The On-Ramp: An Autonomous, Connected, and Electric Mobility Newsletter

6 min

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 weeks, the federal government has continued to advance policies impacting autonomous and connected vehicles through both regulatory and legislative action. The National Highway Traffic Safety Administration (NHTSA) has maintained its focus on updating vehicle safety standards and refining its regulatory approach to automated driving systems, while Congress remains focused on evaluating legislative and oversight priorities related to emerging transportation technologies. With Congress preparing to adjourn for its August recess, attention will shift primarily to ongoing agency rulemakings and implementation efforts in the coming weeks.

U.S. Department of Transportation

NHTSA Issues Call to Action on AV Interactions with First Responders

On July 8, 2026, National Highway Traffic Safety Administration (NHTSA) Administrator Jonathan Morrison issued a call-to-action letter urging developers of automated driving systems (ADS) to prioritize safe interactions with first responders. In the letter, Administrator Morrison stated that NHTSA identified a trend of autonomous vehicles (AVs) failing at times to properly yield to first responders and avoid accidently obstructing their operations. NHTSA stated that it plans to meet with AV developers by the end of July to discuss solutions for improving first responder actions.

Transportation Items in New 2026 Unified Agenda of Regulatory and Deregulatory Actions

On July 7, 2026, the Office of Management and Budget released the 2026 Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions (Unified Agenda), which outlines the regulations federal agencies expect to issue in the near term and long term and provides status updates on ongoing rulemakings.

The Unified Agenda includes several notable AV-related actions from the National Highway Traffic Safety Administration (NHTSA). Key new AV rulemakings include an advance notice of proposed rulemaking on Automated Driving System (ADS) Performance Assessments and proposed updates for Federal Motor Vehicle Safety Standards (FMVSS) Nos. 111, rear visibility; 126, electronic stability control systems; 201, occupant protection in interior impact; and 208, occupant crash protection, to accommodate ADS-equipped vehicles that lack traditional manual controls.

The Unified Agenda also advances several ongoing AV rulemakings, including Incident Reporting Requirements for Automated Driving Systems and Level 2 Advanced Driver Assistance Systems, Motor Carrier Operation of ADS-Equipped Commercial Motor Vehicles, and Light Vehicle Automatic Emergency Braking (FMVSS No. 127). The Agenda also includes a long-term action item for a proposed rule on medium- and heavy-duty connected vehicles from the Department of Commerce, building on an existing rule governing passenger vehicles.

NHTSA Withdraws AV STEP NPRM

On June 25, 2026, the National Highway Traffic Safety Administration (NHTSA) withdrew its January 2025 proposal to establish the Automated Driving System-Equipped Vehicle Safety, Transparency, and Evaluation Program (AV STEP). The proposed program would have created a voluntary reporting and public disclosure framework for automated vehicle developers. NHTSA stated that it withdrew the proposal after considering public comments and determining that more recent initiatives—including the agency's April 2025 AV Framework and the expanded Automated Vehicle Exemption Program—better advance the agency's objectives. NHTSA added that the agency is in the process of developing guidance for General Exemptions to expedite those exemptions and promote the commercial deployment of noncompliant ADS-equipped vehicles.

NHTSA Proposes ADS-Related Amendments to FMVSS 135 Light Vehicle Brake Systems

On June 25, 2026, the National Highway Traffic Safety Administration (NHTSA) published a Notice of Proposed Rulemaking (NPRM) to amend Federal Motor Vehicle Safety Standard (FMVSS) No. 135, Light vehicle brake systems to address the braking requirements for vehicles driven by automated driving systems (ADS) that lack manual controls.

The proposal would remove requirements for hand- or foot-operated brake controls on vehicles without manual controls, establish technology-neutral brake control requirements, adapt existing performance tests for driverless vehicles, and update several definitions and technical provisions throughout the standard. NHTSA emphasized that the rule would not change existing stopping distance requirements and is intended to preserve current safety performance while eliminating design requirements tied to human drivers. The agency also noted that it is developing separate ADS-specific safety standards and reaffirmed it will continue using its defect enforcement authority to address unsafe ADS performance. In the agency's press release, NHTSA stated the proposal is part of the administration's broader AV Framework to modernize federal vehicle safety standards for automated vehicles. Comments on the NPRM are due July 26, 2026.

Other Agencies

BIS Connected Vehicle Rule Changes

On June 18, 2026, the Department of Commerce's Bureau of Industry and Security (BIS) issued amendments and new general authorizations under the Connected Vehicle Rule that both refine existing exemptions and create a new compliance pathway for suppliers. The amended Limited Use Cases General Authorization expands certain exemptions for vehicles use solely for display, testing, or research while narrowing the temporary public-road exemption to testing purposes only.

BIS also established a new Approved Supplier Registry, allowing connected vehicle manufacturers and vehicle connectivity system (VCS) hardware importers to engage in otherwise prohibited transactions if the relevant supplier and product have been approved by BIS. Eligible suppliers of covered software and VCS hardware may apply for approval by demonstrating that they have adequately mitigated national security risks.

Congress

Hearings
Connected Vehicle Security Act Markup

On July 22, 2026, the Senate Commerce, Science, and Transportation Committee held a markup to consider S. 4429, the Connected Vehicle Security Act of 2026 (CVSA). The Committee approved S. 4429, as amended, unanimously by voice vote. The version reported by the Committee consists of an amendment in the nature of a substitute as modified from Sen. Bernie Moreno (R-OH), along with one amendment from Ranking Member Maria Cantwell (D-WA). The amendment from Ranking Member Cantwell would require the U.S. Department of Transportation to submit to Congress a report on educating consumers about Chinese counterfeit airbags in passenger cars.

The markup discussion reflected broad bipartisan support for addressing the national security risks raised by the CVSA. At the same time, members debate the appropriate scope of the legislation, particularly as it relates to battery-related components and how it should align with the Commerce Department's Connected Vehicles Rule. Several senators emphasized that negotiations on the bill's key provisions will continue as the bill advances, indicating that further revisions remain possible before Senate floor consideration.

BIS Budget Hearing

On July 14, 2026, the House Foreign Affairs Committee held a hearing, "FY27 BIS Budget: The AI Arms Race and the ICTS Office." The sole witness at the hearing was Jeffrey Kessler, Under Secretary of Commerce for Industry and Security, U.S. Department of Commerce. The purpose of the hearing was to discuss the Bureau of Industry and Security's (BIS) budget for the upcoming fiscal year 2027, the artificial intelligence (AI) race with China, and the importance of the Office of Information and Communications Technology and Services (ICTS) in overseeing foreign technology threats.

The hearing highlighted BIS's continued focus on implementing and enforcing the ICTS Connected Vehicle Rule, with Under Secretary Kessler emphasizing the agency's efforts to build a robust compliance and enforcement framework. Members also focused on the rule's implementation, particularly BIS's oversight of specific authorizations and its approach to addressing national security risks posed by foreign adversary technology in the automotive supply chain.

 

The authors would like to thank Nicole M. McCormick, Autonomous & Connected Mobility Analyst, for her assistance writing this newsletter.