OOIDA to USDOT on AI: Proceed with Caution

The regulatory approach taken by the Department could have very large ramifications for the deployment of technologies such as autonomous vehicles

Regulatory comments submitted by the Owner-Operator Independent Drivers Association regarding the US Department of Transportation’s approach to Artificial Intelligence. The regulatory approach taken by the Department could have very large ramifications for the deployment of technologies such as autonomous vehicles.

Key excerpt below and included the entirety of our comments, as well. All comments submitted are public and can be found at regulations.gov HERE.

The most prominent application for AI within trucking will likely be in the development of autonomous vehicles (AVs). Despite the various claims that AVs will lead to zero deaths, there continue to be real-world situations in which automation has devastatingly failed. For truckers who must share the road with these vehicles to do their job, an accident caused by autonomous technology could put them out of business and cause serious injury or death. Unfortunately, mostly voluntary reporting requirements have left truckers and the general public in the dark about the safety and reliability of autonomous technologies to this point. OOIDA has urged DOT to develop AV standards that are based on documented research and testing data. OOIDA supports mandatory testing, safety, and crash reporting requirements that provide the public with direct and easy access to information about AV performance. Many of these same recommendations would be necessary to ensure AI safety and oversight.

Re: Docket # DOT-OST-2024-0049, “Request for Information: Opportunities and Challenges of Artificial Intelligence in Transportation”

Dear Mr. Hampshire:

The Owner-Operator Independent Drivers Association (OOIDA) is the largest trade association representing the views of small-business truckers and professional truck drivers. OOIDA has approximately 150,000 members located in all fifty states that collectively own and operate more than 240,000 individual heavy-duty trucks. OOIDA’s mission is to promote and protect the interests of its members on any issues that might impact their economic well-being, working conditions, and the safe operation of commercial motor vehicles (CMVs) on our nation’s highways.

The potential applications of Artificial Intelligence (AI) will likely play a role in developing transportation policy as AI technology evolves. However, we caution against embracing any unproven and unreliable AI innovations that will not accomplish safety objectives. Rushing to introduce or mandate such “innovations” has not resulted in touted highway safety benefits and forced many experienced truck drivers out of the industry because they can’t afford the costs of the equipment.

Certainly, the broader evolution of technology has led to safer trucks that are physically easier to drive along with numerous other improvements. However, some emerging technologies have proven to distract drivers, do not work as designed, or are simply too expensive an investment for small-business trucking companies. We expect there could be a multitude of benefits emerging from AI, but it’s yet unclear how such applications will be implemented throughout the supply chain and/or how they will be adopted by motor carriers. At the same time, AI presents various ethical, operational, cybersecurity, and further unknown challenges that merit comprehensive consideration.

The most prominent application for AI within trucking will likely be in the development of autonomous vehicles (AVs). Despite the various claims that AVs will lead to zero deaths, there continue to be real-world situations in which automation has devastatingly failed. For truckers who must share the road with these vehicles to do their job, an accident caused by autonomous technology could put them out of business and cause serious injury or death. Unfortunately, mostly voluntary reporting requirements have left truckers and the general public in the dark about the safety and reliability of autonomous technologies to this point. OOIDA has urged DOT to develop AV standards that are based on documented research and testing data. OOIDA supports mandatory testing, safety, and crash reporting requirements that provide the public with direct and easy access to information about AV performance. Many of these same recommendations would be necessary to ensure AI safety and oversight.

Currently, it is difficult to fully understand what role AI will serve for the trucking industry. AI has the potential to drastically change the transportation sector, among others, but there must be safeguards in place that protect small-businesses, the trucking workforce, and consumers. Emerging technologies hold the potential for improving safety, lowering costs, and enhancing efficiency, but DOT must ensure that future policies result in safe, secure, affordable, and equitable deployment of new innovations.

Thank you,

Todd Spencer

President & CEO

Owner-Operator Independent Drivers Association, Inc.

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