Panda videos and lots of AV comment opportunities, reports, events

All those months when nothing came from the Federal Register about autonomous vehicles (AVs) are in the rear view mirror and a few weeks ago the outgoing US Department of Transportation (USDOT) leadership released a flurry of documents - and thereby opened comment periods - charting a course for a road to accessible AVs. 

My small brain has been having a hard time keeping this all straight, so I am making the virtual effort of straightening out the piles, the dates, and the entities involved. To keep sane and smiling, enjoy the three panda cub videos sprinkled among the AV info.

Best in-a-nutshell AV resource 

Before we get to all that good stuff that has popped up in the Federal Register, here is a big treat: Eric Dennis of the Center for Automotive Research has just updated his excellent table of AV state laws. Warning - Not all of the laws within each category are the same, so this is not a deep dive, but it is a fabulous snapshot and an excellent resource. Also note that sources of regulations for a given state might be a law or an executive order of a governor. Dennis also maintains maps of state laws. Follow him on Twitter @EricPaulDennis for notices of his updates.

A database of state AV legislation and laws is available from the National Conference of State Legislatures. Dennis also maintains his own resource.

You didn't have to - lots of AV comment opportunities

Really, Elaine (Chao), you did not have to feel the need to leave so many parting gifts and all with open comment periods. I am sure this work will be helpful to USDOT staff, and I mean that sincerely, but it is also a gift to all of us who care about expanding transportation access and equity because the Chao USDOT made clear where exactly we are and how much we can expect if we do not alter the current public-private transportation divide. Of course, the staff who will be tasked with reading, interpreting, classifying, and preparing a document in response to each document might not be so happy.

• Framework for Automated Driving System Safety - The National Highway Transportation Safety Administration (NHTSA) seeks comments about various aspects of AV safety, testing, and standards development in terms of NHTSA's role. There are over 20 specific questions posed. The comment deadline has been extended to Apr. 1, 2021. This is an Advance Notice of Proposed Rule Making (ANPRM). I have several posts about comments submitted, though, as of today the number is well north of 613 and I am just at the beginning of reading all of those. 😟  Now well over 500 behind. 🤔 Maybe time to clone myself.
• Request for Information: Inclusive Design Reference Hub - The Office of the Secretary (OST) at the USDOT issued this request for information (RFI), which seeks ideas for collating inclusive design research with the goal to "establish a library of resources for accessibility in automation, and work with outside experts to study voluntary best practices for ensuring accessibility in automated vehicles." An RFI is not a commitment; it's a much less formal counterpart to a request for proposals. The comment period ends Feb. 19, 2021. The original comment period, which ended on Jan. 20, 2021, was officially extended. Thus far, there are seven comments and these are summarized in previous posts.*
• Draft Strategic Plan on Accessible Transportation - The USDOT is seeking comments on its draft plan, which aims toward "mak[ing] America's transportation system accessible to all travelers." That is a tall order and I am just beginning to read this document. (Nothing thus far about requirements or legislation that mandate production of accessible vehicles.) Comments are due on or before Feb. 16, 2021. Six comments submitted so far.
• See safety and cybersecurity section below for one more open comment period.

* Please note that as of the publication date that the USDOT website is not making available an OST page.

Events

Inclusive Design of Autonomous Vehicles - Mar. 10 - Apr. 21, 2021, every two weeks. Hosted by the US Access Board.

A four-part series of public forums to discuss different aspects of accessibility and the transportation needs posed by particular groups of disabilities. Links to the forum are not posted yet.

African American Conference on Disabilities - Sessions throughout February 2021. Hosted by the  Arizona Center for Disability Law and the Arizona Center for African American Resources.

This is an event with speakers from across the US. There are no transportation panels; the conference focuses on housing, accommodations, education and the effects of the pandemic. 

Plea to AV report writers: Take a vacation

To make it worse, on top of trying to keep abreast of AV work at the USDOT, I am also trying to keep track of and read all of the excellent AV reports that have been issued recently. There's a list below. I have to admit a certain personal conundrum of figuring out what exactly I want to read and focus on these days. I am supposed to be starting a podcast and a book, but, instead, I am treading through virtual piles of AV reading just to remain up to date. 🏊  (That's a swimmer emoji, in case it's not obvious. No frantic, treading water emojis were available.)

• Inspiring Autonomy: How Auto Insurers Will Lead Through Changing Risks - This is an updated 2018 report from Travelers Insurance about AV developments, how the auto insurance industry should continue as AVs roll out, and the best strategy for quickly compensating crash victims. 
• Autonomous Vehicles and the Future of Auto Insurance - This is a report from RAND Corporation, which has done excellent research and reports on AVs. It explores different AV ownership and insurance regulation possibilities, with recommendations to investigate international models and public-private collaboration.
• Low-Speed Automated Vehicles (LSAVs) in Public Transportation - This report is from the Transit Cooperative Research Program (TCRP) (within the Transportation Research Board (TRB)). It provides an overview of slow-speed AV shuttles, where they have been used, and factors that contribute to success. This is a practical report, with checklists for procurement, evaluation, and monitoring, among others. There are also a few detailed case studies provided.
• Automated Vehicle and Shared Mobility Forum (AVSM Forum) - This TRB website hosts a library of brief reports of research summaries and discussion workshops with invited speakers and forum members, an A-list of AV and shared-use mobility thinkers (with professionals from state, local, and federal agencies, the private and non-profit sectors, and academia). The issues covered are wide ranging, but often in the form of articulating research needs and concerns around data, equity, and accessibility, among others. 

Goodies for safety and cybersecurity experts

• Cybersecurity Best Practices for the Safety of Modern Vehicles - This is NHTSA's draft update of its 2016 (Obama administration) cybersecurity document. Comments are due on or before Mar. 15, 2021.
• Notice Regarding the Applicability of NHTSA FMVSS Test Procedures to Certifying Manufacturers - The comment period is closed. This document essentially reverses (using judicial terminology) the 2016 statement of the Obama-era USDOT that required AV compliance with the NHTSA-issued federal motor vehicle safety standards (FMVSS). This document basically declares that FMVSS are not themselves performance standards. I am not a safety engineer, so I will offer a quote here. "While the manufacturer of a motor vehicle must produce vehicles that comply with all applicable FMVSS and must exercise reasonable care in certifying compliance, the Safety Act does not require that a manufacturer ensure that NHTSA can validate the manufacturer's certification through the FMVSS test conditions and procedures when it certifies the vehicle." This document has nothing directly to do with accessibility. There were 12 comments submitted and it will be interesting to read these as major organizations and businesses are among those who responded to the notice.
• Safe Enough: Approaches to Assessing Acceptable Safety for Automated Vehicles - This RAND report is a dive into different ways to measure safety. 

For more panda time, visit the Giant Panda Cam. 

Request to Congress: Please concentrate on other topics until I am up to date, maybe in four months, before you all circle back to AVs. Thank you. 

Since I am not on the top of anyone's list for that magical vaccine, I can stay home and read official documents and comments.

Insurance Industry Critical of Vehicles and Legal Landscape

A patchwork of state laws and voluntary federal guidelines is attempting to cover the testing and eventual deployment of autonomous vehicles in the U.S. It is a decidedly pro-technology approach that lacks adequate safeguards to protect other road users. 

From Status Report: Reality Check (Insurance Institute for Highway Safety, Aug. 2018).

The report from the Insurance Institute for Highway Safety (IIHS) examines both partially automated vehicles, such ones equipped with Tesla Autopilot, and the vehicle involved in the Uber crash in Arizona, as well as the federal and state-level legal landscape governing - or neglecting to govern - AV testing and deployment.

If you are looking for a good source to quickly educate someone about the regulatory and legal provisions applicable to AVs, this report's final few pages provides an excellent source.

AV passport at state borders?

While there are states that have laid out the welcome mat - nary a question asked - for AVs, others have requirements in place for documentation, permits, and coordination with state agencies, particularly law enforcement. Right now, fully AVs are not crossing borders. They are not coming with a pile of papers for safe crossing of state borders or an AV equivalent of a passport.

The report concisely describes the many state laws that have been passed in the past few years, pointing out that 11 states allow for full AV deployment without requiring the equivalent of a driving test or a pile of documents that establish that a particular vehicle is capable of safe operation.

Federal vacuum creates state laboratories of democracy

The report does not come right out and expressly state that the federal government, specifically the National Highway Safety Transportation Administration (NHTSA), has abdicated its responsibility over vehicle safety of partially or fully AVs, because IIHS is too diplomatic to be so blunt, but it basically finds that NHTSA has taken a very hands-off approach.

The report adequately summarizes the safety-regulation issues thwarting the easy passage of legislation in the Senate and the players who are opposing the lenient, incredibly pro-business bill that is pending there. Just a few Senators currently stand between passage of the bill and reconciling a similar version that passed eons ago in the House of Representatives.

Plain speaking

IIHS is being blunt in expressing its opinion that crash data be shared so that the insurance industry can analyze the data to determine the relative safety of the vehicles involved.

To that end, IIHS strongly advises NHTSA to create and maintain a nationwide public database of vehicles with automated driving systems and those exempt from safety standards that is indexed and searchable by vehicle identification number (VIN). Currently, VINs aren’t required to encode information about optional crash avoidance and automation features. ... As it weighs which regulations to amend, NHTSA also should consider new ones to ensure that automated driving is safe for all road users. Recording vehicle data is one area that needs to be addressed. 

I would think that the insurance industry, and IIHS in particular, would be a powerful voice due to its long experience, its profit motive, and its familiarity to political leaders, regulatory agencies, and the public. After all, every safe ride is at least a nickel in an insurance company's pocket. Okay, I have absolutely no data to substantiate that statement. For all I know, it could be $.0001.

Bunch of links: Pilots, UK law, SAE announcement

Pilots

Truly awful of me to send out a post that is a list with links. Too busy this week to do otherwise and this post is more personal filing of information than entertaining or informative writing for an audience. My apologies.

Australia - Regional pilot locations announced in New South Wales.

Phoenix, Arizona area - Waymo and Phoenix's public transit, AND Waymo and Walmart partner up for rides to the store, AND Waymo test families include a teenager with the coolest driver - as in none.

Austin, TX - Cap Metro, the transit agency, is testing AVs prior to year-long pilot with EasyMile shuttles. More local coverage.

Dallas/Fort Worth, TX, area - AV service within geofenced area by Drive.ai with bright orange Nissan vans.

Regulation and insurance

Pennsylvania - Stronger "voluntary" regulations, I mean "guidelines," demand more of AV testing companies.

New insurance law in England, mostly concerned with partial vehicle automation.

SAE

SAE to develop standards for AV safety. First draft due by end of 2018.

New SAE J3016 levels of automation came out in June and a new graphic was released in July. Still clumping together the very different and distinguishable partial automation level 3 with full automation levels 4 and 5.

Insurers Active on AVs

Suddenly, there is lots of movement from the insurance industry in relationship to autonomous vehicle (AV) regulation. Many companies and industry representatives have been or are now waking up to smell the coffee that an autonomous transportation system could potentially - though, not definitely - wreak havoc with their stable business model of consumer and commercial vehicle insurance that is regulated at the state level in the United States. They are comfortable, I am guessing, with state legislators and regulators; that's their backyard, as it were, and they know their territory.

It's a valid fear. Look what happened to taxis when Uber and Lyft came along. Taxis were comfortable with city and local regulators and political leaders, only to be blindsided when Uber, in particular, went above their heads to the state level, dumped money in state capitals, and got states to preempt municipalities from regulating or disallowing ridehailing operations.

Background

In two weeks, just in time for the 28th anniversary of the Americans with Disabilities Act (ADA), the Uniform Law Commission (ULC) will consider the draft of the Highly Automated Vehicles Act, which has gone through a few preliminary drafts at the level of the Commission's Highly Automated Vehicles Committee (HAV Committee). My last post discussed the draft, which was released last month.

Foreground

In response to the draft, the National Association of Mutual Insurance Companies (NAMIC) sent a letter to the ULC's HAV committee. I was stunned to see intriguing tidbits that went beyond the usual concerns of generic safety and cybersecurity.

First,  NAMIC wants to see safety repeated over and over throughout whatever model uniform state legislation is adopted by the ULC. The NAMIC literally complained about the decrease in the number of times the word safety was used in the last draft. A decrease of more than 20, by the way.

Second, NAMIC said - well, actually, its general counsel wrote - straight out that because Congress and the federal government are not legislating or regulating, respectively, in effect the states are in charge.

Travelers argues for insurance industry stability and advantages

The Travelers Institute issued a white paper this week that makes a few arguments in favor of retaining the current insurance industry model for the age of AVs. Insuring Autonomy: How auto insurance can adapt to changing risks maintains that whether we own our own cars or whether we all go out and get our rides with shared-use and transit services, we should stick with the current insurance model because - to butcher a cliche - if it ain't broke, why fix it. After all, we all know about and are familiar with auto insurance.

[T]here is a high level of certainty and stability – for consumers, businesses, regulators and legal systems – in the current auto insurance structure. For example, we generally know that all vehicles and drivers are covered with some liability protection whether through insurance (the case with the vast majority of drivers); bonds or cash deposits in place of traditional insurance; or proof of ability to pay for an at-fault accident (e.g., in New Hampshire). And auto insurance has a robust legal and regulatory infrastructure with proper, comprehensive consumer protections in place to govern insurance providers and policyholders. 

Though the white paper makes sensible points in opposition to relying solely on a product liability model of litigation, with its inconsistent results, and years-long delays, the white paper ignores the reality of quick, large settlements by the airlines any time there is a crash - effectively establishing a strict liability system in reality, though not in law.

The paper asks for model state AV insurance legislation, a uniform system of insurance regulation during the long transition to an AV-only vehicular transportation network, and a big dose of education for consumers as they drive partially automated vehicles. Personally, I do not believe any amount of education will eradicate human nature and that partially automated vehicles are an open invitation to dangerous distracted and inattentive human driving.

In the Weeds on NTSB Uber Report and House Hearing

What I Learned This Week

We may be a society of social media images, tweets, and sound bytes BUT there is much to be learned when you get into the weeds of something that most people, even professionals, do not have time for. On today's menu is the NTSB preliminary report on THE Uber crash and the Congressional hearing about insurance and business models for autonomous vehicles (AVs).

Drumroll please for the preliminary - meaning "don't quote us quite yet" - NTSB report on THE Uber crash that killed Elaine Herzberg in Tempe, AZ., on Sunday, Mar. 18, 2018.

As background, let us remember that Arizona Gov. Doug Ducey signed an executive order in August 2015 putting out the welcome mat for driverless vehicles to operate in the hot and sunny state without a person present, though with a licensed driver, either physically present or remotely able to take over operation (though, to be fair, that latter part was not explicitly stated).  THE Uber crash could have occurred elsewhere, but Gov. Ducey was the unlucky AV proponent for whom the fates aligned to get mud on his face for pushing a developing technology, failing to provide oversight, and shouting out loud about getting out of the way of the inherently innovative private sector, and, in particular, a company such as Uber, which has made a name for itself by harassing women and treating laws and regulations as pesky and irrelevant. Gov. Ducey thus somewhat arbitrarily received the punishment of media attention for being the governor of the state where the first pedestrian - meaning innocent person who did not assume the risk of engaging with what was said to be an AV - was killed by a technology that was supposed to see and brake for people.

Well, turns out, and I would bet the Governor and others, including me, were not quite aware,  the automated operating system responsible for hitting and killing Ms. Elaine Herzberg was not quite autonomous. That technology was unable to operate the vehicle without human assistance. In fact, the car was outfitted with a system that was more auto assist, similar to the Tesla Autopilot system, than AV. But let's allow the National Transportation Safety Board (NTSB) preliminary report to speak for itself.

As one twitter person said, and I forget who, NTSB employs the rather outdated word "accident" instead of "crash," thus undermining the hard work of many transportation writers and professionals to acknowledge that roads designed for speed and lack of pedestrian access are inherently and foreseeably dangerous places where crashes will occur.

Key quotes

The vehicle was factory equipped with several advanced driver assistance functions by Volvo Cars, the original manufacturer. The systems included a collision avoidance function with automatic emergency braking, known as City Safety, as well as functions for detecting driver alertness and road sign information. All these Volvo functions are disabled when the test vehicle is operated in computer control but are operational when the vehicle is operated in manual control. ...

As the vehicle and pedestrian paths converged, the self-driving system software classified the pedestrian as an unknown object, as a vehicle, and then as a bicycle with varying expectations of future travel path. At 1.3 seconds before impact, the self-driving system determined that an emergency braking maneuver was needed to mitigate a collision (see figure 2). 2 According to Uber, emergency braking maneuvers are not enabled while the vehicle is under computer control, to reduce the potential for erratic vehicle behavior. The vehicle operator is relied on to intervene and take action. The system is not designed to alert the operator.  ...

The inward-facing video shows the vehicle operator glancing down toward the center of the vehicle several times before the crash. In a postcrash interview with NTSB investigators, the vehicle operator stated that she had been monitoring the self-driving system interface. The operator further stated that although her personal and business phones were in the vehicle, neither was in use until after the crash, when she called 911. The NTSB continues to gather information on the Uber self-driving system, the vehicle interface, and the driver’s personal and business cell phones. 

Those quotes do not make me feel better, rather I feel like the Governor dropped the ball and Uber basically lied to the people of Arizona as well as the broader public and maybe even the driver/operators - who are now, by the way, out of their jobs - about what kind of vehicle was actually being operated on public roads.

NTSB does not address the inequitable and unsafe situation of Ms. Herzberg, who, like people all across America every day, walked across a road without benefit of a stop sign or traffic signal. Instead NTSB leaves for others to consider the prioritization of motor vehicles above other road users and the dangerous design of roads where 100-plus pound people walk and two-ton machines speed.

House hearing shows lots of bipartisan and public, private consensus and concern

Looking for a House of Representatives subcommittee hearing that carefully considers the future, displays bipartisan respect, and demonstrates concerns that cross not only the aisle between Democrats and Republicans, but also between public interest organizations and private companies? Look no further than this week's Housing and Insurance Subcommittee Hearing Entitled “TheImpact of Autonomous Vehicles on the Future of Insurance.” If you are interested in this topic, the approximately one-hour hearing is fascinating. (Don't be put off that the video says it is approximately two hours. The first hour is dead air and the actual start at about one hour begins with apology for the delay.)

Presiding was Wisconsin Congressman Sean Duffy, Chairman of the Financial Services Subcommittee on Housing and Insurance. He is a Republican from a rural district, but, like many in his historically progressive state, Rep. Duffy clearly sees the future and the significant role that regulation will play. He even said right out during the hearing that most of his staff doesn't even own a car and that the shared mobility/transit lifestyle is the wave of the future.

Highlights taken from my twitter coverage during my day-late viewing of the video:

One congressman suggested federal regulation of insurance and declared truth that ridehailing will control vehicle market when AVs come - greatly changing insurance industry. 

Insurance companies continue to back state regulation insurance business. They are accustomed to that. 

House hearing on AV insurance not mentioning transit or AV shuttles, how these are already on roads. Talking as much about partial automation as complete automation. Much on data needed.

Wow moment at 1 hr, 28 min into House hearing. @StateFarm insurance rep tells how tech, auto companies are resisting even talk of states requiring AVs with event data recorders (EDRs).

There was lots more, with the Congressional questioners, the insurance industry representatives, and the lone representative of the world of safety public interest advocates concurring about the necessary role of insurers and the changes inherent in combining operation of the vehicle with the vehicle itself. Like much of the public and media reports, there was much conflation of partial and full AV technology.

And here's another twitter tidbit, this one demonstrating my shock about the NTSB preliminary Uber report: OMG, NTSB prelim rpt says Uber was testing equivalent of Tesla autopilot, calling it full AV (lulling human driver/backup into complacency?) and killing an innocent pedestrian on road ≠ #completestreets. Don't blame the pedestrian.

Congress Members of the Roundtable

I went to a roundtable discussion on Monday hosted by the US House of Representatives, Subcommittee on Highways and Transit, where six Congressional representatives from the left to the right and various industry and other stakeholders all agreed that innovation is good and stymying autonomous vehicle development and implementation would be bad. The room was packed even though no food, drinks, or particularly new information were served. The members of Congress were guest star Chairman of the House Transportation Committee Bill Schuster (R-PA), subcommittee Chairman Sam Graves (R-MO), Eleanor Holmes Norton (D-DC), Thomas Massie (R-KY), Daniel Webster (R-FL), and Daniel Lipinski (D-IL). I hope I did not leave out anyone. (Information in the parentheses refers to party, Democrat or Republican, and state.)

The subcommittee's informal conversation - NOT a Congressional hearing - was with:

• Mr. Chris Spear, President and CEO, American Trucking Associations (ATA),
• Hon. David Strickland, Counsel and Spokesperson, Self-driving Coalition for Safer Streets (and former NHTSA Administrator during the Obama Administration),
• Mr. David Zuby, Executive Vice President and Chief Research Officer, Insurance Institute for Highway Safety, and
• Mr. Kevin Acklin, Chief of Staff and Chief Development Officer, City of Pittsburgh

Keeping a straight face award goes to ...

The representative from the American Trucking Associations said - without laughing - that no jobs will be lost and that it will take decades for driverless technology to roll out. However, without turning his head completely around, he also said that trucking fleets would transition to driverless much more quickly than passenger vehicles because these are business vehicles and are operated as fleets. Mr. Spear also said that truck driver jobs are difficult to fill, so, presumably, the never-get-tired driverless technology will be a better bet than humans.

On the other hand, the Pittsburgh representative and David Strickland were much more jolly and upbeat about the prospect of autonomous vehicles, what they can accomplish for society, and the improvement in quality of life for older adults and people with disabilities.

Eyes on safety and commerce

Safety was a topic on everyone's lips with the significant uptick in fatalities on US roads in 2015 and 2016. Mr. Strickland emphasized this and it was also noted by the representative of the Insurance Institute, Mr. Zuby. Mr. Zuby was first runner up for the straight face award because he managed to express a belief in innovation and risk while also suggesting that the insurance industry needs complete proof. But insurance is a follower and not a leader in this field.

One aspect of safety that the members of Congress hung on to was the question of safety during the expected three decades - not my expectation - when "legacy" and fully autonomous vehicles will be sharing the road.

The other significant topic discussed was commerce with no one enjoying the prospect of 50 states with differing regulations governing driverless operations. The Commerce Clause of the US Constitution allows Congress to pass legislation that affects any related issue and to preempt state laws and regulations that interfere with interstate commerce. The representatives present at the roundtable discussion referred to their Constitutional authority. It was mentioned (I think by Strickland) that the California regulations go beyond the traditional self-certification model that NHTSA generally uses. 

What does "driverless" mean exactly?

Like people off the street, participants on both sides of what was a long rectangular table with Congress members on one side and the invited guests on the other, talked about both partially autonomous and fully autonomous vehicles. The guests were generally better at articulating these distinctions.

Really not any news here. Just interesting to see alignment among unusual Congressional bedfellows. No one mentioned the elephant in the room - what will happen when a completely different kind of Administration fills the offices of the government on January 20 and beyond.

Japanese Insurance, Israeli Optics, and Michigan Laws

Israeli company Oryx Visionis scaling up on a cheap optical radar system for driverless. It sees better.

Or - spelled in Hebrew - אור - means light. Just check the beginning of Genesis; that is one old word. I'm guessing that's where Oryx comes from. There is no information about that on the website.

In the tea leaves of tech development, NXP Semiconductor, a company that concentrates on driverless technology for trucks, has been acquired by Qualcomm and is bringing advances in driverless computing power.

Deals on driverless insurance

Another insurance company will be providing coverage for self-driving vehicles - in Japan. The company is Tokio Marine. The first company to do so was in Britain and that was quite recent.

Michigan passes bill - forget the steering wheel

Michigan's governor is going all out to ensure that vehicles continue being developed, tested, and manufactured in his state. He signed a package of four bills (good summary article). Here's a previous post with more details and a statement from Gov. Snyder's office.

Self-Driving Lorries Might Come Before Trucks

Trucks are an easy opportunity for driverless due to fleet purchases, labor savings, and non-stop time on the road without having to stop at Flying J or another truck stop to go the bathroom, shower, and eat. And it is not only fleets of large tractor-trailer trucks that will go without human operation, autonomous vans and small trucks will transform deliveries. 

Wording: self-driving lorries may come before trucks

In the UK, concepts of quick-and-easy-to-assemble driverless delivery vans are being presented now. Charge, an automotive technology company, this week unveiled a truck that can be assembled in four hours. Charge plans to sell these vans at prices competitive with conventional, driver-operated, vans. Plus, less power of whatever type will be needed because the various sizes of these small lorries - translation: trucks - will be made of light, composite materials. I will ask the materials scientist in the family for an explanation (though sometimes this person finds it difficult to dumb down on the technical stuff).

The UK is fertile ground with the government declaration of intent to lead the self-driving race and have driverless vehicles on roads in 2020. Planting itself on Britain's fertile self-driving ground, Charge intends to have the vehicles ready for sale next year after driving legislation passes.

Deliveries without humans will mean no tips and no conversation. In my case, no "have a safe night and thank you."

Matching insurance

To go with the new driverless vehicles in the UK will be insurance for driverless vehicles. Adrian Flux is first with insurance policies for sale to the public for autonomous cars. Don't get too excited, the company envisions this product more as a conversation starter than as an immediate money maker.

Turtle-like regulatory environment across the pond

With the regulatory debates and polarized politics in the US, it is probable Americans will wait longer to buy or get shared use driverless as soon as the British, Singaporeans, or even the Japanese. In fact, the recent NHTSA letter prior to the impending sale of the Comma.ai after-market, partially driverless system possibly demonstrates an unwillingness to entertain anything other than sale of an entire car by a car company. NHSTA did not even give Hotz's company wiggle room or a roadmap to demonstrate safety. It's an odd episode because not one Tesla has been ordered off the road.

Michigan is pushing for itself to be in the forefront of driverless development and eventual sales, but to accomplish that, at the very least, the state will need a friendly federal regulatory and legal environment. One thing is for certain, New York will not be the first state to get driverless vehicles on its roads and the question is which will come first for the Empire State, Uber in Upstate New York or autonomous vehicles. The state has not yet passed a law allowing testing or actual driverless travel on its roads.

Well, perhaps driverless vehicles will be late to the US and we will get flying robo-taxis from Airbus instead. The company is shooting for testing to begin in 2017. That would require a whole different set of regulations, presumably, and the involvement of the US Federal Aviation Administration, which oversees air travel and safety.

Before I Write About NHTSA

Yes, yes, yes, I'm reading the long NHTSA guidelines document. It will take a few days to digest, or at least a day. This is called reading beyond the executive summary. And there is actually other news.

UK insurers are handling driverless stuff behind the scenes and dealing calmly with the driving - or partially self-driving - public by stating that all normal car insurance policies will cover human-operated vehicles and self-driving vehicles. And coverage will extend to whatever insurance usually covers inside and outside of the vehicle.

Lots in England

Oxford-spawned Oxbotica, over in England, is busy designing driverless software and hardware for many types of vehicles. The hardware is lasers and cameras. This is for cars, of course, but also for forklifts, mining trucks, and a NASA Mars rover (I guess the Buy America requirements do not apply).

By a lovely canal

In Amsterdam, you might soon see and be able to ride on a driverless - or should I say captainless - boat. It is called, no joke, Roboat. This is the product of a partnership among MIT, which is a US university, and two Dutch universities. To be ready for testing next year, the Roboat will be able to carry people or packages. Since it is basically a flat raft, a succession of Roboats lined up can operate as a walkway or a bridge.

For fun, meet the Rolls Royce moving fancy TV den 

Without steering wheel and brakes, but with "Eleanor," your personal artificial intelligence assistant, the Rolls Royce driverless concept design is neat, but totally impractical. Bright beige carpeting means you will not be bringing kids, coffee, wine, or pizza. There is a very large screen and a loveseat. Fancy, in a futuristic way.

Catching Up

Just the updates for right now.

George Hotz and Comma.ai still aiming for late 2016 release for their gizmo to make existing cars turn into driverless ones (at least on the highways) and for gathering driver data with an app - Chafr.

First insurer to go all out with a policy for self-driving cars and partially driverless is in the UK.

Toronto council member pushing for plan for driverless buses. 

Why stop at a vehicle? There's a passenger drone, kind of a driverless helicopter, approved for testing in Nevada. Drone taxi anyone?

Speaking of flying, Google co-founder Larry Page is deep into inventing (and, presumably, selling, renting, or share-using) flying cars. The report claims this is easier to accomplish than driverless vehicles, but isn't flying way more three dimensional? Just to be clear, these would be self-flying. No pilot's license necessary. Beyond George Jetson.

I have to look at this more closely. The NHTSA Administrator has expressed in public the need for government guidelines that will allow innovation to proceed regarding self-driving vehicles. The word regulation was not used. Mark Rosekind emphasized that we need to improve our safety record and noted that we kill a large airplane's worth of people with human-operated vehicles every week - just in the US.

Comments on NHTSA comments.

And lots and lots of buzz about rumors that Uber will take over Daimler or some other auto manufacturer, partner with an auto manufacturer (maybe Fiat Chrysler, but other names mentioned), or be taken over. I'm not going to give a source because this is super easy to find. The one thing that is significant is the big pile of money from Saudi sources being put into Uber, whose valuation is - not actual value, I think - is higher than that of conventional car companies. I mention this because of Uber's substantial investment in and testing of driverless vehicles.

Is Tesla in denial?

Another Tesla crash and Tesla is again blaming the driver - after reviewing crash data. Fortunately, the crash was not serious; it happened when the car accelerated while parking. Similar Tesla argument as it has previously spouted, that the driver had switched off autopilot. When will Tesla learn that partially autonomous is a recipe for disaster? It is the company's fault, in my opinion, if it puts out a vehicle that was designed to "understand" how a sometimes software/sometimes human-controlled vehicle works without itself understanding and testing how humans would act in those circumstances. I'd like to write a brief for that plaintiff in the inevitable lawsuit - unless Tesla quietly settles soon, which is likely.

I'm also reading in various sources about GM CEO statements that the company is holding onto steering wheels, brakes and other human-operated equipment. I am presuming that GM is not as advanced as it would like to be and is likely jealous of the companies that are further along in this regard. A couple of years ago it was saying that driverless vehicles were decades away. Now it is investing billions and making deals. GM will stay wedded to the idea of steering wheels etc. until it has developed - or purchased a company that has developed - a fully autonomous vehicle without such human-operator equipment.

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.

We Got a Us a Convoy

Well, the Dutch. And they are not talking trucks out West, either. Nor are we talking about truckers seeking to fall under the radar of the Man, specifically state troopers.

This is a convoy today of partially-driverless vehicles doing a test for a risk-management company to gather data on safety and vehicle spacing in mixed traffic. Though the vehicles were not completely autonomous, the humans left to the cars decisions about acceleration and lane changes, Not an entertaining video.

A good group of car companies participated. "The cars making the journey include BMWs, Hyundais, Mercedes, Teslas, Toyotas and Volvos." 

You want to see this again. Kris Kristoferson, Ali McGraw, and Ernest Borgnine. Classic grade B movie.

Good read on insurance goes driverless

This article is a good in-depth examination of possible no fault and other liability models as well as what the insurance industry and state legislatures will be looking at in considering insurance (and its regulation) for driverless vehicles.

When I bring up the topic of driverless vehicles with non-transportation - a/k/a normal - people, they always raise liability as the red flag, the ultimate obstacle, to the driverless revolution. I disagree, but there are valid issues and this article does a good job at summarizing them.