As the nation’s leading advocate for the technological modernization of our transportation system by focusing on advancing research and deployment of intelligent transportation technology, the Intelligent Transportation Society of America (ITS America) is grateful for the opportunity to comment on the U.S. Department of Transportation’s (USDOT) Non-Traditional and Emerging Transportation Technology (NETT) Council Request for Comment.

ITS America was founded in 1991 as an advisory council to USDOT on technology innovation and emerging transportation technologies. ITS America is the only organization in the country that represents all sectors – public, private, academic, and nonprofit – to advance transportation technology. Our membership includes state and city departments of transportation, transit agencies, metropolitan planning organizations, automotive manufacturers, technology companies, engineering firms, automotive suppliers, insurance companies, and research and academic universities. Our vision is a better future transformed by intelligent mobility: one that is safer, greener, and smarter. We advance a world in which we promote the nation’s Vision Zero goals to eliminate fatalities and serious injuries on our roadways; a world that is more sustainable, resilient and adaptable to climate change; and a world in which communities have equal and affordable access to transportation and critical services to advance equity. Our vision aligns directly with the DOT’s goals to advance safety, climate, and equity.

ITS America recognizes the NETT Council as playing a significant role in realizing and advancing the research, development, and deployment of new mobility technologies to help us realize the benefits of future mobility. These benefits can save lives, promote sustainability, advance equity, seamlessly integrate our system, promote economic prosperity, and advance a more efficient, world-class transportation system.

With these comments, ITS America suggests that the NETT Council has the potential to serve as a guiding body that truly helps us realize the future of our nation’s transportation system, provided the council better defines the concept of emerging technologies in an expansive way, engages with a diverse group of transportation stakeholders and decision makers, and provides ample opportunity for the public to weigh in on these critical issues. ITS America’s responses to the questions posed in the request for comments are below.

The NETT Council’s Work

1. How can the NETT Council most effectively serve as an entry point for nontraditional and emerging innovation and technologies ready for integration into the transportation system?

ITS America believes that the NETT Council should: (1) develop a working definition of emerging technologies that seeks to be expansive and comprehensive in the way it defines emerging technologies; (2) serve as a single point of leadership for DOT to oversee advancing technologies; (3) create clear performance indicators to measure progress and success; and (4) take a system of systems approach to understand how emerging technologies fit into the larger ecosystem of transportation.

First, to-date there is no unified vision of ‘emerging technologies’ – with some viewing advanced technology like connected and automated vehicles as emerging, despite those technologies being proven and, to some degree, deployed. Having a working definition of what ‘emerging technologies’ mean within the U.S. will help us understand how to direct investment in research and deployment and which policies need to be developed to promote harmonized approaches and equal opportunity. A working definition may prompt an important discussion about how to distinguish between emerging technologies at various places on the innovation curve (research, development, deployment, adoption). While some technologies have been proven through research and development, they may still be considered ‘emerging’ as far as deployment and adoption are concerned. Given the critical importance of defining the concept, we urge USDOT to ensure that such an effort to define ‘emerging technologies’ would not have the effect of restricting existing programs, regulatory actions, or guidance using that term. We also urge USDOT to ensure that inclusion in the purview of the NETT Council will not hinder deployment of new technologies. Finally, any NETT Council effort to define ‘emerging technology’ must formally consider public input. ITS America would be pleased to support the NETT Council in defining this concept and convening the appropriate stakeholders and members of the public to ensure this exercise is comprehensive, strategic, and forward looking to the future technologies that will drive safety, sustainability, and equity.

Second, with the Council being expanded to comprehensively define emerging technologies, we can create a ‘one- stop-shop’ and single point of leadership for DOT to oversee advancing technologies such as personal delivery devices or automated air mobility so that DOT – together with researchers, private companies, communities, nonprofits and all levels of government – can convene and collaborate to collectively advance its goals. The NETT Council is well suited to inform research on transportation innovations that touch multiple modes, particularly those that align with Bipartisan Infrastructure Law (BIL) programs (such as connected vehicles, automated vehicles, vehicle-to-infrastructure technologies, cellular-vehicle-to-communications technologies, etc.) across modal administrations and departments.

Third, USDOT’s current Strategic Plan identifies one of the department’s key performance indicators as: “Double[ing] the number of research and deployment projects centered on breakthrough discoveries that introduce new technologies or approaches not currently deployed in the transportation system.”1 ITS America suggests that this performance indicator might serve as a useful metric for the work of the NETT Council. Developing strong performance indicators and ways to measure progress will show the benefit of the NETT Council and how it collaborates with organizations like ITS America, which represents research institutions, private sector innovation, communities benefiting from these advancements, and the state and local governments that support this work.

Finally, there are many new technologies that have been developed, deployed, and piloted in recent years that have the potential to bring innovation and positive outcomes to communities and our nation’s transportation system, including: transit technologies, safety technologies (e.g. bicycle and pedestrian detection sensors), trip planning technologies, open and contactless/integrated payment technologies, unmanned and automated aerial mobility and

drones, hyperloop, personal and automated delivery devices, micromobility, solar-power paved highway technologies, rubberized roads, right-of-way solar, airless tire technology, integrated signal systems, traffic and vulnerable road user analytics, and more. The NETT council should also aim to focus its efforts on how any specific emerging technology fits into the entire transportation system and the foundational connectivity that requires technology advancement. Our transportation network is increasingly reliant on the digital layer that undergirds our traditional hard infrastructure. Mobility providers and intelligent transportation technology companies are developing, testing, and deploying products that increasingly demand and rely on the network. Connectivity is paramount to the success and deployment of many of the new mobility technologies and innovations on the horizon. Investment in digital and connected infrastructure and the digitalization of public space plays a critical role in cultivating an environment that enables and supports many nontraditional and emerging mobility technologies and innovations. Even more critical than the success of these new and emerging technologies is the important role that building out and investing in digital infrastructure plays in meeting our desired equity, climate, security, and privacy outcomes.

Many of the transportation technologies and innovations that ITS America supports include connected infrastructure technologies that: help reduce accidents and improve safety; connect and facilitate communication among various modes and roadway users; and improve efficiency of our nation’s roadways, transit corridors, and freight systems. These technologies are critical to supporting and enabling deployment of other emerging technologies and serve as the cornerstone of the new mobility ecosystem.

2. What has worked well, and not well, about the current structure and activities of the NETT Council?

ITS America has several suggestions in response to this question:

• Transparency – Historically, the work of the NETT Council has been opaque and a lack of transparency or regular information sharing has made the benefits of the Council or how it is helping to advance the national research and deployment of transportation technologies unclear. The Council should commit to regular reporting – either quarterly or annually – to show goals progress, work, outreach, outcomes, and approaches toward reaching these goals (organization, staffing, procedures, governing structure, workplans, etc.).
• Stakeholder engagement – The NETT Council has historically remained internally focused but now has an opportunity to engage stakeholders like ITS America members leading these emerging technology innovations. The NETT Council should invest in engaging, listening, and collaborating with all sectors of ITS America members including private companies, state and local government and planning agencies, communities, researchers, nonprofits, and other related and relevant professional associations. Specifically, ITS America urges the NETT Council to engage with the public sector (including states, cities, regional planning bodies, transit agencies and tribal governments), as these are the entities that serve as hosts to the piloting and deployment of new technologies. Finally, ITS America urges the NETT Council to utilize public notice and comment when approaching any decisions involving interpretation of statutory or programmatic language — particularly in areas lacking jurisdictional or regulatory clarity. ITS America can support the Council in convening these discussions and advising the Council on emerging innovations, priorities, and strategy.
• Balanced innovation portfolio –The NETT Council and US DOT should aim to maintain a balanced portfolio of work on the innovations of the future while also addressing today’s innovations.
• Clear definition of ‘emerging technology’ – In defining emerging technologies and what the scope of the NETT Council might include, we urge consideration of where specific technologies sit on the innovation curve and how the council might consider bleeding-edge technologies versus those that have already been

widely piloted and deployed. Given the critical nature of defining such a concept, we urge USDOT to seek public input on this to come to consensus across public-private-academic industries and communities. ITS America can serve in this vital role to help convene stakeholders and the public and to seek public input.

• Expansive definition of the term ‘emerging’ to capture different phases of innovation – Innovation comes not just from the foundational science (like research and development) but also from the practical implementation thereof (deployment and adoption). We urge the NETT Council to consider technologies that are newly emerging in the research and development space as well as those that might be considered proven but are emerging in terms of deployment and adoption. Noting that the council was originally founded to assist in the regulatory uncertainty of hyperloop technologies, it should consider the full range of technologies and where they sit on the innovation curve, which will help focus the council’s efforts. For instance, given the widespread research, development, piloting and deployment of connected and automated vehicle technologies, the council should not focus on these technologies and instead on more early-stage innovations to provide regulatory certainty and clarity where there is none for newer, less mature emerging technologies.
• Diversity of thought – Innovation stems from diverse backgrounds, skills, lived experiences, and expertise, and the NETT Council must consider this range of perspectives in its work. The NETT Council should avoid being an ‘echo chamber’ of internal thought leaders and ensure that diversity is a key priority of its membership and in the advisors and stakeholders it engages. Moreover, disruptive innovation has occurred outside the transportation sector – we can learn from this. The council should seek out women, people of color, diverse sector researchers, and other innovators to ensure the emerging technologies developed and deployed consider organizations, innovations, and individuals beyond DOT’s traditional stakeholder network. ITS America can support this need by convening stakeholders from various sectors. Examples include standards bodies that rely on technical experts as volunteers to support thought leadership and creatively brainstorm consensus-based solutions and continuing to advance clear goals on membership that take into account women and innovators of color.
• Timely and planful reporting and information – Recognizing that government must protect itself to mitigate risks, the NETT Council is one example in which the federal government must move at the speed of innovation, using agile methods and practices to nimbly prepare and respond to emerging technologies. The NETT Council should plan for regular reporting to public stakeholders, regularly update its website, and include a docket of new and emerging technologies it is including in its evaluations to provide regulatory certainty and clarity. The council should include a list of questions on its website and an email form for the public and stakeholders to submit and require the Council to provide clarity and responses in a timely manner, similar to a frequently asked questions document. We support the requirement that the council should meet at least quarterly to ensure the Department addresses new and emerging transportation technologies in a timely manner and innovation is not stifled.
• Cross agency convenor and lead for federal agencies – Transportation technologies impact a variety of systems. Sustainable technologies impact energy and utilities, safety technologies support homeland security and emergency response, and automation impacts labor and workforce development planning needs, among other examples. Just as the NETT Council should be the lead body for emerging technologies for DOT, it should also serve as the lead among federal government agencies, working collaboratively and extensively to ensure coordination on emerging technologies across Labor, Energy, Commerce, Homeland Security, and other federal agencies.

3. How can the NETT Council best incorporate the perspective of and engage with other Federal agencies and a broad range of stakeholders (e.g., academia, labor unions, state, local, and tribal governments, private sector) to fully understand potential issues and opportunities related to transportation innovation?

To fully incorporate outside perspectives to develop an equitable, holistic, research-driven strategy on research and development, the NETT Council should:

1. Expand to include more members;
2. Open its meetings to the public, avoid closed meetings when possible, and share meeting agendas,deliverables and questions on its website;
3. Engage researchers, communities, and practitioners to learn how to scale emerging technologies throughmeetings, listening sessions, rulemaking, forums, and other means;
4. Expand the diversity of its membership to include broad perspectives on innovation, research, anddevelopment;
5. Find new and innovative ways to seek stakeholder engagement;
6. Identify well-defined goals and objectives for the council with clear metrics to evaluate success;
7. Create a strong stakeholder engagement plan and include a quality web and social media presence; and
8. Report to and be led by the White House Office of Science and Technology Policy.

First, ITS America sees the current membership model and lack of transparency in the council’s activities as problematic. Based on the language present on USDOT’s website, the NETT Council membership currently consists of:

the Secretary (ex officio), Deputy Secretary (chair), Under Secretary for Policy (Vice-chair), Chief of Staff, Modal Administrators, and other senior leaders from across the Department.

This membership model comprised entirely of internal USDOT leaders offers an extraordinarily limited set of perspectives with very little opportunity to engage and coordinate with vested stakeholders in this space outside of the traditional request for comments and rulemaking process.

Second, this closed model also provides the public very little insight as to the purpose, intent, proceedings, and outcomes of the meetings of the NETT Council. The meetings should be open to the public and meeting materials should be readily made available on a public website.

Third, to fully understand the current landscape involving new transportation technologies, the NETT Council must engage researchers, early deployers, and pilot participants to understand how to most effectively advance and scale emerging technologies. Relying on individual use cases or concerns without robust and formal stakeholder and industry engagement could result in unintended consequences, including limiting or impeding other innovations. The council must seek feedback from technical experts, communities, and practitioners responsible for implementing technology advancements. It must find ways to engage private companies, the public sector including state, local, and tribal governments, community members, researchers, and other stakeholders to identify relevant emerging technologies and understand the barriers and benefits of emerging technology advancement. Public comment, listening sessions, and community workshops are critical for meaningful stakeholder engagement, similar to the DOT’s previous forums for technologies like automated vehicles, but these should be expanded to include key

stakeholder and community voices. ITS America can serve in this capacity to help convene, facilitate, and engage stakeholders to advance the council’s work.

Fourth, as noted above, mobility innovation relies on the acknowledgement and lessons learned from those with diverse backgrounds, skills, lived experiences, and expertise. To better achieve diversity of thought on these topics, the NETT Council must consider a range of perspectives in its work, ensure that equity is a key priority of its membership, and that it is paramount in decisions related to the advisors and stakeholders that are engaged. The council should seek out women, people of color, diverse sector researchers, innovators in other fields, stakeholders in related fields such as social services, housing, and education, as well as organizations that represent system users and vulnerable and under resourced populations that often don’t have a place in transportation planning efforts – this will help ensure the emerging technologies researched, developed, and deployed take into account the range of important perspectives both within and beyond DOT’s traditional stakeholder network.

Fifth, in addition to the more formal notice and comment rulemaking process, the council should rely on new and innovative ways to seek stakeholder feedback through listening sessions at conferences, workshops, virtual engagement activities, and other methods, all of which ITS America can support and help coordinate on the council’s behalf.

Sixth, ITS America suggests incorporating transparency and accountability into the structure of the NETT Council, such as defined annual goals and objectives for the council’s activity, accompanying metrics for achievement of those goals and objectives, and publication of meeting proceedings.

Next, the council should create a stakeholder engagement plan that summarizes its goals and a strategic communications plan that outlines how DOT can more publicly discuss the council’s work whether through social media, a regularly updated website, or other channels. Historically, the NETT Council’s website was not regularly maintained and did not include updated information or guidance, which led to government lagging behind technology. If, however, the council creates a strong web and media presence and more strategically communicates its work, stakeholders will be more engaged and the United States will be more competitive.

Lastly, with the level of effort required to meaningfully identify new and emerging technologies across the Department and federal agencies, the NETT Council should be led and administered by the White House Office of Science and Technology Policy (OSTP). Many of the transportation emerging technologies are being developed to directly advance OSTP’s goals safety, climate resiliency, equity, economic prosperity, health, and U.S. competitiveness – thus, it makes the most sense that the council report directly to the White House to ensure these innovative technologies support a national approach to science and innovation and consider a system of systems approach.

4. How can the NETT Council more effectively reflect inputs from a broad range of transportation stakeholders to assess the positive and negative consequences of transportation innovation?

The Council should be led by DOT’s Chief Innovation Officer, rely on public-private stakeholder organizations like ITS America to convene stakeholders, and conduct workshops to discuss emerging technologies.

First, USDOT’s Chief Innovation Officer and the Office of Innovation should manage overall administration of the NETT Council’s work, which will enable a consolidated strategic focus on emerging technology, engagement of the proper stakeholders, and more consolidated coordination across the modal administrations. Likewise, the council should ensure the modal innovation officers take ownership to plan and prepare for emerging transportation technologies to support DOT’s overall mission. The NETT Council should periodically review and report on how each of the modal administrations is promoting and incorporating new and emerging technologies into all their initiatives, including research and development, policy guidance, regulation and oversight, funding opportunities, strategies like NHTSA’s National Roadway Safety Strategy, and tactical implementation plans. The Chief Innovation Officer should report to OSTP. OSTP’s mission maximizes the benefits of science and technology to advance health, prosperity, security, environmental quality, and justice for all Americans and leads efforts across the federal government on research and development. It therefore seems appropriate that the NETT Council’s work should fall within OSTP, similar to other bodies like the Council on Environmental Quality and National Security Council, both of which include innovative research on emerging technologies.

Second, the Council should rely on third-party organizations like ITS America to help convene stakeholders, summarize feedback, update websites and guidance, and advise and inform on new and emerging technologies to keep the council relevant, up-to-date, and ensure it continues to lead.

Third, the Council should conduct workshops with transportation agencies and stakeholders of different sizes and focus areas to reflect the broad spectrum of needs across the nation. For example, the council could conduct a workshop with the largest cities that have large transit ridership and another with suburban traffic managers from locations with limited transit utilization. The needs for innovation vary based on communities, regions, perspectives, and the transportation challenges each community faces. Understanding what emerging technologies can do to solve these challenges relies on listening to varying perspectives. While request for comment and other federal register engagement efforts are mechanisms to solicit official comments, other mediums of engagement offer different opportunities for participants to provide more constructive, candid, and open feedback. USDOT and the NETT Council might consider some of the many venues in which transportation innovation is discussed as engagement opportunities for stakeholders to provide honest and constructive comments and feedback without attribution.

5. Are there additional stakeholders the NETT Council’s analysis should reflect?

The NETT Council should coordinate and collaborate with transportation stakeholders outside of USDOT and those efforts should extend beyond requests for comment and other federal register notices. The council should institute a federal advisory committee –ITS America was founded as one – whose role would be to help guide and facilitate the council’s goals and objectives. ITS America would serve as a natural source for these advisory needs, and the committee could be built out with representatives from various corners of the transportation industry, including our members who represent:

• Stakeholders and decision makers at the state, regional, and local levels (state DOTS, MPOs, Regional Councils, counties, tribal governments and cities);
• Transportation trade and industry associations (ITS America, APTA, AASHTO, Transportation Trades Department- AFL-CIO);

• Academia, research institutions, and think tank representatives (University Transportation Centers, think tanks, independent research institutions);
• Private sector organizations and firms (architectural and engineering firms, intelligent transportation technology supplies and companies, OEMs, new mobility providers);
• Consumer advocacy groups; and
• Representatives from affected populations, community stakeholders, end users, and vulnerable groups.NETT Council stakeholders must ensure that emerging technologies are developed to focus on the needs of the end user and incorporate concepts from human-centered design principles, which use empathetic inquiry in the research and innovation process. The advisors who sit on this committee should provide their time pro-bono and offer unbiased input and insight into technical and policy elements of innovation. In addition to the stakeholders mentioned above, USDOT should make a concerted effort to regularly engage new stakeholders in the transportation space who might bring a different perspective to these emerging technology discussions, which would promote diverse company perspectives and listening to all voices – not just the loudest voice – and help eliminate bias toward products or outcomes.

6. Are there stakeholder groups that have been marginalized in transportation technology innovation that should be better represented in the NETT Council’s analysis and work?

In short, yes. Diversity, equity, inclusion, and belonging should be prioritized across all the NETT Council’s work. Of the approximate 14.8 million jobs in the transportation sector, less than 15 percent are held by women and women of color. Census data shows that from 2005 to 2019, the number of women in the sector only grew by three%. Today’s transportation systems suffer from historic and ongoing inequities embedded in infrastructure, access, and cost. To help overcome these challenges and advance DOT’s goals to promote transportation equity, councils like NETT need to include a diverse set of stakeholders and ideas. As we explore and fulfill the promise of new technologies, we must embrace and support the paradigm shift occurring in our nation, learn from the lessons of the past, and incorporate transportation equity principles into the research, development, and implementation of new mobility technologies.

ITS America’s vision sees this revolution of future mobility technologies as a once-in-a-lifetime opportunity to rethink how the system is built to be more innovative, nimble, inclusive, and equitable. If the NETT Council engages communities, develops strong metrics and goals, and remains up to date on cutting-edge emerging innovations, the U.S. can harness the ability to rethink the system, repair past harms, and increase economic opportunity to advance civil rights and social justice. ITS America believes that access to transportation is central to opportunity and technology can promote transportation justice if USDOT willingly takes the lead to align the council’s priorities with these objectives to advance technology through meaningful collaboration.

This work requires people in the transportation sector – including the future leaders of the NETT Council – to understand technology’s impacts on those least prepared to use it or who face barriers to adoption. For many underserved communities, it is difficult to find time and resources to attend public meetings and think about why emerging technologies are so important to consider because they face more acute pressures and challenges at home. However, as we celebrate the Bipartisan Infrastructure Law and prepare to invest billions of dollars into the transportation system, it is critical to empower communities to have a seat at the table to inform policy around emerging technology. It must also ensure the safety, access, and mobility of these populations are not

compromised. The NETT Council can and should serve as a lever to prioritize safety, equity, accessibility, inclusion, and community partnerships that incorporate racial equity factors in USDOT programs, including grant and loan programs, as a selection criterion.

Priority Technologies and Innovations for the NETT Council to Review

7. Using DOT’s authorities, what nontraditional and emerging innovation and technologies should NETT Council prioritize for analysis as most impactful, positive or negative, for the transportation system? What emerging innovations have the most significant potential impact on DOT’s strategic goals of safety, economic strength & global competitiveness, including creating good-paying jobs, equity, climate and sustainability, transformation, and organizational excellence?ITS America suggests emphasis on 1) safety-oriented technologies and innovations; 2) sustainability-oriented technologies; 3) freight-related technologies; 4) innovative infrastructure technologies and 5) personal mobility technologies. Examples may include transit technologies; safety technologies (e.g. bicycle and pedestrian detection sensors); trip planning technologies; open and contactless/integrated payment technologies; unmanned aerial mobility and drones; hyperloop; personal and automated delivery devices, micromobility; solar-power paved highway technologies; rubberized roads, right-of-way solar, airless tire technology, integrated signal systems, and traffic and vulnerable road user analytics.
8. What emerging innovations face gaps in focus, support, and/or regulation under DOT’s existing regulatory frameworks, and should be reviewed by the NETT Council?
   As an emerging paradigm, mobility-on-demand and the various technologies and deployment efforts related to it often face gaps in support or regulation. The NETT Council should explore the ways in which MOD-related technologies or deployments might be made eligible for more support.
9. What emerging transportation technologies should the NETT Council evaluate for their potential to contribute to ensuring American workers and domestic sourcing and supply chains are strengthened rather than weakened through transportation innovation, including advancing activities under the President’s Made in America Executive Order 14005, dated January 25, 2021, and the President’s Executive Order 14017 on America’s Supply Chains, dated February 24, 2021?The NETT Council might consider devoting specific resources to the workforce implications of emerging transportation technologies, liaising with the Department of Labor and representatives from transportation unions, private sector corporations, State and local public sector agencies, and various transportation trade and industry associations. The Council must also coordinate with the Department of Commerce to understand the available supply of emerging transportation technologies domestically and the available products and resources through relationships with the US Trade and Development Agency. The Council should use a data-driven approach to supply chain and Buy America implementation provisions to ensure that as technology and innovations scale, DOT includes a plan for how increasing demands will be met by available existing technologies. ITS America urges USDOT to maintain flexibility in Bipartisan Infrastructure Law program administration for emerging technologies, which have

been hard-hit by the global supply chain disruptions, making eligibility and competitiveness for grant programs especially difficult for small emerging technology companies.

10. What other pressing issues, challenges, and opportunities for transportation innovation should be addressed through the NETT Council?
ITS America urges the NETT Council to incorporate this work into USDOT’s Innovation Principles and develop clear metrics for how the Innovation Principles will be incorporated and measured across DOT and modal programs – including the Bipartisan Infrastructure Law investments and discretionary grant programs. By aligning the work of the NETT Council and the USDOT’s Innovation Principles and by developing goals, metrics and strategy for the Council that support each of the six Innovation Principles, the Council can show value as well as an effort to effectively coordinate this work. The NETT Council, for instance, might be a platform to further build out the Innovation Principles, which could guide its work and emphasis. ITS America has already developed a framework to apply specific technologies to the innovation principles which we would be happy to share with the Council to support its further development and success.

ITS America also notes that certain programs are still being funded via the Bipartisan Infrastructure Law that are not technology neutral, which we find inconsistent with DOT’s Innovation Principles. ITS America suggests the NETT Council aim for continuity among the Innovation Principles and US DOT’s innovation related programs and work. This could be developed by creating strong performance metrics and key performance indicators (KPIs) for the Council’s work and the programs out of the Bipartisan Infrastructure Law.

Finally, ITS America suggests the Council should have a short, but pointed overarching strategy, outlining their top priorities so that America has a vision and framework for the research, deployment and adoption of emerging mobility technologies as well as some degree of regulatory certainty.

ITS America looks forward to working with US DOT on emerging technology issues and seeing how we may support the NETT Council’s work and development moving forward.

Sincerely, Laura Chace

President and CEO ITS America