The rush to market Automated Vehicles (AVs) has the AMA membership and board concerned. To ensure that clear expectations are developed at an early stage, the AMA urges the National Highway Traffic Safety Administration to test algorithms and software in highly automated vehicles to ensure that this new technology fully and effectively identifies and properly responds to motorcycles in all traffic situations.
Advanced crash-avoidance warning systems technologies used in motor vehicles must not supplant an operator’s responsibility to operate the vehicle in a safe and responsible manner. While technology can, and should, enhance the actions of the operator to maintain control of the vehicle, safe operation of a motor vehicle should remain the operator’s highest priority. Therefore, the federal policy for highly automated vehicles should include a campaign to educate the public on these new technologies.
The safety of motorcyclists is of singular importance to the mission of the American Motorcyclist Association. As technology allows vehicles to communicate with each other and with roadway infrastructure, the promise of improved safety is alluring. To decrease the number of motorcycle crashes and resulting injuries and fatalities, it is paramount that automated vehicle technology, including highly automated vehicles, be capable of recognizing and properly reacting to motorcycles in all traffic situations and settings, including in parking lots, amid urban congestion, at intersections and on highways, expressways and rural roads.
Automated vehicles can bring a greater measure of safety to motorcyclists and cannot be overlooked. Distracted driving is one of the major causes of motorcycle crashes that are frequently the fault of the motorist. A properly designed, complete automated system of control, highly refined in its ability to recognize motorcycles, can truly save lives. The AMA welcomes the potential of this type of vehicle, once thoroughly vetted. Unfortunately, the industry is still many miles away from the development of a system that is able to interact safely with motorcycles in many common real world situations.
The rush to market of driver-assist systems, semi-autonomous vehicles and highly automated vehicles—referred to collectively as AVs—poses a significant threat to motorcyclists when the developers of this technology and the vehicle manufacturers are not held to the highest safety standards throughout the entire development and implementation process. If AV systems are not conceived and developed with motorcycles and motorcyclists in mind, the eventual result could be that motorcycles would be excluded from certain roadways, or, worse, banned from roads altogether.
Motorcyclists have been an integral component of daily transportation and recreational activity on our public roads and highways for over a century. The AMA has an indelible history of protecting access for motorcyclists to our transportation infrastructure.
Motorcycles meeting federal design, safety, sound and emission requirements operate legally on our public roadways. The issue of safe access is also directly related to the high cost of licensing, ownership and fuel taxes, including the substantial expense to the motorcycle consumer of meeting state and federal laws pertaining to safety and emissions in the manufacturing process. Additionally, motorcyclists are and have been direct contributors to both the building and policing of our highway systems and hence contribute directly to the safety of all motorists.
Motorcycling provides many benefits to riders and to the public at large. On average, motorcycles and scooters consume fewer resources and emit less carbon dioxide per mile, take up less space in parking areas and impose very little wear and tear on our nation’s roads and infrastructure, especially compared to automobiles, trucks and SUVs. Furthermore, motorcycling tourism and events provide substantial economic benefit in the form of revenue and tax receipts to towns, municipalities and counties that cater to motorcycling enthusiasts.
The AMA has been monitoring the development of safety-enhancing technology for decades—and AV systems since the early 2000s. The AMA is committed to ensuring that AV technology benefits all road users, and, specifically, motorcyclists.
Working with the U.S. Department of Transportation and its agencies, including the National Highway Traffic Safety Administration and the Federal Highway Administration, as well as elected officials, automakers, technology companies and software developers—the AMA has strongly advocated that motorcycle safety must be an integral component of every AV technology program. The goals of this effort include ensuring that:
- Motorcycles are included when AV, vehicle-to-vehicle (V2V) and vehicle-to-infrastructure (V2I) communication systems are designed, tested and implemented;
- The implemented communications systems, whether using Wi-Fi or another technology, are secure from hacking; and
- These technologies protect the privacy of all road users.
If manufacturers can self-certify that their AVs comply with existing applicable safety standards, no federal law or regulation prevents AVs from being built or from being tested on roadways shared with motorcycles. Neither the 2016 Federal Automated Vehicles Policy nor the 2017 Automated Driving Systems guidance change addresses this situation. They instead sacrifice safety for technological flexibility. Administrative agencies actions often reflect pressure from manufacturers to bring products to market without adequate testing.
The federal policy lists examples of behavioral competencies that AV manufacturers should assess, test and validate. However, as expressed above, what are the sanctions for failure to address motorcycles, which are a legal class of motor vehicle with distinct operating characteristics? Currently, the answer is none.
As a result, the AMA continues to demand that motorcyclists be included in the ongoing discussion, planning and implementation of the policies and regulations governing the rollout of AVs.
Failure to specifically address motorcycles in statutory and regulatory language amounts to the abandonment of motorcycle safety by legislators and regulators. Essentially the issue of distracted and inattentive driving will mushroom into a monumental hazard for motorcyclists when flawed AV technology enters the transportation mainstream.
Moreover, the AMA opposes any provisions that limit or eliminate motorcycle access to public roadways. The AMA maintains that acceptance of a policy that attempts to perpetuate a view that motorcyclists present a "social burden" on America's highways based on flawed AV technology is both discriminatory and contrary to the long-term interests of motorcycling.
From the beginning, the AMA has offered its expertise repeatedly during AV development. The AMA now calls upon the president and Congress to immediately direct the appropriate federal agencies to implement automated-vehicle policy and guidelines to improve and ensure the safety of motorcyclists.
In summary, the American Motorcyclist Association position regarding AVs, V2V and V2I technology is such that these technologies must be thoroughly reviewed and tested to maximize crash avoidance involving motorcyclists. However, the rush to market for maximization of sales of AVs without complete and competent analysis of the relationship of motorcyclist safety to the AV environment, is an invitation to injury and death.
Simultaneously, the president and Congress, along with pertinent federal agencies, must hold vehicle manufacturers and those developing this technology accountable by enacting regulations and/or guidelines that include consideration of motorcycles and motorcyclists in the development and deployment processes.
These regulations must come with sanctions to be genuinely effective at achieving the level of safety motorcyclists are entitled to whether it is in fairness for their monetary contributions to road use or more importantly enjoy the right to be safe operating on the public streets, roads and highways.
Finally, we encourage all stakeholders involved in the development, testing and rollout of AV technology to include the AMA in their efforts.