Comma.ai cancels comma-one add-on box after threats from NHTSA
Submitted by brad on Fri, 2016-10-28 13:13Comma.ai, the brash startup attempting to make a self-driving system entirely from a neural network has announced it will cancel the "comma one" add-on box it has planned to sell to owners of certain Honda vehicles. The box stuck on the rear-view mirror and used the car's own bus commands to provide an autopilot similar to those offered by car makers, with lane-keeping and adaptive cruise control.
Of particular importance is the letter from NHTSA to comma.ai which I suggest you read. This letter creates several big issues:
- There are many elements of this letter which would also apply to Tesla and other automakers which have built supervised autopilot functions.
- Of particular interest is the paragraph which says: "it is insufficient to assert, as you do, that the product does not remove any of the driver's responsibilities" and "there is a high likelihood that some drivers will use your product in a manner that exceeds its intended purpose." That must be very scary for Tesla.
- I noted before that the new NHTSA regulations appear to forbid the use of "black box" neural network approaches to the car's path planning and decision making. I wondered if this made illegal the approach being done by Comma, NVIDIA and many other labs and players. This may suggest that.
- We now have a taste of the new regulatory regime, and it seems that had it existed before, systems like Tesla's autopilot, Mercedes Traffic Jam Assist, and Cruise's original aftermarket autopilot would never have been able to get off the ground.
- George Hotz of comma declares "Would much rather spend my life building amazing tech than dealing with regulators and lawyers. It isn't worth it. The comma one is cancelled. comma.ai will be exploring other products and markets. Hello from Shenzhen, China."
To be clear, comma is a tiny company taking a radical approach, so it is not a given that what NHTSA has applied to them would have been or will be unanswerable by the big guys. Because Tesla's autopilot is not a pure machine learning system, they can answer many of the questions in the NHTSA letter that comma can't. They can do much more extensive testing that a tiny startup can't. But even so a letter like this sends a huge chill through the industry.
It should also be noted that in Comma's photos the box replaced the rear-view mirror, and NHTSA had reason to ask about that.
George's declaration that he's in Shenzen gives us the first sign of the new regulatory regime pushing innovation away from the United States and California. I will presume the regulators will say, "We only want to scare away dangerous innovation" but the hard truth is that is a very difficult thing to judge. All innovation in this space is going to be a bit dangerous. It's all there trying to take the car -- the 2nd most dangerous legal consumer product -- and make it safer, but it starts from a place of danger. We are not going to get to safety without taking risks along the way.
I sometimes ask, "Why do we let 16 year olds drive?" They are clearly a major danger to themselves and others. Driver testing is grossly inadequate. They are not adults so they don't have the legal rights of adults. We let them drive because they are going to start out dangerous and then get better. It is the only practical way for them to get better, and we all went through it. Today's early companies are teenagers. They are going to take risks. But this is the fastest and only practical way to let them get better and save millions.
"...some drivers will use your product in a manner that exceeds its intended purpose"
This sentence, though in the cover letter and not the actual legal demand, looks at the question asked so much after the Tesla fatal crash. The question which caused Consumer Reports to ask Tesla to turn off the feature. The question which caused MobilEye, they say, to sever their relationship with Tesla.
The paradox of the autopilot is this: The better it gets, the more likely it is to make drivers over-depend on it. The more likely they will get complacent and look away from the road. And thus, the more likely you will see a horrible crash like the Tesla fatality. How do you deal with a system which adds more danger the better you make it? Customers don't want annoying countermeasures. This may be another reason that "Level 2," as I wrote yeterday is not really a meaningful thing.
NHTSA has put a line in the sand. It is no longer going to be enough to say that drivers are told to still pay attention.
Black box
Comma is not the only company trying to build a system with pure neural networks doing the actual steering decisions (known as "path planning".) NVIDIA's teams have been actively working on this, as have several others. They plan to make commentary to NHTSA about these element of the regulations, which should not be forbidding this approach until we know it to be dangerous.




Of course, for the social site to aggregate and use this data for its own purposes would be a gross violation of many important privacy principles. But social networks don't actually do (too many) things; instead they provide tools for their users to do things. As such, while Facebook should not attempt to detect and use political data about its users, it could give tools to its users that let them select subsets of their friends, based only on information that those friends overtly shared. On Facebook, you can enter the query, "My friends who like Donald Trump" and it will show you that list. They could also let you ask "My Friends who match me politically" if they wanted to provide that capability.
Recordings of mundane driving activity are less exciting and will be easier to gather. Real world incidents are rare and gold for testing. The sharing is not as golden, because each vehicle will have different sensors, located in different places, so it will not be easy to adapt logs from one vehicle directly to another. While a vehicle system can play its own raw logs back directly to see how it performs in the same situation, other vehicles won't readily do that.
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.
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.