Impacts of Laws and Regulations on CV and AV Technology Introduction in Transit Operations (2017)

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IMPLEMENTATION OF RESEARCH 90 IM P L E M E N T A T IO N O F R E S E A R C H F IN D IN G S A N D P R O J E C T S

IMPLEMENTATION OF RESEARCH 91 AV Technology Evolution in Transit Actions identified related to technology include: 1. Assessment of restrictions on transit platooning strategies 2. Research identifying possible changes to transit facilities and stations 3. Research on transit vehicle sizing, dynamic “entrainment,” and other innovations enabled by automation 4. Research on design of platform edge protection and automated entry for vehicle berths Assessment of Restrictions on Transit Platooning Strategies Description – Platooning of transit vehicles has been demonstrated as feasible more than 14 years ago. Several states have restrictions on following distances that may preclude platooning of vehicles at short headways. This applies to both trucks and buses. AV/CV technologies enable platooning of vehicles that can have many benefits including fuel usage and increased capacity, without need for articulated coaches in BRT guideways. This review of existing regulations would focus on identifying the safety case for relaxation of such restrictions to deliver the anticipated benefits. Differences between truck and bus platooning would also be highlighted. Urgency – May resolve naturally as the trucking industry demonstrates that platooning has significant benefits for interstate travel. Not a critical path element, but worthy of attention in 2018-2020 time frame. Related activities – Studies on virtual entrainment, design of multi-berth stations, and use of AV for high-speed BRT Budget/Schedule – Small-scale study, $150K, nine months Changes to Transit Facilities and Stations Description – Dynamic-dispatch, direct route systems of smaller shuttle-type vehicles will likely need station and intermodal center designs that are much different from existing transit facilities. AV transit vehicles without human attendants will need station designs that safely accommodate all types of passengers. Urgency – AV transit shuttle systems are not yet proven at speeds that can perform as large- scale revenue service systems without dedicated guideways. As transit agencies gain more experience with small-scale point-to-point systems and simple loops, this issue will be more relevant as network possibilities are realized. 2020-2022 target date. Related activities – Studies on virtual entrainment, design of multi-berth stations, and use of AV for high-speed BRTs Budget/Schedule – Medium-scale study, $1M, 18 months

IMPLEMENTATION OF RESEARCH 92 Transit Vehicle Sizing, Entrainment, and Other Innovations Description – Dynamic-dispatch, direct route systems of smaller shuttle-type vehicles may allow new concepts such as virtual entrainment that can increase capacity of highly traveled routes without operation of today’s traditional coaches, articulated coaches, or even light rail. Groups of smaller vehicles may be able to be coupled dynamically to serve different demands between specific stations without the limitations of traditional operations that stop at all stops in- between. Urgency – AV transit shuttle systems are not yet proven at speeds that can perform as large- scale revenue service systems without dedicated guideways. As transit agencies gain more experience with networks of dynamically dispatched individual vehicles, this issue will be more relevant. 2022-2025 target date. Related activities – Studies on design of multi-berth stations, technology evolution, progress of safe shuttle operations at arterial speeds Budget/Schedule – Large-scale study, $1M, 24 months; may also take form of “AV transit challenge” similar to DARPA grand challenge, Smart City challenge, etc. Platform Door Protection and Automated Entry at AV Berths Description – AV transit vehicles without human attendants will need station designs that safely accommodate the loading and unloading of all types of passengers including the disabled and elderly. Urgency – As transit agencies gain more experience with networks of dynamically-dispatched individual vehicles, this issue will be more relevant. 2020-2022 target date. Related activities – Studies on design of multi-berth stations, progress of safe shuttle operations at arterial speeds Budget/Schedule – Pilot projects: $5M-$20M, 24 months Safety Considerations for AV Transit Actions identified related to safety include: 1. Categories of hazards and risks for L3 and L4 AV transit 2. Hazards analysis methodology for L3 and L4 AV transit implementation 3. New consensus safety standard(s) for AV transit systems 4. Transit operational design domain definitions 5. Hazards assessment and mitigations for L3 operations Categories of Hazards and Risks for L3 and L4 AV Transit Description – This study would comprehensively itemize all categories of risks and hazards in AV transit operations as defined by MIL Std. 882 and its derivatives. All phases of transit service would be covered including stations, berths, boarding and alighting, dedicated guideways, mixed traffic operations, and so on. Urgency – As the popularity of low-speed L4 shuttles is growing, this guidance is needed imminently before systems are introduced into regular revenue service. 2018-2019 target date.

IMPLEMENTATION OF RESEARCH 93 Related activities – Generic hazards analysis methodology, consensus safety standard Budget/Schedule – Medium-scale study, $250K; 12 months Hazards Analysis Methodology for L3/L4 AV Transit Implementation Description – This study would follow the definition of hazards and risks. The design guidelines would be used by transit agencies to plan the implementation of AV transit routes. Separate yet compatible guidelines are needed for L3 and L4 systems. All phases of transit service would be covered including stations, berths, boarding and alighting, dedicated guideways, mixed traffic operations, and so on. Urgency – As the popularity of low-speed L4 shuttles is growing, this guidance is needed imminently before systems are introduced into regular revenue service. 2018-2019 target date. L4 operations dependent upon regulatory issue resolutions. Related activities – Hazards and risks identification, consensus safety standard Budget/Schedule – Medium-scale study, $500K; 18 months Consensus Safety Standard(s) for AV Transit Systems Description – Existing automated guideway transit safety standards would be adapted for rubber-tire L4 AV systems. The design standards would assist transit agencies in system procurement, installation, and safe operations. Separate standards may also be needed for L3 systems. All phases of transit service would be covered in the standards including stations, berths, boarding and alighting, dedicated guideways, mixed traffic operations, and so on. Some pilot project experiences may be needed before developing ratified standards. Urgency – As the popularity of low-speed L4 shuttles is growing, this guidance is needed imminently before systems are introduced into regular revenue service. 2021-2023 target date. L4 operations dependent upon regulatory issue resolutions. Related activities – Hazards and risks identification, consensus safety standard Budget/Schedule – Large-scale effort, $1.5M; 24 months Transit Operational Design Domain Definitions Description – Relative to the definition of safety standards and hazards analysis, it would be helpful to define a standard set of AV transit operational design domains (ODDs). This concept proposed by NHTSA in the AV model guidance is a helpful construct for everyone to “speak the same language”. This set of standard definitions would help agencies with procurement and discussing issues with a common vernacular. This activity could be developed in conjunction with the hazards analysis and safety standard definitions, or precede those activities. Urgency – As the popularity of low-speed L4 shuttles is growing, a set of standard definitions could be helpful to focus conversations. 2018-2020 target date. L4 operations dependent upon regulatory issue resolutions. Related activities – Hazards and risks identification, consensus safety standard Budget/Schedule – Small-scale effort, $150K; 9 months

IMPLEMENTATION OF RESEARCH 94 Hazards Assessment and Mitigations for L3 AV Transit Description – L3 systems pose significant challenges as the AV system is not in full control all the time. The handoff between vehicle and user control poses some risk, and potentially more risk for transit operations than for private vehicles. This study would identify mitigations to L3 handoff risks and define a standardized mitigation strategy for use of L3 AV transit. Urgency – AV BRT systems are nearing introduction into service in Europe and the Middle East. Although regulatory issues need resolution for introduction of L3 AV in the U.S., at least one pilot project has already been conducted with L1 AV. Medium term target 2020-2023. Related activities – Hazards and risks identification, consensus safety standard Budget/Schedule – Medium-scale effort, $350K; 15 months Workforce Deployment Issues Actions identified in workforce deployment include: 1. Definition of AV transit employee roles and responsibilities 2. Employee involvement guidelines 3. Union Contracting Guidelines 4. Automation of employee actions in compliance with ADA Definition of AV Transit Employee Roles and Responsibilities Description – While there is much concern about AV transit systems displacing vehicle drivers, there will be plenty of other jobs and positions at transit agencies to manage the operations of AV systems. This includes staff to remote-pilot the vehicles, security monitoring, station attendants, cleaning, and maintenance and repair. The role of remote pilots is a particularly important one that requires careful design and specification. Staff training and KSAs will need attention as well. Standards will need to be developed for retraining. Urgency – As transit agencies gain more experience with pilot deployments of low-speed L4 shuttles, this issue will require attention if/when agencies decide to scale up operations to revenue service and networked operation. 2020-2022 target date. Related activities – Employee involvement guidelines, union contracting guidelines Budget/Schedule – Medium-scale effort; $350K: 18 months Employee Involvement Guidelines Description – While there is much concern about AV transit systems displacing vehicle drivers, there will be plenty of other jobs and positions at transit agencies to manage the operations of AV systems. As an agency begins to adopt AV transit services, interactions with union representatives and employee advocates will ensue. This planning guide may assist new agencies in following best practices for resolving issues with win-win outcomes. Urgency – As transit agencies gain more experience with pilot deployments of low-speed L4 shuttles, this issue will require attention if/when agencies decide to scale up operations to revenue service and networked operation. 2021-2023 target date. Related activities – AV transit employee roles and responsibilities, union contracting guidelines

IMPLEMENTATION OF RESEARCH 95 Budget/Schedule – Small-scale effort; $200K: 12 months Union Contracting Guidelines Description – While there is much concern about AV transit systems displacing vehicle drivers, there will be plenty of other jobs and positions at transit agencies to manage the operations of AV systems. As an agency begins to adopt AV transit services, interactions with union representatives and employee advocates will ensue. This effort would develop, in conjunction with existing union representatives, draft language for future union contracts that include provisions for AV transit services. Urgency – As transit agencies gain more experience with pilot deployments of low-speed L4 shuttles, this issue will require attention if/when agencies decide to scale up operations to revenue service and networked operation. 2021-2023 target date. Related activities – AV transit employee roles and responsibilities, employee involvement guidelines Budget/Schedule – Medium-scale effort; $500K: 18 months Automation of Employee Actions in Compliance with ADA Description – AV transit is particularly challenged by ADA requirements. This study would document existing employee actions and responsibilities for ADA compliance and identify potential technology functions and features that could assist in providing win-win solutions. Urgency – Deeper analysis of ADA requirements beyond what was done in this project can be started at any time, and it is important to resolve ADA issues as soon as possible for realization of benefits. 2019-2020 target date. Related activities – AV transit employee roles and responsibilities Budget/Schedule – Small-scale effort; $250K: 15 months Agency Operating Policies Actions identified related to operating policies include: 1. Long-range planning AV transit benefit/cost analysis guidelines 2. Integration of AV transit scenarios in regional transit master planning 3. AV transit service types and operational planning parameters 4. Benefit/cost analysis of conversion from L3 to L4 operations 5. AV Cybersecurity issues affecting transit agencies 6. Management of “big data” in AV transit systems 7. AV Operations Control Center Concept of Operations 8. Investigation of risk, liability, and insurance for AV transit operations Long-Range Planning AV Transit Benefit/Cost Analysis Guidelines Description – While conceptually it appears that dynamically-dispatched, point-to-point L4 AV transit service will provide mobility benefits (i.e. reducing travel time for transit patrons), it is unclear if operating costs will also be reduced for agencies. In addition, there are no existing tools for sizing of vehicles, fleets, stops, and designing networks and routes (which is not surprising, since the systems do not yet exist except in limited locations). This project would

IMPLEMENTATION OF RESEARCH 96 develop such a tool(s) for use by transit agencies in determining cost estimates for system delivery and benefit comparisons with existing services. Simulation tools will likely be required to develop trade-off formulas that can then be used by lower fidelity planning tools for agency planning activities. Urgency – As transit agencies gain more experience with small demonstration projects of L4 AV transit in loops and single routes, networks are the next logical step. 2020-2022 target date. Related activities – Integration of AV transit scenarios in regional transit master planning Budget/Schedule – Large-scale effort, $1M; 24 months Integration of AV Transit Scenarios in Regional Transit Master Planning Description – Regional master plans, wither they be for transit or for all transportation, generally look 10-20 years into the future. AV transit technologies will likely be available in that time frame. No current master planning tools consider L4 AV transit capabilities. Assuming regulatory issues can be mitigated, these services need to be included in long term master planning of transit network design. This project would evaluate the current state of the art in transit master planning and identify gaps that need to be addressed for agencies to properly consider L4 AV transit services in future scenarios. The project would also implement these functionalities in prototype planning tools and demonstrate the results on test cases with real- world transit agencies. Urgency – As soon as practicable. 2019 target date. Related activities – Long-range planning benefit/cost analysis Budget/Schedule – Large-scale effort, $750K; 24 months AV Transit Service Types and Operational Parameters Description – Transit ridership suffers greatest from the first-mile, last-mile problem. Several types of AV transit operations can resolve these issues and likely boost ridership, or replace the need for high-capacity line-haul systems by operating point-to-point. In this research study, several types of services would be identified and detailed operational plans developed to illustrate how the services would be managed daily. Simulation tools may be needed to identify vehicle fleet sizing, dispatch characteristics, passenger service performance (e.g., station wait times) and other operational aspects such as recharging and refueling, maintenance, and deadheading. Urgency – As transit agencies gain more experience with small demonstration projects of L4 AV transit in loops and single routes, using such systems for first-mile, last-mile solutions is a logical next step. 2019-2021 target date. Related activities – Long-range planning benefit/cost analysis Budget/Schedule – Large-scale effort, $1M; 24 months Benefit/Cost Analysis of L3 to L4 Conversion Description – Removing the operator may be generally considered a cost-saving measure, but it may be offset by other costs such as liability insurance, technology, and station

IMPLEMENTATION OF RESEARCH 97 enhancements. In this study, the benefits and costs associated with L3 and L4 operations would be compared. Urgency – L3 transit BRT systems are only now being piloted in Europe and the Middle East. Confidence in L4 transit for standard and articulated coaches may require many more years of L3 experience. 2021-2022 target date. Related activities – Integration of AV transit scenarios in long-range transit master planning Budget/Schedule – Small-scale effort, $250K; 12 months AV Cybersecurity Issues Affecting Transit Agencies Description – Cybersecurity of AVs is one of the most challenging technology issues faced by developers today. It is inherently necessary in transit operations that remote connections to the vehicle must be available, much more so than that for privately operated AVs. At the same time, those remote connections need to be strongly protected. In this study, the security risks to the vehicle, the communications system, and the operations center should be identified. Technically feasible mitigations should be designed and a standards guide and technical architecture for cybersecurity protections for transit should be developed. Experiences in cybersecurity measures as developed for CVs in the USDOT pilot programs currently ongoing in Tampa, New York City, and Wyoming will be a starting point for this work. Urgency – Confidence in cyber-protection of AV transit systems is paramount to their successful introduction into revenue service. 2019-2020 target date. Related activities – Security Operation Concepts in USDOT CV Pilots, AUTO-ISAC standards Budget/Schedule – Medium-scale effort, $750K; 18 months Management of “Big Data” in AV Transit Systems Description – The connected vehicle data available from AV transit systems including video/audio, location and status, command and controls, and diagnostics will be many orders of magnitude larger than any operations data collected by transit agencies today. Big data tools and technologies are currently mainstreamed in many commercial markets to manage huge data sets while gaining “actionable insights” through analytics and data science. In this study, guidance for transit agencies on use of big data systems for managing CV data from transit operations will be developed. The guide will educate transit agencies on use of the current state of the art, and identify strategies for integration of new tools and technologies with legacy systems and new operations practices. Urgency – Even without AV systems, CV technologies are opening analytics opportunities for transit agencies already today. 2019-2020 target date. Related activities – Operations control center concept of operations Budget/Schedule – Medium-scale effort, $350K; 18 months AV Operations Control Center Concept of Operations Description – L4 AV transit systems will require constant remote monitoring to ensure safety and security of the patrons. Vehicles may need to be remote piloted during unusual circumstances, and communications will need to be available always. This type of operation is

IMPLEMENTATION OF RESEARCH 98 much different than current OCC operations of a typical transit agency. New operating principles will need to be developed to ensure staff roles and responsibilities are appropriate and human factors issues are mitigated. It is unlikely that one operator will be needed for each vehicle (this would defeat the basic purpose of removing drivers from the shuttles), but it is currently unknown how many vehicles a single operator could monitor simultaneously (4? 8? 16?). Human factors research is needed to simulate a variety of situations in determining guidance for OCC staffing levels and operating principles to ensure safe operations. Urgency – As L4 shuttles are gaining in popularity and being tested in single routes and loops, the next logical step is networks and larger fleets of shuttles which will require concerted efforts to develop formalized operations concepts. 2020-2021 target date. Related activities – Operations control center concept of operations Budget/Schedule – Medium-scale effort, $350K; 18 months Investigation of Risk, Liability, And Insurance for AV Operations Description – It is anticipated that automation will increase safety of vehicle operations with 360-degree situational awareness and standardized vehicle behaviors, but this is currently unproven. Initially, insurance and liability protection of AV transit systems may be costlier. As technology is proven, liability claims will likely drop and self-insurance costs will be reduced, affording agencies to pay for the technologies. Some of these liabilities may then be passed to the manufacturer. A primer on liability and insurance issues in AV transit is needed to educate the community and identify models for technology introduction that can be adopted by agencies as they consider providing AV transit services. Urgency – The motivation for AV adoption in transit operations to reduce liability claim costs is profound. 2018-2019 target date. Related activities – Categories of hazards and risks for L3/L4 AV transit systems Budget/Schedule – Small-scale effort, $150K; 12 months Laws and Regulations Actions identified related to laws and regulations include: 1. Scenario analysis of AV transit operations without federal funding 2. Possible changes to Section 13c of Federal Transit Act 3. Evaluation of Applicability of transit-related laws and regulations to private contractors (e.g., “TNCs”) 4. Evaluation of OSHA regulations for robotic vehicles in the workplace 5. Evaluation of Minority population involvement and environmental justice in AV transit 6. Evaluation of Title VI adjustments and incentives 7. Evaluation of boarding requirements and exceptions to ADA compliance 8. Evaluation of Buy America requirements 9. Evaluation of Implications of FMVSS for low-speed L4 AV transit vehicles 10. Safety management system development guidance

IMPLEMENTATION OF RESEARCH 99 Scenario Analysis of AV Transit Operations Without Federal Funding Description – L4 AV transit systems may reduce operational costs significantly enough that a transit agency could operate without federal funds. As many of the regulatory challenges existing today stem from the provisions of federal funds, it is conceptually possible that many of these issues could be mitigated by operating without federal subsidy. However, this is merely conjecture without detailed analysis. This study would assess this possibility for small and perhaps medium sized transit agencies to operate without federal support through PPPs and a variety of other fiscal and operational innovations. Urgency – As the issues related to AV operations under receipt of federal funds are considerable, it is of high curiosity to analyze such scenarios sooner rather than later. 2019- 2020 target date. Related activities – Changes to Section 13c of Federal Transit Act, Evaluation of Title VI adjustments and incentives Budget/Schedule – Small-scale study, $150K; 12 months Possible Changes to Section 13c of Federal Transit Act Description – As many of the regulatory challenges existing today stem from the provisions of federal funds, identifying potential mitigations are critical to evaluate. This study would further analyze transit regulations related to employee protections and propose innovative mitigations that may allow AV operations by public agencies. Issues include replacement and retraining of employees and how the use of contracted services that supply L4 AVs may or may not be subject to the rules. Urgency – As the issues related to AV operations under receipt of federal funds are considerable, the study is needed as soon as practicable. 2018 target date. Related activities – Evaluation of Title VI adjustments and incentives Budget/Schedule – Medium-scale study, $350K; 12 months Evaluation of Applicability of Transit Regulations on Private Contractors (e.g., “TNCs”) Description – Currently in some states TNCs are considered taxi services and in others they are not. Without a driver, their argument that the service is “ride sharing” becomes less defendable, and may be considered a transit service, particularly if they service multiple strangers at the same time (who may or may not be going to the same place). This study would identify the legal applicability of transit regulations on TNCs, or private providers that contract such services to a public agency. Urgency – As the issues related to AV operations under receipt of federal funds are considerable, the study is needed as soon as practicable. The recently released TCRP project on PPPs between TNCs and transit agencies may address some of these issues. 2019 target date. Related activities – Changes to Section 13c of Federal Transit Act Budget/Schedule – Small-scale study, $150K; 12 months

IMPLEMENTATION OF RESEARCH 100 Evaluation of OSHA Regulations for Robotic Vehicles in the Workplace Description – OSHA 29 CFR Part 1910 contains Robotics in the Workplace from OSHA Publication 3067 – Concepts and Techniques of Machine Safeguarding65. This aspect of OSHA regulations is worthy of further studies to determine if specific requirements are necessary for AV transit for operations facilities (dispatching and storage yards), as well as maintenance facilities where AVs must be “aware” of human(s) in the vicinity and communicate desired automated actions through some means (audio, lights, text, etc.). Urgency – As L4 shuttles are gaining in popularity and being tested in single routes and loops, the next logical step is networks and larger fleets of shuttles which will require concerted efforts to develop formalized operations concepts. 2020-2021 target date. Related activities – Changes to Section 13c of Federal Transit Act Budget/Schedule – Small-scale study, $150K; 12 months Evaluation of Minority Populations and Environmental Justice in AV Transit Description – A working plan could be prepared by which minority populations can be engaged and involved in the public outreach process as planning for AV Transit deployment begins. Developed as guidance of transit operating agencies, the study documents would establish a framework for any transit agency to accomplish the required public involvement process with minority communities, as well as provide an initial assessment of how AV Transit can be deployed without violating Title VI Civil Rights law. Urgency – Widespread acceptance of L4 transit operations is dependent upon resolution of environmental justice issues. 2020-2021 target date. Related activities – Evaluation of changes to Title VI of the Civil Rights Act Budget/Schedule – Small-scale study, $150K; 12 months Evaluation of Title VI Adjustments and Incentives Description – The benefits to providing allowances or exceptions to the Title VI requirements could be studied to evaluate advancement of the progress of AV technology during the early years of transit deployment. The study could also assess the use of incentives to encourage AV transit deployment in low density, high transit dependency conditions. Urgency – Widespread acceptance of L4 transit operations is dependent upon resolution of Title VI issues. 2020-2021 target date. Related activities – Evaluation of environmental justice issues 65 https://www.osha.gov/Publications/Mach_SafeGuard/chapt6.html

IMPLEMENTATION OF RESEARCH 101 Budget/Schedule – Small-scale study, $150K; 12 months Evaluation Of Boarding Requirements and Exceptions to ADA Compliance Description – L4 AV transit vehicles will have no operator to assist disabled patrons. In this study, the options for ADA compliance exceptions and boarding operations could be evaluated. In addition, technical design requirements, challenges and new potential hazards/risks to providing automated ramp deployment and automated wheelchair lift deployment could be identified. The means for automated wheelchair securement, and the potential technology required to allow remote operator involvement in the process could be identified. Urgency – ADA requirements require resolution for wide-scale adoption of L4 AV transit operations. 2019-2021 target date. Related activities – Evaluation of environmental justice issues Budget/Schedule – Medium-scale study, $500K; 18 months Evaluation of Buy America Requirements Description – FTA funding for New Starts transit projects is normally contingent on compliance with Buy America regulations in the procurement of systems, facilities and rolling stock. The stipulations of the regulations generally require that equipment and construction materials be purchased from American manufacturing sources specified as a percentage of total content for the subsystems and component parts. To address the evolution of AV technology and to not constrain innovation, this approach of the federal government granting waivers may be a key path to moving forward in the near term. This study would identify the potential for alternative requirements and revisions for L4 AV operations. Urgency – The issue may resolve itself as foreign suppliers work within the existing regulations, but is still worthy of evaluation. 2021-2023 target date. Related activities – N/A Budget/Schedule – Small-scale study, $150K; 12 months Evaluation of Implication of FMVSS for Low-Speed AVs Description – The National Highway Traffic Safety Administration (NHTSA) establishes and maintains safety standards known as the FMVSS for the automobile industry in the United States. The FMVSS are only one part of NHTSA’s responsibility, but the ultimate regulation of AV technology will likely come through new FMVSS regulations. A study would be helpful to evaluate if the crashworthiness criteria can be adjusted for AV technology and if less stringent crashworthiness and crash survivability criteria be made in the near term for AV transit vehicles that operate in protected environments dedicated to transit vehicles and pedestrians (such as campuses, parking lots, and guideways). Urgency – Low-speed shuttles currently do not adhere to FMVSS for operation in mixed traffic facilities. As the interest in L4 AV shuttles is growing quickly, this evaluation study is needed sooner rather than later. 2019-2021 target date.

IMPLEMENTATION OF RESEARCH 102 Related activities – N/A Budget/Schedule – Small-scale study, $150K; 12 months Safety Management System Development Guidance Description – Recent updates to these FTA safety programs have included a SMS component which has drawn extensively from the safety program experience of the FAA. As with other FTA regulatory guidelines, noncompliance with these safety rules by a transit operating agency could potentially jeopardize FTA New Start funding or conceivably even incur fines or other penalties imposed by FTA if unsafe practices and/or designs are determined to be deployed. Many operators that do not have fixed guideway transit and have never implemented such a thorough safety program as part of their bus operations will likely face a reorganization of their decision- making process, as well as enacting policies and procedures to develop, implement and maintain a comprehensive system safety program plan. Guidance would be helpful for these agencies on the establishment of SMS for AV transit. Urgency – As the interest in L4 AV shuttles is growing quickly, this guidance is needed in the next few years. 2019-2021 target date. Related activities – Hazard and risk identification, Safety assurance procedures Budget/Schedule – Medium-scale study, $350K; 18 months