On behalf of the Competitive Enterprise Institute (“CEI”), the R Street Institute (“R Street”), and TechFreedom, we respectfully submit these comments in response to the National Highway Traffic Safety Administration’s (“NHTSA”) Request for Comments on the Federal Automated Vehicles Policy (“RFC”). CEI is a nonprofit, nonpartisan public interest organization that focuses on regulatory policy from a pro-market perspective, R Street is a free-market think tank with a pragmatic approach to public policy challenges, and TechFreedom is a think tank with a mission to promote the progress of technology that improves the human condition and expands individual capacity to choose.
Our comments are divided into the following sections, which correspond to the sections of the Federal Automated Vehicles Policy subject to the RFC:
I. Vehicle Performance Guidance for Highly Automated Vehicles;
II. Model State Policy;
III. NHTSA’s Current Regulatory Tools; and
IV. New Tools and Authorities.