Regulations say you need a steering wheel airbag, but what if there is no wheel?

General Motors is getting ready to ditch the driver for good—at least in its newest R&D vehicles. In 2019, Cruise—the self-driving startup acquired a couple of years ago by GM—wants to begin testing the fourth generation of its autonomous vehicle, the Cruise AV. (This is a modified Chevrolet Bolt EV, no relation to the Chevrolet Cruze.)

The company has filed a safety petition with the US Department of Transportation requesting permission to deploy the fourth-generation Cruise AV, which will be completely driverless, without any steering wheel, pedals, or other form of manual controls.

According to The Verge, part of the request has to do with ensuring passenger safety despite the car not conforming to the Federal Motor Vehicle Safety Standard regulations. For instance, it lacks a steering wheel, therefore it lacks a steering wheel-mounted airbag. As GM President Dan Amman explained, "[w]hat we can do is put the equivalent of the passenger side airbag on that side as well. So it's to meet the standards but meet them in a way that’s different than what’s exactly prescribed, and that’s what the petition seeks to get approval for.”

News of the petition was made public at the same time as GM's 2018 self-driving safety report (pdf), a document that gives a good high-level overview of GM's autonomous driving operations and the approach the company is taking with the Cruise AV with regard to sensor fusion, safety and redundancy, and testing.

Safety reports of this kind, while not legally mandated, were suggested as a voluntary action by the DOT when it released its guidance on autonomous driving in 2016, and the request was reiterated after the guidance was slightly tweaked under the Trump administration. (So far, Waymo is the only other company to have published such a report.)

Where exactly GM plans to test the fourth-gen Cruise AVs in 2019 remains to be seen and will likely require a little more paperwork on GM's part, since many jurisdictions require a safety driver ready to take over at a moment's notice, something that won't be possible in these cars, lacking as they do a steering wheel or pedals. GM has been testing on the streets of San Francisco and the suburbs of Phoenix, in addition to private test tracks and proving grounds. The company has also announced that testing will also begin in Manhattan this year.