SAFETY FIRST, ALWAYS
Families for Safe Streets Framework for Autonomous Vehicles
download the WHITE PAPER
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
"This is an impressive exploration of what it will take to ensure the autonomous vehicle industry delivers on their promises of improving road safety.
– Phil Koopman, author of Embodied AI Safety and How Safe is Safe Enough?, and the Substack newsletter Autonomous System Safety
“FSS has developed a novel, bold framework intended to elevate an important but sometimes overlooked goal in robotaxi regulation—safety, especially the safety of non-users. This framework adds a tool to help us think about the tradeoffs of new tech vs. the status quo along multiple dimensions.”
-Greg Shill – Professor of Law, Arizona State University
“Humans are dangerous drivers. The promise of this technology is machines that do dramatically better than humans, and a serious safety framework should demand exactly that. I find the Gain & Guard Rule compelling because it sets a bar with teeth: it's a standard some systems already clear and others plainly don't, which makes it meaningful.”
– Andrew Miller, co-author of The End of Driving, and author of the Substack newsletter Changing Lanes
VOICES ON THE FRAMEWORK
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VOICES ON THE FRAMEWORK -
“Every crash is a family changed forever—mine included. We cannot accept a system where life-saving technology is released under weaker standards than aviation or medicine. Autonomous vehicles must be held to a level of safety that prevents tragedy before it happens, not one that responds after lives are already lost.
- Amy Cohen, Founder and President, Families for Safe Streets
“Families for Safe Streets, formed out of tragic necessity, is once again at the forefront of developing and advocating for practical, real world solutions to make our streets safer and save lives. Requiring autonomous vehicle companies to collect and share standardized, detailed data, contribute to the cost of infrastructure upgrades, and meet safety standards grounded in the principles of Vision Zero are critical components of the Families for Safe Street’s framework. These measures help ensure that autonomous vehicle technology works for people, not the other way around.
— Meera Joshi, President of Green-Wood Cemetery; former Deputy Mayor of Operations, City of New York; and Chair & Commissioner, New York City Taxi & Limousine Commission