Another Bunch of NHTSA Comments

I'm just renumbering here and giving links. So, here's comment number one for today.

Comment #1: From SAE International, which has been doing research for DOT, the comment requests that NHTSA employ standard terms and definitions so that a plethora of confusing terms do not blossom like a garden of weeds after a summer rain. Okay, the comment did not use such language.

Comment #2: This comment is from the Future of Privacy Forum and, as the name suggests, privacy of data is the organization's concern. This is the worry in a nutshell.

... [T]here is a risk that information like pickup and dropoff locations may allow government agencies—or anyone else who obtains this information through FOIA and other mechanisms—to identify individual riders by associating it with publicly available records. 

Comment #3: Ford Motor Company, which sent a representative to both NHTSA hearings, submitted this comment. Safety? Data security? Data recorders in case of accidents? Ford is in favor. I think it votes in favor of motherhood and apple pie as well. It's an educated guess. Oh and the company says that it is looking forward to working with NHTSA for safe autonomous vehicles.

Comment #4: AAA submitted comments that raise a few issues. Here's two: data privacy and driver/operator training to use driverless vehicles. Okay, in my mind, the whole point of driverless is that I don't have to do anything but tell the vehicle where to go. I'm still dreaming of the tiny house that's driverless.

Comment #5: Google's comment discusses succinctly an important concern that 50 states with 50 laws and 50 different sets of definitions and requirements would be a nightmare - my word. In a nutshell, this is Google's point.

We strongly urge that the guidance to the states recommend that those states intending to regulate the deployment and operation of automated vehicle technologies adopt NHTSA's operational guidelines with respect to the safety of the vehicles rather than impose different, conflicting state rules. We have seen 15 states propose such laws over the last 12 months; all of which have different scope and different definitions. 

Comment #6: More from Google. The company comes out in favor of manufacturer self-certification that safety guidelines are met. Wow. Google is asking for a lot of trust and, let's face it, corporations have not always deserved that trust. They have not always looked out for the public good or even the good of their actual consumers.

Google talks about operational limits of vehicles on the way to full automation in all types of places and in all types of conditions. Add to that, Google's point that the vehicle must reliably recognize those limits. Has Google seen the Nvidia video?

One thing very heartening in Google's comment is the commitment to helping people with disabilities who are currently unable to operate our current driver-required cars.

In the interest of my own time, here's a list of issues/thoughts in Google's comment.

1. Data recording so that we learn from crashes and other performance errors. Google goes into the fact that for current vehicles, not all crashes are reported - only ones in which the police are involved. Google would like to see collection of broader sets of data and common standards that allow for comparison of data. (I hope I am reading that correctly.)

2. Fully autonomous vehicles should have good crash avoidance technology.

3. Full scope of testing and data privacy protections.

4. Encouragement that NHTSA allow for advances in sensor technology.

We therefore recommend any guidelines proposed by NHTSA should avoid focusing on being prescriptive about equipment and instead focus on overall performance. The functionality and reliability of components such as sensors should be examined as part of the vehicle manufacturer’s functional safety analysis as it pertains to the system or subsystem in which the component is used.

5. Google urging that NHTSA somehow block a patchwork of state laws.

6. Google - and me - wants permission for operation of vehicles without drivers and without driving equipment.

7. Google warns against closing off of innovation relating to technology to avoid crashes involving pedestrians - and, I presume, bikers, deer, etc.

8. Google foresees easier repairs in cases of recalls. The company wants to continue with existing regulatory standard.

9. Google wants NHTSA action to recognize value of computer simulations and modeling.

10. Google includes an appendix with scenario types used by its self-driving vehicle team.

Comment #7: This comment comes from the Alliance of Automobile Manufacturers, meaning the old car companies, representing 77 percent of car and light truck sales. The crux of AAM's three-page comment is:

Facilitation of the deployment and adoption of Advanced Driver Assist Systems (ADAS), active safety systems and eventually driving automation technology starting with a nationally-applicable legal and regulatory framework that avoids a patchwork of state laws and regulations and maintains current selfcertification practices, will accelerate the availability of such technologies and achievement of the potential benefits. 

Everyone wants to avoid the nightmare of 50 different states with 50 different regulatory regimes, standards, and sets of definitions.

Comment #8: Delphi Automotive shares its "proven expertise" with NHTSA. That's Delphi's words - not that it's wrong, just bold. Delphi envisions a future that has both autonomous and connected vehicle technology. It's comments address both as part and parcel of future vehicles.

I'll number these as well. These companies are verbose. No judgment; I just don't have much time. This long comment goes way into the weeds - important, geeky weeds.

1. Definitions are important.

2. Operational boundaries and detection of those boundaries, which will all change over time as the technology becomes able to operate in more places and situations. The comment also covers the issue of partial automation and driver takeover. I love that Delphi mentions that it can take up to 40 seconds for a driver to takeover, even mentioning that a driver might be asleep when a takeover request is made. Thank you Delphi for raising this important consideration.

3. Delphi diplomatically suggests communication with and involvement with groups representing people with disabilities as we move toward a driverless future.

4. Delphi calls for archiving of data as the learning and development process happens - and thereafter. (Does data ever disappear?)

5. Delphi wants NHTSA timeline for crash avoidance to "not slip." Current deadline of 2016.

6. Yes to electronic and cyber safety.

7. List of some technical standards.

8. Nice discussion related to pedestrian safety and signage/signals for AV.

9. Need for recognition of emergency vehicles.

10. Discussion of recalls and in what circumstances AV should be permitted to continue to operate.

Comment #9: Orbit City Lab posits the "what if a terrorist/evildoer thing happens?"

Comment #10: Also from Orbit City Lab on the terrorism issue.

Comment #11: Comment from the Association of Global Automakers, meaning car companies outside the US. Here's the list of wants.

1. Again, that word "patchwork." No one wants it when it comes to different state laws with different standards and conduct permitted or prohibited.

2. AGA wants standard definitions.

3. Manufacturer flexibility. Not wanting to be hampered by slow regulatory approval processes.

4. Need to incorporate connected vehicle technology issues.

5. International harmony. Standard standards and singing kumbaya.

Comment #12: Oh gee, another Orbit Lab paranoid comment.

Comment #13: Ditto.