November 22, 2016
Docket Management Facility
U.S. Department of Transportation
1200 New Jersey Avenue SE
West Building Ground Floor, Room W12-140
Washington, D.C. 20590-001
Re: Notice and Request for Comments on Federal Automated Vehicles Policy
NHTSA Docket No. 2016-0090-0001
The Center for Democracy & Technology (CDT) respectfully submits these comments in response to the National Highway Traffic Safety Administration’s (NHTSA) request for comment on its Federal Automated Vehicles Policy. CDT is a nonprofit technology advocacy organization dedicated to promoting democratic values online, including digital privacy, free expression, and individual liberty. CDT recognizes the tremendous societal benefits that may be derived from autonomous technologies. Automated vehicles (AV) have the potential to expand access to transit for millions of Americans who struggle with adequate and affordable transportation, and for the elderly and the physically challenged population. They also have the potential to improve fuel economy,  reduce accidents, and reduce congestion. For this potential to be achieved, however, NHTSA and other government agencies must address some of the significant technical and policy challenges these technologies pose.
CDT applauds NHTSA’s policy leadership in the deployment of AV technologies, and we encourage NHTSA to further explore the privacy and cybersecurity impacts of AVs. Specifically, these comments focus on the Federal Automated Vehicles Policy’s Cross-Cutting Guidance with respect to: (1) data sharing; (2) privacy; (3) cybersecurity; and (4) consumer education and training.
 Stephanie Beasley, Older, Disabled Drivers Pose Challenge for Driverless Car Makers, Bloomberg BNA (May 6, 2016), http://www.bna.com/older-disabled-drivers-n57982070757/.
 Julia Pyper, Self-Driving Cars Could Cut Greenhouse Gas Pollution, Scientific American (Sept. 15, 2014), https://www.scientificamerican.com/article/self-driving-cars-could-cut-greenhouse-gas-pollution/.
 Michelle Fox, Self-Driving Cars Safer Than Those Driven by Humans, CNBC (Sept. 8, 2014), http://www.cnbc.com/2014/09/08/self-driving-cars-safer-than-those-driven-by-humans-bob-lutz.html.
 Peter Wayner, How Driverless Cars Could Turn Parking Lots into City Parks, Atlantic (Aug. 5, 2015), http://www.theatlantic.com/technology/archive/2015/08/driverless-cars-robot-cabs-parking-traffic/400526/.
 Apratim Vidyarthi, Self-Driving into the Future: Putting Automated Driving Policy in Top Gear, Ctr. for Democracy & Tech. (Aug. 9, 2016), https://cdt.org/blog/self-driving-into-the-future-putting-automated-driving-policy-in-top-gear/.