November 5, Responses to Request for Information

Transcription

1 Nvember 5, 2018 Submitted via regulatins.gv U.S. Department f Transprtatin Office f the Secretary 1200 New Jersey Avenue SE West Building Grund Flr, Rm W Washingtn, DC, Re: Scpe f the Study n the Impact f Autmated Vehicle Technlgies n Wrkfrce; Request fr Infrmatin (DOT-OST ) (83 FR 50747) T Whm It May Cncern: On behalf f the Partnership fr Transprtatin Innvatin and Opprtunity (PTIO), thank yu fr the pprtunity t cmment n the Department f Transprtatin s (DOT) request fr infrmatin (RFI) regarding the cngressinally required study n the impact f autmated vehicle (AV) technlgies n the wrkfrce. PTIO whse members include the American Trucking Assciatins, Daimler, FedEx, Frd, Lyft, Tyta Mtr Nrth America, Uber, and Waym is cmprised f leaders in mbility and lgistics that are cmmitted t advancing AV technlgy in ways that imprve quality f life and ecnmic pprtunity fr all Americans. The rganizatin s cllective membership represents a variety f industry sectrs within transprtatin, including autmtive, riginal equipment, trucking, supply chain and lgistics, ridesharing and transprtatin netwrk, and technlgy. PTIO is thus wellpsitined t prvide DOT with feedback n its prpsed study and is grateful fr the pprtunity t respnd t the RFI arund DOT s statement f wrk (SOW), as well as areas f inquiry (AOIs). PTIO is cmmitted t imprving pprtunities fr wrking Americans thrugh cmmn sense adptin f AVs, while als addressing the questins and cncerns that naturally cme with any transitin. In additin t increasing access t mbility, reducing traffic fatalities, and enhancing ecnmic efficiencies, AV technlgy pssesses the ptential t imprve career prspects, pprtunities, and living standards fr Americans acrss the cuntry. Our tp pririty is t identify and encurage adptin f plicies and prgrams that will help cnnect wrkers with AV-related ecnmic benefits and ensure there are pprtunities fr all wrkers during the transitin t a future with AVs. PTIO cmmends Cngress and DOT fr their wrk n these issues as an evidence-based understanding f the interplay between AVs and the wrkfrce is fundamental t this missin. Belw are respnses t the questins psed in the RFI. 1. Is the SOW in line with public interest? Respnses t Request fr Infrmatin PTIO firmly believes the SOW is in line with public interest. Like ther technlgical revlutins, the transitin frm traditinal vehicles t AVs will nt happen vernight. This measured develpment and implementatin f AVs affrds plicymakers, industry, and cmmunities that may be impacted the pprtunity t practively prepare the wrkfrce fr a transitin. We need t develp a data-based

2 understanding f the changes n the hrizn t adequately prepare, s PTIO cmmends Cngress and DOT fr pursuing this study and urges lawmakers t cntinue t supprt research n this tpic. 2. Shuld the SOW be expanded r reduced t include r exclude any tpic(s)? The SOW divides AOIs int fur categries, tw f which are fcused n the wrkfrce labr frce transfrmatin and labr frce training needs. With respect t labr frce transfrmatin, the AOI fcuses n pace f change and defining industry segments that will likely be impacted. The labr frce training needs AOI fcuses n minimum training requirements fr new pprtunities, the ability f current prgrams t meet these training needs, and what steps are needed t address the gaps in current prgrams. PTIO ffers the fllwing recmmendatins and insight int issues where DOT, in cnjunctin with the Departments f Labr (DOL), Cmmerce, and Health and Human Services (HHS), (cllectively the agencies ) might cnsider further explratin. Labr Frce Transfrmatin In rder t adequately prepare ur wrkfrce fr AV-related changes t ur ecnmy, the gvernment and thers shuld fcus n the jb pprtunities that will arise frm AV manufacturing and deplyment, including an analysis f which jbs will be created in the different stages f AV adptin. Such infrmatin is vital in develping strategies t assist any displaced wrkers and facilitate prgressin int sustainable and prtracted career pathways. PTIO is encuraged t see an AOI regarding the impact AVs will have n different segments f cmmercial drivers. In its reprt n AVs and the wrkfrce, Securing America s Future Energy (SAFE) ntes that partial autmatin f trucks (up t Level 3) des nt reduce emplyment sme studies have even prjected increases in trucking emplyment with Level 3 autmatin. 1 Additinally, the American Center fr Mbility s (ACM) research, Preparing the Wrkfrce fr Autmated Vehicles, finds that with respect t trucking, the transitin t autmated driving is expected t be relatively gradual in a large segment f this industry and is nt expected t culminate in extensive and rapid jb cutting and will supplement, rather than substitute, vehicle peratrs. 2 Therefre, we recmmend that DOT als explre hw prgressing levels f autmatin acrss the SAE Internatinal scale 3 will impact different ccupatins including a reprt n the new jb pprtunities that may result frm each level f AV adptin as well as the likely skills required fr these new psitins. In creating a predictive statistical mdel t estimate labr frce effects, we recmmend that DOT seek industry input t develp a cmprehensive understanding f pssible AV adptin 1 SAFE, America s Wrkfrce and the Self-Driving Future, June The American Center fr Mbility, Preparing the Wrkfrce fr Autmated Vehicles, July SAE Internatinal is a glbal assciatin f engineers and related technical experts in the aerspace, autmtive, and cmmercial-vehicle industries that places a fcus n life-lng learning and vluntary cnsensus standards develpment. Mre infrmatin is available at 2

3 timelines depending n gegraphical, technlgical, and regulatry factrs. Examining hw different deplyment scenaris culd impact the labr market will be imprtant in preparing the wrkfrce fr pssible utcmes, and further explring hw each will impact regulatry and ecnmic timelines is crucial fr all stakehlders acrss federal, state, and lcal gvernments as well as industry, the educatin cmmunity, and wrkfrce develpment prviders. ACM s study, Preparing the Wrkfrce fr Autmated Vehicles, sught input frm industry leaders in varius business segments cncerning hw AVs may impact the wrkfrce. PTIO believes that DOT will realize benefit in fllwing this apprach. Labr Frce Training Needs PTIO urges the agencies t fcus the study n new, AV-related jb pathways, the skills and adjacent training needs fr these psitins, and hw gvernment, industry, and ther stakehlders can partner t deliver training and placement services fr these new careers. With respect t credentialing, ccupatinal licensing, and ther pssible barriers t emplyment, PTIO recmmends that the study: Include a detailed analysis f hw current credentialing mechanisms like CDL training can be adapted and streamlined t evlve alngside AV technlgy in ways that benefit bth incumbent and new wrkers. In ding s, the agencies shuld study hw training fr the AV wrkfrce can align and avid duplicatin with existing CDL requirements. The study als shuld identify best practices in existing CDL training and explre hw these may be replicated in an AV cntext. Cnsider barriers wrkers may face when shifting t new jbs r ccupatins as a result f ccupatinal licensing and the implicatins f jb credentialing and skills recgnitin standards. Examine ther barriers t emplyment and career entry that exist fr different demgraphic and gegraphic ppulatins within the transprtatin and driver cmmunities acrss the cuntry. Identifying and addressing these bstacles nw is critical s they d nt deter these ppulatins frm taking advantage f career pprtunities related t AV advancement. Understanding behavir and differences amng these grups culd help drive the design f future wrkfrce develpment plicies and prgrams and determine where and t which cnstituencies they are delivered. With respect t jb placement, PTIO recmmends that the study: Explre hw emplyers and industry may assist in evaluating existing federal and state gvernment-spnsred labr market prgrams used t match individuals with emplyment pprtunities and the capacity f these prgrams t meet future needs related t AV adptin. Emplyers and industry are well-psitined t help identify 3

4 where additinal r supplemental prgrams are needed and t uncver and help bridge any pssible gaps in delivery. With respect t training prgrams and reskilling effrts, PTIO recmmends that the study: Explre hw existing DOL retraining prgrams may be applied t the AV wrkfrce and subsequently ensure they are made available t individuals interested in pursuing career pprtunities enabled by AV technlgy. When cnsidering what gaps exist between current training prgrams and the needs f cmmercial and nn-cmmercial drivers (as prpsed in the SOW), als cnsider, frm a scilgical and psychlgical perspective, what mtivates incumbent wrkers t either take advantage f emplyer-prvided training and educatin benefits r seek reskilling pprtunities. PTIO believes it imperative t understand hw an individual will respnd t an evlving wrkplace and what factrs drive human behavir therein. Quality f Life Effects Due t Autmatin In acknwledging that the highest levels f autmatin may allw the driving wrkfrce t cnduct tasks ther than driving, DOT prpses t study hw this will impact the health and quality f life f the driving labr frce. Accrding t the American Trucking Assciatins (a PTIO member), America had a shrtage f 50,000 truck drivers at the end f 2017 a shrtage cmpunded by the fact that the median age f a lng-haul trucker is 49 years (seven years lder than the median U.S. wrker). 4 AV technlgy represents an pprtunity t enhance truck driving jbs and imprve wrking cnditins inherent t the nature f the industry, thereby helping t address the current driver shrtage. And by blstering safety and guarding against human errr, AV technlgy may enable quicker entry int the prfessin as many prspective drivers must currently meet insurance cmpany-impsed minimum driving experience requirements. As ACM s study ntes, AVs will likely relieve the burden f certain individuals perfrming a physically demanding jb and enhance the safety f vehicle ccupants, while als helping t supplement the needs f cmpanies, rganizatins, and individuals. 5 PTIO wuld welcme further infrmatin n the quality-f-life benefits AV technlgy may affrd truck drivers as such infrmatin is imprtant in building and preparing the wrkfrce. PTIO is encuraged t see DOT prpse t study what AV deplyment will mean fr transprtatin-disadvantaged ppulatins, such as peple with disabilities and senirs. We wuld als welcme further study arund hw AVs may serve as an emplyment enabler fr ppulatins wh lack access t public transprtatin r a persnal vehicle due t gegraphic and ecnmic reasns, and hw increasing access t mbility may supprt new AV-enabled business mdels. 4 The American Trucking Assciatins, Truck Driver Shrtage Analysis, Octber The American Center fr Mbility, Preparing the Wrkfrce fr Autmated Vehicles, July

5 3. Are there specific literature r studies that have been cnducted n this subject that DOT and DOL shuld review befre initiating this cmprehensive analysis? While PTIO is still evaluating assumptins, cnclusins, and recmmendatins in existing research, we have fund the data cllected in the fllwing studies insightful: The American Center fr Mbility (ACM), Preparing the Wrkfrce fr Autmated Vehicles. Securing America s Future Energy (SAFE), America s Wrkfrce and the Self-Driving Future. UC Berkeley Center fr Labr Research and Educatin & Wrking Partnerships USA, Driverless? Autnmus Trucks and the Future f the American Trucker. Cnclusin PTIO and its members stand ready and willing t prvide DOT with further assistance as the agency, in cnjunctin with DOL, Cmmerce, and HHS, cmmences the study. We believe that effrts t prepare the wrkfrce fr AVs require the input f a diverse range f stakehlders and cmmend the agencies fr sliciting feedback n its SOW. PTIO appreciates the pprtunity t respnd t this RFI and lks frward t cntinued cllabratin n this critical issue. Sincerely, Kathryn Bransn On behalf f The Partnership fr Transprtatin Innvatin and Opprtunity Kathryn@ulmanplicy.cm 5