California DMV Notice of Proposed Regulatory Action for Autonomous Vehicles
March 16, 2017
On March 10, 2017, the California Department of Motor Vehicles (DMV) issued a proposed set of regulations for autonomous vehicles (commonly referred to as automated vehicles). The proposed regulations include noteworthy updates related to the testing of automated vehicles and establishes rules for the public deployment of automated vehicles. In a significant departure from previous draft regulations, the proposed set does not require the presence of a driver, for testing and deployment purposes, thus allowing for truly driverless vehicle operation. With these proposed regulations, California is now the second state to allow the testing and evaluation of driverless vehicle operation. On December 9, 2016, Michigan passed similar legislation allowing driverless vehicle operation on Michigan roads. Prior California DMV draft regulations considered requiring independent third party testing to certify and assess the safe operation of all automated vehicles. However, the DMV concluded that this would not be feasible and, instead is now proposing a self-certification model.

Additionally, supplemental reporting requirements in the proposed California regulations include:

  1. Submission of a copy of the 15 point safety assessment letter that will have been submitted to the National Highway Traffic Safety Administration (NHTSA). The safety assessment letter and its voluntary submission to NHTSA is outlined in the Federal Automated Vehicles (FAV) Policy, which was published in September 2016.  
  2. If a vehicle diverges from a conventional vehicle design (e.g., exclusion of manual controls, alternative cabin layouts) and is not able to certify to current Federal Motor Vehicle Safety Standards (FMVSS), an approved exemption letter from NHTSA is requested.
  3. Providing test data showing how the automated vehicle technology was tested, including information on test locations, miles driven, test methods and safety-critical incidents encountered.
  4. Submission of a consumer education plan for public deployment of automated vehicles. 

How Can Exponent Assist You?

To realize the full potential of automated vehicles and Advanced Driver Assistance Systems (ADAS), there are many complex technical and policy challenges that need to be addressed.  Exponent’s engineers and scientists are well-versed in solving these kinds of challenges. Our technical capabilities include:

  • Vehicle engineering and testing
  • Regulatory analysis
  • Human Factors
  • Data analytics
  • Risk and threat assessment
  • Failure analysis
  • Accident investigation
  • Safety critical control systems
  • Sensors
  • Software
  • Artificial intelligence (AI)
  • Cybersecurity

Exponent is able to quickly pull these capabilities together into high-functioning, multi-disciplinary teams. Our team has extensive experience providing regulatory compliance guidance and supporting correspondence with federal and state agencies. Exponent services for automated vehicle and ADAS technologies include but are not limited to:

  • Developing data collection, analysis, and sharing plans in anticipation of future regulatory requirements and risk management
  • Conducting vehicle, subsystem, and component testing
  • Evaluating and testing the crashworthiness for alternative cabin layouts
  • Developing and conducting human machine interface (HMI), driver training and human factors testing
  • Assessing driver and occupant disorientation and motion sickness associated with new and different driving experiences as well as alternative seating layouts     

For more information, please contact one of Exponent’s experienced consultants.