NHTSA Regulations part 4: Crashes, Training, Certification, State Law, Operation, Validation and Autopilots
Submitted by brad on Fri, 2016-09-30 13:27After my initial reactions and Overall Analysis here is a point by point consideration of second set of elements from NHTSA's 15 point certification list for robocars. See my series for other articles or the first half of the list.
Crashworthiness
In this section, the remind vendors they still need to meet the same standards as regular cars do. We are not ready to start removing heavy passive safety systems just because the vehicles get in fewer crashes. In the future we might want to change that, as those systems can be 1/3 of the weight of a vehicle.
They also note that different seating configurations (like rear facing seats) need to protect as well. It's already the case that rear facing seats will likely be better in forward collisions. Face-to-face seating may present some challenges in this environment, as it is less clear how to deploy the airbags. Taxis in London often feature face-to-face seating, though that is less common in the USA. Will this be possible under these regulations?
The rules also call for unmanned vehicles to absorb energy like existing vehicles. I don't know if this is a requirement on unusual vehicle design for regular cars or not. (If it were, it would have prohibited SUVs with their high bodies that can cause a bad impact with a low-body sports-car.)
Consumer Education and Training
This seems like another mild goal, but we don't want a world where you can't ride in a taxi unless you are certified as having taking a training course. Especially if it's one for which you have very little to do. These rules are written more for people buying a car (for whom training can make sense) than those just planning to be a passenger.

Registration and Certification
This section imagines labels for drivers. It's pretty silly and not very practical. Is a car going to have a sticker saying "This car can drive itself on Elm St. south of Pine, or on highway 101 except in Gilroy?" There should be another way, not labels, that this is communicated, especially because it will change all the time.
Post-Crash Behavior
This set is fairly reasonable -- it requires a process describing what you do to a vehicle after a crash before it goes back into service.
Federal, State and Local Laws
This section calls for a detailed plan on how to assure compliance with all the laws. Interestingly, it also asks for a plan on how the vehicle will violate laws that human drivers sometimes violate. This is one of the areas where regulatory effort is necessary, because strictly cars are not allowed to violate the law -- doing things like crossing the double-yellow line to pass a car blocking your path.




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.
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.