A version of the following public comment was submitted to the Minnesota Senate Transportation Committee on March 16, 2026.
Our assessment of Senate File 4010 is based on my more than 15 years of research on the law and policy related to driving automation. We share the sponsors’ goal of enabling access to this safety-enhancing technology in Minnesota and believe SF 4010 strikes the appropriate balance.
Specifically, we find:
- The definitions of key terms such as “automated driving system” and “dynamic driving task” conform to the international consensus technical standard, SAE International Recommended Practice J3016, Taxonomy and Definitions for Terms Related to Driving Automation Systems for On-Road Motor Vehicles;
- Required submission of first responder interaction plans to the Department of Public Safety will enable adherence to the Automated Vehicle Safety Consortium (AVSC) Best Practice for First Responder Interactions with Fleet-Managed Automated Driving System-Dedicated Vehicles (ADS-DVs) (AVSC-I-01-2024);
- Collision reporting requirements avoid duplicating or contradicting the federal data reporting mandate established by the National Highway Traffic Safety Administration’s Standing General Order 2021-01;
- Financial responsibility requirements are consistent with the state of practice in the United States;
- Clarification of human-specific provisions related to the operation of commercial motor vehicles and equipment requirements reflects best practices; and
- Establishing a statewide autonomous vehicle policy on the basis of nondiscrimination preserves traditional local government and airport authorities to manage roadways and traffic.
Thank you for the opportunity to submit this written testimony on SF 4010, and we welcome the opportunity to advise the legislature on this subject in the future.