The timeline is not unreasonable at all.

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.

Two weeks is not reasonable for the demands made in the letter. That, plus a $21,000/day penalty, is a clear "fuck you".

There's no $21,000/day penalty. That's the statutory maximum possible. If NHTSA wants to fine Hotz they would have to propose a fine, let him respond with a defense, and then convince a court that it is the most reasonable solution to impose the fine amount recommended. There's no way on earth it would come to anything like $21,000/day.

Two weeks are totally reasonable. If you intend to sell the thing in less than two months, that information should already be ready

Why would you have all the random crap the NHTSA demanded ready to go if this wasn't a pre-existing regulation?

What's random about it? It's basically:

- 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.

#10-12 is gg. Removing the mirror for your device? Wat?

The requested things are pre-existing regulation requirements, simply worded with leading questions to prevent unnecessary back-and-forth.

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.

It's an unreasonably short timeline if you're a bakery owner. Not when you're about to release a driver-assist hardware. He should have most of the required documents and information already prepared, or else he really has no business being anywhere near car hardware.

He chose the launch date without making sure he was legal first.

I think this is the most sane, non-politicized way of stating what happened here. You can speculate as to the motives of the regulator (short timeframe, high costs, certain friends), but the fact of the matter is this was a major flaw in his plan which he didn't see coming.

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

Do I have to check with every relevant government agency for permission every time I do something? If an endeavor not specifically outlawed, it should be presumed legal.

If the endeavor is selling a product for use in a highly regulated industry where the failure case is death, then of course you have to work with regulatory agencies. It's not like the automotive industry is a mysterious minefield hidden in uncharted territory.

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.

> WTF is he even doing

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.

His particular endeavour is specifically outlawed (e.g. blocking the rear view mirror). The NHTSA is simply trying to establish whether or not he complies with the existing regulations - clearly, he doesn't.

Wat. If you intend to sell it as a product. Yes. Yes you do.

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.