A version of the following public comment was submitted to members of the Maryland Senate Judicial Proceedings Committee on March 2, 2026.
Our assessment of SB 909 is based on my more than 15 years of research on the law and policy related to driving automation. We share the goal of the sponsors to enable access to this safety-enhancing technology in Maryland, and believe SB 909 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 Motor Vehicle Administration 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 statewide autonomous vehicle policy on the basis of nondiscrimination preserves traditional local government authorities to manage roadways and traffic.