Advocates’ Joint Letter as the House Considers Autonomous Vehicle Legislation – National Consumers League

Move this letter into the official record in the current session to establish mandatory occupant protection standards and transparent data-sharing requirements for auto safety. This step also has a companion data appendix that tracks incidents and disengagements, giving government and congress a concrete starting point to turn policy into practice.

The joint letter also specifies a dedicated section that performs rigorous testing, real-world performance tracking, and incident reporting. It asks Congress to set a baseline for crash avoidance and for a public, searchable record of outcomes. latta and other lawmakers have signaled a readiness to press for stronger consumer protections, while the letter also notes that occupants must be included in every risk assessment. The recommendation emphasizes that those behind the wheel deserve clear accountability and that auto makers should meet a published timeline to deliver improvements.

The letter highlights the role of government in safeguarding everyday users and instructs regulators to demand disclosure of safety metrics, disengagement events, and software updates. It also urges a transparent process so congress can evaluate whether a vehicle performs safely across a range of conditions, including nearly all urban streets and highways, keeping occupant safety at the center of policy decisions. It also ensures accountability for those behind the wheel.

To translate ideas into action, the letter calls for a staged approach: require near-term reporting on disengagement incidents, define a standard for disengagement transparency, and mandate that regulators publish quarterly updates. This moving momentum keeps attention on real protections and allows the government to enforce penalties for non-compliance if a company fails to meet the timeline.

In practice, the package of recommendations offers a practical path for lawmakers as they consider the next session on auto legislation. By centering occupants and consumer protection, the joint letter performs a critical role and pushes for more protection for occupants, ensuring the technologies safeguard people on every seat.

AV Legislation and Advocates’ Joint Letter: National Consumers League and State Perspectives

Recommendation: require a binding privacy and safety assessment before the bill is passed, with a public report aligned to usdot guidelines and an independent third-party evaluation that takes occupants, health, and consumer protections into account, ensuring safety is prioritized safely over speed.

From the National Consumers League and state coalitions, the emphasis is on transparency, privacy protections, and robust health safeguards for autonomous vehicles. Occupants will ride in these vehicles, and health data could be collected, so the plan addresses these concerns directly in the bill’s framework. It refers to a recent statement from the usdot that urges guardrails, and notes that the former pilot programs lacked sufficient data controls, which must be addressed as part of addressed requirements in the bill.

The joint letter outlines three subsections and, in particular, the third subsection covers liability, reporting, and alerting provisions. It insists on data minimization and a strict prohibition on selling or exploiting data beyond stated purposes. It also highlights an explicit exemption path for limited pilot deployments while ensuring public oversight through a state safety council and the agency, a structure that can help the bill move forward without compromising safety or privacy.

Operational steps require an independent assessment before deployment, covering health impacts, privacy safeguards, and safety metrics. The evaluation should be posted publicly and updated at least annually. States can reference the plan in their bills, with a clear title for the AV program and a defined assessment timeline. The plan takes a risk-based approach and will change the regulatory landscape over time, delivering clarity for manufacturers and consumers alike.

State perspectives emphasize staged rollout and disciplined oversight. Some states seek to shorten timelines for pilot programs, but the letter argues that status updates, alerting systems, and occupant protections should not be skipped. Until metrics show safe operation for all occupants, the plan recommends conditional authorization and strengthened oversight. The council should issue alerts when incidents rise, and any exemption should have guardrails to prevent data sold or misused, protecting privacy and health while supporting legitimate innovation.

In sum, the joint letter provides concrete steps: refine subsections, align with usdot and state authorities, and ensure an assessment-driven process takes hold before the bill is passed. This approach keeps consumer protections at the core, address health and privacy concerns, and takes a thoughtful path toward safer autonomous operation for occupants. State plans should be coordinated through the council and agency to maintain consistency as the bill evolves, and lawmakers should ensure the statement of goals is clear before any final vote.

What the joint letter requests from House committees on AV legislation

Recommend that House committees jointly establish rulemaking with a clear purpose to govern AV policy, organize the bill into subsections and chapters, and set a final draft within the session so health and safety provisions reach the marketplace before any AV is sold, unless an extension is approved, with each chapter carrying a defined purpose.

Specifically, the joint letter requests that the rulemaking provide a clear definition of automation levels, occupant protection, and safety responsibility; require testing and evaluation of health outcomes; and maintain a robust process for updating standards, with required protections for consumers.

Publish data in a searchable format on testing results, safety incidents, and performance metrics to inform consumers and the marketplace; follow an evaluation process that covers every impact over the lifecycle, as said in the letter, and provide access to the data unless restricted by law.

Set an oversight schedule over the session with regular reporting to the Senate, structure AV legislation into chapters and subsections, and publish a final rule with a transition plan that maintains occupant safety and health protections while ensuring ongoing evaluation and consumer privacy in the marketplace.

Which AV START Act language concerns governors and state legislatures

Push for explicit state carve-outs and a robust privacy framework, plus funding provided to states for three years to build testing, oversight, and infrastructure suitable for motor vehicles on roads. latta language should be reviewed for alignment with state interests.

To safeguard state interests, prioritize language that preserves governors’ authority to tailor safety and privacy rules within their jurisdiction, and to coordinate with a state council or steering body that can translate national standards into local practice. The expressed goals should address significant privacy protections and the evolution of oversight across three primary areas: data governance, funding, and governance structures.

• Preemption and state autonomy: require an exempt for state-specific safety rules and local testing programs, and establish a governors council or steering committee to guide implementation between federal baseline provisions and state law. Ensure that governors retain authority to set higher standards where public safety demands it.
• Privacy and data governance: define data collected by AV systems, limit retention, prevent unnecessary sharing, and include explicit protections for privacy, including child data; ensure that any data sharing between agencies stays within state control and subject to public records laws, during testing and deployment, to protect more lives.
• Funding and oversight: ensure funding provided, with a three-year timeline, supports state testing, infrastructure on auto roads, and public safety programs; require annual reports to governors and state legislatures and clear use metrics; include additional safeguards to measure impact on privacy and safety.
• Scope and exemptions: clearly identify what’s included and what’s exempt, including subsections that relate to title auto, motor areas, and road testing; spell out the boundaries between federal requirements and state responsibilities within the act’s subsections; specify that areas included significantly affect state planning and resources.

latta language proposals should be reviewed to ensure that the bill’s evolution preserves state flexibility while maintaining strong safety and privacy protections; the bill shall articulate three clear subsections that governors may use to tailor provisions within their borders, including funding that is provided for state use, and that the mechanisms to monitor compliance remain transparent and expressible to the council and steering bodies. Ensure that the language clarifies that more testing can occur without compromising privacy, and that lives on the roads, including children, are protected during all phases of deployment.

How consumer protections are addressed: safety, data privacy, and accessibility

Recommendation: Implement a federal rule mandating a 12-месячный развертывание pilot with an independent assessment of safety и privacy, approved only after transparent findings are published, and with access для consumers to the results until a stable baseline is demonstrated.

During this phase, establish oversight by a federal комиссия с member governors and a dedicated section that codifies safety metrics, incident reporting, and penalties for noncompliance. Alert regulators and the public about significant events, so consumers stay informed as deployment proceeds over the deployment period. Почти all decisions hinge on verifiable data.

Privacy protections include minimizing data collection, limiting use to necessary purposes, encrypting data, and setting retention limits. Require a formal privacy assessment, publish a data map, and provide consumers с access to policies; ensure data included for safety and offer opt-out options where feasible. Include a mechanism to safeguard privacy and preserve digital integrity.

Доступность guards require inclusive in-vehicle interfaces and companion apps, with support for screen readers, captions, and alternative input methods. Gather input from member communities including people with disabilities, and test throughout testing phases to ensure access and usability across devices. Report results in a public section to show progress in ensuring equitable access.

Exemption provisions may apply to early-stage pilots, but require ongoing assessment and publicly posted criteria; avoid political delays by tying exemptions to robust oversight. Align with governors and state leaders to keep section goals clear. The framework should also fuel innovation while keeping protections in place; unless data show safety risks, advance deployment in a controlled manner that protects consumers.

Oversight, accountability, and enforcement around AV pilots and testing

Create a permanent US DOT commission to oversee AV pilots and testing, with binding authority, transparent reporting, and enforceable penalties for noncompliance.

The commission should require a searchable safety data dashboard for every pilot program, including incident counts, disengagements, miles driven, and trip outcomes. This is the evolution from a former, ad hoc approach to a common, standardized process that could set a baseline for all states.

Operators must be equipped with secure telemetry and data-collection tools, and the approval process must be digital–requiring a safety case, risk assessment, and mitigation plan before any on-road testing begins; no program may proceed without commission review. The process should track motor controller events and fuel usage where applicable.

Implement a robust enforcement regime with clearly defined penalties, expedited remedial actions, and the ability to suspend or revoke permits; nada tolerance applies to falsified data and evasion of reporting. If safety warnings exceed thresholds, the Commission can pause testing within 24 hours to protect drivers and pedestrians.

Exemptions must be carefully bounded, with explicit limits for emergency research and limited trials; exemptions should include sunset checks and renewal criteria, and they must be applied within defined guardrails. They must be reviewed within each session and cannot be extended beyond the fourth quarter without new authorization.

Link oversight to the legislative process by requiring bill-level reporting of outcomes; in last session, four bills passed unanimously that strengthen accountability, and the final bill could set a standard for coordination with usdot and other agencies. They also should address cross-jurisdiction coordination within and between states and ensure operators are prepared to share common data fields with the commission.

Next steps for stakeholders: timeline, hearings, and public comment

Submit formal public comments by the House deadline to influence the policy. Provide data-backed input on safety benchmarks, privacy protections, and equal access for all users, including people with mobility challenges and low‑income communities.

Timeline: In the coming weeks, build a unified position with chapter partners and coalitions, focusing on automation, the fmvss framework, and exempted use cases. By september, hearings are expected to open; usdot and nhtsa will outline milestones under federal transportation oversight, and the record will address gaps in current rules.

Hearings: Seek opportunities to testify; prepare concise briefs; push for unanimity among consumer groups, and present data on privacy, safety, and equal protection. While advocates press for robust protections, raise questions about timelines and exemptions for different automation scenarios (nhtsa) to ensure broad buy‑in.

Public comment process: Use the committee portal to submit comments, including sections on privacy, safety, and equal access; include references to fmvss provisions and NHTSA interpretations. Include data from testing or case studies; note exemptions and the practical impact under usdot oversight; propose amendments that could be considered during the advisory phase, unless new information emerges.

Next steps if momentum continues: after comments, the process turns toward rulemaking under federal transportation law to align standards across states. The advisory path will clarify exemptions and scheduling, with more detail on exempted uses. Left to regulators, the record should remain transparent, accessible, and centered on privacy protections and consumer safeguards while engaging stakeholders through hearings, public comment, and ongoing dialogue with usdot and nhtsa.