Welcome to The On-Ramp, the newsletter published by Venable's Autonomous and Connected Mobility Team. The On-Ramp explores legal and policy developments in the world of autonomous and connected vehicles, smart infrastructure, electrification, and other emerging automotive and mobility technologies, from Capitol Hill to the U.S. Department of Transportation and beyond.
While Congress was on recess for the month of August, the Trump administration remained active in issuing policies and regulations related to emerging transportation technologies. Lawmakers face a busy schedule upon their return: only three out of 12 House spending bills have been passed, all of which will need to be reconciled with the Senate's versions before the fiscal year ends on September 30, 2025. Lawmakers may instead have to pass a short-term funding measure, known as a Continuing Resolution, to avoid a government shutdown. The Senate will also return from recess with the additional task of confirming President Trump's nominees for various leadership roles. At the time of publication, several key U.S. Department of Transportation agencies remain without a Senate-confirmed leader.
U.S. Department of Transportation
USDOT RFI on AV Deployment Research Support
On August 18, 2025, the U.S. Department of Transportation (USDOT) published a Request for Information (RFI) on "research ideas to support nationwide automated vehicle (AV) deployment." The purpose of the RFI is to seek input from industry and stakeholders to assist the Office of the Assistant Secretary for Research and Technology (OST-R) in developing a research agenda to facilitate safe nationwide deployment of Automated Driving Systems (ADS).
In the RFI, USDOT stated that it is seeking information from "industry, technology developers, operators of ADS vehicle fleets, State/local transportation agencies, researchers and other stakeholders[.]" The RFI focuses on the software and data needs of AV deployment, requesting information on "technical, data, and resource needs to improve the ability of software-driven AV systems[.]" USDOT is requesting comments on:
- Data Standards and Integration
- Edge Case Characteristics Identification
- Supervision Dynamics and Human Interaction
- Evidence Based Evaluation
- Transparency and Building Public Understanding of Variations in AV Impacts on the Transportation System and
- Evaluation of Consistent and Robust Vehicle Behavior Interactions with Other Road Users and the Transportation System
Comments on the RFI are due October 17, 2025. This RFI is distinct from USDOT's request for information on the Surface Transportation Reauthorization bill, which is detailed below.
FHWA Releases Updated NEVI Formula Program Guidance
On August 11, 2025, the Federal Highway Administration (FHWA) released an updated Interim Final Guidance for the National Electric Vehicle Infrastructure (NEVI) program. This interim final guidance is effective immediately, but FHWA also published a request for comments and will consider whether any further changes are needed based on public comments it has received.
Updated State Electric Vehicle (EV) Infrastructure Deployment Plans are due within 30 days of the notice and must include:
- A description of how the State intends to use NEVI Program funds for each fiscal year, covering all unobligated funding for fiscal years 2022-2026
- A Community Engagement Outcomes Report (per 23 CFR 680.112(d)) and
- A description of physical and cybersecurity strategies (per 23 CFR 680.106(h))
Additional changes to the previous NEVI guidance, issued June 11, 2024, include:
- Providing States with the flexibility to determine the appropriate distance between stations along alternative fuel corridors to allow for reasonable travel
- Encouraging selection of charging locations where the charging station owners are also the site host to accelerate project delivery and
- Providing States with more flexibility in determining when their system is built out allowing NEVI funds to be used on public roads statewide
NEVI funds had temporarily been frozen by USDOT following President Trump's January 20, 2025 executive order, "Unleashing American Energy." On June 24, 2025, Judge Tana Lin in the Western District of Washington issued a preliminary injunction ordering USDOT to restore NEVI funding for 14 states, which took effect on July 2, 2025. Sixteen states and the District of Columbia had sued the Trump administration following the executive order, stating that the freeze impacted pre-prepared plans to deploy EV charging stations. The injunction was granted to California, Oregon, Washington, Arizona, New Mexico, Colorado, Wisconsin, Delaware, Rhode Island, New Jersey, New York, Maryland, Hawaii, and Illinois.
NHTSA Issues First Exemption for American-Built Automated Vehicles
On August 6, 2025, USDOT announced that the National Highway Traffic Safety Administration (NHTSA) had issued the first demonstration exemption under the recently expanded Automated Vehicle Exemption Program (AVEP). The exemption is the first to be issued for American-built vehicles under the program. The AVEP previously included only imported AVs, but USDOT expanded the program in April to also include domestically produced AVs. The announcement of adjustments to the current Federal Motor Vehicle Safety Standards (FMVSS) exemption process was made in a letter signed by Peter Simshauser, chief counsel, NHTSA. The letter states that NHTSA will now begin to accept and process requests for vehicles built in the United States to receive FMVSS exemptions for non-commercial purposes that involve research or demonstration in accordance with 49 U.S.C. § 30114(a), opening up the current 49 CFR Part 591 exemption process for foreign vehicles to domestically built vehicles as well.
This action is part of the AV Framework NHTSA announced in April 2025. Part of Secretary Duffy's transportation innovation agenda, the AV Framework is intended to support American ingenuity, maintain key safety standards, and prevent a patchwork of state laws and regulations. The Framework is centered on three principles: (1) Prioritize Safety; (2) Unleash American Innovation; and (3) Enable Commercial Deployment. The key policy actions in the AV Framework include (1) revisions to the Standing General Order on Incident Reporting for Automated Driving Systems (ADS) and Level 2 Advanced Driver Assistance Systems (ADAS) and (2) creating a process for NHTSA to accept and review requests for vehicles built in the U.S. to receive Federal Motor Vehicle Safety Standard (FMVSS) exemptions for non-commercial purposes that involve research or demonstration.
USDOT Request for Information on "Advancing a Surface Transportation Proposal that Focuses on America's Most Fundamental Infrastructure Needs"
On July 21, 2025 USDOT published a request for information (RFI) on the forthcoming surface transportation reauthorization (STR) bill to solicit ideas from industry and the public on projects and priorities the department could push Congress to include in the reauthorization bill. In the RFI, USDOT requests comments related to the four major policy "themes of importance" the Department has identified:
- Enhancing transportation safety. USDOT seeks to improve safety measures in areas related to bridges, transportation workers and pedestrians, truck parking, and AVs
- Accelerating project delivery for transportation projects. The RFI emphasized ongoing projects, including reforming the National Environmental Policy Act (NEPA) and permitting, enhancing One Federal Decision, and increasing the use of technology
- Increasing investment opportunities. The RFI states that investment in transportation infrastructure should promote economic growth, specifically through expanded capacity and mobility, congestion relief, and private sector investment and
- Strengthening partnerships. The RFI noted the importance of improving partnerships with States and other key stakeholders to improve transportation outcomes and efficiency
Comments on the RFI are due September 8, 2025.
NHTSA Publishes Report to Congress on ADS-Equipped Vehicles
At the beginning of July, NHTSA published its second biannual report summarizing the agency's research and rulemakings associated with Automated Driving Systems (ADS). The report outlined USDOT's regulatory framework for AVs and Secretary Duffy's innovation agenda, highlighting NHTSA's cooperation in streamlining its research and rulemaking activities to effectively support the framework's objectives.
The report provided the following updates on NHTSA's ADS Research:
- Progress on a multiphase project evaluating 81 Federal Motor Vehicle Safety Standards (FMVSS) for their applicability to innovative vehicle designs, especially those with ADS
- A recently conducted safety assessment examining how simulation and augmented reality tools can be an effective resource to support ADS-equipped safety evaluation
- Continued research analyzing the benefits and limitations of artificial intelligence (AI) models within ADS
- Research conducted on the crashworthiness of new ADS-equipped vehicle designs using Human Body Models and Advance Crash test dummies, in addition to research regarding best practices for safe interactions between non-occupied ADS-equipped vehicles with existing vehicles, roadside hardware, pedestrians, cyclists, and motorcyclists and
- Continued research regarding mobility and the information needs of all people riding in ADS-equipped vehicles, including those with varying disabilities and those using wheelchairs
The report also included an update on NHTSA's ADS rulemakings, stating that the agency is analyzing previously submitted comments on various NPRMs to determine next steps for developing further regulations.
USDOT Releases a Report on FMVSS Considerations for "ADS-Dedicated Vehicles"
On July 1, 2025, the Department of Transportation published a report, "FMVSS Considerations for Vehicles With Automated Driving Systems: Volume 3." This report extensively details various options for technical translations of 28 different FMVSS, including crash avoidance standards, low-speed vehicles, and crashworthiness standards, for "ADS-dedicated vehicles that lack manually operated driving controls." USDOT published two previous "volumes" in 2020 and 2021 that initially established the framework used to evaluate the regulatory barriers to be removed for verifying ADS-dedicated vehicles' compliance with FMVSS. However, this report includes the caveat that "the legality of the potential options discussed . . . [has] not yet been verified[, and] [does] not include all translation possibilities for the FMVSS or test procedures."
USDOT Announces Several Actions to Support Truck Drivers
On June 27, 2025, USDOT announced a series of new initiatives, pilot programs, and regulatory updates intended to support America's truck drivers. The package comes in response to President Trump's April 28, 2025 executive order, "Enforcing Commonsense Rules of the Road for America's Truck Drivers." Secretary Duffy emphasized that these actions underscore USDOT's commitment to support America's truck drivers and improve overall roadway safety.
The package includes several updates that USDOT states are designed to provide regulatory flexibility for truck drivers. This includes the withdrawal of a joint rulemaking from the Federal Motor Carrier Safety Administration (FMCSA) and the National Highway Traffic Safety Administration (NHTSA) that proposed mandating speed limiters on heavy-duty trucks. Additionally, FMCSA is proposing a deregulatory initiative to eliminate what the announcement describes as burdensome regulations on the trucking industry.
In addition to the deregulatory actions, USDOT will advance more than $275 million in grant funding to expand truck parking availability, launch new digital assets in order to modernize driver resources, including updating the DataQ system and the National Consumer Complaint Database, and initiate two pilot programs to study increased flexibility in hours-of-service regulations.
Other Federal Agencies
EPA Proposes to Repeal Greenhouse Gas Emission Standards
On August 1, 2025, the Environmental Protection Agency (EPA) published a proposed rule to repeal all greenhouse gas (GHG) emission standards for light-, medium-, and heavy-duty vehicles and engines. EPA states that Clean Air Act (CAA) section 202(a) does not authorize the EPA to prescribe emission standards to address global climate change concerns and, on that basis, is proposing to rescind the 2009 findings that GHG emissions from new motor vehicles and engines contribute to air pollution that may endanger public health or welfare. EPA further proposes to rescind the 2009 findings because the agency states that it previously "unreasonably" analyzed the scientific record and more recent developments cast "significant doubt" on the reliability of the findings. Last, EPA is proposing to repeal all GHG emission standards on the basis that no technology for vehicle and engine emission control can address the global climate change concerns identified in the findings without risking greater harms to public health and welfare. Comments on this proposed rule close on September 15, 2025.
White House
Spring 2025 Unified Regulatory Agenda Released
On September 4, 2025, the Office of Information and Regulatory Affairs released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions (Unified Agenda), which reports on the regulations and actions administrative agencies plan to issue in the near and long term and provides status updates on ongoing agency rulemakings.
The Unified Agenda includes three new rulemakings from the National Highway Traffic Safety Administration (NHTSA) related to Automated Driving Systems (ADS). These rulemakings would amend certain Federal Motor Vehicle Safety Standards (FMVSS) to address ADS-equipped vehicles with no manual controls. The FMVSS to be amended are:
- FMVSS No. 102, "Transmission shift position sequence, starter interlock and transmission braking effect."
- FMVSS No, 103, "Windshield defrosting and defogging systems," and FMVSS No. 104, "Windshield wiping and washing systems."
- FMVSS No. 108, "Lamps, reflective devices, and associated equipment."
Another notable motor vehicle-related rulemaking introduced in the Unified Agenda is an Interim Final Rule, anticipated in September 2025, on "Securing the Information and Communications Technology and Services Supply Chain: Medium- and Heavy-Duty Connected Vehicles," from the Department of Commerce, building on an existing rule governing passenger vehicles.
White House Releases AI Action Plan and Three AI-Related Executive Orders
On July 23, 2025, the White House released its AI Action Plan (the Plan) that details the Trump administration's policy priorities on artificial intelligence (AI). These actions follow from Executive Order 14179, which removed the Biden-era executive orders on AI policy and instead directed the development of an AI Action Plan that would "sustain and enhance America's global AI dominance in order to promote human flourishing, economic competitiveness, and national security." The Plan recommends policy actions based on three "pillars": (1) boosting the industry's development and deployment of AI tools through deregulation, government programs for innovation, and leveraging AI for research; (2) expanding data centers, semiconductor manufacturing, and energy infrastructure, primarily through expedited permitting processes and removing regulatory hurdles; and (3) "succeed[ing] in the global AI competition," particularly against China. The Plan offers express support for the development and scaling of drones, autonomous vehicles, and robotics, through federal programs and grants for small businesses and defense research, and through engagement with stakeholders. The Plan recommends that agencies "explore leveraging new and existing location verification features on advanced AI computers to ensure that the chips are not in countries of concern." Finally, the Plan urges federal agencies to consider limiting the disbursement of "AI-related discretionary funding" for states with "AI regulatory regimes that may hinder the effectiveness of that funding or award."
On the same day President Trump signed three executive orders directing several agencies, including the Department of Commerce, the Department of State, the Office of Science and Technology Policy, the Department of Defense, the Department of Energy, the Small Business Administration, the Office of Management and Budget, the Environmental Protection Agency, and the Department of the Interior, to implement some of the policy actions recommended in the Plan.
Congress
Hearings
- Senate Surface Transportation, Freight, Pipelines, and Safety Subcommittee Hearing on the Trucking Industry
On July 22, 2025, the Senate Commerce, Science, and Transportation Subcommittee on Surface Transportation, Freight, Pipelines, and Safety held a hearing, "Shifting Gears: Issues Impacting the Trucking and Commercial Bus Industries." The purpose of the hearing was to discuss the current state of the trucking and motorcoach industries regarding matters such as regulatory concerns, safety issues, and workforce challenges. Witnesses at the hearing included (1) Chris Spear, President and CEO, American Trucking Associations; (2) Lewie Pugh, Executive Vice President, Owner-Operator Independent Drivers Association; (3) Fred Ferguson, President and CEO, American Bus Association; and (4) Sean O'Brien, General President, International Brotherhood of Teamsters.
Several members of the subcommittee asked questions related to AVs and their impact on commercial trucking. During the hearing members and witnesses discussed the promise the AV space holds for enhancing safety in commercial trucking; the potential for automation to improve productivity and efficiency; and the witnesses' policy priorities with respect to AVs, including developing a federal framework to protect interstate commerce.
- House Transportation and Maritime Security Subcommittee Hearing on Drone Warfare and Homeland Security
On July 15, 2025, the House Committee on Homeland Security's Transportation and Maritime Security Subcommittee held a hearing, "Surveillance, Sabotage, and Strikes: Industry Perspectives on How Drone Warfare Abroad Is Transforming Threats at Home." The hearing discussed the current state of drone technologies in the U.S. and matters including homeland security, regulatory concerns, and public safety. Witnesses at the hearing included: (1) Church Hutton, Chief Growth Officer, AeroVironment, Inc.; (2) Tom Walker, Founder and CEO, DroneUP, LLC; (3) Brett Feddersen, Vice President, Strategy and Government Relations, D-Fend Solutions; and (4) Michael Robbins, President and CEO, Association for Uncrewed Vehicle Systems International.
During the hearing, members discussed their concerns regarding homeland security and international threats from drones and asked how legislation could be developed to expand counter-drone authority, optimize the benefits of drone technology, and ensue public safety. Witnesses and members also highlighted the risks posed by unidentified and unauthorized drones and the importance of airspace awareness technologies.
- House Energy and Commerce Subcommittee Hearing on Motor Vehicle Safety
On June 26, 2025, the House Energy and Commerce Subcommittee on Commerce, Manufacturing, and Trade held a hearing, "Looking Under the Hood: The State of the National Highway Traffic Safety Administration and Motor Vehicle Safety." The purpose of the hearing was to discuss the current state of the U.S. automotive sector regarding such matters as safety, regulatory concerns, and innovation, and for members to gain a greater understanding of the evolving technologies of the industry. Witnesses at the hearing included (1) Jeff Farrah, CEO, Autonomous Vehicle Industry Association; (2) John Bozzella, President and CEO, Alliance for Automotive Innovation; (3) David Harkey, President, Insurance Institute for Highway Safety and Highway Loss Data Institute; and (4) Catherine Chase, President, Advocates for Highway and Auto Safety.
Members of the Subcommittee asked a range of questions related to automotive safety and new vehicle technologies. As it concerned AVs, the discussion between members and witnesses focused on the current state of federal AV policy, the steps Congress can take to develop a comprehensive AV framework, and what rulemakings are needed from NHTSA to support AV regulation and deployment. Members and witnesses also discussed issues related to the safety and performance of AVs, data collection and privacy, and the impact of state and federal roles in regulating artificial intelligence (AI) on AV policy.
Nominations
- Senate Commerce, Science, and Transportation Committee Nomination Hearings for Key USDOT Positions
The Senate Commerce, Science, and Transportation Committee convened two hearings in July to consider the nominations for several USDOT positions. On July 16, 2025, the Committee considered the nominations for modal administrators of USDOT. Nominees included (1) Derek Barrs to be Administrator of the Federal Motor Carrier Safety Administration (FMCSA); (2) Jonathan Morrison to be Administrator of the National Highway Traffic Safety Administration (NHTSA); and (3) Paul Roberti to be Administrator of the Pipeline and Hazardous Materials Safety Administration (PHMSA). On July 23, 2025, the Committee considered the nominations for additional positions within USDOT. Nominees included (1) Seval Oz to be Assistant Secretary of Transportation for Research and Technology; (2) Michael Rutherford to be Assistant Secretary of Transportation for Multimodal Freight, Infrastructure, and Policy; and (3) Gregory Zerzan to be General Counsel of the Department of Transportation.
Automotive innovation, AVs, and American competitiveness received significant attention throughout both hearings. In his opening statement on July 23, Chairman Ted Cruz (R-TX) emphasized that the U.S. is facing a new era of transportation driven by AVs, smart infrastructure, and artificial intelligence, and that USDOT must modernize regulations and enhance safety standards.
On July 30, 2025, the Committee voted to advance the nominations of Derek Barrs, Jonathan Morrison, Paul Roberti, Michael Rutherford, and Gregory Zerzan to the full Senate for consideration. The nomination of Seval Oz will be considered by the Committee on a later date.
Legislative Updates
Fiscal Year 2026 Transportation, Housing and Urban Development, and Related Agencies Appropriations Bill
On July 17, 2025, the House Appropriation Committee advanced the Fiscal Year 2026 Transportation, Housing and Urban Development, and Related Agencies Appropriations Act (House THUD Appropriations) by a vote of 35 to 28. The bill provides a discretionary total of $22.097 billion to USDOT, resulting in a total of $105.078 billion in budgetary resources in combination with $83.285 billion in obligation limitation for highway and airport trust fund programs.
The House THUD Appropriations report incorporates several measures related to AVs, including a directive to the Secretary of Transportation to establish a national framework for the regulation of AV technologies. In the report the Committee also encourages the Secretary of Transportation to update Federal Motor Vehicle Safety Standards (FMVSS) to accommodate AVs and to consider launching a public education initiative regarding AVs.
On July 24, 2025, the Senate Appropriations Committee advanced the Fiscal Year 2026 Transportation, Housing and Urban Development, and Related Agencies Appropriations Act (Senate THUD Appropriations) by a vote of 27-1. The Senate bill appropriates $26.5 billion in discretionary funding to USDOT, marking an increase from the House THUD Appropriations.
The Senate THUD Appropriations report contains several notable provisions impacting the automotive industry, including a $13,900,000 appropriation for NHTSA's Office of Automation Safety to support the safe deployment of AVs. In the report the Committee also directs the Secretary of Transportation to issue new guidance on the NEVI formula program. FHWA issued new guidance after the Senate appropriations report was published.
When Congress returns in September, the House and Senate will need to reconcile their respective versions of the bill to pass them by the start of the new fiscal year on October 1 to avoid a government shutdown.
Reconciliation Bill Signed into Law
On July 4, 2025, President Trump signed the "One Big Beautiful Bill Act" (H.R. 1) into law, successfully advancing his signature policy legislation. The bill passed the Senate by a vote of 51-50, with Vice President J.D. Vance casting the tie-breaking vote, on July 1, 2025. The bill passed the House of Representatives by a vote of 218-214 on July 3, 2025. Two House Republicans, Representatives Thomas Massie (KY) and Brian Fitzpatrick (PA), along with three Senate Republicans, Rand Paul (KY), Susan Collins (ME), and Thom Tillis (NC), joined Democrats in voting against the bill.
The reconciliation package includes several rollbacks of clean energy incentives impacting the automotive industry that were passed in President Biden's Inflation Reduction Act:
- The termination of Section 30D tax credits for purchasing or leasing a new electric vehicle (EV), Section 25E tax credits for purchasing a used EV, and Section 45W tax credits for purchasing a qualified commercial clean vehicle by September 30, 2025 and
- The elimination of Section 30C tax credits for EV charging infrastructure by June 30, 2026
The Senate stripped out a previously introduced provision creating new registration fees on EVs and hybrid vehicles.
*The authors would like to thank Tess Brennan, Senior Autonomous & Connected Mobility Analyst, for her assistance writing this newsletter.