CHALLENGES & OPPORTUNITIES Our Recommendations to the Industry
are not unique to our project but are issues all agencies engaged in this work will have to address. The challenges and opportunities identified in our program are highlighted below.
At the JTA, we aim to be a model for other agencies as we advance modern and seamless mobility solutions. From our Route Optimization Initiative in 2014, to Mobility Integration (later Mobility as a Service, MaaS) as early as 2016, and now AVs, the JTA has been at the forefront of transportation innovation for years and is no stranger to being on the cutting edge. Our experience has given us a firsthand understanding of both the opportunities and challenges that come with integrating AV technology into public mobility solutions. Since 2015, the JTA has been navigating challenges; specifically, policies and regulations that need to be addressed for AV projects like ours to move from pilot to full revenue service deployments. These challenges
The JTA strongly feels that with engagement and partnership with FTA, NHTSA, and vehicle manufacturers, these challenges can be overcome. The U 2 C program is poised to transform public transportation, as it will set the standards for AV shuttle deployment on public roadways in the US. As such, we request US DOT, including FTA and NHTSA, to dedicate resources to develop the standards for FMVSS, Buy America, Useful Life, and AV Technology Stack Testing.
CHALLENGES
OPPORTUNITIES
NHTSA Safety Standards & Exemption Process – Existing Federal Motor Vehicle Safety Standards include requirements (e.g., steering wheels) incompatible with driverless AVs. The NHTSA Part 555 exemption process is lengthy (about a year), led by manufacturers, and subject to a production cap of 2,500 vehicles/year that restricts scale for public transit. The exemption process and cap were designed for private vehicles and are insufficient for mass transit needs. Buy America Compliance & Manufacturing – No current U.S.-manufactured purpose-built autonomous shuttles; domestic production expected by 2027. This timeline conflicts with federally funded deployment schedules.
Policy Reform & Advocacy – Advocate for an expedited, transit-specific exemption pathway with increased or performance-based sales caps (e.g., raising cap to 10,000 vehicles annually for transit). Seek FTA support to influence NHTSA and streamline approval processes that recognize AVs as revenue-generating transit vehicles, not just test platforms. Implement temporary emergency flexibility measures to meet urgent transit needs (e.g., driver shortages). Onshoring & Job Growth – Onshoring & Job Growth – Leverage commitments by OEMs like HOLON to build AVs in the U.S., stimulating local jobs and innovation. Explore partial waivers or flexible funding strategies (e.g., allocating federal funds to U.S.-made components, leasing vehicles) as transitional solutions to incentivize domestic manufacturing while ensuring compliance. Develop AV-Specific Useful Life Guidance – Collaborate with FTA to establish useful life standards tailored to AV technology cycles, potentially treating the AV tech stack’s intellectual property separately to allow ongoing upgrades without full vehicle replacement. Standardization & Industry Collaboration – Form industry-regulator cohorts to create universal testing and approval standards for AV technology stacks. This unified approach can streamline federally funded project governance and accelerate AV deployment. Revise Testing Protocols for AVs – Engage with FTA and testing bodies to adapt Altoona and similar certification processes to the unique operational characteristics of AVs, focusing on relevant durability and safety performance without requiring unnecessary or counterproductive tests. Innovative Procurement & Early Funding – Use procurement models like Design-Bid-Operate-Maintain (DBOM) to cut red tape and accelerate timelines. Secure grant funding early, including during testing phases, to provide project flexibility and maintain momentum. Develop statewide contracts with piggyback clauses to enable wider access and cost efficiencies. Collaborative Innovation & Flexibility – Foster partnerships with technology providers and manufacturers to develop customized, compliant solutions. Utilize retrofitting and flexible design approaches as interim steps to meet deployment goals while domestic production scales up. Proactive Safety Communication & Community Engagement – Prioritize transparent safety messaging, actively involve community stakeholders, and maintain high operational safety standards to build trust and encourage ridership. Cross-Agency Coordination & Advocacy – Promote industry-wide collaboration and unified advocacy efforts to influence policy harmonization and regulatory clarity, reducing barriers for transit agencies deploying AVs.
Useful Life Standards – Current FTA useful life rules for rolling stock do not reflect AV technology where the value lies primarily in software, sensors, and evolving technology stacks rather than chassis.
AV Technology Stack Testing & Approval – No federal standards or approval process for AV software systems exist, leading to regulatory uncertainty. Testing is largely a patchwork of local or state rules
Altoona Testing Requirements – Long and uncertain Altoona bus testing timelines (estimated 9 months), coupled with testing criteria that do not align well with AV operational realities (e.g., avoiding potholes is a feature, but testing demands durability driving through potholes). This discourages investment and complicates certification. Procurement & Funding Timing – Delays in vehicle manufacturing, testing, and regulatory approval create risks for federally funded project timelines. Also, traditional procurement models are often too slow for emerging AV technology deployments. Vehicle Availability & Custom Solutions – Lack of purpose-built AVs meeting policy standards forced the team to retrofit a Ford E-Transit with an autonomous tech stack, requiring close collaboration and innovation to deliver a compliant vehicle on time. Public Trust & Safety Perception – Safety and acceptance depend heavily on clear communication and demonstrated operational reliability, especially for a pioneering technology in public transit.
Regulatory Complexity & Coordination – Navigating multiple overlapping federal, state, and local regulations without clear, harmonized standards adds complexity and risk to projects.
52 | ULTIMATE URBAN CIRCULATOR – A CASE STUDY
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