Even the simplest (non-safety-critical) systems in automotive requires typically a lot more documentation. E.g. if you have to prove that your development process is automotive spice compliant then you need documentation for everything - from detailled requirements to test conformance. For safety critical stuff it's even more.

This letter is designed to kill the company. That is a result I support, but, the people saying "This letter is designed to kill the company" are entirely correct.

I think that he could have gotten away with showing a substantial effort towards answering the questions and getting some kind of experimental license to verify the technology is viable, I emphatically do not believe that the goal was to 'kill the company' given that all these questions have - for the automotive industry - reasonable answers and that if Hotz was serious about this that he should not have been totally blindsided by this request.

If he was then he should probably have researched the space a bit better before embarking on the project, it's one thing to be a 'hot hacker' but it's quite another to go into this business without the required knowledge about what being in that business will entail.

Trying to imagine SpaceX/Elon Musk backing out of the rocket business because 'the paperwork is just too damn complicated and lawyers are no fun', ditto for Tesla, Google or any other party that is trying to re-vamp some branch of industry.

If the tech is for real the reporting requirements are a reasonable extra cost to be born by the company, the amount of money available for this tech would dwarf the cost of the reporting.

You can respond pretty much with anything that accurately answers the questions. If they want more detail, they can then ask for it.

I don't get where this strange idea that if he doesn't provide 100k pages, he's going to be subject to a fine immediately comes from. It's 100% completely and totally wrong.

If he literally answers the questions, he's fine. If they want more detail, they can ask for it.

The letter is not designed to kill the company, and the people who think so have probably never dealt with any regulatory agency.

My source on this, btw, is that i've dealt with many regulatory agencies many times.

They aren't psychos, even when they are adversarial.

To give you an example, when involved in a pretty adversarial issue with the DOJ, i cannot say they were anything but professional.

When the DOJ wanted more info on something we said "hey, can we just sit down for an hour and chat", and they'll usually say "great, let's do it", and then maybe they'll say a few weeks later "hey, thanks for doing that, we have some more questions about x, can we set up another hour" and so on. Are they always like this? No. (am i the most experienced person in the world? also no, it's also not what i do anymore at all, but this was my experience with pretty much every agency, every time)

But the vast majority of the time, they literally are just trying to gather info to decide what to do.

It's only when they are trying to actually get a particular result that things change. But you'll pretty much know when that happens, and this ain't it.

The only agency i've ever seen just be outright hostile is the CPSC.

The NHSTA, in my experience, is pretty much one of the most level headed and professional agencies you will find.

If you have actual evidence to the contrary, where they have "shut a company down", i'd love to see it.

https://www.nhtsa.gov/staticfiles/communications/pdf/Honda-r...

If I were one of his investors I'd be pissed right now.

This letter is designed to give pause to (e: previously I wrote "kill") a company operating with complete disregard for proper operations in a regulated industry.

We are in entire agreement, but people cannot believe in the superposition of this and "Oh that's just some simple questions from the regulator."

Edit to add: Quoted bit appears to have changed after my quote. I think the old version remains accurate.

I originally wrote "kill" to mirror your original comment, but I changed it because it (as I perceive the word) presumes a level of intent that I don't think NHTSA operates with: I don't think that NHTSA has any intent to destroy this company. In fact, if comma.ai reached out to NHTSA, I would expect NHTSA to assist (within reason) in answering the letter.

I do think that these are straightforward questions for a group that has its act together. Part of having one's act together in a regulated environment is maintaining open lines of communication with regulators, so that questions would be asked should come as no surprise. Keeping up to date with the regulatory environment would also be expected, and given the recent autonomous driving publication the content and scope of these questions should come as no surprise.

If these questions kill the company, I don't see that as being the fault of NHTSA, I see that as being the fault of whoever is in charge of regulatory affairs at comma.ai.

If you really do want to be polite, then it's better to avoid expressions like "clue you in."

Phrases like that exist to indicate that one is emotionally dissatisfied but at a level where it's bubbling underneath the surface rather than something you'd like to display fully. It gives just enough plausible deniability of the fact for it not to become the center of discussion, while still unambiguously letting the person you're communicating with know that you're pissed.

A lot of people here are assuming just by turning in "some answers" that it would satisfy the NHTSA. I see it as a much more involved an grinding process. They have the power, not George, so a lot of refrains about how he's just chickening out don't resonate with me.

If this list surprises you then you probably shouldn't be in the self driving car business.

That doesn't mean his product is shit or dangerous. It just means that the incredible amount of time and effort required to respond - and still without any guarantees that's the end of the inquiry - may be a huge time sink and a distraction from the primary objective of product development.

I've worked in many fields with entities from local, county, state, and federal RFPs/RFIs/SOQs/etc and even if you're the best in the business and have proof it's not always easy to patch it together in a format desired in a timeline that's desired and call it done.

And I personally feel that's a good thing. Even if Hotz' software is a-ok I'd still expect him to have it properly documented and vetted before one of his customers hits my vehicle.

The roads are not a playground.

I've done a fair bit of work on vehicles and I'm happy to say that my work passed inspection, and that I would consider it to be irresponsible to see such control over the workmanship and quality as un-necessary interference by busybodies, the primary objective of product development does not obviate the need for a reasonable overhead to prove that you did your homework.

Also, I never meant to say or imply that his product is shit or dangerous, merely that it is not up to snuff for deployment let alone sales at the present stage and that the gap between that and where it should be is too large to overcome for Hotz. In other words: it is not a product - yet.

RFP's and RFI's are not the same thing, they are often thousands of pages of trying to meet hundreds of pages of random requirements.

What you are talking about sounds mostly like dealing with the contracting side of it, which is a very different world.

Have you also dealt with the "Response to regulatory agency concerns" part of it?

Because I have, and while yeah, with say, the SEC, it can be a trip, i wouldn't throw the NHTSA into that category.

Satisfy is not the question. Yes, they will request more info if they are not satisfied. But he will not be fined, it will not "shut down the company".

I have no idea what FMVSS is but that there are regulations here should be obvious, no doubt this would be something you'd become aware of after a little bit of research. As a consequence you should have an answer to that. This covers 10-12.

13 and 14 he should have known at the top of his head. 15 it seems you could just say you've nothing to add or drop whatever else you have on hand.

Nothing about this strikes me as unusual, unexpected or hard to answer. There is no way this is the reason Holtz gave up unless the product is a complete failure, he hasn't run any safety tests whatsoever or he's using this as an excuse to cover up something else.

Modifying a car is one thing but directly interfering with parts critical to safety?

I think that's the reason he's bailing - he doesn't have the lawyer crew, he doesn't want to play the law game - he just wants to create things.

Turning a risk analysis into a deliverable suitable for interfacing with federal regulatory bodies is actually fairly easy. You're just generating a report on engineering work you already did. It's only hard if you want to get away with not mitigating risks (or high levels of residual risk). Because if you document the risk, it serves as proof the engineering team knew about the risk when the product was brought to market.

Re comma.io - having to play the legal game is a substantial existential risk, only mitigateable with very well paid lawyers and a decent PR crew. That's very different than providing an engineering report. I would guess that if they get rolling in China, they will come back and have the funding and will to hire lawyers to sort the problems.

If you want to contemplate the difficulty of doing engineering vs. surviving the law, consider Tesla's issues selling its car.

It's not the rap - it's the ride.

There is some gap between just wanting to create things and to create things that impact personal body integrity. It is of some concern that in today's software engineering environment that this is even a question.

It would be so much easier to respond if you could just do exactly the same thing that the larger players did.

Unless, of course, those other companies didn't have to produce any such documentation. In that case, clearly, every last company working on autonomous vehicle functions would have to receive a substantially similar order, post haste. We wouldn't want anyone crying about selective enforcement, after all.

[1] http://www.nhtsa.gov/nhtsa/av/av-policy.html

There is quite a lot of "voluntary" in there, along with "future regulation". I would guess that a lot of the voluntary safety assessment letters they get essentially say, "this is not entirely safe in absolute terms, but is definitely safer than an inattentive human driver."

Also: secret commercial information is exempt from FOIA.

The commercial info is not necessary. They need to learn and follow the forms and protocols, and at least pretend to to be respectful when kissing the ring. If GeoHotz ran a restaurant, I wouldn't want him to be the one talking to the health inspector, either. He has the wrong personality for it. You really want the schmooziest suck-up in the company to do that stuff.

I fully expect that all the companies with compliance departments have reams and bales of responsive documentation. As comma.ai appears to be clueless with respect to regulators, the more sample material that they can look at to crib the correct answers, the less likely it is that regulators would summarily drop the axe rather than try to work with them in a reasonable manner.

http://www.fda.gov/ICECI/ComplianceManuals/RegulatoryProcedu...

They also generally warn of fines ahead of time, because otherwise they get people arguing due process.

Seriously, this is not that uncommon. Note the fine warnings in all of these special orders:

http://www.documentcloud.org/documents/1349845-n-h-t-s-a-spe...

https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&c...

http://www.safercar.gov/staticfiles/safercar/recalls/Special...

http://www.autosafety.org/sites/default/files/imce_staff_upl...

etc

The FOIA route is appealing because it feeds into a sense of perceived indignation.

But the most important thing to copy from the large players is never going to be spelled out in their submissions.

I'll let everyone in this thread in on the secret: hire someone that specializes in quality management systems.