FR 2021-00390

The National Highway Traffic Safety Administration (NHTSA) recently published an updated draft document for public comment titled Cybersecurity Best Practices for the Safety of Modern Vehicles. This document serves as a follow-up to the guidance initially introduced in 2016, focusing on enhancing vehicle cybersecurity with an emphasis on safety. The NHTSA is seeking input from the public and industry stakeholders to refine the best practices in response to the evolving cybersecurity landscape in vehicle electronics, software, and wireless connectivity.

General Summary

NHTSA’s updated draft document outlines voluntary guidelines intended to assist the automotive industry in addressing cybersecurity risks associated with motor vehicles. By emphasizing safety and security, the Agency aims to foster improvements in the design, manufacturing, and maintenance of vehicles in relation to their electronic and software systems. This collaborative approach allows stakeholders, including manufacturers and suppliers, to adapt practices that mitigate potential cyber threats throughout a vehicle's lifecycle.

Significant Issues and Concerns

The draft document includes complex terminology and references numerous technical standards and methodologies, such as ISO/SAE 21434 and NISTIR 8151. This may present challenges for stakeholders who are not deeply familiar with cybersecurity language and may require additional research to fully comprehend and implement the recommendations. Another issue is the dense and expansive nature of the text, which could obstruct some stakeholders' ability to quickly identify and focus on the most pertinent sections for their specific needs.

NHTSA's analysis of the economic implications acknowledges a lack of detailed knowledge about organizational costs and cybersecurity maturity levels, potentially affecting the accuracy of their cost assessment. Moreover, the guidance's voluntary nature might result in inconsistent adoption across the automotive industry, potentially limiting the effectiveness of the proposed best practices.

Impact on the Public

For the general public, this document represents an effort to make vehicles safer by reducing cybersecurity risks. As modern vehicles become increasingly complex and interconnected, the threat of cyber attacks grows, potentially affecting passenger safety and privacy. By guiding the automotive industry towards better cybersecurity practices, NHTSA aims to ensure that vehicles on the road are better protected against these emerging threats.

Impact on Specific Stakeholders

Positive Impacts:

• Automotive Manufacturers and Suppliers: The guidance offers a framework for these stakeholders to improve their cybersecurity systems, thereby minimizing risks and potential liabilities associated with cyber vulnerabilities. Companies that engage with these guidelines may benefit from a stronger public image and increased consumer trust.

• Policy Makers and Regulatory Bodies: The document provides an opportunity to gauge the effectiveness and acceptance of voluntary standards within the industry, which could inform future regulatory policies that ensure public safety.

Negative Impacts:

• Smaller Companies: For companies with less mature cybersecurity programs, the extensive recommendations may seem overwhelming and could require substantial adjustments to current practices, involving both time and financial resources.

• Stakeholders Concerned with Consistency: The non-binding nature of the guidance means that some entities might delay implementation or opt for different standards, potentially leading to uneven cybersecurity levels across the industry, which could undermine the collective safety effort.

Overall, NHTSA’s document underscores the importance of advancing cybersecurity measures in modern vehicles to protect public safety, but highlights several challenges that stakeholders will need to navigate in adopting and implementing these best practices.