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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On March 17, 2020, the National Highway Traffic Safety Administration (NHTSA) published a notice of proposed rulemaking (NPRM) aiming to remove unnecessary barriers to vehicles equipped with automated driving systems (ADS) and proposing to amend and modernize 11 of its Federal Motor Vehicle Safety Standards (FMVSS) related to crashworthiness and occupant protection.

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While an important first step, NHTSA explains that its NPRM should be viewed as part of a series of regulatory actions it will take to address the challenges associated with ADS-equipped vehicles “that lack the traditional manual controls necessary for human drivers, but that are otherwise traditional vehicles with typical seating configurations.” NHTSA notes that until it modernizes all FMVSS to address the technological innovations inherent in ADS-equipped vehicles, it “expects that the manufacturers … will seek exemptions from those FMVSS requirements that implicitly or explicitly require manual controls.”

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In general, NHTSA’s proposed changes address the application of certain FMVSS to ADS-equipped vehicles, such as adding definitions to clarify the application of standards to ADS-equipped vehicles; clarifying the application of some occupant protection standards to vehicles designed to carry objects; clarifying the application of FMVSS to motor vehicles without a steering wheel or steering column; modernizing the rules to address issues related to vehicles without a driver’s seat, but having multiple outboard passenger seats; and addressing the treatment of advanced air bags and advanced air bag suppression telltales in light of the expectation that a child occupant of an ADS-equipped vehicle may eventually sit in what we now consider the driver’s seat.

Specifically, NHTSA seeks comments on the following proposals that would amend 11 of its crashworthiness Series 200 FMVSS:

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NHTSA is seeking public comments on the proposed changes as well as whether any additional changes are necessary or appropriate. Comments are due 60 days after the NPRM&nbsp;is published in the Federal Register.

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Karyn A. Booth Partner, Transportation 202.263.4108 <a href="mailto:Karyn.Booth@ThompsonHine.com">Karyn.Booth@ThompsonHine.com</a>

Tim Goodman Partner, Transportation 202.263.4117 <a href="mailto:Tim.Goodman@ThompsonHine.com">Tim.Goodman@ThompsonHine.com</a>

Will Godfrey* Director, Mobility, Automation and Safety 202.263.4119 <a href="mailto:Will.Godfrey@ThompsonHine.com">Will.Godfrey@ThompsonHine.com</a> *Not licensed to practice law

This advisory bulletin may be reproduced, in whole or in part, with the prior permission of Thompson Hine LLP and acknowledgment of its source and copyright. This publication is intended to inform clients about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information contained in it without professional counsel. This document may be considered attorney advertising in some jurisdictions.

https://admin.thompsonhine.com/wp-content/uploads/2022/05/Transportation_Update_-_NHTSA_Proposes_Easing_Certain_Regulatory_Requirements_for_Self-Driving_Vehicles.pdf

NHTSA Proposes Easing Certain Regulatory Requirements for Self-Driving Vehicles

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