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Clarify crash definitions and underreporting in CPUC TNC data versus NHTSA SGO ADS data

Determine the crash reporting definitions and underreporting rates for California Public Utilities Commission Transportation Network Company self-reported crash data and assess their comparability to National Highway Traffic Safety Administration Standing General Order automated driving system crash reports, including whether the Transportation Network Company crash definition aligns with Standing General Order reporting thresholds.

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Background

The paper critiques comparisons that use self-reported Transportation Network Company (TNC) crash data against ADS crash data reported under NHTSA’s Standing General Order (SGO), noting definitional and reporting differences. Without consistent crash definitions and quantified underreporting in TNC datasets, benchmarking ADS safety against human-operated ride-hailing services is unreliable.

Resolving this uncertainty is important for stakeholders who wish to evaluate ADS performance relative to human drivers in similar service models, and to ensure that benchmarks are methodologically aligned.

References

It's unclear what definition of a crash is used for the self-reported TNC crash data, and whether that TNC crash definition is well matched to the ADS crashes reported as part of the NHTSA SGO. That is, there is an unknown amount of underreporting in the TNC crash data, while the ADS data from the SGO includes any amount of property damage with little to no underreporting.

— Comparison of Waymo Rider-Only Crash Rates by Crash Type to Human Benchmarks at 56.7 Million Miles (2505.01515 - Kusano et al., 2 May 2025) in Introduction