Many More NHTSA Comments

I should number these with the NHTSA numbers, but the links are here. These are from the last couple of weeks, when work and vacation interfered with other parts of life.

Comment #1: Safe Driving MN (SDMN) submitted in writing its statement to NHTSA, which was eloquently delivered at the DC hearing in April. SDMN is advocating for self-driving vehicles to be accessible to people with disabilities. They make a very good case for innovation and inclusion.

Comment #2: This comment is a call for sensors that detect explosives be embedded in autonomous vehicles, particularly roaming taxis.

Comment #3: I don't think the American people are fixated on this, but there's a large number of people paying attention to driverless vehicles who equate them with the next big thing in terrorism. This is another comment calling for sensors for explosives.

Comment #4: The Disability Right Education and Defense Fund (DREDR), a national organization, asks NHTSA to take advantage of this revolutionary time in vehicle development to require equal access for people with a broad spectrum of disabilities. Except for the weird analogy to the liberation women experienced with automatic washing machines, the comments represent an effective piece of advocacy for moving past the ADA to true equity in travel. They did not mention the ADA's inadequacies, I am. It's the elephant in the room.

This is DREDR's case in a nutshell.

We urge NHTSA, software developers, designers and manufacturers to keep in mind that a car that can operate in autonomous mode without driver intervention can make an incredible difference in the life of a person with a disability, but not if they can’t open the door to use it, can’t enter with their wheelchair, hear instructions from the vehicle, or access a screen to give operating directions. 

Comment #5: I think this one is also terrorism related, but I'm not certain. 

Comment #6: This is from the American Trucking Associations (ATA). Yes, that's the plural of association. So relieved this is not another terrorism-paranoid comment. ATA wants:
1. Complete flexibility with the use of partial or complete autonomous driving technology, 
2. Government investment in research and testing, 
3. Cybersecurity and self-diagnosing technology,
4. A dedicated bandwidth for connected-vehicle technology, and
5. Display screens and electronic logging devices that do not distract the driver - if there is one (the last part is me).

Comment #7: Can't go long without a terrorism-related comment. Here's another one. 

Do these people think that (a) terrorism will be everywhere with driverless vehicles, and (b) there will be no terrorism opportunity if we have some magic device in driverless vehicles? History shows, I believe, that terrorism is generally low tech and done in places without security devices, though sometimes under the noses of police (i.e., the Boston Marathon bombing). Unfortunately, this is our world. I wish driverless vehicles were magic, but they will not be. Even I will be worried this summer when one of my children will be all over Europe, at airports, in train stations, and in public places. I work near the White House. This is something that crosses my mind frequently. Make that magic device and share it with me. But driverless vehicles are no different than rental or other vehicles we have today. You can put any kind of box you want in them. I hope we choose good and not evil.

One more batch of comments that arrived this morning in my inbox

Comment #8: Oh yes, another terrorism-related comment. Don't these people have some work to do?

Comment #9: This comment is from the American Motorcyclist Association. They are also paranoid about hackers, but in terms of privacy and weird vehicle maneuvers on the roads. I admit that when I saw AMA, I thought the comment would be from a medical association. This AMA, the motorcyclist one, supports research for driverless vehicles and the safety and privacy of motorcyclists.

Comment #10: The Insurance Institute for Highway Safety - Highway Loss Data Institute (IIHS) offered a bland comment, mainly about requiring the collection of specific data in structured formats, basically so that apples can be compared to apples instead of oranges. Data is valuable to number crunching operations at insurance companies, which are busy assessing the risks of driverless technology. In the quest for more data, IIHS is asking that companies operating driverless vehicles - i.e., the Google cars and others on real roads - supply detailed information in every instance of a crash or incident in which a human takes over the wheel (if there is one). They also want something akin to flight data recorders in every vehicle. Oh, and they would like cybersecurity and electronic systems safety.

Comment #11: I know this guy. Sort of. We converse on Twitter. He is English, I think. James Welling, of Speedy Sticks Consulting, is concerned about the accessibility of driverless vehicles for people with disabilities. Welling advocates for unmanned testing of these vehicles in different weather and traffic conditions. He offers a miles per casualty (MPC) performance standard to be established before driverless vehicles are permitted to be operated with unlicensed passengers aboard. Welling goes into much more detail about this. He also wants something akin to an emergency chord or elevator button that could immediately shut down a vehicle. 

Comment #12: A big, potential loser in the driverless revolution will possibly be the association that submitted this  comment, the National Automobile Dealers Association (NADA). I would not not want to hear their thoughts on Tesla or Uber. The comment is pretty much in favor of motherhood and apple pie. NADA's one meaningful statement is the suggestion that autonomous vehicles be subject to the same recall system as conventional vehicles.

Comment #13: This comment is from a true automobile safety expert, Kenneth Saczalski, who has done work for decades for IIHS, NHTSA, and Transport Canada, among others. He advocates for vehicle safety regulations that go further than ones for current vehicles, specifically mentioning rear impact and rollovers. He believes structural protections should be in place because roof equipment, sensors, increase the risk of roof crush when rollovers occur. He goes into detail about a few other safety issues as well. Saczalski shows concern for the "drivers" of Google vehicles and others because they are being subject to risks. Very interesting.

Comment #14: Volvo offers a 14-page response to each of NHTSA's queries. Not all responses are created equal, so I am just going to list the Volvo highlights.

1. Recommendation of a holistic safety and impact evaluation method. Others have the requisite knowledge to judge this detailed comment, but not me. It is detailed and thoughtful.
2. Volvo only conceives of a vehicle in which there is a driver who can take over and equipment for he or she to do so.
3. Methods for detecting the operational limits of sensors.
4. Explanation of types of sensors. No AI mentioned.
5. In terms of data recorders, Volvo will comply with the law. It is collecting lots of data during the testing and pilot phases.
6. Thank you Volvo. Cyber and other security issues are not unique to autonomous vehicles (AV).
7. Volvo recommends: EU CAE simulation voluntary working group P.E.A.R.S.
8. Currently, Volvo's AVs do not interact with, but rather respond to pedestrians.
9. In the case of an AV recall, the AV system will be incapable of activating.
10. "Volvo is open for discussions on platforms for data sharing."

Comment #15: An actual Congressperson submitted a public comment. The comment is from Daniel Lipinski from the Third District of Illinois, which includes a bit of Chicago and the southwest suburbs, not to be confused with the tony, wealthier suburbs north of the city or the hipster neighborhoods north of the Loop. Lipinski is in favor of AV and authored a tech-friendly transportation bill that was mostly incorporated into the FAST Act, the current US transportation law. He believes that now is the time for innovation and communication among stakeholders (my word), which means states as well (his expressed wish), and not for regulation. He is encouraged by how NHTSA is proceeding.

Here's a quote.

I was a co-author of the Future TRIP Act, of which key provisions became law in the FAST Act. Specifically, the language directed the Department of Transportation (DOT) to create update its strategic research plan and to focus resources on top priorities. In a time when the technology that enables automated vehicles is rapidly advancing, I firmly believe that we must continue to promote research and development with the goal of full deployment of automated vehicles on our roads and highways. 

Oh crap! More comments in my inbox this morning. I need a break.