A global initiative ensuring that animal welfare is integrated into the core of autonomous driving systems.
As autonomous systems begin to navigate our physical world, the definition of "safety" must evolve. We advocate for a multi-stakeholder approach to autonomous vehicle safety that accounts for all road users, including the companion animals in our homes and the wildlife in our ecosystems.
The scale of animal mortality on U.S. roads is staggering. An estimated 1–2 million crashes with large animals are reported every year, but this captures only a fraction of the toll. The U.S. Fish & Wildlife Service estimates that 89 to 340 million birds alone die annually in vehicle collisions, with total small-animal roadkill plausibly reaching into the hundreds of millions.
Article 13 of the Treaty on the Functioning of the EU requires that in formulating and implementing policies on transport, research, and technological development, the EU and its Member States must pay full regard to the welfare requirements of animals as sentient beings. The EU's Code of Practice for General-Purpose AI Models further lists "non-human welfare" among the risks providers must address in systemic risk identification.
The UN Working Party on Automated/Autonomous and Connected Vehicles (GRVA) is developing a Global Technical Regulation for ADS. While the draft's Annex 5 lists animals as objects ADS should expect to encounter, the core definition of "other road user" in Section 2.21 does not explicitly include them—leaving animal safety obligations ambiguous despite NHTSA's own 2017 guidance recognizing animal detection as an expected ADS function.
A UN GTR that does not explicitly include animals as "other road users" would be out of step with the EU's legal framework and NHTSA's own prior guidance. The fix is simple: add animals to the definition in Section 2.21, ensuring that existing safety obligations clearly extend to all road users.
The proposed UN Global Technical Regulation (GTR) on Automated Driving Systems has a blind spot: while Annex 5 lists animals alongside pedestrians and cyclists as objects ADS should expect to encounter, the definition of "other road user" in Section 2.21 does not explicitly include them.
Our formal comment to Docket No. NHTSA-2026-0034 proposes a single clarification to restore consistency with NHTSA's established position on animal detection.
“Other road user (ORU)” means any entity making use of publicly accessible road infrastructure, including but not limited to vehicles, pedestrians, cyclists, and animals.
Without explicit inclusion in Section 2.21, manufacturers may disclaim safe interaction obligations (4.1.2.7), safety case requirements (6.3.2.2.3), and incident reporting (Annexes 2 & 3) for animal encounters.
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