It’s too early to know if Pennsylvania will have federally designated “proving grounds” for self-driving cars or if state lawmakers will pass laws regarding the vehicles this session.
But two recent PennDOT documents provide glimpses into what the contract process might be for both new and current (such as Uber) testers of self-driving vehicles in the state. That process could vary depending on if the self-driving vehicle is at a “proving ground” facility, on public roads — or both.
Testing at a Proving Ground
Earlier this week, PennDOT announced that it submitted a plan for Pittsburgh, Penn State and the Pocono Raceway to become federally designated “automated vehicle proving grounds.” The U.S. Department of Transportation is expected to make site selections in the first quarter of this year.
PennDOT’s application stressed how streamlined the process would be and wrote that this “proposed framework minimizes any bureaucratic processes that could squelch or discourage testers interested in testing HAVs in Pennsylvania.”
State law currently allows self-driving cars to be tested here as long as a licensed driver is in the driver’s seat. The proving ground designation wouldn’t change that law, so Uber could continue operating in Pittsburgh. Uber could, however, go through the contract process if it wanted to be part of the pilot program, which would allow Uber to share data and safety practices with the state and federal transportation departments and other testers.
If PennDOT’s proposal is accepted, this is how testers of self-driving vehicles would get a contract to use the proving grounds.
Step 1: Start with a Pennsylvania Proving Ground’s Testing Self-Assessment. According to the PennDOT application, the assessment could be through an online platform and in checklist format. It would help the tester select which facility to use.
Step 2: Select a facility or ask the Pennsylvania Proving Ground Safety Advisory Committee for its recommendation(s). The committee would be similar to the state Automated Vehicle Policy Task Force, which has representatives from industry, academia and government, according to the application. Here are the facility choices and what they’d offer.
- Western Testing Facility, Pittsburgh — Offers live traffic on public facilities, an urban environment, connected signals and experience with bridges and tunnels
- Central Testing Facility, Penn State — Offers a closed track, low speeds, transit and commercial vehicle testing, and controlled safety crashes
- Eastern Testing Facility, Pocono Raceway — Offers a closed track, as well as high speed and platooning testing, and other testing upon request
Step 3: Once the tester has a facility selected, the contract would be directly between the testing facility and the tester.
Testing on a Pa. Highway
Last month, the state Automated Vehicle Policy Task Force gave recommendations to PennDOT Secretary Leslie S. Richards on what should be required for testers to be on public roadways.
The recommendations aren’t a final policy — the state is collecting feedback until Jan. 12 — and there could still be revisions. Plus, the policy can’t be permanent until after new legislation regarding testing on public roadways is passed.
That legislation could impact Uber, and the company would have to follow whatever requirements the new law has for testers already here.
If the contract process stays as is in the current recommendations, this is how the contract process would work for testers who want to be on state roadways.
Step 1: A tester would submit a proposal to PennDOT. Existing testers will have 90 days to submit a testing proposal and can continue testing during this process. The proposal would include:
- Proof the tester has met all requirements of state legislation on self-driving vehicle testing and other applicable state laws, as well as all Federal Motor Vehicle Safety Standards and federal laws.
- An Operation Design Domain for each self-driving vehicle on a public roadway. This includes information about the vehicles’ capabilities on various types of roads, speed range, geographic areas and other constraints. If this document changes after a contract is issued, the tester must notify PennDOT.
- Information about the tester including company name, address and phone number for its headquarters, a principal contact for the testing project with address and phone number; names of in-vehicle or remote operators
- A list of vehicles being tested and their unique identifying information
- Safety override features and use of cybersecurity best practices
- Proper registration and title, as well as valid safety inspection
- Indicators for when the vehicle is in self-driving mode, and in the case of vehicles that are always in self-driving mode and have no operator inside, an exterior indicator
Step 2: Once PennDOT receives the proposal, the department would have 10 business days to approve or decline it or request clarification. PennDOT would consult Pennsylvania State Police and, as needed, other state and federal government agencies in its review of proposals.
- If approved, PennDOT would give a temporary letter of authorization to test while the contract execution process takes place.
- If declined, PennDOT would give the tester a written explanation as to why and the tester gets 30 days to appeal to Richards.
- If clarification is needed, PennDOT would outline its request, and the tester gets 30 days to respond. Once PennDOT has the response, it has five business days to make a decision or ask for more clarification
Step 3: Once the tester is approved, a contract would be created between the tester and PennDOT (as well as the turnpike commission if needed.) PennDOT will issue a testing permit for each test vehicle. An example of the contract was included in the policy recommendations, which you can read here.