Letter to the Hon. Elaine Chao, DOT - Change Automated Vehicle Policy

Letter

Dear Madam Secretary:

As the department continues to support the safe deployment of autonomous vehicles, we are writing to follow up on delegation letters from February 2017 promoting Ohio's Transportation Research Center (TRC) as an ideal vehicle proving ground site.

As you know, on January 19, 2017, the department released a list of ten sites to be designated as Automated Vehicle Proving Grounds (AVPGs). Despite TRC's status as the largest independent automotive proving ground on the continent and its decades-long record of continuous automotive testing, it was not included on this list.

TRC, located in East Liberty, Ohio, is already a key facility in the National Highway Traffic Safety Administration's development of regulations for highly automated vehicles. Among TRC's 18 distinct test tracks are a 7.5-mile multi-lane oval track and a 1.5-mile winding road course, alongside many other courses and facilities that allow for vehicle testing on a wide variety of pavement types and conditions and in all types of weather.

At your April 12 appearance in front of the House Appropriations Subcommittee on Transportation, Housing and Urban Development, and Related Agencies, you testified that the site selection was not fair and seemed not to have been based on any discernible criteria. We are grateful for your willingness to consider expanding this list, especially considering that the Consolidated Appropriations Act of 2018 set aside $20 million for entities "designated as automated vehicle proving grounds."

Absent the AVPG designation, TRC is thus at a competitive disadvantage to those locations chosen in the department's site selection. Consistent with all applicable rules and regulations governing your work, we respectfully request that you expand the list of designated AVPG sites and reconsider TRC for inclusion on this list.

Should expanding the list of sites prove infeasible, though, we request that you consider getting rid of the AVPG designation altogether. Given the unfairness of the site selection and the need to create the most effective framework for testing autonomous vehicles, the department might be better served by eliminating this arbitrary constraint and basing its decisions on solid criteria, availing itself of the resources best equipped to meet its goals.

Thank you for your consideration of this request, for your leadership on this issue, and for your service to our nation.