Detailed analysis of NHTSA robocar regulations: Overview
Submitted by brad on Thu, 2016-09-29 00:50The recent Federal Automated Vehicles Policy is long. (My same-day analysis is here and the whole series is being released.) At 116 pages (to be fair, less than half is policy declarations and the rest is plans for the future and associated materials) it is much larger than many of us were expecting.
The policy was introduced with a letter attributed to President Obama, where he wrote:
There are always those who argue that government should stay out of free enterprise entirely, but I think most Americans would agree we still need rules to keep our air and water clean, and our food and medicine safe. That’s the general principle here. What’s more, the quickest way to slam the brakes on innovation is for the public to lose confidence in the safety of new technologies. Both government and industry have a responsibility to make sure that doesn’t happen. And make no mistake: If a self-driving car isn’t safe, we have the authority to pull it off the road. We won’t hesitate to protect the American public’s safety.
This leads in to an unprecedented effort to write regulations for a technology that barely exists and has not been deployed beyond the testing stage. The history of automotive regulation has been the opposite, and so this is a major change. The key question is what justifies such a big change, and the cost that will come with it.
Make no mistake, the cost will be real. The cost of regulations is rarely known in advance but it is rarely small. Regulations slow all players down and make them more cautious -- indeed it is sometimes their goal to cause that caution. Regulations result in projects needing "compliance departments" and the establishment of procedures and legal teams to assure they are complied with. In almost all cases, regulations punish small companies and startups more than they punish big players. In some cases, big players even welcome regulation, both because it slows down competitors and innovators, and because they usually also have skilled governmental affairs teams and lobbying teams which are able to subtly bend the regulations to match their needs.
This need not even be nefarious, though it often is. Companies that can devote a large team to dealing with regulations, those who can always send staff to meetings and negotiations and public comment sessions will naturally do better than those which can't.
The US has had a history of regulating after the fact. Of being the place where "if it's not been forbidden, it's permitted." This is what has allowed many of the most advanced robocar projects to flourish in the USA.
The attitude has been that industry (and startups) should lead and innovate. Only if the companies start doing something wrong or harmful, and market forces won't stop them from being that way, is it time for the regulators to step in and make the errant companies do better. This approach has worked far better than the idea that regulators would attempt to understand a product or technology before it is deployed, imagine how it might go wrong, and make rules to keep the companies in line before any of them have shown evidence of crossing a line.
In spite of all I have written here, the robocar industry is still young. There are startups yet to be born which will develop new ideas yet to be imagined that change how everybody thinks about robocars and transportation. These innovative teams will develop new concepts of what it means to be safe and how to make things safe. Their ideas will be obvious only well after the fact.
Regulations and standards don't deal well with that. They can only encode conventional wisdom. "Best practices" are really "the best we knew before the innovators came." Innovators don't ignore the old wisdom willy-nilly, they often ignore it or supersede it quite deliberately.
What's good?
Some players -- notably the big ones -- have lauded these regulations. Big players, like car companies, Google, Uber and others have a reason to prefer regulations over a wild west landscape. Big companies like certainty. They need to know that if they build a product, that it will be legal to sell it. They can handle the cost of complex regulations, as long as they know they can build it.





Here are some basic models of cost. I compare a low-cost 1-2 person robotaxi, a higher-end 1-2 person robotaxi, a 4-person traditional sedan robotaxi and the costs of ownership for a private car, the Toyota Prius 2, as
In other Uber news, Uber has announced it will sell randomly assigned Uber rides in their self-driving vehicles in Pittsburgh. If your ride request is picked at random (and because it's in the right place) Uber will send one of their own cars to drive you on your ride, and will make the ride free, to boot. Of course, there will be an Uber safety driver in the vehicle monitoring it and ready to take over in any problem or complex situation. So the rides are a gimmick to some extent, but if they were not free, it would be a sign of another way to get customers to pay for the cost of testing and verifying self-driving cars. The free rides, however, will probably actually cause more people to take Uber rides hoping they will win the lottery and get not simply the free ride but the self-driving ride.
Consider here in California, which is very solidly for Clinton. Nate Silver rates it as 99.9% (or higher) to go for Clinton. A vote for Clinton or Trump here is wasted. It adds a miniscule proportion to their totals. Clinton will fetch around 8 million votes. You can do the un-noticed thing of making it 8 million and 1, and you'll bump her federally by an even tinier fraction. Your vote can make no difference to the result (you already know that) and nor will it be noticed in the totals. You're throwing it away, getting an insignificant benefit for its use.
But it is a contest, and while it looks like
The same is true for trucks, but both trucks and buses have huge power needs which presents problems for having them be electric. Electric's biggest problem here is the long recharge time, which puts your valuable asset out of service. For trucks, the big win of having a robotruck is that it can drive 24 hours/day, you don't want to take that away by making it electric. This means you want to look into things like battery swap, or perhaps more simply tractor swap. In that case, a truck would pull in to a charging station and disconnect from its trailer, and another tractor that just recharged would grab on and keep it going.
Most importantly, it is far from complete. There is tons of stuff it's not able to handle. Some of those things it can't do are known, some are unknown. Because of this, it is designed to only work under constant supervision by a driver. Tesla drivers get this explained in detail in their manual and when they turn on the autopilot.
What does it look like?