The Legal and Policy Road Ahead: An Analysis of Public Comments in NHTSA’s Vehicle-to-Vehicle Advance Notice of Proposed Rulemaking
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The Legal and Policy Road Ahead: An Analysis of Public Comments in NHTSA’s Vehicle-to-Vehicle Advance Notice of Proposed Rulemaking
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2015
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Minnesota Journal of Law, Science & Technology
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Article
Abstract
As motor vehicle accidents have overwhelming human and economic costs, policy interventions that lower the risk of accidents have tremendous potential to improve public health and safety. One particularly promising innovation is Vehicle-to-Vehicle (V2V) communication technologies, which transmit information between nearby automobiles in order to warn drivers of an imminent collision. V2V communications may enable drivers to avoid or mitigate harmful accidents, but only if widely adopted. The National Highway Traffic Safety Administration (NHTSA) has begun planning for the implementation of V2V technology, and has recently completed the public comment period of an Advance Notice of Proposed Rulemaking (ANPRM) in preparation for rulemaking in this area.
In this Article, we qualitatively and quantitatively analyze the public comments received by NHTSA in response to its ANPRM concerning V2V communications technologies. Over 800 individuals and groups responded to the ANPRM; almost ninety-five percent of comments were provided by members of the general public. We discuss major considerations articulated by various stakeholder groups, including industry, policy advocacy groups, and the public as a whole. In particular, we focus on three concerns identified by NHTSA as potential barriers to acceptance of V2V communications technology by both interested stakeholder groups and the public: implications for privacy, threats to security, and potential liability. We then discuss the implications of our analysis for public acceptance of V2V communications technology and NHTSA’s upcoming privacy impact assessment of V2V communications devices.
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Boustead, Anne E.; Stanley, Karlyn D.. (2015). The Legal and Policy Road Ahead: An Analysis of Public Comments in NHTSA’s Vehicle-to-Vehicle Advance Notice of Proposed Rulemaking. Retrieved from the University Digital Conservancy, https://hdl.handle.net/11299/172957.
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