Introduction
The closing years of the Obama administration saw a whirlwind of
regulatory activity from NHTSA, including multiple consent orders,
record penalties, and soaring recall numbers. The more aggressive
enforcement posture, hailed as the "New Normal," has
largely remained in place as the Trump administration has been slow
to bring in new political leadership to the agency. Although the
Trump administration's regulatory philosophy is still unclear,
the future direction of the agency is beginning to come into focus
as the new year gets underway. NHTSA is significantly boosting its
investigative staff and implementing structural changes in its
enforcement office, changes that are almost certain to lead to more
defect investigations. The agency also recently revised its
autonomous vehicle policy, setting forth twelve "Priority
Safety Design Elements" for automated vehicles. This year, the
industry expects to see passage of autonomous vehicle legislation,
which
