SAFETY FIRST, ALWAYS

Highlights of What the Paper Covers

• A new safety benchmark for AVs — the paper introduces the “Gain & Guard Rule” requiring substantive, measurable safety improvements before deployment

  • At its core, the Rule holds that where they operate, AVs must be substantially safer than human drivers on average (Gain), and never worse in any single operating environment (Guard). 

  • In greater detail: Before full-scale commercial deployment, AVs must (1) demonstrate at least a ten-fold reduction in fatality, injury, and crash rates relative to human driving, as an exposure-weighted average across all authorized operational design domains (ODDs), and (2) not increase such rates within any individual authorized ODD.

  • The Gain & Guard Rule simplifies AV safety into a clear, measurable standard that helps the public understand, regulators evaluate, and companies plan for responsible deployment. 

• "The Lawful AV" — a complementary traffic law compliance framework establishing regulatory intervention triggers for persistent unlawful AV behavior, even when no crash results

• Aviation-style liability — a strict liability pooled industry compensation fund modeled on aviation and maritime law, ensuring crash victims receive immediate compensation without needing to prove fault or identify which company's component failed

• A staged certification pathway — five stages from simulation testing through full commercial deployment, with regulators — not companies — controlling advancement at each gate

• Accessibility requirements — framing broad accessibility as a core safety requirement

• And more