Self-driving car prototypes should not be subject to the same safety regulations as production vehicles, Apple argued in a letter last month to the National Highway Traffic Safety Administration.

The letter commends many other aspects of the agency's proposed Federal Automated Vehicles Policy (FAV), but it offers few clarifications to the rumors that have been swirling in recent months about Apple's own self-driving car ambitions.

From securing car-related domain names to hiring executives from Tesla, it's clear that Apple is at least exploring autonomous driving. But the company in September reportedly laid off dozens of employees working on the self-driving project, code-named Project Titan, in a sign that the tech giant is rethinking its efforts.

In the letter, sent by Apple Director of Product Integrity Steve Kenner on Nov. 22 and spotted by the Wall Street Journal last week, the company said it agreed with many safety and certification rules for the production of self-driving cars, but suggested that prototypes should not be subject to all of them. Rather than requesting exemptions from the rules each time it makes a modification to a prototype, Apple wants to self-certify that its prototypes are safe.

"Instead of applying for exemptions, all companies should be given an opportunity to implement internal safety processes summarized in a Safety Assessment," Kenner wrote. That's akin to the current process, which allows established manufacturers to test on public roads without pursuing exemptions from federal safety standards. But the proposed FAV policy has no such provision, a potential burden for Apple if it decides to test its own cars after the policy is enacted.

"To maximize the safety benefits of automated vehicles, encourage innovation, and promote fair
competition, established manufacturers and new entrants should be treated equally," Kenner wrote.

Main image courtesy of designer Meni Tsirbas (@MeniThings; YouTube)