The National Society of Professional Engineers is disappointed and concerned that the House Energy and Commerce Subcommittee’s Digital Commerce and Consumer Protection draft legislation, the Highly Automated Vehicle Testing and Deployment Act of 2017, will allow automakers to deploy highly automated vehicles without first addressing the major safety, technological, and ethical implications of autonomous vehicles. Recognizing the promise of autonomous vehicles, NSPE has been a leading advocate on the need to place the public health, safety, and welfare first, and require a licensed professional engineer to play a key role in the development, testing, and safety certification of autonomous vehicles. NSPE urges defeat of the draft legislation in its current form and urges the committee to revise the bill to address the following key issues:
There is no requirement for a third-party certification of autonomous vehicles and technologies by someone in the decision chain who has a duty that puts public safety first and overrides competitive pressures– i.e., a professional engineer. These guidelines allow manufacturers and suppliers to self-certify, eliminating a critical third-party safety check. Instead, the legislation allows automakers to deploy up to 100,000 selfdriving vehicles without meeting existing safety standards. Moreover, the legislation specifically states: “The Secretary may not condition deployment or testing of highly automated vehicles on review of safety assessment certifications.” Safety should be the primary concern of this legislation and policymakers. Instead, it removes safety requirements.
Despite encouraging results of autonomous vehicle deployments in controlled environments, there is still significant work to be done before the achievement of human-operated and autonomous vehicles safely sharing public roadways. Many factors—weather, pedestrians, road conditions— are common, rapidly changing, and highly unpredictable. Moreover, the legislation does not address how these highly automated vehicles will interact within the larger infrastructure system with millions of non-highly automated vehicles.
The enormous ethical implications of deploying autonomous vehicles are simply not addressed. Highly autonomous vehicles will replace human decision-making and will need to be programmed to make life or death decisions. Yet, there is not a single mention of how these decisions are to be made nor does it propose any method of regulatory oversight. Professional engineers should play a key role in this evaluation as their oath in holding the license is to place the public health, safety, and welfare above all other considerations.
NSPE understands and shares interest in the impact of emerging technologies to transform our society. However, the Highly Automated Vehicle Testing and Deployment Act of 2017 does not properly address the safety, technological, and ethical implications of deploying autonomous vehicles. The Committee must revise the legislation to address these fundamental issues before allowing deployment of highly automated vehicles.
The National Society of Professional Engineers is a member-centric, nimble, future-focused, and responsive organization, serving as the recognized voice and advocate of licensed Professional Engineers. Through education, licensure advocacy, leadership training, multidisciplinary networking, and outreach, NSPE enhances the image of its members and their ability to ethically and professionally practice engineering. Founded in 1934, NSPE serves more than 31,000 members and the public through 52 state and territorial societies and over 400 chapters. For more information, please visit www.nspe.org.