Overview
Title
Agency Information Collection Activities; Submission to the Office of Management and Budget for Review and Approval; Request for Comment; Automated Driving Systems 2.0: A Vision for Safety
Agencies
ELI5 AI
The government is asking people to share ideas about how self-driving cars can be safe and wants companies to keep telling everyone how they make sure their cars are safe, but they don’t have to if they don’t want to.
Summary AI
The National Highway Traffic Safety Administration (NHTSA) has issued a notice inviting public comments on proposed revisions to the information collection process associated with the "Automated Driving Systems 2.0: A Vision for Safety." This proposal seeks to extend and revise the currently approved collection, which helps entities demonstrate their safety practices concerning automated driving systems (ADS) through Voluntary Safety Self-Assessments (VSSA). NHTSA plans to keep the current framework, which allows entities flexibility in how they communicate safety information, without requiring changes to the existing information collection structure. They estimate approximately 2,400 total annual burden hours for four responses from entities developing and deploying ADS technology.
Abstract
In compliance with the Paperwork Reduction Act of 1995 (PRA), this notice announces that the Information Collection Request (ICR) summarized below will be submitted to the Office of Management and Budget (OMB) for review and approval. The ICR describes the nature of the information collection and its expected burden. This document describes a collection of information for which NHTSA intends to seek OMB extension approval titled "Automated Driving Systems 2.0: A Vision for Safety" and is identified by OMB Control Number 2127-0723, currently approved through February 28, 2025. A Federal Register Notice with a 60-day comment period soliciting comments on the following information collection was published on October 23, 2024. Three comments were received in response to that notice; however, no changes to the information collection tool, methodology, nor burden were made as a result of those comments.
Keywords AI
Sources
AnalysisAI
The document discussed here is a notice from the National Highway Traffic Safety Administration (NHTSA). It announces the intention to revise and extend the information collection process related to "Automated Driving Systems 2.0: A Vision for Safety." This process will collect data from entities involved in the development and deployment of automated driving systems (ADS) through Voluntary Safety Self-Assessments (VSSA).
General Summary
The primary aim of the notice is to continue collecting data that demonstrates how these entities address safety considerations for ADS. The NHTSA plans to request an extension from the Office of Management and Budget (OMB) to keep collecting this information for another three years. While the document mentions that suggestions from public comments were received, the agency decided not to change the existing framework for these assessments. The process aims to promote transparency and build public trust in automated driving technologies.
Significant Issues and Concerns
A key issue arising from the document is the lack of transparency in how the estimated 600 hours needed for entities to develop a VSSA was calculated. Without detailed explanation, the time and cost burden may appear arbitrary to some stakeholders.
Furthermore, the estimated cost per hour for preparing VSSAs relies on a specific occupational classification. This estimation might not universally apply across different entities, as the expertise required for compiling a VSSA could vary significantly.
Additionally, suggestions made by the Insurance Institute for Highway Safety (IIHS) about expanding data sharing and transparency were not incorporated. This could be a missed opportunity for improving the information collection and enhancing public confidence in ADS technologies.
For those unfamiliar with previous documents or technical jargon, terms like "ADS 2.0 voluntary guidance document" may be unclear. This lack of clarity might lead to misunderstandings about the document's intentions and functionality.
Impact on the Public
The document has a mixed impact on the public. On the positive side, it encourages enhanced transparency and safety assurance concerning automated driving technologies, potentially fostering public trust. For those interested in the technological advancement of ADS, the document may reassure them of ongoing safety considerations.
However, without any mandatory requirements for consistency or thoroughness, the voluntary nature of the VSSA may not fully guarantee the public the safety assurances they might expect. If entities choose not to be entirely transparent, there could be safety gaps that remain unaddressed.
Impact on Specific Stakeholders
Entities involved in developing and deploying ADS are the primary stakeholders and may be most affected. They benefit from the flexibility to present their safety data according to their standards, potentially protecting proprietary information. However, the lack of mandatory requirements may lead to varying levels of public scrutiny, impacting public perception and market success.
For stakeholders like state governments, the VSSAs provide valuable safety information, offering insights into the implications of ADS on public roadways. Yet, without a standardized approach, the data's reliability and applicability could vary, complicating regulatory and planning efforts.
Consumer advocates and safety organizations might feel that the document does not go far enough in safeguarding public interests. The voluntary framework, without enforced standards or accountability measures, could limit its effectiveness in ensuring rigorous safety practices across the industry.
Overall, this document highlights the delicate balance between encouraging innovation in ADS, maintaining public safety, and ensuring industry accountability. The continuation of voluntary assessments signifies trust in industry self-regulation, but possibly at the cost of more stringent oversight.
Financial Assessment
In the Federal Register document pertaining to the National Highway Traffic Safety Administration (NHTSA) and its information collection activities for "Automated Driving Systems 2.0: A Vision for Safety," financial references focus predominantly on the estimated costs associated with preparing Voluntary Safety Self-Assessments (VSSAs). These assessments are crucial for entities involved in testing and deploying Automated Driving Systems (ADS).
Estimated Costs and Labor
The document provides a detailed breakdown of the financial implications of developing and disseminating VSSAs. The estimated total annual burden cost is reported as $282,384. This figure is derived from a few key components:
Hourly Labor Cost: The hourly cost associated with preparing VSSAs is estimated to be $117.66. This estimate is based on the Bureau of Labor Statistics' mean hourly wage for architectural and engineering managers in the motor vehicle manufacturing industry.
Annual Burden per Respondent: Each of the estimated four respondents incurs an annual burden of $70,596. This calculation assumes 600 hours of labor per respondent, multiplied by the hourly rate of $117.66.
The document notes a decrease of $885,936 in annual labor costs, indicating a reduction from previous estimates. This reduction is due to changes in the annual number of respondents and related adjustments.
Cost Calculations and Potential Issues
The calculated estimates derive from specific occupational classifications which may not fully encompass the varying types of expertise required across different ADS entities. While architectural and engineering managers in motor vehicle manufacturing are highly skilled, entities creating VSSAs may draw on a range of professional expertise. The reliance on this classification might obscure variations in the actual costs faced by different entities.
Lack of Detailed Methodology
One issue with the document is the absence of specifics regarding the calculation of the 600 hours estimated per VSSA. Without details on this estimation methodology, stakeholders may question the accuracy of the financial burden estimation. This could potentially impact the perceived utility or fairness of the cost projections to participating entities.
Response to Public Feedback
Despite critical feedback during the public comment period, particularly from the Insurance Institute for Highway Safety (IIHS), the document indicates that no changes were made to the information collection process or cost estimates. This decision means that any suggestions for improving transparency, particularly about data sharing and VSSAs, were not integrated. As a consequence, the financial allocations related to these tasks remain untouched by potentially valuable input.
Summary
While the financial references in the document provide a clear framework for evaluating the costs associated with VSSAs, stakeholders might find the lack of detailed methodology troublesome. The unchanged financial treatment following public comments also suggests a potential gap in addressing stakeholder concerns, which might have implications for the perceived equity and effectiveness of the program's financial aspects. Overall, the clarity and transparency of these financial allocations are essential to maintaining trust and cooperation among ADS stakeholders and the NHTSA.
Issues
• The document does not specify how the estimated 600 hours required for each entity to develop a VSSA were calculated, which may lead to questions about the accuracy of burden estimation.
• The estimated cost per hour ($117.66) for preparing VSSAs is based on a specific occupational classification which might not accurately represent the varying levels of expertise required for VSSA development across different entities.
• The decision not to incorporate any suggested changes from comments received, such as those by IIHS regarding data sharing and transparency, may neglect potential improvements in the information collection process.
• Language like 'ADS 2.0 voluntary guidance document' might be unclear without a brief description or clarification for readers unfamiliar with previous documents or guidance terminology.
• Some readers might find terms like 'Voluntary Safety Self-Assessment (VSSA)' and other technical jargon challenging without additional context or explanation.
• The document does not clarify what measure or feedback mechanism is used to ensure companies are fully transparent and comply with the outlined ADS safety assessments beyond voluntary disclosures.
• There is a lack of detailed follow-up process or corrective actions if the voluntary nature of VSSA submissions by ADS entities doesn't lead to satisfactory public transparency and safety assurance.