Review of the Federal Motor Carrier Safety Regulations for Automated Commercial Vehicles: Preliminary Assessment of Interpretation and Enforcement Challenges, Questions, and Gaps

Perlman, David; Bogard, Dan; Epstein, Alex; Santalucia, Antonio; Kim, Anita · 2018 · ROSA P / John A. Volpe National Transportation Systems Center (U.S.)

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Summary

This report, prepared by the Volpe National Transportation Systems Center for the Federal Motor Carrier Safety Administration (FMCSA), addresses the regulatory compatibility of automated commercial motor vehicles (CMVs) with existing Federal Motor Carrier Safety Regulations (FMCSRs). The study was motivated by the rapid advancement of automated vehicle technology and the likelihood of its early adoption in commercial trucking, particularly for long-haul operations on limited-access highways. Because the FMCSRs were drafted under the assumption that a human driver would always operate the vehicle, the report aims to identify compliance and enforcement challenges that may arise when applying these regulations to automated systems. The methodology involved a comprehensive review of the FMCSR text by a team of four reviewers, who analyzed regulations against thirteen hypothetical automated CMV operating concepts. These concepts ranged from near-term driver-assistance features (SAE Levels 2–3) to highly automated vehicles with onboard technicians or remote supervisors (SAE Levels 4–5). The reviewers identified passages that posed potential compliance hurdles for operators or enforcement difficulties for regulators, focusing on issues such as licensing, hours of service, physical qualifications, and equipment inspections. The analysis also sought to identify general gaps in the current regulatory framework regarding the safe operation of automated vehicles. The findings indicate that the severity of regulatory challenges depends heavily on the level of human involvement and the interpretation of key definitions, particularly "driver" and "operator." Concepts retaining active human driver involvement face the fewest challenges, as many issues can be resolved through regulatory interpretation. However, concepts involving onboard non-driving technicians or remote supervisors face significant ambiguities regarding the application of training, licensing, and hours-of-service requirements. Fully driverless concepts encounter the most substantial hurdles, particularly concerning cargo inspection, physical fitness qualifications, and alcohol restrictions, which are inherently tied to human operators. Broad safety provisions prohibiting unsafe equipment or operation also present potential conflicts for all automated concepts. The report concludes that resolving these challenges requires explicit clarification from FMCSA on how existing definitions apply to automated driving systems, onboard technicians, and remote supervisors. It highlights that while near-term automation may fit within current regulations with minor adjustments, higher levels of automation will likely necessitate new regulatory frameworks or significant reinterpretations to ensure safety and operational efficiency. The study serves as a preliminary assessment to guide future policy development and enforcement strategies for automated commercial vehicles in interstate commerce.

Key finding

Automated commercial vehicles that do not require an onboard human operator face the most significant compliance challenges with existing Federal Motor Carrier Safety Regulations, particularly regarding driver qualifications, hours of service, and equipment inspections.

Methodology

review

Provenance

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Topics

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