NHTSA Comment by Professional Engineers Group

There's a bit of a conflict of interest when your comments say both "We need a gatekeeper!" and "We should be that gatekeeper!" The National Society of Professional Engineers (NSPE) is asking NHTSA and the State of California to slow down on the road to self-driving transportation, well slow down at least until NSPE is designated as the developer of standards, perhaps, but definitely the arbiter of what model vehicles pass muster before being permitted on the road.

Maybe I am way too cynical. Maybe I just disagree with a go-slow-approach when a planeload full of people die on our nation's roads each week as human drivers fall asleep, drive while intoxicated, try to get the kids to pipe down, or spend a second too long looking at something pretty outside.

What data is being entered into this equation?

Seems to me that a scientific organization would look at the data and make calculations. On one side of that equation, the human driver side, there are a whole lot of deaths and lives significantly changed due to auto crashes. That side is not even mentioned in the NSPE comments.

I agree with NPSE pushing technology-neutral standards and a watchdog to make sure standards are met and inspections are performed and performed diligently. The agreement ends there.

This is NPSE's bottom line. I guess no one at that association has watched the Nvidia video or the videos of the Ford driverless vehicles.

 [T]he notice asked what aspects of autonomous vehicle technology may not yet be suitable for guidelines. As stated earlier, there are still major thresholds for safety that must be met. We do not believe that the technology has yet advanced enough to deploy fully autonomous vehicles. Deploying such cars when there are still issues with navigating in inclement weather, merging at intersections, responding to nonautonomous vehicles, responding to road hazards or sub-optimal operating conditions—in short, responding to the unexpected and variable conditions that manned vehicles routinely face on the roadway today—a vehicle without an operator poses a major threat to the public safety. Let’s acknowledge the current limitations of the technology, work within those limitations, and take an important first step, not a final one, to develop and deploy technology that offers significant but as-yet-unproven promises for improved transportation efficiency and safety.”

I agree with the following reasoning in favor of a disinterested judge, but I do not believe that a group so doubtful about the technology will consider it in a timely and fair fashion.

Public safety is best served when there is someone in the decision chain who has a duty that overrides competitive pressures to be first to market or surpass other manufacturers’ offerings. Someone who has a clear and enforceable duty that overrides even peer pressure to be a team player and not the department or group within the corporation whose legitimate safety concerns might delay a high-stakes project. 

I hope that the Department of Transportation, or one of its agencies within the department, can be that judge or be the neutral party to select such a judging entity.