The government appears well aware of this hand waving garbage that companies are trying with "it isn't really autopilot, keep your hands on the wheel wink." This is exactly government's job and is a fabulous example of a government reacting to ongoing events that have proven that so-called autopilot systems are inherently a danger to the public at this stage.

Can confirm at least though many years ago, the internal NTSB IT staff/programmers/DB were a joke. I guess that's just government though and like much of government, they relied a lot on outside contractors. For years they were a ColdFusion shop, so I'll let your mind start there.

Can you expand on how they are an inherent danger, rather than a possible danger? I only challenge you because Tesla has published several occasions where Autopilot has possibly saved lives by auto-braking.

I do not believe those words (inherent & possible) are in any way mutually exclusive. They might even mean the same thing when describing a latent danger. So I do not quite understand the basis of your challenge. Also, I'm not parent poster.

So what I mean is, the autopilot could turn out to be safer than manual, in my mind, so how is it "inherently" dangerous.

It would nonetheless also be accurate to describe it as a possible danger, because the danger only manifests in certain circumstances.

> So what I mean is, the autopilot could turn out to be safer than manual, in my mind, so how is it "inherently" dangerous.

That could well be the case but I don't think it eliminates the inherent danger. Maybe it's less dangerous, but cars on the road are just kind of dangerous in general.

I think it's also very generous to assume that the early auto pilot car systems we have today are necessarily safer than human drivers. Emergency braking is almost certainly a net gain. Self driving might be or might not be. A self driving add-on cooked up by geohot? I'm doubtful it's yet gone through the kind of engineering rigor we'd expect of a system like this.

In the same way that the ocean is still inherently dangerous even if you're wearing a life jacket, or how airplanes are still inherently dangerous even though aircraft autopilot systems are effectively mainstream at this point.

Just like a piano suspended from a rope is inherently dangerous. The danger may not manifest at all for that to be the case.

Contrary to Tesla's publishing several occasions where Autopilot has possibly saved lives, there have been concrete incidents where people have died while Autopilot is being used. Tesla has backed away from these incidents with the same hand waving that NHTSA has specifically touched on here: that the user is exceeding the system's design purpose.

In this context ("at this stage"), where consumers have historically and will most likely continue to exceed these systems' design purposes and operate them outside of their intended scope, it seems very clear to me that these systems are inherently dangerous to the public. That is, there is no way to make these systems not a danger to the public in their current form.

[1] http://www.autoblog.com/2016/03/17/nhtsa-iihs-20-automakers-...

Each computer system will be encountering new, diverse things in the real world without a good understanding of how they'll perform. There are lots of crazy hard problems here that no one has solved yet. So to suggest we just automatically trust it because humans make mistakes is foolish when the consequences are so high. If someone came out with a surgery "autopilot" tomorrow, would you suggest it start giving triple bypass surgeries right away without FDA approval because humans make errors too?

It's a belt-and-suspenders system.

So yeah, I a bit of thorough testing of a completely new hardware running completely new software isn't too much to ask for.

Until autonomous vehicles are subject to the full spectrum of conditions that human drivers face, incidents/mile is not a meaningful measure of comparative safety. And until then, the burden of proof should be on the creators.

The way you compare, is you give a self driving car to a person, and compare actually usage for that person, and see if owning a self driving car increases or reduces accidents for that person.

Being perfect only half the time is still revolutionary.

People still crash every day in good conditions. That's thousands of lives that could be saved with our imperfect, sunny weather on the highway only self driving car.

You underestimate how bad human drivers are even in perfect conditions.

Lets say that Semi-Autonomous Cars are currently tested on about 80% of the tasks that humans currently face in the real world, and that through some feat of engineering and design we don't have to worry about the ridiculously messy transitions between Autonomous Mode and Human Mode.

And let's say that for those 80% of tasks, the Semi-Autonomous Cars have a 0.05% accidents/100k miles incident rate.

And let's also say that Humans on average have a 1% accidents/100k miles incident rate.

What you're telling me is that the Semi-Autonomous car has a much better safety record, so give us Semi-Autonomous RIGHT NOW OR WE'RE ALL GONNA DIE!!!

But what I'm telling you is that you don't know enough to make that decision yet, because you don't know exactly how well humans do on the 80% that Semi-Autonomous cars currently handle, you merely know the average accident rate over the current 100% of scenarios. For all you know, Human drivers could have their average 1% accident rate as a result of a 0.0% accident rate for that 80% subset and a 5% accident rate on the remaining 20% that Semi-Autonomous cars can't handle. And if that were the case, then forcing us all to use Semi-Autonomous cars would actually increase the average accident rate from 1% to 1.004%.

Until you fully understand what Semi-Autonomous Cars are capable of, AND know how well human drivers do on that restricted subset, you can't definitively say that current technology is better than humans.

"Human drivers could have their average 1% accident rate as a result of a 0.0% accident rate for that 80% subset "

No they couldn't, because they don't.

I am asserting that for this specific 80% of perfect conditions, humans are still terrible drivers. And that being better than them is EASY, because of just how terrible humans are at driving (even in "perfect conditions").

The numbers were deliberately exaggerated to make the point. The fact stands though that until you know what the numbers are, the best answer is not easy to come by.

> I am asserting that for this specific 80% of perfect conditions, humans are still terrible drivers. And that being better than them is EASY, because of just how terrible humans are at driving (even in "perfect conditions").

And I am asserting the opposite: that the appearance of safety of autonomous vehicles is the result of highly selective conditions with near laboratory levels of control, the likes of which are so monumentally easy to handle that even humans, as shitty and inattentive as they are at driving, can handle with comparative levels of safety. And I certainly think it's possible that computers will lag behind humans for another 20-50 years while we slowly develop the massive body of fast-heuristics research necessary to make NP-complete planning decisions with the speed and capability of even below-average humans.

Proof?

Just two days ago, driving on a roundabout some lady enters the roundabout right in front of my car. Fortunately it was a two lane roundabout and the left lane was empty so I could swerve to avoid crashing into her left hand side door (I was coming straight at her).

At the traffic light I asked her if she had not seen me and she went 'Seen what? Where?', so apparently she had not seen me at all, which is pretty impressive given that I was less than 5 meters away from her when it happened.

This sort of thing happens with some regularity. All it takes for a situation like that to turn into an accident with possibly a fatality is for me also not to pay attention.

I wonder if they could shut him down on the basis of car insurance requirements and the legal definition of "driver". If "driver" is defined as the "person" inputting control commands, then either you dont consider the computer a person, and then nobody is legally "driving" the car, or else the software somehow meets the definition of a "person" or driver, in which case its an unlicensed driver operating the vehicle and insurance may not have to cover it.

The device would probably be SAE Level 2, and should be regulated as such.

Suddenly the price people will pay for parking is going to be closely related to the price of gas. The maximum value of a parking space in the city is basically the cost to send the car back out to some suburban parking garage during the day and have it come back in later for you. My guess is that the market-clearing price is going to be a lot lower than it is today. Lots of urban parking structures might end up getting repurposed for other uses, if you can't fill them at hundreds of dollars per space per month.

In the short run I could see the average self-driving car's gas usage being higher than a conventional car's, but in the longer run the same self-driving features might make fully electric cars more palatable. Long charging times don't really matter if you can let the car go and charge itself while you're at work, for e.g.

Edit: grammar

And it is likely necessary. Meeting regulations is far harder and more expensive than just the feel good that you met the reqs. If there wasn't a stick held up as a credible threat, plants would just trash everything. Not because they're evil, but because plants simply can't care - they aren't people. Thusly these agencies are impersonal and brutal in kind.

It can displace air, causing death.

Here's one example of a death, although here they deliberately put the argon in there: http://maritimeaccident.org/2014/08/safespace-argoninert-gas...

I know argon is denser than air at STP, and so tends to accumulate in enclosed spaces --- but propane is even denser. (Leading cause of catastrophic accident in yachts: gas explosion. It's not like you can have a hole in the bottom to let the gas out in the event of a leak.) And any plant which deals with liquid gasses is going to prioritise ventilation anyway, which should easily deal with any gas buildup.

The parent sounded like there was something specific to do with argon which made the regulators tetchy, and I wouldn't have thought that asphyxiation risk would be enough. Am I wrong?

"Describe in detail the features of the comma one"

and

"Provide a detailed description of the conditions under which you believe a vehicle equipped with comma one may operate safely ... [and] a detailed description of the basis for your response to [the previous question] including a description of any testing or analysis..."

and

"Describe in detail any steps you have taken to ensure that the installation of the comma one ... does not have unintended consequences..."

I'm not saying the request is unreasonable, but to say that "the information requested is not that great" isn't really true. To completely answer those questions would take a lot of effort. (Assuming of course that he's done such testing. His canceling the product rather than respond makes you think he realized his answers would not be credible...)

Ironically, if he hasn't done any such testing, the answers would be much easier to generate. "We haven't done any." Not that the NHTSA would take it well....

I've been involved in writing similar descriptions to provide to NASA, and when you get down to exactly how each module works and need to enumerate every branch, it ends up being a lot of work.

It would appear that he didn't have any interest in cooperating at all, though. Which inevitably leads me to wonder if it's not more of a face-saving maneuver; better to blame failure on the pesky regulators than admit your technology isn't up to the investor pitches you might have made.

Also, the documentation being asked for is something the company should be able to put together fairly easily because they ought to have asked and answered these questions along the way to building the product.

Have you ever considered establishing product direction through use cases branded as "stories" and pulling them out of your ass every two weeks?

/s

Which article of the Constitution is that? I don't seem to recall it.

"We the People of the United States, in Order to form a more perfect Union, establish Justice, insure domestic Tranquility, provide for the common defence, promote the general Welfare, and secure the Blessings of Liberty to ourselves and our Posterity, do ordain and establish this Constitution for the United States of America."

Keeping its citizens safe would likely fall under general welfare.

Have you actually read Article I, Section 8? You'll have to squint very, very hard to see any authority to pass laws related to safety in it. That's because it's simply not there. The state governments, of course, do have that power, and the Congress arguably has power to regulate cars used in interstate commerce.

But there's simply no constitutional scope for safety regulation of cars built & used in only one state.

Instead of nitpicking, let's focus on the actual issue. The NHTSA didn't order Hotz to shut it down, it merely asked about the safety of the product, which led to Hotz shutting it down himself.

It also raises the question of what you think the Bill of Right's purpose is.

Granted, it's a huge stretch for him based on the language of the letter, but that's how I read the situation.

The more software becomes mission critical the more we will need level headedness and quality rather than tantrums.

As I've followed these developments and those of Google and Tesla I've been wondering at times if I live in some alternate universe. The level of diligence and care that must go into systems which have the potential to maim an kill are nothing to laugh at. They require serious engineering which takes time. You can find the best and smartest humans on the planet and they'll still fail at building reasonable controls for life critical systems in controlled environments. When you are building these controls for life critical systems which will operate in the diversity of our roadways, honestly the task gets very hard.

I'm not against progress and I do think that self-driving cars are the future. However, it may be wise for those trying to march towards that future at breakneck speeds to take a step back and consider that these systems should first be implemented as backups to humans. Develop the solutions through preemptive braking and accident avoidance where humans are still very much engaged in the driving activities or focus on building expertise in controlled environments. On that note, kudos to Google for doing just that. Their first phase has focused on low speed situations and have been restricted very much to lab work whereby they have paid employee's serving as observers and backup.

The degree of care that went into the e-stop design of the lathe and mill controller and the number of checks and tests of the fuel estimation software are stuff that I'm (hopefully justified) proud of, that's not stuff to cut any corners with. In both cases that took me longer than Hotz claims to have spent on creating the whole self driving car code, there is no way you can do this safely with that mentality. It is absolutely irresponsible to take that attitude towards systems like this, life is not a video game with 3 more lives if you lose this one (or cause others to lose theirs).

For a machine with the potential to easily maim and kill, to be completely autonomously operated in a chaotic environment where it interacts not just with other computer controlled machines but also with humans, even children, I honestly hope that the amount of safety precautions required will grow very quickly.

I like Tesla's and what Elon's accomplished has been impressive but he seems hellbent on "winning the race" to release a self driving car and that worries me.

Almost.

Alternatively, earlier editions of Model S shipped without autopilot, which was then sold as an aftermarket upgrade as late as this spring (when autopilot was an optional $2,500 package on a new Model S).

A car is a bit more complicated to leave stuff out I am sure and the volumes far different. It would likely require at least more resources to have separate parts of lines for some of that as well as different check procedures as so on. But like you said, paying more could help offset that, though it's a gamble for the manufacturer.

I'm more in the camp of please do not release anything driving a car until you guys can figure out how to secure basic software, keep websites running, parse input properly, and so on. In other words, I'd rather them wait decades if that's what it takes.

Personally, I'd rather be killed by a person rather than a person's dumb choice trusting technology. What concerns me in all these situations is that I did not at any point agree or vote to allow someone in a self-driving car to drive on the same road as me. Until they can mathematically prove 100% it is safe in all conditions and situations, I'm not buying things like "driver assist" if a big part of the justification is that AI is better than a human driver (if so, then why assist?). Others may disagree, so be it - I'm a weird guy. I also hate cruise control. And fat-free ice cream.

It took airplanes a long time to become safe (through a long and scary process), and now they're safer than my front porch. Whatever the outcome, self driving cars will very likely be safer than human drivers, and that means more lives are saved than lost, even with the occasional horrific problem. It is entirely plausible that self driving cars are already safer than human ones.

Is this a bad thing? Is it not justified by utilitarianism?

This is a perfect example of the biggest and IMO most compelling critique of utilitarianism -- namely, that it's too susceptible to bullshitting.

People decide what they want to do, then completely invent (or, in more sophisticated cases, carefully fabricate) numbers and time-frames in order to hide their unethical opportunism behind the facade of objective moral assessment.

This is especially problematic when you have to estimate things that are pretty much impossible to estimate without completely bullshitting. For example, "number of people killed by not following certain safety standards", or "impact on time-to-completing of some particular safety standard". We're talking about a novel technology, so there's no way anyone has even remotely high confidence in a sufficiently bounded estimate of these numbers. It's all just bullshitting.

> Is thus a bad thing? Is it not justified by utilitarianism?

These are two VERY different questions.

Moreover I don't see how you can conclude on a whim what's possible to estimate and what is not. Given these things take expertise in the relevant field and more than just casual analysis.

Finally, it's not like there is a small margin of error. Can you even really comprehend 30,000 deaths every single year caused by conventional cars and drivers? This is fricking 9/11 times ten happening every year, and you're not even willing to consider that speeding up r&d might save a few lives?

Yes, exactly. Like in so many cases, coming up with good values for the parameters is often the most difficult part of the analysis... that was exactly my point!

> Given these things take expertise in the relevant field and more than just casual analysis.

Except in this case, there are a lot of experts, and they all seem to be taking roughly the same approach.

> Finally, it's not like there is a small margin of error

It's not clear to me, at this point, what your assumptions even are. What percentage of those deaths would be prevented by self-driving technology? How many new types of accidents would be caused by self-driving technology? By what percentage would that number decrease if the regulatory environment were more friendly? And what's your basis for these numbers?

Also, it's perhaps telling that there really hasn't been a single example of regulators preventing self-driving up until this one, which is rather extreme. Google, Uber, and the scattering of startups and car companies have all taken a more cautious road to deployment of entirely their own making.

> and you're not even willing to consider that speeding up r&d might save a few lives?

There's a big difference between speeding up r&d and rushing unproven tech to market.

I don't think the case has been made yet that today's tech will reduce the number of road deaths. I don't think it's unreasonable to be skeptical of the claim "this works great, trust me".

See, we already have cars, it's not like we're going from 'horses and buggies' to cars, it is going from one good solution to an even better one and even though there is a risk at being stuck at the present local maximum for a little longer going down in order to find the peak of this particular mount improbable would not be an acceptable path for the majority of the public.

And without having a time machine or a functional crystal ball you won't know if it is 10K, 100K or a few million people that get killed before you get it right so the bar has been set at 'it needs to be better than the present level before it is acceptable'.

If you know that after ten thousand deaths, the technology will be good enough to start saving more lives every year, then your utilitarian argument works. The problem is that you can't possibly ever know that in advance. It's equally plausible that the last 0.001% will take decades to solve, or even remain out of reach indefinitely. Then you just threw away ten thousand lives for nothing.

This is why the burden of proof needs to be on the new system, and why the precautionary principle applies.

It's like how IUDs (birth control device) are disproportionately unpopular in the United States despite many benefits - all because of one particular brand that caused infections with horrible repercussions:

http://www.motherjones.com/blue-marble/2012/09/why-are-iuds-...

What is the acceptable casualty rate to get from where we are now to where you think we will be in the future. Is your family an acceptable casualty? If not, then why is mine?

Continuing on with the status quo is just as much of an action and a choice as pushing forward with automation. Both choices are going to get people killed. We can either evaluate the choices and choose the one that seems better, or we can ignore the question and possibly have more people die than is necessary, but there's no option where your family isn't at risk.

So do I really want untested first gen software released without extreme safety standards and heavy testing? No. Do I think the net result of that happening would be a safer driving experience? No. Give me the iOS 9 or so of self driving car software or the unix. Not the Amazon Fire phone.

I'm not sure if it's entirely relevant here, since the comment above presumes that these systems are safer than humans, and the reply doesn't seem to be questioning that.

I think it's very likely that these systems will rapidly become far better than human drivers, and probably already are in the domains where they're meant to be used. But we definitely can't just take that on faith and hope it's being done properly.

Is that reduction a result of self driving or advances in other safety (airbags, seat-belts, crumple zones)?

It is clear that your mind is already made up and that you are a self driving car evangelist. Please endeavor to approach these debates with an open mind and in good faith.

As for your question, you basically destroyed the conversation when you asked "Is your family an acceptable casualty?" If you just wanted numbers, you shouldn't have made it personal like that. That's all my point is here.

This is a really fair point but I also don't think it's a bad thing to say this. I think people distance themselves from possible problems by calling things a numbers game but they don't factor in the fact that they could be part of those numbers.

If I say that 27000 people per year die from listening to Mambo Number 5 then I say that we can lower that to 15 if we remix it to take out the deadly frequency but we will have to test it on 20 people to find which is the deadly frequency for sure. That sounds great. A couple people might die but what's that to save 27000/year?

Well, take that and say we will have to test it on 20 people and 5 of those will be your family. That makes the decision a lot harder. Logically it's exactly the same but emotionally instead of "people" it's 15 "people" and 5 of your family.

So, it's important to mention it could be your family because if someone was alright with it because they are looking at the pure numbers, they should be brought back to the reality that we all actually live in a little.

I guess this all boils down to what you think of the Trolley Problem. I'm one of those who say, yes, of course you pull the lever if you have no way to save everybody, it's obviously better.

Of course, but public perception is, you know... not largely logic-oriented. Whether or not you personally find @abduhl's argument convincing, there's still that emotional hurdle you'd have to clear to convince significant numbers of people to sign up.

In the future, 1.2m people die a year so say self driving reduces that to 0.2m/year, that's a million lives saved per year.

You family is thousands of times more likely to die in a conventional motor accident than due to a self driving vehicle. If unnecessary red tape slows things down and causes 100k extra deaths is that ok? Even if someone you know is amongst the 100k?

That said there's an argument system like Hotz's should be tested first. That's probably not going to slow things that much.

That's an imaginary scenario. You have no idea if that's the way it plays out. Let me give you another scenario: the first self-driving cars kill a bunch of people, and no one wants to touch them for years after they finally become safe; delaying the adoption of cars, and causing millions of additional people to die.

Makes sense, since they regulate the activity that is the 4th largest cause of death in the US.

In other words, is it acceptable to move fast, knowing it will cause deaths, if we could be certain the net lives saved would be greater?

Cruise Automation was very lucky to be acquired by GM before they got a similar letter. Similarly, Otto being acquired by Uber. They were both proposing to sell similar add-on systems. Their valuations would have been much lower after receiving such letters.

NHTSA has it right. "It is insufficient to assert, as you do, that 'your product does not remove any of the driver responsibilities from the task of driving'. As you are undoubtedly aware, there is a high likelihood that some drivers will use your product in a manner that exceeds its intended purpose."

Did Tesla got a similar letter? They have exactly that problem and exactly the same excuse. Tesla claims “Autopilot is an assist feature. You need to maintain control and responsibility of your vehicle.”

Here are three dashcam videos of Teslas crashing on autopilot. These are the three where there was a stopped vehicle partially blocking the left edge of the lane, and the Tesla plowed right into it. Tesla blames the driver. Looks like the NHTSA isn't buying that.

[1] https://twitter.com/comma_ai [2] https://www.youtube.com/watch?v=rJ7vqAUJdbE [3] https://www.youtube.com/watch?v=xoSNw_n1Xgk [4] https://www.youtube.com/watch?v=qQkx-4pFjus

Is it the same problem? One is an aftermarket kit vs being built-in to the car.

The level of rigor Tesla has applied to this problem, as cavalier as it may seem at times in the news, is many, many times that which was applied to what Comma.ai is building.

Tesla's mode == aggressive, but diligent.

Comma's mode == aggressive, and flippant.

Did Mercedes? Did Volvo? They have the same systems in place in production vehicles.

Mercedes even advertised their vehicles as autonomous.

http://blog.caranddriver.com/mercedes-benz-pulls-e-class-ad-...

> Here are three dashcam videos of Teslas crashing on autopilot.

Glad you had the opportunity to bash Tesla.

>One of the biggest flaws of the tech industry is the belief that being a tech expert is enough to disrupt other industries in which they don't have any expertise. Sometimes they get lucky and it works despite something like Uber's or Airbnb's total ignorance of the law. Sometimes it fails like with numerous cryptocurrency companies relearning why the finance industry has so many dang regulations. Seems like comma.ai is falling in the latter camp.

Take a look at the front page of Hacker News right now: in addition to this story, there's "Soylent halts sales of its powder as customers keep getting sick" and "Uber drivers win employee rights case" (presumably over Uber's fierce opposition). With 30 items on the front page, that means we've got 10% of the news in our field which could plausibly be parsed by outsiders as "technolibertarian assholes". I've been watching public opinion of the Bay Area startup scene gradually eroding in the last half-decade or so, and this is a big part of the reason; it's a real problem that we need to start thinking about.

It's definitely not just outsiders as you (and I) can attest; I went with that line of argument to try and convey some sense of urgency about the problem. It's easy to dismiss internal dissent about SV libertarian groupthink as not important, but "outsiders" have the potential to bring the party to an end if they collectively get really grumpy about what we're doing. I thought that might be more motivation.

- thinks it's OK for neighbors and local government to have a say in whether people run a hotel next door, possibly sharing a roof or even a wall

- thinks it's OK to require pretty reasonable background checks ala Austin for taxi drivers

- thinks it's OK to have some safety regulations around self driving cars sharing our roads beyond hey, it worked in my car on this specific stretch of road so, you know, yolo

What about those people? The people who WILL die in car accidents next year unless we do something about it. Screw them, right?

The question at hand is: Does this specific piece of equipment actually work as described, and move us towards that goal, or is it a piece of cobbled together junk that will cause more accidents? If you want to sell this specific piece of equipment on the consumer market, you'd better have a good answer to that question, and be able to back it up with more than "hey, it worked for me this morning!"

It's a bet without much of a downside.

[1] http://articles.chicagotribune.com/2014-03-26/news/chi-suit-...

Since he hasn't done the due diligence he's throwing a fit. Sigh... Looks like self-driving isn't something that can be accomplished Today without a good amount of resources.

[1] At least not as a direct cause/effect relationship.

With regard to the more general point of your post, even if it's nominally possible to eke out a profit under overburdening regulation, you're still allowed to take a principled stand against it.

They were planning to ship by the end of the year -- obviously the regulator should get involved before it's in the hands of users.

I've seen requests from regulators before. If you don't have or can't produce exactly what they asked, you call them up and tell them some parts will take longer. The point is to have a dialogue; the threat of sanctions is just to make sure you work with them.

- What's in the installation + operating manual? - Items 1-3

- Is it safe? Did you do testing? How? Items 4-6

- What vehicles does it work on? What happens if you screw up during installation? Items 7-8

- What happens if an owner screws up and puts in an unsupported car? Item 9

- Did you think about whether this keeps the car compliant with other safety regulations? In particular, did you think about the legality of blocking/removing the mirror? Did you do testing? Items 10-12

- When are you selling/shipping it? Items 13-14

- Anything else you want us to know? Item 15

Every single item is a completely reasonable question to ask. I'd certainly hope comma.ai knew the answer to each of these questions before they sold it to the public.

Again, if 2 weeks wasn't enough time, then negotiate with them and give them what you have. Threats of daily fines are often boilerplate that get tacked on to ensure that people take the request seriously; I'd challenge anyone to find an example where the regulatee cooperated with the regulator in good faith and still got fined for not responding.

For one of many examples, public information seems to show that his device affects the rear view mirror in a manner that violates specific pre-existing regulations, they ask him how does it affect the rear view mirror and how does it comply with those regulations.

There are only two reasonable responses for such a question - (a) he submits the evidence he has (and had before receiving that letter!) that his product is compliant with these regulations; or (b) he acknowledges that right now he cannot demonstrate that the product is safe and will not sell the product.

For such devices, documentary evidence (including testing results, and all other "random crap" requested) is an integral component of the device - if you don't have all this done, attempting to sell the product is prohibited. That is pre-existing regulation.

[edit] unless his real plan was to go to China all along...

If he couldn't answer these very basic questions 2 months away from shipping these things, WTF is he even doing. If he hadn't proactively initiated communications with NHTSA long before now, WTF is he even doing. These are all excruciatingly, painfully obvious things to do, and the fact that it never occurred to him to do them brings into question his judgement about pretty much everything, from technical issues to basic life choices. At this point I don't think I'd trust this guy to mow my lawn, much less develop autonomous vehicle software. His reaction to all of this and how he deals with adversity is just as revealing about his competence as everything he's done so far.

Trying to innovate without being encumbered by the glacial pace of government regulatory bodies?

His refusal to put up with the NHTSA is an indicator of a low tolerance for bullshit, not incompetence.

Double so if it's a product that is very likely to kill its owner.

And square all that, if your products is either used every day or can cause large amount of death, accidentally.

He gets two weeks to provide an enormous amount of detailed information about the product, I assume under threat of legal consequences if any of it contains an error, interspersed with lots of reminders that they can and will close down his business if they feel like it.

He has announced the release of the product, was taking orders for it and said it was going to be shipping by the end of the year [1]

The timeframe here is driven by Hotz who apparently has not had any communication with the relevant regulatory agencies. Any attorney he hires would tell him "Okay lets push back the release to mid next year while we work with the NHTSA on resolving their concerns" and the NHTSA would probably be perfectly fine with working with him.

"Move fast and break shit" doesn't count when you're putting lives at risk.

lots of reminders that they can and will close down his business if they feel like it - yes and they should.

[1] https://electrek.co/2016/09/14/comma-ai-claims-to-have-packa...

You can't just wire up an Arduino to the CAN bus of a 4,000-pound missile and sell it on the open market willy-nilly.

best self-driving comment ever.

Which either he should have readily available, since he's the creator, or he should have known, since he should be able to demonstrate the safety of the device.

> I assume under threat of legal consequences if any of it contains an error

Usually you hand over what you have, then you negotiate with the regulator for a time frame to answer the more difficult questions. If you're unsure about something, tell the regulator up front.

The correct response is not to throw a tantrum and shut everything down.

> interspersed with lots of reminders that they can and will close down his business if they feel like it

That's the textbook definition of 'regulation'.

I think the correct response is to work with them 110%. Having that government body happy with you isn't a bad thing - you could become the reference spec for self-driving if you please them to an appropriate degree.

> That's the textbook definition of 'regulation'.

Right, and it's one of the big problems I have with this form of regulation.

I think it violates the idea of "Rule of Law", as opposed to "Rule of Man", which was one of the major factors behind the rise of modern free society.

The empirical experience is that regulatory agencies over time gravitate towards favoring the big established players in the industry they're regulating.

The economist term is "Regulatory Capture".

Giving some people a lot of discretionary power of others does worry me a lot. It might well be unavoidable sometimes, but it's really naive to not see the potential for abuse.

The calculation needs to be "if this agency is run by the usual corruptible and imperfect people like you and me, will it be a net gain for society?", rather than the "assume a selfless set of civic minded experts..." mindset I think a lot of people have.

As long it's humans that write and execute laws, this is strictly unavoidable. It doesn't depend on the particular details of how we do regulation.

Set 1 (legislators) can and do write laws to favor and disfavor individual actors, and I agree that that is in part unavoidable.

Set 2 (judges and juries) are appointed randomly after it's become a legal matter, so it's impossible for any inappropriate influence in either direction before that.

And there is no "set 3" of regulators that issue orders during the day-to-day running of the business.

So I think you're right that this problem always exist, but in my estimation it's a few orders of magnitude bigger under a "Rule of Man" regulation scheme.

You mentioned 2 branches of government, the legislative and judicial. But the third branch, the executive, does (in part) exactly what you described above.

Taken to the logical extreme, your view means we should replace every government adminstrator with a court, including for mundane decisions like whether to grant a marriage license. That system would be horribly inefficient and probably not much more consistent or effective since random people off the street won't have the domain knowledge a regulator has.

Also, regulators are representatives of the people and are subject to laws just like everyone else. The escape hatch of the legal system is always available -- if you think the regulator got it wrong, then take it to a court, and a judge and jury decides who is right.

I mean, how do even mundane things like zoning codes and work permits work in this universe where there are no regulators and gov't bureaucrats? Everything must go through a court? Why are you so sure a group of 12 random people will come to decisions more effectively than a bureaucrat in a domain that requires specialized knowledge?

In any case, I fully agree that sometimes regulators, or regulations are bad. But this particular case is an example of regulation working as designed. The NHTSA has been at the forefront of working with the self-driving car industry to make sure there is a legal path to developing, testing, and releasing this tech. Textbook example of regulators doing their job without imposing undue burdens on the regulated industry.

I talked about regulators. You added bureaucrats on your own.

Perhaps NHTSA is a great organization. I know nothing about them specifically. I'm talking about general principles.

> Why are you so sure a group of 12 random people will come to decisions more effectively than a bureaucrat in a domain that requires specialized knowledge?

I'm saying they'll be more impartial. Don't know about effective.

One of the common ways this works is that the regulator keeps adding more and more complex regulations.

It's counterintuitive that a major company welcomes or instigates added regulations that will cost $20M/year to comply with. But since that makes it more expensive to start competing companies, they can make a lot more money from their increasingly secure oligopoly position.

Hmm. Regulatory capture? Yeah. That.

Seriously, with agencies like the FAA, FCC, EPA, FDA, NHTSA, etc. you can just call them up and you will be connected to a regulator who can help you with every step of getting your product past regulatory requirements. The Small Business Administration also has a lot of people dedicated to helping entrepreneurs with regulatory oversight.

And when a big govt stick comes a'knocking, unless you're also big and well connected, you will get shut down.

This was clear as a way to "do insane amount of documentation in a laughably short timeframe, or fuck your business with a fine-stick."

Yeah, GeoHotz is an ass, but this is inane. Great way to kill small businesses.

He's publicly stated they were aiming for year-end release.

I would understand filing that documentation prior to selling. But I'm also familiar with using "Filing with govt" as a tool of oppression that large companies try to pass as a barrier of market entry. Lawyers are rather expensive, and requiring more volumnous paperwork requires more lawyers.

And speaking of that, what is the repercussions of what you send to NHTSA? Say he sends something inaccurate or glosses over details. What is the liability of sending something wrong to govt? Hmm...

Yes. Wait till he's selling them. And when there's a claim, act on it. Not before.

We as a democratic society decided awhile ago that the benefit of knowing a car product was probably safe outweighs the frictional burden of testing them before they can be sold.

There's a lot of insinuation here that the regulator is actively trying to kill his product, but no evidence. This seems like a run-of-the-mill request, one that the NHTSA probably sends out thousands of times a year to various automakers and auto parts suppliers.

As a counterpoint, I'm sure Tesla has gotten these letters as well, but the NHTSA didn't prevent them from putting AutoPilot on the market.

> what is the repercussions of what you send to NHTSA? Say he sends something inaccurate or glosses over details.

The letter specifically says that estimates are ok. There's nothing wrong with telling the regulator 'We're not sure yet, give us a month to figure it out please?'.

I remember the tactics used to kill most butcheries and local meat shops. Same games, with onerous and idiotic requirements of "compliance" that the big guys can do. Of course, the big companies got legislation to enforce their standing.

This is not opening a dialogue, this is a shakedown to kill a product.

Yes, regulatory capture exists, and incumbents often benefit from it. But I'm having trouble seeing how this particular case is a 'shake down' -- the NHTSA is simply asking him to follow the law, which he should be doing anyway.

[1] https://www.federalregister.gov/documents/2016/03/01/2016-04...

Here's a nicely readable transcript of what they wanted:

https://news.ycombinator.com/item?id=12817061

None of them sound particularly difficult to answer. Maybe they are difficult to answer in sufficient detail to satisfy the NHTSA, but you can always start out by answering them as best you can, and then seeing if they want more. There are people on the other end of this letter, not some unthinking machine. Toss off a quick response and say, "If you have any other questions or need further detail on the answers given here, please feel free to contact me at any time."

I think you have pretty much already assigned a negative agenda to NHTSA, when they've just requested some info.

While they may have followups if they don't like the answers they get, of all the agencies you find, NHTSA is not one that tends to have a serious pre-bias towards anyone.

I mean yeah, it sucks that the government is so darn picky about things, but that's not an excuse to just skip the process. They should have hired someone like you from the start to ensure that their ducks were in a row when they were ready to release.

There's only one question which could be considered too broad, which is compliance with safety standards, but it's generously worded as a yes or no question. He could simply answer "no, I haven't analyzed my product against against the safety standards".

[1] http://www.nhtsa.gov/Research/Vehicle-Research-&-Testing-(VR...

He said the NHTSA made "no attempt at a dialog". What does he call that letter? Ridiculous.

The truth is that rapid advancements in software development happen because most software has a failure rate which would be considered appalling in any real engineering discipline.

this all a pr move by andreeseen/horowitz to pump all their holdings in companies doing selfdriving tech. they prolly knew he'd never succeed.

jus odd to throw in the towel after the gov comes knockin esp after a $3 mil investment like these investors are smart are we honestly supposed to believe they didn't know this was going to happen

eh or maybe $3mil ain't nothing and they's jus threw it at him because jus maybe he could do it if not it's a win win

probably both.

[0] https://twitter.com/anakkurt/status/785677337819947008

His follow up tweets imply he's moving on to China, since they're less likely to be a major hamper of innovation.

And we wonder why the United States' influence is in decline...

Really, this sort of thing should be done in a much more controlled environment before pulling the trigger on releasing it on the unsuspecting public.

Read the bloomberg article and be amazed.

Another way to look at it: western foreigner looks to beta test a product with the lives of Chinese citizens. I'm not sure how well that's going to go over.