PennDOT Issues Guidance for Increased Safety Oversight of Highly Automated Vehicles
Harrisburg, PA – Following discussions and meetings with the state’s Autonomous Vehicle Policy Task Force and more than a dozen automated vehicle technology companies, PennDOT today issued guidance to enhance safety oversight of Highly Automated Vehicles (HAVs) in Pennsylvania.
“We are taking an active role in ensuring HAV testing is done as safely as possible,” PennDOT Secretary Leslie S. Richards said. “While we await legislative action on our request for permanent authorization, our new guidance underscores our expectation that companies are taking every possible step to prepare their vehicles and personnel for on-the-road testing.”
Until enactment of HAV legislation sought by the administration, starting Aug. 1, PennDOT expects all testers to comply with the guidance by submitting a “Notice of Testing” to PennDOT on the department’s AV site, www.penndot.gov/AV. The application will require submission or confirmation of operational details such as:
•Basic Information: Name of the company, address, phone number, email, and principal point of contact for the testing;
•Verification attesting that the HAVs meet all federal and state safety standards;
•A Safety and Risk Mitigation Plan or a Voluntary Safety Self-Assessment as established by the National Highway Traffic Safety Administration in the 2017 Voluntary Guidance for Automated Driving Systems, Section I;
•Acknowledgment that all safety drivers and secondary safety associates have successfully completed the tester’s safety driver training program. (PennDOT strongly recommends clean driving records for HAV operators);
•Certification that all drivers have met/passed program requirements and when training was completed;
•Name of approved safety drivers, with valid DL numbers;
•List of vehicles that will be involved in the testing, their VIN and/or Plate number, and proof of current registration;
•Acknowledgment of insurance;
•List of counties where testing is expected to occur, providing the anticipated roadways if testing will only occur on limited access roadways;
•Acknowledgment that the HAV can safely alert the safety driver, when applicable, that the driver must take back control of the vehicle;
•Acknowledgment that the HAV has been tested under controlled conditions for the Operational Design Domain (ODD) in which the tester intends the HAV to operate and the tester has reasonably determined that the HAV is capable of operation within the ODD parameters while obeying all applicable traffic and motor vehicle laws as well as traffic control devices. The ODD describes the specific conditions under which a given HAV is intended to operate, including where (such as what roadway types and speeds) and when (under what conditions, such as day/night, weather limits, etc.); and
•In addition, testers will be required to confirm that quality controls are deployed and monitored to ensure the acknowledgements are implemented, adhered to and measured to ensure safe operation.
These safety requirements apply for all testers regardless of a roadway’s posted speed limit. For operations on roadways with speed limits posted above 25 mph, testers must meet these conditions and there must be a secondary safety associate present in the vehicle. Testers requesting the usage of a single safety driver for operations on roadways posted above 25 mph must present evidence of an enhanced performance driver training plan for department review.
If approved by PennDOT, compliance with these voluntary policies will qualify the tester to receive an “Authorization Letter” from PennDOT valid for a year, with annual renewals. If there are material changes in the HAV tester’s program or ODD such that the original submission no longer adequately or accurately describes the testing program, the tester shall electronically notify the department.
The guidance also outlines conditions when the department may suspend or revoke testing authorization, such as: falsifying information in tester submissions; if a tester’s HAV is involved in an incident resulting in serious bodily injury or death; the HAV-specific Automated Driving System (ADS) is the subject of a National Transportation Safety Board (NTSB) investigation; the HAV shares proprietary ADS software with any HAV that is part of a NTSB investigation; or the tester fails to disclose any known violations of these situations.
In addition, the guidance provides for conditions when the department and the Pennsylvania Turnpike Commission may request that testers temporarily prohibit or restrict testing on certain roadways or statewide during certain emergencies, special events, or safety concerns. Local municipalities may contact the department to make a request to restrict or prohibit testing under the same criteria.
To document and measure the impact of HAV testing in the state, PennDOT will collect certain data from all testers through a semi-annual submission by the HAV testers to PennDOT using an online form. This will include:
•Approximate miles traveled by ADS-engaged HAVs in Pennsylvania.
•Type of roadway where the majority of testing occurred.
•Counties where HAVs were tested on public roadways.
•Approximate number of employees in Pennsylvania involved with HAV testing.
•If applicable, the approximate number of new jobs created in Pennsylvania because of HAV testing.
•If applicable, the approximate number of new facilities constructed, purchased, or rented in Pennsylvania because of testing.
The guidance was issued following the secretary’s announcement of an action plan at the state’s second Automated Vehicle Summit held in Pittsburgh in April. The guidance is the latest of a series of actions the Wolf Administration has taken to prepare for the benefits and challenges presented by this emerging technology, including the summits and the establishment of the task force. The task force, created in June 2016, coordinated with industry, academic and government stakeholders and delivered policy recommendations to the General Assembly in November 2016.
PennDOT continues to urge the Automated Vehicle industry and testers to:
•Continue and foster open lines of communication with PennDOT.
•Coordinate with PennDOT on developing best practices for operating HAVs within safety critical locations such as signalized intersections and work zones.
•Put greater emphasis on developing and deploying vehicle-to-vehicle, vehicle-to-infrastructure, and vehicle-to-device connectivity.
•Establish and fund an independent technical review body to promulgate best practices and pledge adherence to its recommendations.
In addition, PennDOT will continue to urge the General Assembly to adopt legislation that provides for AV testing on public roadways subject to PennDOT’s safety oversight and requires compliance with PennDOT’s testing safety policies.
PennDOT looks to the federal government for these actions:
•The National Highway Safety Administration (NHTSA) should revise Guidance 2.0 to make a safety checklist mandatory. It now is voluntary.
•Congress should amend current HAV legislation to strengthen state control over roadway operations with respect to HAVs.
•Third Party safety auditors should adopt independent certification similar to the work Underwriters Laboratories (UL) does. This would help reduce system failure (both software and hardware).