Currently there are almost 1,000 safety drivers licensed to test the 285 autonomous vehicles currently licensed with the DMV, but the regulations released today would allow companies to deploy cars without any human behind the wheel of the vehicle.

 The original rules proposed in 2015 nixed autonomous vehicles without a human driver. Fortunately for Google, and the other forty-one autonomous companies currently testing self-driving vehicles, in May the DMV reversed itself in a new proposal. The proposal not only allows for testing of self-driving cars without a human driver, but also allows for regulations of the manufacture and the eventual sale of fully autonomous vehicles. The revisions released today included provisions requiring manufacturers to notify local governments if and when they plan to test autonomous vehicles in their cities or towns. The DMV also introduced a new template for manufacturers to use to report how many times an autonomous vehicle required a human driver to take control of the car because the technology failed to safely navigate road conditions. However, a lack of steering wheels and pedals completely cuts out a human's power to intervene, even if there is a human being in the vehicle. Incident recording devices need to record for a sufficient length of time to determine what caused a loss. In an accident with an autonomous vehicle and a human driven vehicle, who would be liable for the loss? The potential liability issues are huge and have yet to be analyzed. This is going to make a significant difference in the potential for damages and injury.

 Congress is now considering similar legislation that, among other things, would allow companies to manufacture and deploy cars without traditional human controls like steering wheels and pedals. Congress's proposed bills would prevent states from establishing their own laws in order to oversee autonomous vehicle testing on state grounds. This legislation would clash head-on with California's well-established, some would say risky, system. Some leaders of car safety groups and some U.S. Senators are urging for changes to that bill because it lacks industry accountability. At this point, among other things, the bill gives the autonomous vehicle manufacturers the approval to sell self-driving cars to consumers. Those who oppose the bill acknowledge that autonomous vehicles are a huge part of the future, but fear there will be a rush to get them on the market, which will create as many problems as it will potentially solve. Appropriate safeguards need to be in place to ensure safety, privacy, and cybersecurity of the drivers. Before allowing autonomous vehicles without human controls to be available for public purchase, they should be completely and thoroughly tested. Autonomous vehicles seem to function well in good weather, but further testing should be performed to verify proper vehicular reactions during thunder or snow storms.

 The new legislation allows for increased exemption for autonomous vehicle manufacturers from some federal safety standards. Currently 2,500 vehicles are exempt from the Federal Motor Vehicle Safety Standards for testing. Under the new bill, that number will be increased to 100,000, allowing automakers and tech firms to test and deploy tens of thousands of autonomous vehicles without federal safety standard compliant components designed for humans such as steering wheels, pedals, and mirrors. This could potentially pose a significant risk to the public at large.

 We anticipate that without these safety requirements, the fifteen-day comment period will generate a lot of activity, as many questions about the relationship between public safety and autonomous vehicles remain unanswered.