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.
In recent months, the U.S. Department of Transportation and Congress have continued to advance policies to shape the future of emerging transportation technologies, particularly in the autonomous vehicle (AV) space. The department is moving forward with efforts to update safety standards, advance rulemakings, and engage stakeholders on automated driving systems, while also supporting innovation across areas such as advanced air mobility and infrastructure. At the same time, lawmakers are actively examining a range of transportation technology issues, including AVs, vehicle safety, and national security, signaling ongoing interest in developing bipartisan frameworks to govern these technologies.
U.S. Department of Transportation (USDOT)
NHTSA Publishes Third Biannual Report to Congress on ADAS Research and Rulemaking
On March 18, 2026, the National Highway Traffic Safety Administration (NHTSA) published its third biannual report to Congress summarizing the agency's research and rulemaking activities on automated driving systems (ADS). The report describes several updates at the agency following its second biannual report published in July 2025. Specifically, the report highlights the confirmation of Jonathan Morrison as NHTSA administrator, the expansion of NHTSA's Automated Vehicle Exemption Program for domestic manufacturers, and the Safety Research Portfolio Public Meeting and ADS Workshop held in November 2025. The report also provides updates on research in categories related to Federal Motor Vehicle Safety Standards (FMVSS) compliance; system safety performance assessment; component and subsystem testing and functional safety; and crashworthiness and alternative cabin design.
On the rulemaking side, the report discusses three rulemaking actions listed in the spring 2025 Unified Agenda of Regulatory and Deregulatory Actions to modernize several FMVSS to accommodate ADS-equipped vehicles. The list includes a yet unpublished Notice of Proposed Rulemaking (NPRM) to modernize FMVSS No. 108 related to vehicle lighting. The list of rulemaking actions also includes the recently published NPRM to modernize FMVSS Nos. 103 and 104, regulating windshield wipers and windshield defrosters, and the NPRM to modernize FMVSS No. 102, regulating transmission shift interlock.
National AV Safety Forum 2026
On March 10, 2026, the NHTSA convened the National AV Safety Forum to provide updates on and insights into ongoing and upcoming vehicle automation activities. The morning session featured remarks from USDOT leadership and NHTSA personnel, as well as moderated panel discussions. The afternoon featured breakout sessions for participants to discuss various topics related to autonomous vehicle (AV) deployment.
U.S. Transportation Secretary Sean Duffy provided opening remarks for the day. Secretary Duffy announced a notice and comment period on an exemption petition from an AV company to deploy a novel-design vehicle, while also announcing that NHTSA will be developing updated technical guidance on AV deployment. He noted that this will build upon work on AV guidance initiated under the first Trump administration. Finally, Secretary Duffy announced the approval of updated Federal Motor Safety Standards (FVMSS) to accommodate vehicles designed to operate without a human driver.
Administrator Morrison elaborated on Secretary Duffy's remarks, noting that the forthcoming AV guidance would address minimum performance standards for AV competencies. He also announced that the first tranche of FMVSS to be updated for vehicles without human controls would include No. 102 (Transmission shift position sequence, starter interlock, and transmission braking effect), No. 103 (Windshield defrosting and defogging systems), and No. 104 (Windshield wiping and washing systems).
The afternoon featured four breakout sessions: Remote Assistance; Automated Driving System (ADS) Behavioral Competencies; Readiness for Driverless Deployment; and Safety Management Systems. During the sessions, participants discussed key questions related to the safe deployment and operations of automated driving systems. Conversations explored distinctions between remote assistance and remote driving, safety metrics, connectivity requirements, training protocols, and human factors associated with remote assistance. Participants also examined how simulation, testing, and real-world exposure contribute to validating system robustness, as well as building strong safety cultures within AV companies.
Update on ADS-Related Rulemakings
Over the past several months, NHTSA has advanced a series of automated driving system- (ADS) related rulemakings and requests for comment (RFCs) aimed at modernizing the regulatory framework for autonomous vehicles (AVs). On March 16, 2026, NHTSA published two NPRMs to update several FMVSS as part of its broader effort to adapt existing safety standards for ADS-equipped vehicles that do not include traditional human controls. The first NPRM amends FMVSS No. 102 (Transmission shift position sequences, starter interlock, and transmission braking effect), and the second amends FMVSS Nos. 103 and 104, related to windshield defrosting, defogging, wiping, and washing systems. Comments on these NPRMs are due April 15, 2026.
On January 21, 2026, Jonathan Morrison, administrator of the National Highway Traffic Safety Administration (NHTSA), announced at the 2026 Society of Automotive Engineers (SAE) Government and Industry Meeting that the agency would issue several RFCs related to automated driving systems (ADS), two of which were published on January 23. The first, "Request for Comment on Vestigial Vehicle Safety Regulations," seeks input on FMVSS that may add cost and complexity without improving safety, particularly those written for outdated technologies. Comments on this RFC are due on March 24, 2026. The second, "Proposal for a New United Nations Global Technical Regulation on Automated Driving Systems (ADS)," requests feedback on a November 10, 2025 proposal from United Nations Working Party 29. Comments were due on February 23, 2026.
In addition to the published actions, NHTSA has previewed further rulemaking and policy activity in the AV space, including updates to ADS guidance to address safety cases, safety management systems, and remote operations. The agency has also highlighted a forthcoming proposal to revise vehicle classifications to address design practices aimed at meeting fuel economy requirements without delivering corresponding benefits. Administrator Morrison and NHTSA have indicated interest in using negotiated rulemaking procedures under 5 U.S.C. section 561 et seq. to engage stakeholders and accelerate regulatory modernization.
Next-Gen Aircraft Proposals
On March 9, 2026, U.S. Department of Transportation Secretary Sean Duffy and the Federal Aviation Administration (FAA) announced the selection of eight proposals as part of the new Advanced Air Mobility and Electric Vertical Takeoff and Landing (eVTOL) Integration Pilot Program (eIPP), aimed at accelerating the safe integration of next-generation aircraft into the national airspace. The program was originally outlined in President Trump's June 2025 executive order, "Unleashing American Drone Dominance." The projects span 26 states and involve partnerships among aircraft manufacturers, operators, and public agencies, with the objective of testing a range of use cases, including urban air taxis, regional passenger travel, cargo logistics, emergency medical response, and autonomous flight technologies. The FAA intends to use data generated through these real-world demonstrations to help the agency develop regulatory standards and operational frameworks to safely enable advanced air mobility at scale.
NHTSA Requests Approval from OMB for a Three-Year Extension of the SGO
On March 4, 2026, the NHTSA issued a notice and request for comments on its plan to seek Office of Management and Budget approval for a three-year extension, with modifications, of Standing General Order (SGO) 2021-01. The SGO prescribes incident reporting requirements for ADS and Level 2 Advanced Driver Assistance Systems (ADAS). As amended in April 2025, the order streamlined certain reporting requirements and updated the list of covered companies to 106 entities. The Third Amended SGO took effect on June 16, 2026, superseding prior versions. The NHTSA is requesting comments by May 4, 2026, on any aspect of this information collection request.
FHWA Proposes Elimination of EV Charger Buy America Requirements
On February 12, 2026, the Federal Highway Administration (FHWA) published a notice requesting comment on a proposed modification to its existing Buy America waiver for electric vehicle (EV) chargers used in federally funded highway projects. The proposal would increase the domestic cost-of-components threshold from 55 percent to 100 percent, meaning all components must be mined, produced, or manufactured in the United States to qualify. The proposal revisits the temporary public interest waiver issued in February 2023, which was intended to support the early deployment of EV charging infrastructure while domestic manufacturing capacity developed. Under that waiver, EV chargers manufactured on or after July 1, 2024, are required to undergo final assembly in the United States and contain at least 55 percent domestically manufactured component costs. The proposed change would apply to EV chargers funded through Title 23 programs, including the National Electric Vehicle Infrastructure (NEVI) Formula Program and the Charging and Fueling Infrastructure (CFI) discretionary grant program. FHWA is seeking input on whether a 100 percent domestic content threshold is feasible, given current supply chain and manufacturing capacity. Comments on the request closed on March 16, 2026.
OST-R Issues RFI on Transportation Digital Infrastructure (TDI) Strategy
On February 4, 2026, the USDOT Office of the Assistant Secretary for Research and Technology (OST-R) published a request for information (RFI) seeking stakeholder input on the development of a Transportation Digital Infrastructure (TDI) Strategy. The strategy will guide digital infrastructure investments, research priorities, and program decisions across all USDOT modal agencies, including highway, rail, air, maritime, transit, and pipelines. In the RFI, OST-R requested comments on USDOT's research activities and efforts to deploy digital infrastructure at scale to inform the agency's TDI Strategy. This effort is separate from the Transportation Research and Development Strategic Plan RFI, which focuses more on physical infrastructure. Comments on the RFI closed March 6, 2026.
White House
White House Releases National AI Legislative Framework
On March 20, 2026, the White House released a comprehensive national legislative framework outlining key policy considerations for artificial intelligence (AI). The framework follows President Trump's December 2025 executive order, "Ensuring a National Policy Framework for Artificial Intelligence," which directed the development of legislative recommendations. The framework focuses on six core objectives:
- Protecting Children and Empowering Parents. The framework calls for providing parents with tools to manage their children's digital environments, including controls over privacy settings, screen time, and content exposure.
- Safeguarding and Strengthening American Communities. The framework recommends streamlining permitting for data centers to support grid reliability and enhancing federal capabilities to address AI-enabled fraud and national security risks.
- Respecting Intellectual Property Rights and Supporting Creators. The framework encourages Congress to consider licensing or collective rights systems for compensation, while continuing to monitor developments in copyright law and enforcement.
- Preventing Censorship and Protecting Free Speech. The framework emphasizes the need for guardrails that ensure AI systems promote truth and accuracy without undue limitation.
- Enabling Innovation and Ensuring American AI Dominance. The framework recommends reducing regulatory barriers, accelerating AI deployment across sectors, and expanding access to testing environments.
- Educating Americans and Developing an AI-Ready Workforce. The framework calls for increased investment in workforce development and skills training to support job creation in an AI-driven economy.
The White House states that the framework will succeed only if it is applied uniformly across the U.S., emphasizing that a patchwork of state laws regulating AI will undermine innovation and American competitiveness.
Congress
Hearings
House Hearing on Surface Transportation Research
On February 11, 2026, the House Science, Space and Technology Subcommittee on Research and Technology held a hearing, "Accelerating Progress. U.S. Surface Transportation Research." The purpose of the hearing was to discuss the research and development priorities relevant to authorizing surface transportation programs. Witnesses at the hearing included Diana Furchtgott-Roth, former deputy assistant secretary for research and technology at the U.S. Department of Transportation; Greg Winfree, agency director, Texas A&M Transportation Institute; and (3) Henry Liu, professor of civil and environmental engineering, and director of the Center for Connected and Automated Transportation, Mcity and the University of Michigan Transportation Research Institute. Subcommittee members and witnesses discussed how the Committee's research and technology title in the Surface Transportation Reauthorization bill can support advancements in emerging transportation technologies like autonomous vehicles (AVs). Rep. Vince Fong (R-CA) highlighted his introduction of the AMERICA DRIVES Act to create a national framework for autonomous trucking, noting that a federal framework will benefit supply chains. The conversation about the bill discussed the benefits of autonomous corridors for trucking while emphasizing that productivity, wages, and employment opportunities will increase with the deployment of AVs. Witnesses generally agreed that the lack of federal leadership in AV policy is harmful to safety and noted the importance of expanding research opportunities related to AVs to increase both safety and public trust.
House E&C Subcommittee on Commerce, Manufacturing, and Trade Automotive Legislation Markup
On February 10, 2026, the House Energy and Commerce Subcommittee on Commerce, Manufacturing and Trade convened a markup to consider 12 bills aimed at modernizing and ensuring motor vehicle safety, promoting innovation, and ensuring automotive affordability. All 12 bills advanced for full committee consideration. The bills address a broad range of vehicle safety, consumer protection, and emerging technology issues, including standards for advanced driver assistance systems and AVs and pedestrian and roadway safety. The Subcommittee participated in significant discussion about the SELF DRIVE Act, with members emphasizing the importance for Congress to pass a federal framework for AVs to secure American leadership and prioritize safety. Members also noted that a federal AV framework should be a bipartisan effort.
Senate Commerce Hearing on Autonomous Vehicles
On February 4, 2026, the U.S. Senate Committee on Commerce, Science, and Transportation held a hearing, "Hit the Road, Mac: The Future of Self-Driving Cars." Witnesses at the hearing included Jeff Farrah, chief executive officer, Autonomous Vehicle Industry Association (AVIA); Lars Moravy, vice president of vehicle engineering, Tesla; Dr. Mauricio Pena, chief safety officer, Waymo; and Bryant Walker Smith, associate professor of law, University of South Carolina. The purpose of the hearing was to discuss opportunities to develop a federal framework and safety standards for AVs to promote U.S. innovation and global competition. Members and witnesses agreed that a federal AV framework provides an opportunity for collaboration between state and federal governments to promote innovation and American leadership. Several members focused their questions on AV safety and how a federal framework would enable the safe deployment of AVs.
House Judiciary Oversight Subcommittee Hearing on Transportation Threats
On January 21, 2026, the House Judiciary Committee's Subcommittee on Oversight convened a hearing, "Embedded Threats: Foreign Ownership, Hidden Hardware, and Licensing Failures in America's Transportation System." Witnesses at the hearing included: Emily de La Bruyere, senior fellow, Foundation for Defense of Democracies; Rocky Cole, former intelligence analyst at the National Security Agency, co-founder of iVerify, and commentator, Fox News; Chris Spear, president and CEO, American Trucking Associations; and Robert Knake, former deputy national cyber director for management and budget, Office of the National Cyber Director. The purpose of the hearing was to examine how foreign actors endanger U.S. transportation systems and discuss how additional federal oversight can protect national security. Members and witnesses expressed concern for national security threats posed by technologies manufactured by foreign adversaries embedded in U.S. transportation systems and discussed legislative approaches to limiting access to U.S. data by foreign actors.
States
As 2026 state legislative sessions progress, multiple states have introduced bills addressing AV operations, with a continued mix of proposals under consideration. Several states-including Maryland, Minnesota, Missouri, Oregon, and Virginia-introduced comprehensive AV authorization bills. Meanwhile, other states have pursued different approaches. "Driver-in" bills that would require a human to be physically present in certain AVs, such as during commercial or passenger operations, have been introduced in various states. Such proposals have faced significant opposition and had limited success; to date, no state has enacted a driver-in bill.
On the regulatory front, the California Department of Motor Vehicles (CA DMV) has continued its formal rulemaking process initiated in April 2025 to establish a path for deployment of heavy-duty AVs over 10,000 pounds, and to modify existing regulations applicable to light-duty AVs. A second set of modifications to the proposed regulations was released in January 2025, alongside a 15-day public comment period. The regulations have been formally submitted to the Office of Administrative Law (OAL) for review. OAL has 30 working days to review the rulemaking record to ensure procedural requirements were met
In addition, Texas, following enactment of its updated AV law in 2025, has finalized regulations to implement its new AV law. Starting in May 2026, entities operating AVs without a human driver in furtherance of a commercial enterprise will be required to obtain authorization to operate from the Texas Department of Motor Vehicles (TxDMV). TxDMV has established an Automated Vehicle Regulatory Advisory Committee to support implementation of these new requirements.
*The authors would like to thank Tess Brennan and Nicole McCormick for their assistance writing this newsletter.