Driverless Vehicles: The Leading Nations for Testing Without a Human Driver

Anurag Maheshwary

Anurag Maheshwary is an attorney at a federal government agency. All viewpoints here are those of Mr. Maheshwary.

The race to develop the first driverless vehicles (i.e., NHTSA Level 4 and SAE International Standard J3016 Level 5) has spurred a fierce competition, not just among industry stakeholders, but also among jurisdictions vying furiously to establish themselves as the premier global test-bed for such technology. Although many jurisdictions have adopted a formal framework to permit testing driverless vehicles when a human driver is present, few, if any, have addressed testing without human driver presence. Over the past year, however, a frenzy of developments has occurred in jurisdictions worldwide that may soon enable driverless vehicles to be tested without human drivers. This survey highlights some recent developments in jurisdictions that have adopted a formal framework (comprising regulatory, legislative, and/or quasi-regulatory actions) that addresses public road testing or mass deployment of driverless vehicles without human presence. The survey compares and contrasts differing approaches among jurisdictions and ranks them according to their “testing friendliness” from the perspective of industry stakeholders. Finally, the survey concludes that although some U.S. states were the early global leaders, that lead is in danger of being eclipsed by other jurisdictions that are quickly catching up.

I. New Zealand: The World’s Most Testing-Friendly Jurisdiction — For Now

In what seems to be a well-kept secret, New Zealand — yes, New Zealand — appears to be the world’s most testing friendly jurisdiction. In February 2016, the New Zealand Ministry of Transport issued guidelines entitled, “Testing Autonomous Vehicles in New Zealand” that set forth prerequisites for stakeholders seeking to test driverless vehicles.[1] Among them are liability and indemnity insurance, submission of a “safety management plan” setting forth a description of the technologies being tested, a summary of prior private testing thereof, a log of incidents that occurred during testing, and compliance with (or application for exemption from) applicable regulations.[2] Upon satisfaction of these conditions, New Zealand will permit testing on any public roads without restriction. In contrast to other jurisdictions that have adopted traditional rulemaking or legislative tools to enable testing (see below), New Zealand has adopted a purely “quasi-regulatory” approach (e.g., government-issued guidelines, policy statements, and exemptions from vehicle standards).

While New Zealand’s approach is unique, what truly distinguishes the country is its express proclamation that existing laws do not require a human driver to be present in the vehicle: “A particular advantage of testing autonomous vehicles in New Zealand is that our legislation does not explicitly require a vehicle to have a driver present . . . . So long as any testing is carried out safely, a truly driverless vehicle may be tested on public roads today.”[3] Granted, the guidelines are silent as to whether existing laws implicitly require human driver presence. However, the guidelines’ plain language and multiple references to testing without human driver presence show a clear intent to allow such testing.[4] Moreover, the guidelines encourage stakeholders to seek exemptions from provisions in vehicle standards “where requirements are clearly unreasonable or inappropriate,” suggesting a willingness to remove implicit barriers to testing driverless vehicles.[5] With respect to deployment, however, New Zealand has not proposed any enabling initiatives, opting instead to monitor international developments and respond when appropriate.[6]

New Zealand’s newly issued testing guidelines specifically encourage testing of driverless vehicles without human driver presence. Although there is an open question as to whether implicit regulatory barriers exist, New Zealand’s willingness to entertain exemptions suggests an openness to address that issue quickly. Arguably, for those seeking to test a truly driverless vehicle today, New Zealand is the most testing-friendly venue in which to do so.

II. U.K.: Runner-Up

After New Zealand, the U.K. appears to be the world’s second most testing-friendly venue. The U.K. has been aggressively developing a quasi-regulatory approach to facilitate testing of autonomous vehicles, publicly declaring its goal of becoming the global leader in this area. Since 2015, the U.K. has issued several policy guidance documents to achieve this goal. In February 2015, the U.K. Department for Transport issued a report entitled, “The Pathway to Driverless Cars: A Detailed Review of Regulations for Automated Vehicle Technologies.”[7] This report summarized findings of an audit of existing U.K. motor vehicle regulations, which was tasked with identifying regulations that were incompatible with the testing of autonomous vehicles. The audit report concluded that existing regulations permit such testing on public roads, provided that a human driver is present in the vehicle.[8] Importantly, no certifications, permits, or posting of bonds are required to commence testing, which are significant burdens imposed by many other jurisdictions. Finally, the U.K. committed to issuing detailed testing guidelines in collaboration with stakeholders. Notably, the U.K. touted its “light touch/non-regulatory approach” as “quicker to establish, more flexible and less onerous for those wishing to engage in testing than the regulatory approach being followed in other countries, notably in the U.S.”[9]

In July 2015, the U.K. issued its testing guidelines in a report entitled, “The Pathway to Driverless Cars: Code of Practice for Testing.”[10] Although non-statutory, the U.K. clearly intended the testing guidelines to be affirmative proscriptions, warning that non-compliance would constitute negligence.[11] The guidelines established detailed requirements for driver licensing and training, documentation of prior in-house testing on closed roads, data recording devices, data privacy and cybersecurity protections, among other things. But most critically, the guidelines appear to soften — or depart completely from — the audit report’s earlier requirement of human presence. The guidelines provide that either a human driver or a “test operator . . . who oversees testing . . . without necessarily being seated in the vehicle” shall supervise testing and be able to override autonomous mode at any time and take control of the vehicle.[12] This conflicts directly with the audit report, which provides that “[r]eal-world testing . . . is possible . . . providing a test driver is present and takes responsibility for the safe operation of the vehicle.”[13] It is unclear how to resolve this conflict. Still, given that the audit report predates and defers to the guidelines for establishing testing requirements, driverless vehicles without a human driver present arguably could be tested so long as a remotely located human supervisor is capable of taking control of the vehicle. As with New Zealand, stakeholders should consider seeking interpretations or exemptions to resolve this ambiguity.

In contrast to its quasi-regulatory approach to enable testing driverless vehicles without human driver presence, the U.K. recognizes that deployment would require regulatory and legislative actions, and the country has established a roadmap for doing so. By summer 2017, the U.K. aims to identify necessary regulatory reforms, and by the end of 2018, it would complete an assessment concerning the need for enabling legislation.[14] Overall, the U.K.’s testing guidelines raise the tantalizing prospect of testing driverless vehicles without human driver presence, pending resolution of conflicting guidance in the audit report. A resolution endorsing the view set forth in the guidelines could establish the U.K. as a leading testing-friendly jurisdiction in the near term, as well as a leading venue for deployment in the longer term.

III.      U.S.: Federal Leadership vs. State Patchwork Quilt 

At the state level, the U.S. was the pioneer in evangelizing autonomous vehicle testing. In 2011, Nevada became the world’s first jurisdiction to adopt a formal regulatory framework permitting testing on public roads. As of this writing, three states (Florida, California, and Michigan) and the District of Columbia have adopted formal frameworks explicitly permitting such testing, and many others are currently considering regulation and/or legislation. Collectively, roughly two dozen states have proposed more than fifty bills varying widely, resulting in inconsistency and confusion.[15] For example, Michigan restricts testing to OEMs, California requires the posting of a $5 million bond, and Nevada requires the presence of two licensed individuals in the vehicle, storage of pre-collision sensor data, special license plates, and geographic restrictions on testing.[16] This fractured approach has created a regulatory “patchwork quilt” that impedes testing, and it is largely due to an absence of comprehensive federal guidance. However, recent NHTSA announcements and actions aim to resolve this regulatory morass and create a uniform national policy. A summary follows.

A. Federal: A New, Uniform Approach May Soon Provide Leadership

In January 2016, Transportation Secretary Anthony Foxx unveiled the Department’s new strategy for autonomous (i.e., NHTSA Level ≤ 3 and SAE J3016 Level ≤ 4) and driverless vehicles, comprising various announcements and milestones that NHTSA committed to meeting this year. Among them, first, by July, NHTSA would propose guidelines regarding the deployment of driverless vehicles, along with a common understanding of requisite performance criteria and test procedures needed to assess them. Second, by July the agency would release a model state policy concerning both testing and deployment of autonomous and driverless vehicles that offers a path to consistent national policy. Third, NHTSA acknowledged that its existing legal authority is likely insufficient to support mass deployment of autonomous vehicles, “including those designed without a human driver in mind,” and stated that it would consider seeking additional authority via legislation or initiating rulemaking. Finally, Secretary Foxx encouraged stakeholders to seek FMVSS interpretations or exemptions, where appropriate, to facilitate testing or deployment of driverless vehicles — including those without human driver presence.[17] With these announcements, the U.S. has committed to a comprehensive framework to accelerate the advent of truly driverless vehicles.

Next, in a February 2016 letter, NHTSA responded to a rule interpretation request from Google concerning the definition of the term “driver” for purposes of compliance with certain FMVSS provisions.[18] In a major policy shift that may have a significant impact on enabling driverless vehicles, NHTSA interpreted “driver” broadly to include an artificial-intelligence self-driving system, which opened the door to legal recognition of truly driverless vehicles for the first time.[19] However, the agency cautioned that until it develops performance criteria and test procedures for evaluating whether a self-driving system meets various FMVSS provisions, it could not categorically interpret self-driving systems as compliant with existing regulations.[20] The agency allowed that some FMVSS provisions could be addressed in the short term via requests for interpretations and petitions for exemptions, but cautioned that other provisions, such as requirements for manual controls, would require a traditional regulatory solution.[21]

In March 2016, the DOT issued a preliminary report entitled, “Review of Federal Motor Vehicle Safety Standards (FMVSS) for Automated Vehicles,” which summarized results of an audit of existing FMVSS provisions.[22] One purpose of the audit was to identify standards that include references, both implicit and explicit, to a human driver that could impede deployment of driverless vehicles.[23] The audit report painstakingly examined each of the 73 standards specified in the FMVSS and identified specific provisions that could be problematic. Among other things, the audit found that although few existing regulations would hinder deployment of autonomous vehicles designed for human driver presence, vehicles without human drivers or manual controls would indeed conflict with FMVSS provisions or policy objectives.[24] However, the DOT noted that its analysis predated NHTSA’s interpretation of the definition of “driver” and therefore did not reflect this development.[25]

Together, imminent federal guidance documents, results of the regulatory audit, and NHTSA’s innovative interpretation of “driver” show leadership that may establish the U.S. as among the world’s preeminent venues for both testing and deployment of truly driverless vehicles. In the near term, NHTSA’s quasi-regulatory approach should help harmonize conflicting state approaches, resulting in a consistent and uniform national policy. Longer term, contemplated legislative and rulemaking efforts should facilitate deployment.

B. States

1.    Florida: Soon to Become the Leader?

In 2012, Florida became the second state (after Nevada) to permit operation of autonomous vehicles on public roads. However, it placed onerous restrictions on those wishing to do so, including: restricting operation to testing only, restricting testing to either OEMs or educational institutions, requiring the presence of a human driver, and requiring either proof of insurance or a bond in the amount of $5 million.[26]

In April 2016, however, Florida enacted H.B. 2027, which was a sweeping expansion of the permissible uses of autonomous vehicles on public roads.[27] Among other things, the legislation jettisoned all of the foregoing limitations — including the requirement of human presence. Theoretically, removal of this limitation would enable driverless vehicles without human driver presence to be tested or deployed on Florida roads. It remains to be seen, however, whether implicit Florida or federal regulations would thwart such testing or deployment. Still, if stakeholders are able to obtain favorable regulatory interpretations or exemptions, Florida may have catapulted itself to the status of being among the world’s most testing-friendly venues. The legislation takes effect on July 1.

2. California: Soon to Become the Laggard?

California is one of the world’s only jurisdictions to develop regulations for the deployment of autonomous vehicles. In December 2015, California released draft rules that address only the transition from testing to deployment, but not full deployment.[28] The rules would require, among other things, manual controls, human driver presence, new safety and performance requirements, certifications from third-party testing organizations, regular submission of usage reports, and restriction of distribution to leases, not sales.[29] Unsurprisingly, many stakeholders have criticized the proposed rules harshly as unnecessarily restrictive and likely to stifle development of autonomous technologies. In particular, critics have condemned the requirements for human drivers and manual controls, contending that if finalized, such restrictions would deter firms from deploying — or even testing — driverless vehicles in California.

Echoing these concerns, in February 2016, legislators introduced bill A.B. 2866 in the California State Assembly, which amounts to a full frontal assault on many of these restrictions in the draft regulations.[30] Among other things, the bill would overturn the proposed requirements for human presence and manual controls, and it directs California, by July 2018, to adopt regulations expressly permitting the testing and deployment of driverless vehicles without human drivers or manual controls. The bill would also expressly permit public road testing and deployment of driverless vehicles upon adoption of the new regulations.[31] The bill is currently in the embryonic stages of the legislative process. Until it is enacted, however, California’s strict regulatory approach has brought with it the dubious distinction of being the least hospitable jurisdiction in this survey in which to test truly driverless vehicles.

IV. Australia: The Most Comprehensive Approach Yet

In November 2015, Australia launched a comprehensive plan to enable testing and deployment of autonomous and driverless vehicles. The plan sets forth specific milestones, including auditing all relevant federal and state laws and regulations to identify potential barriers to testing and deployment, recommending remedial actions, and commencing some preliminary reforms. Australia has set an aggressive timeline to achieve these milestones — just over one year.[32]

The first fruit of this effort was borne in February 2016, when Australia’s National Transport Commission (“NTC”) issued an initial report entitled, “Regulatory Barriers to More Automated Road and Rail Vehicles Issues Paper.”[33] The report provided an overview of Australia’s existing regulatory landscape and identified key issues that could impede testing and deployment of autonomous and driverless vehicles. The report concluded that although most aspects of its existing regulatory framework are unlikely to impede driverless vehicles, still other potential barriers exist. In particular, the NTC noted that “the most significant barrier[s]” were some federal and state laws, as well as vehicle safety and performance standards, that implicitly require human driver presence.[34] The report identified several additional categories of potential barriers, including: ambiguity in the definition of “control” concerning who or what is in “control” of an autonomous vehicle, liability issues, and data privacy and access thereto.[35] The NTC painstakingly examined the proper role of government in removing the foregoing barriers, and considered whether the optimum approach should involve rulemaking, legislation, or a quasi-regulatory approach. Ultimately, the NTC cautioned against a rush to rulemaking or legislation at this time, fearing that such processes could chill innovation in this rapidly evolving technological area, devolving into a U.S.-style regulatory patchwork quilt.[36]

In May 2016, the NTC issued a follow-up report entitled, “Regulatory Options for Automated Vehicles.”[37] Analogous to audits conducted by the U.K. and U.S., Australia audited relevant laws and regulations and identified specific provisions — 716 in total — that were potential barriers to testing and deployment.[38] It also proposed recommendations to address these issues, which are subject to revision based on upcoming public comments. Importantly, these reforms would be coordinated at the federal and state levels, in contrast to the current approach in the U.S. The remedies differ in purpose and scope and would phase-in over five years. Phase 1, which would commence as soon as possible, would facilitate testing of driverless vehicles and deployment of autonomous vehicles by introducing national guidelines to support a uniform approach to testing and state-based exemptions to existing standards, as well as clarifying the meaning of “control.” Phase 2, which would commence within two years, would enable deployment of driverless vehicles via new legislation expanding the definition of “driver” to include autonomous driving systems, providing a “safety assurance framework” for autonomous vehicles, among other things. Finally, Phase 3, which would commence within three to five years, would initiate rulemaking to remove implicit references in vehicle standards to human drivers and manual controls, and issue new standards governing cybersecurity, data privacy, and other issues.[39] The NTC will make final recommendations to federal and state transportation ministers in November 2016, and in December 2016, the agency will issue a final report summarizing the direction chosen by the ministers.[40]

Australia has embarked on an ambitious journey that may establish it as a preeminent jurisdiction in which to both test and deploy truly driverless vehicles. Under its proposed regulatory reforms, public road testing of vehicles without human drivers could commence almost immediately, and full deployment may be possible in 2020. Like the U.S., Australia has embraced the idea that the term “driver” in vehicle standards should not be narrowly confined to humans, and instead should be broadened to include autonomous systems — a critical recognition made by no other major jurisdictions. However, unlike efforts in the U.S., Australia’s blueprint proposes comprehensive, coordinated reforms at the state and federal levels, which should provide greater uniformity and clarity. Coupled with Australia’s phased approach to reforms — ranging from a quasi-regulatory approach in the short term, to legislative amendments in the medium term, to initiating rulemaking in the long term — Australia’s overall framework is an innovative solution that should provide clarity and predictability to industry stakeholders seeking to test or deploy truly driverless vehicles.

V. Canada: Last Among the G7

Among G7 nations, Canada is farthest behind in developing a formal regulatory framework for testing autonomous vehicles and has no plans specific to driverless vehicles.[41]  (Canada is included in this survey due solely to its geographic and economic proximity to the U.S.)  However, recent developments show that Canada is keen to shed that status.  In January 2016, Ontario established a pilot testing program, making it the first province to enable public road testing of autonomous vehicles.^[42]  Under the 10-year pilot, a human driver must be present in the vehicle, and a certification of insurance of $5 million is required; no special permits, license plates, identifiers, or other onerous conditions are imposed.[43]  Notably, the application process is highly streamlined, consisting of an online, single-page form that does not require submission of any supporting documentation.[44]  Applicants are simply required to certify, by clicking a checkbox on the form, that they have reviewed the requirements set out in applicable regulations.[45]  This simplified online form is a unique and innovative feature that should facilitate participation in testing.  Although Canada has not yet adopted a formal framework specific to driverless vehicles, Ontario’s actions have already catapulted itself ahead of many U.S. states with respect to testing autonomous vehicles and may hasten development of a federal approach for testing truly driverless vehicles.

VI. Conclusion

An analysis of recent international developments to facilitate testing driverless vehicles without human driver presence shows a continuum of widely varying regulatory approaches. At opposite ends of the spectrum are New Zealand, with its freewheeling, quasi-regulatory approach, and California, with its rigid, traditional rulemaking approach. Occupying the white space in the middle are the U.K., U.S. (federal), and Australia, which are following hybrid frameworks, consisting of a quasi-regulatory approach in the short term, with legislation and rulemaking contemplated in the longer term.

For those seeking to test a truly driverless vehicle today, New Zealand (and perhaps Florida beginning in July) is the most testing-friendly venue in which to do so, although there remains an open question concerning the existence of potential implicit regulatory barriers. The U.K. appears to be the runner-up, as it ostensibly permits testing by a remotely located driver, but a conflict in the relevant guidance documents needs resolution. In the U.S., a regulatory patchwork quilt at the state level, together with recent federal pronouncements, create much uncertainty. However, if imminent federal guidance resolves the regulatory quagmire, the U.S. may be poised to lead. Finally, the Land Down Under is perhaps the most interesting. Although Australia’s legal landscape bans testing vehicles without human driver presence, its proposed reforms, which comprise a comprehensive, coordinated effort at the federal and state levels, are broader and deeper in scope than those of the U.S. and ultimately may yield the most promising outcome for stakeholders seeking to test truly driverless vehicles. Overall, although much uncertainty persists from developments over the previous twelve months, the next twelve are certain to be even more momentous.

Anurag Maheshwary is an attorney at a federal government agency.  Previously, he was an associate at White & Case LLP, and a law clerk in the U.S. District Court for the Middle District of Florida.  Prior to his legal career, Anurag was an automotive engineer at Freightliner Corp.  Anurag holds a J.D. from Boston University School of Law, an M.S. in Mechanical Engineering from Virginia Tech, and a B.S. in Mechanical Engineering from North Carolina State University.  He can be contacted at AnuragMaheshwary.Esq@gmail.com.

This article first appeared in the American Bar Association’s Transportation Quarterly.

Photo – Supreme Court by Brittany Hogan, 2005.

Relief map of Australia by Hans Braxmeier, 2008.

Footnotes

[1] N.Z. Ministry of Transp., Testing Autonomous Vehicles in New Zealand (Feb. 2016), http://www.transport.govt.nz/ourwork/technology/specific-transport-technologies/road-vehicle/autonomous-vehicles/testing-autonomous-vehicles-in-nz/.

[2] Id. at 3-5.

[3] Id. at 1.

[4] See id. at 1 & 5.

[5] Id. at 4.

[6] N.Z. Ministry of Transp., Intelligent Transport Systems Technology Action Plan 2014-18, at 25 (May 2014), www.nzta.govt.nz/vehicles/vehicle-types/automated-and-autonomous-vehicles/testing-autonomous-vehicles-in-new-zealand.

[7] U.K. Dep’t for Transport, The Pathway to Driverless Cars:  A Detailed Review of Regulations for Automated Vehicle Technologies (Feb. 2015), https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/401565/pathway-driverless-cars-main.pdf [hereinafter U.K. Audit Report].

[8] Id. at 10.

[9] Id. at 11.

[10] U.K. Dep’t for Transp., The Pathway to Driverless Cars:  A Code of Practice for Testing (July 2015), https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/446316/pathway-driverless-cars.pdf [hereinafter U.K. Testing Guidelines].

[11] U.K. Audit Report, supra note 7, at 118.

[12] U.K. Testing Guidelines, supra note 10, at ¶ 2.11.

[13] U.K. Audit Report, supra note 7, at 10.

[14] Id. at Annex D, Rows 17 & 21.

[15] See Autonomous/Self-Driving Vehicles Legislation, http://www.ncsl.org/research/transportation/autonomous-vehicles-legislation.aspx (last visited May 26, 2016).

[16] See id.

[17] Press Release, U.S. Dep’t of Transp., Secretary Foxx Unveils President Obama’s FY17 Budget Proposal of Nearly $4 Billion for Automated Vehicles and Announces DOT Initiatives to Accelerate Vehicle Safety Innovations, DOT Press Release 02-16 (Jan. 14, 2016), http://www.nhtsa.gov/About+NHTSA/Press+Releases/dot-initiatives-accelerating-vehicle-safety-innovations-01142016.

[18] Letter from Paul A. Hemmersbaugh, Chief Counsel, NHTSA, to Chris Urmson, Director, Self-Driving Car Project, Google (Feb. 4, 2016), http://isearch.nhtsa.gov/files/Google%20-%20compiled%20response%20to%2012%20Nov%20%2015%20interp%20request%20-%204%20Feb%2016%20final.htm.

[19] Id.

[20] Id.

[21] Id.

[22] Dep’t of Transp., Review of Federal Motor Vehicle Safety Standards (FMVSS) for Automated Vehicles (Mar. 2016), http://ntl.bts.gov/lib/57000/57000/57076/Review_FMVSS_AV_Scan.pdf.

[23] Id. at 20.

[24] Id. at ix.

[25] Id.

[26] Fla. Stat. § 316.86 (2015).

[27] H.R. 7027 (Fla. 2016) (as passed by House, Mar. 11, 2016).

[28] Cal. DMV, Autonomous Vehicles Express Terms (proposed Dec. 16, 2015), https://www.dmv.ca.gov/portal/wcm/connect/ed6f78fe-fe38-4100-b5c2-1656f555e841/AVExpressTerms.pdf?MOD=AJPERES.

[29] See id.

[30] Assemb. B. 2866 (Cal. 2016) (as referred to Comm. on Appropriations, Apr. 19, 2016), http://leginfo.legislature.ca.gov/faces/billHistoryClient.xhtml?bill_id=201520160AB2866.

[31] See id.

[32] Austl. Nat’l Transp. Comm’n, Regulatory Barriers to More Automated Road and Rail Vehicles Issues Paper 5 (Feb. 2016), http://www.ntc.gov.au/Media/Reports/(66E42530-B078-4B69-A5E3-53C22759F26E).pdf [hereinafter Austl. Preliminary Report]; Austl. Nat’l Transp. Comm’n, Regulatory Options for Automated Vehicles 9 (May 2016), http://www.ntc.gov.au/Media/Reports/(049B1ED1-5761-44D5-9E3C-814A9195285D).pdf [hereinafter Austl. Audit Report].

[33] See Austl. Preliminary Report, supra note 32.  The NTC is an independent, inter-governmental agency that develops and submits recommendations to the Transport and Infrastructure Council, which comprises transportation ministers from the federal and state levels.

[34] Id. at 7.

[35] Id. at 7-10.

[36] Id. at 22-24.

[37] Austl. Audit Report, supra note 32.

[38] Id. at Annex, http://www.ntc.gov.au/Media/Reports/(264DF9EA-6247-42C9-8D07-F39E76E95258).pdf.

[39] Id. at 9-12.

[40] Id. at 25.

[41] Canadian Automated Vehicles Ctr. of Excellence, Preparing for Autonomous Vehicles in Canada 5 (Dec. 16, 2015), http:// www.cavcoe.com/Downloads/CAVCOE_AV_White_Paper.pdf.

[42] News Release, Can. Ministry of Transp., Ontario First to Test Automated Vehicles on Roads in Canada (Oct. 13, 2015), https://news.ontario.ca/mto/en/2015/10/ontario-first-to-test-automated-vehicles-on-roads-in-canada.html.

[43] Ont. Regulation 306/15 (2016), https://www.ontario.ca/laws/docs/150306_e.doc.

[44] Gov’t of Ont., Automated Vehicle (AV) Pilot Application Form, http://www.forms.ssb.gov.on.ca/mbs/ssb/forms/ssbforms.nsf/GetFileAttach/023-5084E~1/$File/023-5084E.pdf.

[45] Ont. Regulation 306/15 (2016), https://www.ontario.ca/laws/docs/150306_e.doc.