Agency Information Collection Activities; Proposals, Submissions, and Approvals: Incident Reporting for Automated Driving Systems and Level 2 Advanced Driver Assistance Systems

Persistence Analytics Group LLC / United Grid supports NHTSA's objective of collecting safety-critical incident data for automated driving systems while seeking to reduce reporting burdens. The commenter argues that the reporting framework must prioritize high-quality, timely data that can identify when safety assumptions fail and ensure public transparency and data usability.

The American Association for Justice (AAJ) opposes the proposed modifications to NHTSA's information collection practices for ADS and Level 2 ADAS. They argue that the proposal would reduce the amount and type of data collected on crashes, thereby undermining public safety and making it harder for regulators to monitor the performance and risks of automated driving technologies.

The American Trucking Associations (ATA) supports the Information Collection Request to extend NHTSA’s authority to collect data on Automated Driving Systems and Level 2 ADAS. They argue that this data is necessary for monitoring safety, informing future federal frameworks for automation, and providing feedback on the performance of technologies like automatic emergency braking.

Burak Oktenli suggests two ways to streamline the incident reporting process for automated driving systems: implementing a standardized machine-readable submission schema (like JSON or XML) and allowing for event-keyed incremental updates. The commenter argues that these measures would reduce the manual transcription burden on reporting entities while improving data consistency and machine-analyzability for the agency.