“Firms can make the decision to not comply and be within their rights to do so,” said David Strickland, general counsel for the Self-Driving Coalition for Safer Streets, who was also an NHTSA administrator between 2010 and 2014. “This is evidence of the agency’s willingness to find tools that move more quickly than traditional rule-making, which can take four to eight years.”
The document had a lot of ground to cover. “Not everybody is a well-capitalized automotive manufacturer with risk assessment built in, and not every company is a sophisticated ride-sharing company or mass innovator and disruptor,” Strickland said. “You have to build a regulatory structure that applies to four engineers in a garage. NHTSA guidance has to take into account all of that.”