Review of Federal Motor Vehicle Safety Standards (FMVSS) for Automated Vehicles: Identifyingpotential barriers and challenges for the certification of automated vehicles using existing FMVSS

The purpose of this work is to identify instances where the existing Federal Motor Vehicle Safety Standards (FMVSS) may pose challenges to the introduction of automated vehicles. It identifies standards requiring further review - both to ensure that existing regulations do not unduly stifle innovation and to help ensure that automated vehicles perform their functions safely. The Volpe team conducted two reviews of the FMVSS: a driver reference scan to identify which standards include an explicit or implicit reference to a human driver and an automated vehicle concepts scan to identify which standards could pose a challenge for a wide range of automated vehicle capabilities and concepts. In summary, the review revealed that there are few barriers for automated vehicles to comply with FMVSS, as long as the vehicle does not significantly diverge from a conventional vehicle design. Yet, automated vehicles that begin to push the boundaries of conventional design (e.g., alternative cabin layouts, omission of manual controls) would be constrained by the current FMVSS or may not fully meet the objectives of the FMVSS. Many standards, as currently written, are based on assumptions of conventional vehicle designs and thus pose challenges for certain design concepts, particularly for ‘driverless’ concepts where human occupants have no way of driving the vehicle. Some constraints, of course, may be warranted; this work does not assess the merits of potential future requirements for such vehicles.