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.
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.