House Committee on Energy and Commerce 

Subcommittee of Digital Commerce and Consumer Protection 

Hearing on "Self-Driving Cars: Levels of Automation." 

March 28, 2017 

On behalf of the Association of Global Automakers ("Global Automakers"), I am pleased to 

provide the following statement for the record to the House Energy and Commerce Committee 

Subcommittee on Digital Commerce and Consumer Protection hearing on "Self-Driving Cars: 

Levels of Automation." 

Global Automakers represents the U.S. operations of international automobile manufacturers and 

automotive suppliers. Our automaker members design, build, and sell cars and light trucks in the 

United States and abroad, and these companies have invested $56 billion in U.S.-based facilities, 

directly employ nearly 100,000 Americans, and sell47 percent of all new vehicles purchased 

annually in the country. Combined, our members operate more than 300 production, design, 

R&D, sales, finance and other facilities across the United States. 

By convening this hearing concerning the levels of motor vehicle automation, the Subcommittee 

recognizes the importance of accurately defining what automated vehicles are and what they can 

do. The term "automated vehicle" encompasses much more than the "self-driving" car that 

garners so much press these days. Rather, vehicle automation is evolving and will eventually 

entail a range of functionality depending on customer needs and on the business model of the 

developer. While the future may see the deployment of fully driverless cars, several automated 

and connected technologies are helping to improve safety on our roads today. Features such as 

adaptive cruise control and lane-keep assist provide support to the driver by enabling vehicles to 

assume a greater portion of the driving task. These technologies-which are foundational to the 

development of more highly automated systems-significantly enhance motor vehicle safety and 

the driving experience. As these systems become more advanced, a vehicle's capability to 

operate without the active control by the driver will increase. Additionally, increased penetration 
84 


Globa!Automakers 0 

of automated features will raise consumer awareness and familiarity with these advanced 

technologies and can help smooth consumers' transition to greater levels of automation. 

It is important for policymakers to recognize that vehicle automation can cover a range of 

capabilities. SAE International has established a "Taxonomy" for automated vehicles in its 

Standard J30 16, which defines different levels of automation, ranging from Level 0 (meaning no 

automation at all) to Level 5 (where a car can drive itself in all conditions with no supervision or 

input from a human driver}. The Department of Transportation's Federal Automated Vehicle 

Policy uses this Taxonomy, which Global Automakers supports. The use of uniform definitions 

that recognize the various levels of automation is critical to consumer understanding of the 

technology and consistent treatment of automated vehicles on our roadways. 

Unfortunately, state legislatures and regulators do not always follow or consider the SAE 

Taxonomy in their efforts to regulate automated vehicles. Over the past several years, we have 

seen a number of state proposals using varying definitions for automated vehicles, and in many 

cases these definitions do not account for increased levels of automation. Indeed, in some 

instances the definitions are so poorly constructed that they would unwittingly ban the sale and 

operation of technology in cars on the road today. 

This is why federal leadership on automated vehicle policy is so important. Decisions made 

today will determine how fast and how far our systems evolve, and inconsistent policy 

approaches-particularly as they relate to vehicle characterization, performance, and designcould have significant long-lasting impacts. The federal government must develop a framework 

to encourage the development of highly automated vehicles, and work with state and local 

policymakers to provide guidance and establish clear policy roles and responsibilities. In our 

view, the traditional lanes of federal and state responsibility should apply with respect to 

automated vehicles: the federal government is responsible for safety standards that impact the 

design and performance of motor vehicles while states handle matters such as driver 

responsibility, insurance, and registration. 

We therefore believe that Congress should preempt state laws and regulations that prescribe 

design and performance standards for automated vehicles. This concept is deeply enshrined in 

the structure of the current Motor Vehicle Safety Act, which recognizes the limited role states 

2 
85 


GlobaiAutomakers 0 

play in regulating the safe design of motor vehicles. This structure should be no different for 

advanced motor vehicle safety technologies that rely as much on computer software as they do 

on hardware. State preemption essential to ensure that automakers are not subject to conflicting 

state regulations that will undoubtedly slow the pace of innovation, and limit the ability to 

manufacture vehicles that can operate in all 50 states. 

It is also important for policymakers to recognize that there is an additional aspect of automation 

that needs to be considered in order to support the safety and mobility benefits of these emerging 

technologies: vehicle connectivity. Cars equipped solely with sensors such as radar, LIDAR and 

cameras will have limitations on the way in which they can sense the surrounding environment 

and interact with the vehicles on the road around them. Dedicated Short Range Communications 

(DSRC) supports "vehicle to everything" (V2X) communications, allowing cars to wirelessly 

connect to other road users and the surrounding infrastructure to effectively "see" around corners 

and through vehicles to achieve greater 360-degree situational awareness. DSRC can work alone 

as a sensor to inform or warn the driver to avoid a crash, or it can work in concert with other 

sensors and vehicle systems to support automated driving features, such as cooperative adaptive 

cruise control. 

Soon, we will begin sharing our roads with automated vehicles. DSRC is the code that connects 

the automated vehicle world together-the communication standard that will ensure, regardless 

of mode or automation, vehicles are talking to each other, and that they are speaking the same 

language. This technology is already on the road today and ready for widespread deployment. 

The Department of Transportation has recognized the life-saving potential ofDSRC and has 

issued, with the support of vehicle manufacturers, a proposed rule to create a new safety standard 

that would require new vehicles to be equipped with this technology and transmit a wireless 

basic safety message to support vehicle-to-vehicle (V2V) communications. 

While the V2V rulemaking is a critical step in the right direction, it is important to understand 

that DSRC technology will create a new wireless transportation application ecosystem that will 

enable safer, smarter, and more efficient travel. DSRC operates over the 5.9 GHz spectrum band, 

which is important as it supports the low-latency communications needed for DSRC vehicles to 

speak to each other and the surrounding infrastructure (at the rate often messages per second). 

3 
86 


GlobaiAutomakers 0 

The safety-critical applications in development throughout the DSRC band will support not only 

V2V, but also vehicle-to-infrastructure and vehicle-to-pedestrian communications, as well as 

DSRC applications to support automated features and highly automated driving. Finalizing this 

proposed rule and protecting DSRC from harmful interference in the 5.9 GHz band will provide 

the transportation industry, including original equipment manufacturers and aftermarket 

suppliers, with the necessary federal standards and certainty needed to increase deployments of 

this revolutionary technology. 

Global Automakers and our member companies believe that connected and automated vehicle 

technologies can provide significant benefits. Ifpolicymakers can ensure an environment where 

innovation is permitted to thrive, connected and automated vehicles can truly transform the way 

we move goods and people. Already automated and wireless connectivity have revolutionized 

our economy, and bringing these innovations further into the transportation sector will be no less 

groundbreaking. Congress must work with all stakeholders to ensure that we have consistent 

rules for the deployment of automated and connected vehicles of all levels, and that the 

necessary policies are in place to support continued investment and education so that the labor 

market can adapt over time to support the new jobs and opportunities created by these new 

technologies. 

4 
87 


In the Matter of 

Before the 

DEPARTMENT OF TRANSPORTATION 

National Highway Traffic Safety Administration 

Federal Automated Vehicles Policy Docket No. NHTSA-2016-0090 

COMMENTS OF THE U.S. CHAMBER OF COMMERCE 

TECHNOLOGY ENGAGEMENT CENTER 

Highly Automated Vehicles ("HAYs") have tremendous potential to make our roads 

safer, enhance worker productivity, increase transportation efficiency, and deliver numerous 

other societal benefits. With its deep automobile manufacturing experience and capability along 

with world-leading information, communications, and technology ("ICT") companies, the United 

States has the potential to define and lead this new life-saving innovation and business 

opportunity. NHTSA's recently issued Notice and Request for Comments on the Federal 

Automated Vehicles Policy (the "Guidance") opens the dialogue on the appropriate national 

framework to facilitate the investment and innovation necessary for U.S. companies to claim a 

leadership role in this new era of transportation. The U.S. Chamber of Commerce's Technology 

Engagement Center ("C_TEC") welcomes the opportunity to provide input to NHTSA on this 

important topic. The Chamber established C_TEC to be the face of technology in the economy 

and to advocate for rational policy solutions that drive economic growth, spur innovation, and 

create jobs through the backing of a leading national and global business organization. 

C _ TEC appreciates that the Guidance is just that-guidance seeking voluntary 

cooperation-and not a proposed rule. NHTSA should maintain that status until more is known 

about this new transportation opportunity. As a first principle, C_TEC believes that government 
88 


actions in this new area must be grounded in the realities of the complex and fast-changing HA V 

public testing and development process in order to foster rather than hinder investment and 

innovation. As C _ TEC member Intel recently testified before Congress, "[our] vision for the 

future of transportation is one of zero accidents, mobility for all, environmental sustainability, 

reduced congestion, increased efficiency and innovation that evolves at the pace of technology to 

ensure US. globalleadership."1 

Other agencies recently have faced similar experiences with fast-paced marketplace 

innovation, and NHTSA can learn from their efforts. Specifically, C _ TEC urges NHTSA to 

reference the Federal Aviation Administration's ("FAA") new Small Unmanned Aircraft Rule as 

a guide. 2 The FAA also had the hard job of crafting regulations for a new form of transportation 

still in development. After the agency engaged with manufacturers and other interested parties, 

its final rule, which went into effect this summer, reflects a flexible approach that will allow 

industry to continue testing and developing new forms of transportation and experimenting with 

new operational environments while still promoting safety. In a similar vein, in considering its 

own role NHTSA should have the following goals for the Guidance: it should be supportive of 

innovation and market competition, informed by experts, technologically neutral, and promote 

coordination across the States. 

1 Prepared Statement for the Record oflntel Corporation, U.S. Senate Hearing on "How the 

Internet of Things Can Bring U.S. Transportation and Infrastructure into the 21" Century," at 4 

(J:une 28, 20 16), https://www.commerce.senate.gov/public/ _ cache/files/46c728ce-377e-4060-

9cac-55db2230ddf8/17D 163EB418271 C 1 D3BBC8D572D589EE.doug-davis-testimony.pdf. 

2 See 14 C.F.R. § 107. 

2 
89 


I. The Guidance Raises Critical Questions for Which the Department Should 

Continue to Solicit Expert Feedback 

To aid NHTSA in ensuring HA V safety, the Guidance requests that manufacturers and 

other entities voluntarily submit a Safety Assessment Letter indicating how they have considered 

elements of the Guidance in testing and deploying HA V s. The Safety Assessment proposes to 

cover a wide variety of areas, ranging from technical topics such as data recording and 

cybersecurity to traditional regulatory areas such as registration and certification. 3 C _ TEC 

commends NHTSA for the next steps it has laid out in the Guidance: holding public workshops 

and engaging experts for their review. 4 C_TEC urges NHTSA to work with the broad automated 

vehicle industry in an in-depth manner to clarify elements of the Guidance and determine ifthere 

are alternate solutions to technical issues that would more realistically align with the innovation, 

development, and testing processes for HA Vs. We call particular attention to the following: 

A. Timing 

The Guidance expects that manufacturers and other entities will provide the Safety 

Assessment four months before active public road testing of any new automated feature. 5 

Imposing such an expectation before testing will slow down American companies' development 

of this technology in a fast-paced global HA V market, where new technological developments 

are introduced for public road testing on a daily basis. Both safety and timeliness should be 

critical elements of the Guidance process. 

3 U.S. Department of Transportation and National Highway Traffic Safety Administration, 

Federal Automated Vehicles Policy: Accelerating the Next Revolution in Roadway Safety at 15 

(Sept. 20 16), 

https://www.transportation.gov/sites/dot.gov/files/docs/AV%20policy%20guidance%20PDF.pdf 

("Federal Automated Vehicles Guidance"). 

4 /d. at 34. 

5 !d. at 16. 

3 
90 


B. Data Recording and Sharing 

The Guidance proposes an anonymized data collection and sharing regime, but does not 

consider the difference between different types of data. NHTSA recommends that manufacturers 

and other entities collect data associated with fatalities, injuries, and vehicle damage as well as 

data associated with positive outcomes. Not only should this data be "readily available for 

retrieval by the entity itself and NHTSA," but each company should also "develop a plan for 

sharing its event reconstruction and other relevant data with other entities."6 There are 

significant benefits to data sharing, but in order to promote a voluntary regime that companies 

will follow, they must be balanced against the costs of gathering data and sharing it with 

competitors. Is sharing positive outcome data as beneficial to the industry as a whole as sharing 

crash data? What types of data are proprietary? Would data be shared without repercussions? 

Industry must be further consulted and should lead in the development of any data-sharing plan 

to answer these questions as well as others. 

C. Privacy and Cybersecurity 

NHTSA does not provide prescriptive requirements for privacy and cybersecurity in the 

Guidance. This is the correct approach for several reasons. First, companies in this sector have 

long experience with promulgating privacy policies and best know their relationships with their 

customers. Changes to these policies should be informed by customer expectation and 

technological development. Therefore, companies should lead in developing new requirements, 

as they best understand both the technology they are creating and their customers who will use it. 

Second, with respect to cybersecurity, the Guidance correctly notes that this is an "evolving area 

6 Id. at 18. 

4 
91 


and more research is necessary before proposing a regulatory standard."7 C_TEC actively 

monitors developments in this area, and agrees that implementing in-house cybersecurity 

programs is vital for industry participants. We thank NHTSA for its recognition in the Guidance 

of industry efforts like the Auto Information and Sharing Analysis Center ("Auto-ISAC"). 

II. Pre-Market Approval Would Jeopardize Private Sector Innovation 

In discussing potential new regulatory tools that NHTSA may use in this area, NHTSA 

indicates that it is considering pre-market approval authority. The Guidance acknowledges that 

pre-market approval is not currently part ofNHTSA's authority, and qualifies that its discussions 

of how it could be implemented are preliminary. 8 However, in these preliminary discussions, 

NHTSA not only proposes an inflexible government pre-clearance process, but also suggests that 

as part of this it could implement a "technology-specific process to vehicles that include lower 

levels of automation, below L3-L5.''9 This proposal reflects a misguided policy and a radical 

departure from current practice, and should not progress pass the preliminary stage of discussion. 

First, it is unwise for the Department to adopt a technology-specific process targeted at 

HA Vs. Doing so would run the potential risk ofthe U.S. government indirectly picking 

technology winners and losers by approving one manufacturer's system quickly while delaying 

another's time to market. As C _ TEC and its members have previously emphasized in other 

proceedings, "standards need to be voluntary and carefully designed so they do not constrain 

innovation." 1

° Commenting on the role of government in fostering the advancement of the 

7 ld. at 21. 

8 Jd. at 72-74. 

9 !d. at 72. 

1

° Comments of the U.S. Chamber of Commerce Center for Advanced Technology and 

Innovation, Docket No. 160331306-6306-01 at I 0 (June 2, 2016). The Chamber's Center for 

Advanced Technology and Innovation is C _ TEC's predecessor. 

5 
92 


Internet of Things, C_TEC member Qualcomm noted that "much is unknown about the future 

uses" of that technology. 11 The same is true ofHA Vs. "For this reason, the U.S. Government 

should tread very carefully in the legislative and regulatory space to let any and all innovative, 

and potentially ground-breaking, technologies be freely developed." 12 Technological neutrality 

will benefit consumers, who will receive the benefits of new technologies faster, and American 

manufacturing, which will be able to flex its muscles and develop devices, applications, and 

services that are currently unimagined. 

Second, and in a similar vein, pre-market approval could harm competition. IfNHTSA 

were not up to speed on the newest technologies-an expertise that would be difficult for the 

agency to grow and maintain, given the fast pace of the industry innovation-it could prevent 

new life-saving technologies from entering the marketplace and even risk negative impact on one 

company's competitiveness or in fact the whole U.S. industry's competitiveness. A responsive 

and flexible regulator gives manufacturers the ability to quickly perfect critical new tools, both 

protecting consumers and keeping the industry competitive. 

Third. NHTSA has failed to justify a radical departure from its current self-certification 

and compliance testing process. That process, coupled with NHTSA's safety programs and 

general regulatory authority, has been in place for many years and, as the Guidance proudly 

proclaims, is "responsible for saving hundreds of thousands oflives." 13 The Guidance fails to 

explain why the new technologies surrounding HA V s justifY such a radical change from this 

long-standing and successful process. As has long been the practice, the government should 

11 Comments ofQualcomm Inc., Docket No. 160331306-6306-01 at 16 (June 2, 2016). 

12 Id 

6 
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consider defining objective performance standards for automobiles, and leave to manufacturers 

the important job of meeting those obligations and certifying compliance. 

III. Consistent State Laws and Clarity in Interpretation of Federal Laws Are Beneficial 

to Innovation 

The Guidance speaks both to proposed state laws and enforcement of federal laws. 

While C_TEC commends NHTSA on its proposed model state policy, we raise several issues 

concerning statements in the Guidance regarding existing federal laws and regulations. NHTSA 

proposes a model state policy that, if adopted, would create a "consistent, unified national 

framework for regulation of motor vehicles with all levels of automated technology, including 

HA V s." 14 C _ TEC strongly supports this goal and welcomes the formation of a NHTSA working 

group for information sharing with states engaged on HAY issues. Avoiding a patchwork of 

state laws enables manufacturers to be more innovative and ensures that any safety-enhancing 

automated vehicle technologies will be available throughout the country. 

Additionally, NHTSA should have a consistent message that the voluntary guidance is 

not a set of objective tests or criteria to which HA V s should certify. To effectively support the 

development of HAYs and the safety benefits they will bring, it is important to avoid creating 

conflicts between NHTSA's role as regulator of vehicle safety performance and the states' 

interests in advancing the safe operation of vehicles on their roadways. Section II ofthe 

Guidance suggests a pre-approval approach for the use ofHA Vs within the states, which may 

have the potential to encourage states to regulate the safety equipment of HAYs. We disagree 

with state-level pre-approval of vehicle safety performance because it would create conflicts 

13 Federal Automated Vehicles Guidance at 5. 

14 /d. at 37. 

7 
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between NHTSA's role and the states' role and cause state laws and regulations to be 

unnecessarily complex, time consuming, and costly. 

The Guidance also addresses NHTSA's enforcement authority, both existing and 

proposed. NHTSA has streamlined and expedited its process for evaluating and responding to 

information requests-a simple interpretation request that appears to improve safety and follows 

the Guidance will receive a response within 60 days, while a more complex request will receive 

a response within 90 days. 15 Similarly, NHTSA has expedited its process for exemptions and 

has committed to grant or deny petitions within six months. It has also proposed that Congress 

lift exemption limits (vehicle volume and time) on innovative HAY safety technologies. C_TEC 

welcomes these expedited "shot clocks" for agency action and revisions to remove unnecessary 

regulatory burdens. They are especially important in this fast-moving and competitive sector, 

and as we move forward to a new Administration routine agency actions should not be delayed. 

Somewhat troubling are the vague statements in the Guidance concerning NHTSA's 

enforcement authority. The Guidance states that NHTSA has "broad enforcement authority 

under existing statutes and regulations to address existing and emerging automotive 

technologies." 16 NHTSA made the same statement in its recent Enforcement Guidance Bulletin, 

which post-dates the Federal Automated Vehicle Guidance. 17 In that Bulletin, NHTSA stated 

that its "enforcement authority concerning safety-related defects in motor vehicles and motor 

15 Id. at 54. 

16 Id. at 50. 

17 See NHTSA Enforcement Guidance Bulletin 2016-02: Safety-Related Defects and Automated 

Safety Technologies (Sept. 20, 2016), 

https://www .transportation.gov /sites/dot.gov /files/docsll 2507-A V _site _FedReg_ Final-DefectsAuthority-Enforcement-Bulletin_ 20 I 6.0 .... pdf. 

8 
95 


vehicle equipment extends and applies equally to current and emerging safety technologies." 18 

NHTSA acknowledged that the increased use of"electronic systems (such as hardware, software, 

sensors, global position systems (GPS) and vehicle-to-vehicle (V2V) safety communications 

systems) ... may raise new and different safety concerns," but stated that this does not limit 

NHTSA's authority. 19 

The proposals outlined in the Guidance should only focus on the upper levels of 

automation (i.e., L3-L5). Lower levels of automation are currently in the marketplace, have a 

proven success in helping consumers avoid accidents, and are currently regulated by NHTSA 

through its existing investigation and defect authority. C_TEC respects the role NHTSA has 

played in motor vehicle safety for nearly 50 years. With respect to upper levels of automation, 

we urge NHTSA to consider that regulation in this area may need to proceed differently than in 

the past. For example, HA V manufacturers can now push software updates to their customers 

over the air. Would NHTSA hold these fixes back from consumers until it analyzed them with a 

simulator? Inserting a period of delay before a software fix can be deployed is contrary to public 

safety and eliminates the very safety benefit the ability to remotely receive a software update 

creates. NHTSA itself admits that "[g]iven the newness ofHA V s and the private sector demand 

for persons with the necessary types of scientific expertise to work with those technologies, there 

is a shortage of suitable candidates to meet the Agency's critical hiring needs." 20 Moreover, 

because NHTSA may require additional expertise--particularly with respect to hardware and 

software development--C _ TEC urges the Office of Personnel Management to work with 

18 !d. 

19 !d. 

2

° Federal Automated Vehicles Guidance at 82. 

9 
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NHTSA on providing the agency with the special hiring tools necessary to source adequate 

industry expertise. 

IV. Conclusion 

Automated vehicle technology and self-driving cars have the power to change our 

economy and society in positive ways that we cannot even conceive of now, potentially creating 

benefits both for consumers and American industry. But this technology will only be able to 

flourish to its fullest extent if industry is allowed to safely develop, experiment, and test without 

being slowed by burdensome regulation. We urge this and the next Administration to utilize a 

flexible and rational guidance approach that aligns with the realities of the innovation 

development and testing process, so that America may lead the world in this highly C<lmpetitive, 

life-saving automotive evolution. 

November 22,2016 

10 

Respectfully submitted, 

Is! 

Tim Day 

Senior Vice President, C_TEC 

U.S. CHAMBER OF COMMERCE 

1615 H Street, NW 

Washington, DC 20062-2000 
97 


Statement of American Car Rental Association 

House Energy and Commerce Committee's 

Subcommittee on Digital Commerce and Consumer Protection 

Hearing on 

"Self-Driving Cars: Levels of Automation" 

March 28,2017 

The American Car Rental Association (ACRA) respectfully submits this statement for the record 

of the House Energy and Commerce Committee's Subcommittee on Digital Commerce and 

Consumer Protection's hearing on "Self-Driving Cars: Levels of Automation" on Tuesday, March 

28,2017. 

ACRA is the national representative for over 98% of our nation's car rental industry. ACRA's 

membership is comprised of over 300 car rental companies, including all of the brands you would 

recognize such as Alamo, Avis, Budget, Dollar, Enterprise. Hertz, National and Thrifty. ACRA 

members also include many system licensees and franchisees mid-size, regional and independent 

car rental companies as well as smaller, "mom & pop" operators. ACRA members have over two 

million registered vehicles in service, with fleets ranging in size from one million cars to ten cars. 

ACRA ·s members strongly support the development and gradual deployment of "llighly 

Automated Vehicles" (!lAYs) to improve transportation safety and reduce property damage and 

personal injury and deaths associated with vehicle accidents. However, the introduction of! lAYs 

is a complex technical and public policy challenge. This challenge will require policymakers to 

address and incorporate existing safety, consumer protection. privacy and liability issues into a 

changing vehicle populations that includes HAYs-- while at the same time maintaining flexibility 

to accommodate new and evolving legal issues unique to HA Vs that may not be apparent today. 

The members of the American Car Rental Association (ACRA) purchase one out of every nine 

new cars sold in the United States each year- almost 2 million vehicles in 2016. To the extent 

that HAYs are introduced into the private passenger motor vehicle fleet in the next decade, ACRA 

1 
98 


members will be at the forefront ofHA V deployment and on the front lines of the education of car 

rental customers with respect to interacting with HAYs safely. 

The Promise and Challenges of Antonomons Vehicles- The widespread introduction ofHA Vs 

promises to reduce the number of deaths (about 40,000/year in the United States) and injuries 

(hundreds of thousands every year in the United States) caused by motor vehicle accidents- over 

90 percent of which are caused by human error. But this promise is not without challenges in 

many complex areas, including thorny public policy issues that have been debated by many 

interested parties for decades, including: 

• Liability- Federal and State liability statutes generally hold the driver of a motor vehicle liable 

for injuries and property damage caused by that driver's negligence. With respect to HAYs, 

there is no "driver" per se and thus determining responsibility for injuries and other harm 

become problematic. Federal and State policymakers should consider assigning liability for 

accidents caused by HA Vs to the entities most capable of addressing design and functionality 

shortcomings in HA VS- in most cases, the vehicle and software designers and manufacturers, 

rather than the humans occupying the vehicle or the fleet owners. 

• Ownership of Motor Vehicles- As we move towards an era of widespread HA V deployment, 

our notions of motor vehicle ownership likely will undergo a revolutionary change. Instead of 

owning our personal automobile, or renting a minivan for a family vacation, or boarding a bus 

for a ride to school, or hailing a taxi all of these activities may be undertaken with different 

types of HAYs which may or may not be owned by an individual, a school district, or a fleet 

operator. Resolving vehicle ownership issues, including maintenance, accident reporting, data 

recording and sharing, and other heretofore unaddressed issues with respect to HA V s will need 

to be discussed and resolved. 

• Taxes and Fees- HAYs hold the promise of eliminating distinctions between rental cars, 

taxis, ride-hailing services and individual motor vehicle ownership. With the introduction of 

HAYs, responsibilities must be apportioned for paying Federal and State motor fuel excise 

taxes, State and Local fees on car rentals, ride-hailing services and taxis, and State and Local 

vehicle registration and sales taxes. 

• Harmonization - The customers of ACRA members cross state lines in their current rental 

cars without restrictions and likely will anticipate the ability to do the same with respect to 

HAYs rented from ACRA members. As a result, a myriad of complex and perhaps 

contradictory State laws or regulations with respect to technical, safety or operational standards 

for HAYs should be avoided wherever possible. Continued State regulation of HAYs in 

traditional areas such as licensing, registration and insurance requirements would not in most 

instances pose impediments to the introduction of HAYs in ACRA's opinion. 

• Privacy- Federal and State regulators have started to wrestle with the difficult challenges of 

maintaining individual privacy with respect to data generated by today's increasingly complex 

and technologically advanced motor vehicles and promoting transportation safety and 

enforcement of Federal and State laws. Such thorny privacy issues will only be multiplied 

with HAYs, and ACRA urges policymakers to preserve the right of vehicle owners to control 

and own the data generated by HAYs. 

2 
99 


• CVbersecurity - The increased automation of motor vehicles, leading ultimately to 

deployment of HAYs, heightens the risk of cyber-attacks on single cars or groups of vehicles. 

Such risks must be managed by vehicle manufacturers and designers. However, the same 

technology that opens HAYs to cyber-attacks may hold the promise of reducing motor vehicle 

theft and other crimes involving vehicles. The cybersecurity issues related to HAYs must be 

balanced between protection of the vehicle's occupants and aiding law enforcement agencies 

in crime prevention and the apprehension of criminals. 

Thank you for the opportunity to present this statement for the record at this hearing. ACRA stands 

ready to work with the members of the Subcommittee and all State and Federal legislators and 

regulators, as well as the many stakeholders interested in the development and introduction of 

HA V s, in the months and years ahead. 

Please contact Greg Scott with questions regarding ACRA's HA V development and deployment 

positions at 202-297-5123 or gscott@merevir.com. 

3 
100 


Statement for the Record 

Dan Galves, Senior Vice President, Chief Communications Officer 

Mobileye 

U.S. House of Representatives 

Committee on Energy and Commerce 

Subcommittee on Digital Commerce and Consumer Protection 

"Self-Driving Cars: Levels of Automation" 

Tuesday, March 28, 2017 

Dear Chairman Latta, Ranking Member Schakowsky, Members of the Subcommittee, thank you 

for holding a hearing on this important topic and for the opportunity to share my views with you. 

Mobileye is a global leader in vision technology for advanced driver assistance systems (ADAS) 

and autonomous driving. Our core mission is to save lives and prevent injuries by reducing 

vehicle collisions. 

Our ADAS technology (Level 1 and Level2) is adopted by most of the world's major auto 

manufacturers and there are currently over 15 million vehicles on the road that utilize Mobileye 

te'chnology. In addition to our technology being installed by the auto manufacturers at the factory 

level, Mobileye also offers aftermarket ADAS products which can be installed in any vehicle, 

making it an ideal solution for fleets looking to improve safety. 

Beyond ADAS, which purpose is to avoid and/or mitigate vehicle collisions, Mobileye 

technology is being used by a variety of automakers as an important enabler for future Level 3-5 

autonomous vehicles. These include a Level 3 program with Audi where production vehicles are 

expected to launch in second half of2017, a Level4 program with BMW to be launched in 2021, 

and a partnership with Delphi Automotive to create a Level 4 autonomous platform for use by 

many automobile manufacturers by 2019. 

Mobileye's technology is centered around proprietary software algorithms deployed on a family 

of proprietary computer chips called EyeQ®. The technology turns raw camera data into usable 

information that a vehicle system can use to enhance safety and eventually, we believe, to drive 

autonomously. The technology performs detailed interpretations ofthe visual field in order to 

anticipate collisions with other vehicles, pedestrians, animals, debris, and other obstacles. Our 

products are also able to detect roadway markings such as lanes, road boundaries, barriers, and to 

read traffic signs and traffic lights. These products are validated by Mobileye and its customers 

to the highest level of accuracy and automotive-grade standards and have been proven over 

millions of miles of real-world driving conditions. 

Mobileye's unique capability focuses on interpreting data from a camera fitted onto vehicles. 

We'd note that Mobileye has been able to demonstrate fulfillment of all ADAS functions with 

high accuracy through a single monocular camera sensor configuration, thereby reducing cost 
101 


and simplifYing tooling and packaging within the vehicle. For Level 3-5 vehicles, other sensors 

like radar and lidar will be necessary for redundancy; however, only a camera can identify both 

shape (i.e. vehicles, pedestrians, general objects, etc.) and texture (traffic sign text, lane 

markings, subtle road boundaries, traffic lights, etc.) which leads us to believe that camera will 

be the primary sensor in Level 3-5 vehicles. 

The Problem 

According to the U.S. Department of Transportation's National Highway Traffic Safety 

Administration, 35,092 people died and 2,443,000 were injured as a result of vehicle collisions 

on United States roads in 2015. 1 The number of deaths has increased by 7.2 percent from the 

previous year, the highest increase in over fifty years. Over 90 percent of vehicle collisions are 

attributed to human factors, including distracted driving, fatigue and drunk driving. 

Moreover, according to a Boston Consulting Group (BCG) report titled A Roadmap to Safer 

Driving Through Advanced Driver Assistance System, "the cost [of vehicle collisions] to society 

totals about $910 billion annually, equivalent to roughly 6 percent of U.S. GDP." The BCG 

report further states that ADAS technologies alone have the potential to prevent 30 percent of all 

crashes, and together with fully autonomous vehicles, vehicle collisions could be reduced by 90 

percent.2 

We at Mobileye believe that the number of deaths and injuries caused by vehicle collisions is 

unacceptable and are working hard to significantly reduce and/or mitigate collisions through our 

investment in and development of innovative ADAS and autonomous vehicle solutions. 

Different Levels of Automation 

Mobileye's ADAS technologies--those installed by auto manufacturers at the factory as well as 

our aftermarket products--significantly reduce vehicle collisions, saving lives, preventing 

injuries, and reducing costs associated with collisions. There are also notable improvements in 

driver behavior which appear to result in substantial reductions in fuel consumption. 

As Mobil eye continues to innovate and deploy its ADAS technology, the company is leading the 

efforts in autonomous vehicle innovation and development. 

There are five generally accepted levels of automation. 

~ 

• No automation. The human driver is in control. This includes the majority of vehicles on 

the road today. 

1

https://crashstats.nhtsa.dot.gov/ Api/Public/ViewPublication/812318? ga= 1.154839546.33277525.1477595715 2 https://www.mema.org/sites/default/files/MEMA %20BCG%20ADAS%20Report.pdf 
102 


Levell and Level2: Advanced Driver Assistance Systems 

• Some automated features are introduced, like automatic braking, stability control 

and cruise control, bnt a human is still in charge. Level I means the car can only work 

one automated system at a time, while Level 2 means that multiple automated 

functionalities can work in tandem. For example, Automatic Emergency Braking (AEB) 

plus Lane Keeping Assist (LKA). 

• Mobileye technology supports many Level2 systems on the road today. In 2018, 

introduction ofEyeQ®4, the tri-focal lensed camera, and higher complexity algorithms 

will result in substantially higher ADAS functionality, as well as initial Level 3 systems. 

Level3 through Level 5: Autonomous Driving 

Level3- Autonomous Under Certain Circumstances 

• Level 3 automation means the vehicle can take over all driving functions under 

certain circumstances. The less-complex highway environment (all vehicles moving in 

the same direction, no pedestrians, no complex intersections) is the most logical 

circumstance. 

• All major functions are automated, including braking, steering, and acceleration. At this 

level, the driver can fully disengage until the vehicle tells you otherwise. This is 

where the vehicle crosses into true "autonomous capability," and when technology begins 

to enable substantial benefits beyond safety, such as increased productivity. 

• Going from Level 2 to Level 3 requires substantial increases in functional safety levels 

and system redundancies. In certain circumstances, the vehicle will need to ask the driver 

to re-engage. Since the driver cannot be assumed to take control instantaneously, the 

system will need to ensure safety for a period of time when the driver is still not engaged 

(for example, to pull over and stop if the driver does not respond to repeated requests to 

re-engage). 

• Mobileye expects this additional redundancy to be covered by additional sensors like 

radar and lidar (for shape and object detection) and by Mobileye's REMTM localization 

map for identification of safe drivable paths and knowledge of intersections and other 

traffic signage or instructions. 

Levels 4 & Level 5- Fully Autonomous 

• Level 4 and Level 5 vehicles are autonomous in all situations and driving 

environments, not just "under certain circumstances," as in Level 3. 

• In Level 4 there does not have to be a driver because the vehicle is prepared for every 

situation and the human has moved from being the driver to just a passenger. Level 5 

vehicles will not have a steering wheel or other human-used vehicle controls. 

• We believe the initial deployment of this technology will be for "ride-sharing" fleets 

within confined areas. 

• Driverless vehicles make the ride-share model much more cost-effective and compelling, 

as they eliminate the biggest cost ofride-share fleets: the driver. Initial deployment into 

ride-share fleets brings two other significant benefits: We expect initial usage will include 

a trained operator in the driver seat, to enable consumers to gain experience with the 

technology with the assurance of a trained operator monitoring the situation, and the 
103 


ability to generate real-world performance data in a safe way. Once enough data is 

generated, we would expect the regulatory framework to approve widespread usage. 

• By using our crowdsourced REMTM Roadbook technology, the move from "somewhere" 

autonomy to "everywhere" autonomy is simply a switch of a button because the maps 

will be continuously updated everywhere, not only in confined, geo-fenced areas. 

• Eventually, we will see auto companies scale-up from ride sharing to "shared ownership" 

where people and organizations share ownership of a car that can drive anywhere. This is 

even more transformative than ride sharing because it opens up completely new business 

models for transportation. 

• In 2016 Mobileye announced its partnership with BMW and Intel intending to bring a 

fully autonomous vehicle into serial production by 2021. 

• Also in 2016, Mobileye announced a partnership with Delphi Automotive to produce a 

turnkey autonomous driving system designed for rapid adoption by a variety of 

automakers. 

Mobileye has ADAS programs with more than 25 automakers around the world, 5 programs for 

Level3 Semi-Autonomous, and 5 programs for Level4 Autonomous Vehicles, including with 

BMW and Delphi. 

Path Forward 

Autonomous vehicles and the benefits they will provide through reducing collision-related 

deaths, injuries, cost, and enhancing mobility to underserved communities such as the elderly 

and physically disabled individuals, are immense. Mobileye is fully committed to the vision of 

autonomous vehicles and are one of the leading companies working on making it a reality. 

However, we have some years to go before fully autonomous vehicles are ubiquitous on U.S. 

roads and there is much more that can and should be done to save lives today without waiting for 

fully autonomous vehicles. 

ADAS technologies already exist and have proven to significantly reduce collisions. Adoption 

rates are increasing but can and should be expedited with the help of prudent policy initiatives. 

Every day that goes by over 90 lives are lost in the U.S. due to vehicle collisions. Many lives can 

be saved by using ADAS technologies available today. It is simply unacceptable to not use 

proven technologies that are readily available today. 

Moreover, ADAS technologies being used in vehicles today serve as fundamental building 

blocks for autonomous vehicles of tomorrow. They are paving the way towards autonomy in 

terms of technology validation and public perception and acceptance, all of which will be critical 

to the safe and widespread deployment of autonomous vehicles. 

Policy Recommendations 

ADAS and autonomous vehicle technologies could significantly decrease the number of vehicle 

collisions caused by human factors, reducing the amount of deaths and injuries. Legislators and 
104 


regulators can and should play an important role in expediting the adoption of these 

technologies. 

I) NHTSA should update and strengthen U.S. New Car Assessment Program (NCAP) 

standards to give ADAS technologies greater weight. To receive credit, ADAS 

technologies should be included in the standard fit of a new vehicle similar to seat belts, 

front airbags, and anti-lock brakes, not as optional equipment. The features must also 

verifiably meet the highest standards. Technologies that do not meet these standards 

should not receive credit under the system. 

2) Federal Motor Carrier Safety Administration (FMC SA), should expedite the development 

and implementation of its "Beyond Compliance" program, as directed by the FAST Act, 

providing credits to motor carriers who take concrete safety measure, including the 

installation of advanced safety equipment. 

3) The U.S. government should lead by example in promoting road safety by adopting 

ADAS technologies on government owned vehicles. For instance, USPS is about to 

replace its aging fleet with up to 180,000 new delivery vehicles. This and other vehicle 

procurements for government departments and agencies should require that ADAS 

technologies be included with the new vehicles. Vehicles that will be on the road for 

years to come and don't have ADAS technology should be equipped with aftermarket 

ADAS products. 

4) Policymakers should implement a federal tax incentives program to encourage greater 

and faster adoption of ADAS technologies. At the very least, trucks carrying hazardous 

materials and other higher-damage risk vehicles should receive financial incentives to 

expedite adoption of ADAS technologies. 

5) Auto manufacturers should be allowed to usc ADAS features to meet Corporate Average 

Fuel Economy (CAFE) standards. 

6) Policymakers should establish a single national standard for autonomous vehicle safety, 

preventing a patchwork of state laws. A patchwork of laws could prohibit autonomous 

vehicles from traveling from one state to another, stifling investment, innovation and 

deployment of these much-needed technologies. 

Thank you again for holding this important hearing and for allowing Mobileye to submit this 

statement for the record. 
105 


epic.org 

March 27, 2017 

The Honorable Robert Latta, Chairman 

Electronic Privacy Information Center 

1718 Connecticut Avenue NW, Suite 200 

Washington, DC 20009, USA 

The Honorable Janice Schakowsky, Ranking Member 

U.S. House Committee on Energy and Commerce 

Subcommittee on Digital Commerce & Consumer Protection 

2125 Rayburn House Office Building 

Washington, DC 20515 

Dear Chairman Latta and Ranking Member Schakowsky: 

'- +1 202 483 1140 

tEji +1 202 483 1248 

'!i1 @EPICPrivacy 

I® https://epic.org 

For today's hearing on "Self-Driving Cars: Levels of Automation," 1 we write to you 

again regarding the privacy and safety risks of self-driving vehicles. For more than a decade, 

EPIC has warned federal agencies and the Congress about the growing risks to privacy resulting 

from the increasing collection and use of personal data concerning the operation of motor 

vehicles.' In recent years, we have become increasingly aware of the threat to public safety of 

Internet-connected vehicles 3 

This past weekend, Uher suspend the company's self-driving cars program in Arizona 

after one of their vehicles was in an accident with a traditional car in Arizona.4 The Uher vehicle, 

1 Self-Driving Cars: Levels of Automation before the House Committee on Energy & Commerce, 

Subcommittee on Digital Commerce and Consumer Protection, 

https://encrgycommerce.housc.gov/hearings-and~votes/hearings/self~driving-cars-levels-automation. 

2 EPIC, Comments, Docket No. NHTSA-2002-13546 (Feb. 28, 2003), available at 

https://epic.org/privacy/drivcrs/edr comments.pdf("Thcre need to be clear guidelines for how the data 

can be accessed and processed by third parties following the use limitation and openness or transparency 

principles."); EPIC, Comments on the Benefits, Challenges, and Potential Roles for the Government in 

Fostering the Advancement of the Internet of Things, Docket No. 160331306-6306-0 I (June 2, 20 16), 

available at https://epic.org/apalcomments/EPIC-NTIA-on-IOT.pdf; EPIC, Comments on Federal Motor 

Vehicle Safety Standards: "Vehicle-to-Vehicle (V2V) Communications," Docket No. NHTSA-2014-0022 

(Oct. 20, 2014), available at https://epic.org/privacy/edrs/EPIC-NHTSA-V2V-Cmts.pdf; EPIC, 

Comments on the Privacy and Security Implications of the Internet of Things (June 1, 2013), available at 

https:l/epic.org/privacy/ftc/EPIC-FTC-loT-Cmts.pdf; EPIC et al., Comments on the Federal Motor Safety 

Standards; Event Data Recorders, Docket No. NHTSA-20 12-0177 (Feb. 11, 20 13), available at 

https:l/epic.org/privacy/edrs/EPIC-Coa1-NHTSA-EDR-Cmts.pdf; EPIC, Comments, Docket No. NHTSA2004-18029 (Aug. 13, 2004); available at https://epic.org/privacy/drivcrs/edr_comm81304.html. 3 Statement ofKhaliah Barnes) hearing on the Internet of Cars before the House Committee on Oversight 

and Government Reform, Nov. 18, 2015, https://cpic.org/privacy/edrs/EPIC-Connccted-Cars-TestimonyNov-18-20 15.pdf; Statement of EPIC, hearing on Self-Driving Cars: Road to Deployment before the 

House Committee on Energy and Commerce, Subcommittee on Digital Commerce & Consumer 

Protection, Feb. 14, 20 I 7, http://docs.house.gov/meetings/IF/IF17 /20170214/1 05548/HHRG-115-IF 17-

20170214-SD012.pdf. 

4 Mike Isaac, Uber Suspends Tests of Self-Driving Vehicles After Arizona Crash, New York Times, Mar. 

25, 201 7, https:/ /www.nytimes.com/20 17 /03/25/business/uber-suspends-tests-of-self-driving-vehiclesEPIC Letter to House Energy & Commerce I Self-Driving Cars: Levels of Automation 

Subcommittee on Digital Commerce & Consumer Protection March 28, 2017 

Defend Privacy. Support EPIC. 
106 


had a person in the driver's seat but was in self-driving mode, presumably "Level3." The 

accident with the Uber vehicle highlights the risks of the self-driving mode as well as the dangers 

of having vehicles on the road with traditional vehicles. 

This is not the first accident involving an autonomous vehicle. Late last year, a selfdriving car failed to stop at a red light at a busy intersection.5 A Tesla owner was recently 

involved in an accident when the autopilot failed recognize a lane shift in a construction zone, 

resulting in a collision with a construction barrier.6 

These accidents should alarm the Subcommittee and the public, but they are only one of 

myriad issues with autonomous vehicles. Wide-scale malicious automobile hacking is no longer 

theoreticaC Although a full-scale remote car hijacking is certainly a serious risk to car owners 

and others,8 hijacking is not the only risk posed by connected car vulnerabilities.9 Connected cars 

leave consumers open to car theft, data theft, and other forms of attack as well. These attacks are 

not speculative; many customers have already suffered due to vulnerable car systems. 

For example, criminals have exploited vulnerabilities in connected cars to perpetrate car 

"ransomware" scams, "where a car is disabled by malicious code until a ransom is paid." 10 

According to one expert, computer criminals have installed malicious software in cars via USB 

drives used by mechanics for diagnostics and software updates. The software shuts down, or 

"bricks," the car unless and until the driver meets the criminal's demands. The expert even 

discovered a case where an entire fleet of vehicles was disabled by ransomware. She warns that 

criminals can also infect a car with mal ware remotely over the car's wireless connection. 11 

Car manufacturers should adopt data security measures. Early mitigation of threats to 

public safety may reduce auto fatalities, spur innovation, and result in safer vehicles. 12 

aftcr-arizona-crash.html; Steven Overly, Uber Self-Driving Car Flipped On Side In Arizona Crash, 

Chicago Tribune, Mar. 25, 2017, http://www.chicagotribune.com/bluesky/technology/ct-uber-selfdriving-car-crash-20170325-story.html. 

5 Mike Isaac & Daisuke Wakabyashi, A Lawsuit Against Uber Highlights the Rush to Conquer Driverless 

Cars, New York Times, Feb. 24,2017, https://www.nytimes.com/2017/02/24/technology/anthonylevandowski-waymo-uber-google-lawsuit.html. 

6 Antti Kautonen, Tesla Driver Blames Autopilot for Barrier Crash, Autoblog, Mar. 3, 2017, 

http :1/www .autoblog. com/20 I 7/03/03/tesla-autopilot-barrier-crash/. 7 Brief of Amicus Curiae EPIC, Cahen v. Toyota Motor Corporation, No. 16-15496 (9th Cir. Aug. 5, 

20 16), available at https://epic.org/amicus/cahen/EPIC-Amicus-Cahen-Toyota. pdf. 8 See, e.g., Andy Greenberg, Hackers Remotely Kill a Jeep On the Highway-With Me in It, Wired (July 

21, 20 15), https://www. wired.com/20 15/07/hackers-remotely-kill-jeep-highway/. 9 See Bruce Schneier, The Internet of Things Will Turn Large-Scale Hacks Into Real World Disasters, 

Motherboard (July 25, 2016), http://motherboard.vice.com/read/the-intemet-of-things-will-cause-the-firstevcr-large-scale-intemct-disastcr (explaining that information systems face three threats: theft (i.e. loss of 

confidentiality), modification (i.e. loss of integrity), and lack of access (i.e. loss of availability)). 10 Nora Young, Your Car Can be Held for Ransom, CBCradio (May 22, 2016), 

http://www.cbc.ca/radio/spark/32 1 -life-saving-fonts-ransomware-cars-and-more-1.3584113/your-car-canbe-held-for-ransom-1.3584114. 

II Id 

12 See generally, Ralph Nader, Unsafe at Any Speed (1965). 

EPIC Letter to House Energy & Commerce 2 Self-Driving Cars: Levels of Automation 

Subcommittee on Digital Commerce & Consumer Protection March 28, 20 17 
107 


EPIC urges this subcommittee to take these accidents and security flaws into account as 

you examine the various levels of automation in these vehicles. In addition to the substantial 

privacy concerns that these new cars present, 13 these recent incidents show that there are 

substantial safety concerns to everyone on the road. 

Several states have recognized the risks to their residents and have passed laws regulating 

connected vehicles. 14 But consumer nationwide deserve protection. National minimum standards 

for safety and privacy are needed to ensure the safe deployment of connected vehicles. 

We ask that this letter be entered in the hearing record. EPIC looks forward to working 

with the Subcommittee on these issues. 

Sincerely, 

Jvlarc 'Roten6ern 

Marc Rotenberg 

EPIC President 

Caitriona fitzeera{c[ 

Caitriona Fitzgerald 

EPIC Policy Director 

:Kim Jvli{{er 

Kim Miller 

EPIC Policy Fellow 

13 8 U.S. Gov. Accountability Office, GA0-14-649T, Consumers' Location Data: Companies Take Steps 

to Protect Privacy, but Practices Are Inconsistent, and Risks May Not be Clear to Consumers (2014), 

http://gao.gov/products/GA0-14-649T; Jeff John Roberts, Watch Out That Your Rental Car Doesn't Steal 

Your Phone Data, Fortune, Sep. 1, 2016, http:/ifortune.com/2016/09/01/rental-cars-data-theft/. 14 Nat'! Highway Traffic Safety Admin., Federal Automated Vehicles Policy (Sep. 2016), 

https://www.transportation.gov/sites/dot.gov/files/docs/AV%20policy%20guidance%20PDF.pdf; Ark. 

Code§ 23-112-107; Cal. Veh. Code§ 9951; Colo. Rev. Stat.§ 12-6-401,-402, -403; Conn. Gen. Stat.§ 

14-164aa; Del. Code§ 3918; Me. Rev. Stat. Ann. tit. 29-A §§ 1971, 1972, 1973; Mont. Code§ 61-12-

1001 ct seq.; Nev. Rev. Stat.§ 484D.485; N.H. Rev. Stat.§ 357-G:l; N.J. Stat.§ 39:10B-7 et seq.; N.Y. 

Veh. & Traf. Code§ 416-b; N.D. Cent. Code§ 51-07-28; Or. Rev. Stat.§ 105.925 et seq.; Tex. Transp. 

Code§ 547.615; Utah Code§ 41-la-1501 et seq.; Va. Code§§ 38.2-2212(C)(s), 38.2-2213.1,46.2-

1088.6, 46.2-1532.2; Wash. Rev. Code §46.35.010. 62 Va. Code Ann.§ 38.2-2213.1 (West). 

EPIC Letter to House Energy & Commerce 3 Self-Driving Cars: Levels of Automation 

Subcommittee on Digital Commerce & Consumer Protection March 28, 2017 
108 


March 28,2017 

The Honorable Robert Latta, Chairman 

Subcommittee on Digital Commerce and Consumer Protection 

2125 Rayburn House Office Building 

Washington, DC 20515 

The Honorable Janice Schakowsky, Ranking Member 

Subcommittee on Digital Commerce and Consumer Protection 

2322A Rayburn House Office Building 

Washington, DC 20515 

Dear Chairman latta and Ranking Member Schakowsky, 

HONDA 

Honda North America, Inc. 1001 G. Street, N.W. Suite 950 

Washington, DC 20001 

Phone (202) 65i·4400 

Thank you for this opportunity to share Honda North America, Inc.'s (Honda) views on the "Self-Driving 

Cars: Levels of Automation" hearing. Honda envisions a future society that enjoys a zero-collision 

mobility experience for all road users. Incremental steps towards automation are important in reaching 

this goal to ensure the technology is safely deployed and widely accepted and utilized by consumers. 

Honda has been investing and manufacturing in the U.S. for more than 40 years. This includes $27 billion 

in parts and materials from 610 U.S. suppliers and Honda has Invested $3.4 billion In Its U.S. factories 

over the past four years alone. Our 12 manufacturing plants produce passenger vehicles, power 

equipment, and power sports products. The U.S. also hosts the global headquarters for HondaJet. 

Honda directly employs 30,000 Americans and has never laid off a permanent associate. 

The auto industry is on a path toward widespread use of highly automated (autonomous) vehicles, and 

the SAE levels of automation outline steps along that path. Enabling progression along that path is the 

advent and increased use of connected vehicles. The enhanced situational awareness resulting from 

connections between vehicles, vehicles and pedestrians, vehicles and Infrastructure, and vehicles and 

other road users, also known as V2X technology, is vital to reach the full safety benefit of automation. 

In order to immediately reap the benefits of V2X technology, it is vital to ensure that Dedicated Short 

Range Communications (DSRC) technology is used as a shared platform by all road users. DSRC has the 

capability to expand a car's situational awareness, reducing or eliminating automobile crashes, and 

ultimately, saving lives. This is achieved by both expanding the operational range of vehicle based 

sensors and by providing important redundancies in algorithm based decision-making. 

DSRC, developed to operate In the 5.9GHz Safety Spectrum, will provide a consistent, reliable platform 

for these life-saving technologies. We commend NHTSA for putting forth an NPRM to ensure that all 

vehicles include this common technology platform. Moreover, most of the auto industry stands ready to 

invest in DSRC once the rule Is finalized and there is regulatory certainty for ail vehicles. 

Honda has several technologies under development for deployment using the 5.9GHz Safety Spectrum 

today, however deployment is delayed due to the lack of confidence in the priority status for DSRC 
109 

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HONDA NORTH AMERICA, INC.- PAGE 2 

technology on that spectrum which is currently under deliberation at the Federal Communications 

Commission. We must be able to provide these technologies to our consumers with complete 

confidence that they will work. To do so, DSRC technologies must be prioritized on the 5.9GHz Safety 

Spectrum. 

Honda continues to investigate expanded uses of this technology to improve safety and mobility issues. 

We are conducting studies of Vehicle to Infrastructure, Vehicle to Pedestrian, Vehicle to Motorcycle as 

well as to other vulnerable road users. Furthermore, Honda is currently looking at technology that 

would allow cars equipped with DSRC technology to monitor the road and road users, and allow the car 

and driver to react even if those other road users do not use DSRC technology. This type of technology is 

a critical enabler and should be viewed as a complementary technology on the path toward a highly 

automated vehicle future. 

While examining the five levels of automation, it is our hope that the Subcommittee will also look at the 

most expedient ways to allow innovation to flourish in this area, including utilizing DSRC technology in 

the 5.9GHz Safety Spectrum. Honda looks forward to continuing to work with the Subcommittee on this 

important issue.