The rush to market Automated Vehicles 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
reject 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.