Brad Ideas

Robocars & More

For a few months, Uber has been testing their self-driving prototypes in Pittsburgh, giving rides to willing customers with a safety driver (or two) in the front seat monitoring the drive and ready to take over.

When Uber came to do this in San Francisco, starting this week, it was a good step to study new territory and new customers, but the real wrinkle was they decided not to get autonomous vehicle test permits from the California DMV. Google/Waymo and most others have such permits. Telsa has such permits but claims it never uses them.

Google's car project (known as "Chauffeur") really kickstarted the entire robocar revolution, and Google has put in more work, for longer, than anybody. The car was also the first project of what became Google "X" (or just "X" today under Alphabet. Inside X, a lab devoted to big audacious "moonshot" projects that affect the physical world as well as the digital, they have promoted the idea that projects should eventually "graduate," moving from being research to real commercial efforts.

On the lighter side, the other day I was daydreaming how a conversation about her family might go with a famous character... You'll probably guess who fairly early in, but it's pretty strange to read it like this:

Therapist: So, I'm told you have had some serious issues with your family? I'm here to help.

Patient: You might say that.

T: Did something painful happen recently?

P: My son murdered his father, my ex.

T: You son murdered his father! Is he in prison?

P: Not going to happen, he's too highly placed.

T: Why did he do it?

P: It's a long story. And a bit of a pattern.

T: Others in your family have done this?

P: You might say that. There are bad stories about everybody in my family.

T: Surely you had a good relationship with your mother?

P: I never met my mother. She died just as I was born.

T: How terrible. Death in childbirth is so rare in the modern era.

P: She didn't die in childbirth. I am told my father choked her.

T: Your father! So he went to jail?

Robocars are broadly going to be a huge boon for many people with disabilities, especially disabilities which make it difficult to drive or those that make it hard to get in and out of vehicles. Existing disability regulations and policies were written without robocars in mind, and there are probably some improvements that need to be made.

I've seen many enraged notes from friends on how United Airlines will now charge for putting a bag in the overhead bin. While they aren't actually doing this, my reaction is not outrage, but actually something quite positive. And yours should be to, even when other airlines follow suit, as they will.

I fly too much on United. I have had their 1K status for several years, this year I logged over 200,000 miles, so I know all the things to dislike about the airline. Why is it good for them to do this?

Here's the situation: You're in a place with no bandwidth or limited bandwidth. It's just the place that you need to download an app, because the good apps, at least, can do more things locally and not make as much use of the network. But you can't get to the app store. The archetype of this situation is being on a plane with wifi and video offerings over the wifi. You get on board and you connect and it says you needed to download the app before you took off and got disconnected.

I believe we have the potential to eliminate a major fraction of traffic congestion in the near future, using technology that exists today which will be cheap in the future. The method has been outlined by myself and others in the past, but here I offer an alternate way to explain it which may help crystallize it in people's minds.

Today many people drive almost all the time guided by their smartphone, using navigation apps like Google Maps, Apple Maps or Waze (now owned by Google.) Many have come to drive as though they were a robot under the command of the app, trusting and obeying it at every turn. Tools like these apps are even causing controversy, because in the hunt for the quickest trip, they are often finding creative routes that bypass congested major roads for local streets that used to be lightly used.

Put simply, the answer to traffic congestion might be, "What if you, by law, had to obey your navigation app at rush hour?" To be more specific, what if the cities and towns that own the streets handed out reservations for routes on those streets to you via those apps, and your navigation app directed you down them? And what if the cities made sure there were never more cars put on a piece of road than it had capacity to handle? (The city would not literally run Waze, it would hand out route reservations to it, and Waze would still do the UI and be a private company.)

The value is huge. Estimates suggest congestion costs around 160 billion dollars per year in the USA, including 3 billion gallons of fuel and 42 hours of time for every driver. Roughly quadruple that for the world.

Road metering actually works

This approach would exploit one principle in road management that's been most effective in reducing congestion, namely road metering. The majority of traffic congestion is caused, no surprise, by excess traffic -- more cars trying to use a stretch of road than it has the capacity to handle. There are other things that cause congestion -- accidents, gridlock and irrational driver behaviour, but even these only cause traffic jams when the road is near or over capacity.

Today, in many cities, highway metering is keeping the highways flowing far better than they used to. When highways stall, the metering lights stop cars from entering the freeway as fast as they want. You get frustrated waiting at the metering light but the reward is you eventually get on a freeway that's not as badly overloaded.

Another type of metering is called congestion pricing. Pioneered in Singapore, these systems place a toll on driving in the most congested areas, typically the downtown cores at rush hour. They are also used in London, Milan, Stockholm and some smaller towns, but have never caught on in many other areas for political reasons. Congestion charging can easily be viewed as allocating the roads to the rich when they were paid for by everybody's taxes.

A third successful metering system is the High-occupancy toll lane. HOT lanes take carpool lanes that are being underutilized, and let drivers pay a market-based price to use them solo. The price is set to bring in just enough solo drivers to avoid wasting the spare capacity of the lane without overloading it. Taking those solo drivers out of the other lanes improves their flow as well. While not every city will admit it, carpool lanes themselves have not been a success. 90% of the carpools in them are families or others who would have carpooled anyway. The 10% "induced" carpools are great, but if the carpool lane only runs at 50% capacity, it ends up causing more congestion than it saves. HOT is a metering system that fixes that problem.

Many are writing about the Electoral college. Can it still prevent Trump's election, and should it be abolished?

Like almost everybody, I have much to say about the US election results. The core will come later -- including an article I was preparing long before the election but whose conclusions don't change much because of the result, since Trump getting 46.4% is not (outside of the result) any more surprising than Trump getting 44% like we expected. But for now, since I have written about the college before, let me consider the debate around it.

By now, most people are aware that the President is not elected Nov 8th, but rather by the electors around Dec 19. The electors are chosen by their states, based on popular vote. In almost all states all electors are from the party that won the popular vote in a "winner takes all," but in a couple small ones they are distributed. In about half the states, the electors are bound by law to vote for the candidate who won the popular vote in that state. In other states they are party loyalists but technically free. Some "faithless" electors have voted differently, but it's very rare.

I'm rather saddened by the call by many Democrats to push for electors to be faithless, as well as calls at this exact time to abolish the college. There are arguments to abolish the college, but the calls today are ridiculously partisan, and thus foolish. I suspect that very few of those shouting to abolish the college would be shouting that if Trump had won the popular vote and lost the college (which was less likely but still possible.) In one of Trump's clever moves, he declared that he would not trust the final results (if he lost) and this tricked his opponents into getting very critical of the audacity of saying such a thing. This makes it much harder for Democrats to now declare the results are wrong and should be reversed.

The college approach -- where the people don't directly choose their leader -- is not that uncommon in the world. In my country, and in most of the British parliamentary democracies, we are quite used to it. In fact, the Prime Minister's name doesn't even appear on our ballots as a fiction the way it does in the USA. We elect MPs, voting for them mostly (but not entirely) on party lines, and the parties have told us in advance who they will name as PM. (They can replace their leader after if they want, but by convention, not rule, another election happens not long after.)

In these systems it's quite likely that a party will win a majority of seats without winning the popular vote. In fact, it happens a lot of the time. That's because in the rest of the world there are more than 2 parties, and no party wins the popular vote. But it's also possible for the party that came 2nd in the popular vote to form the government, sometimes with a majority, and sometimes in an alliance.

Origins of the college

When the college was created, the framers were not expecting popular votes at all. They didn't think that the common people (by which they meant wealthy white males) would be that good at selecting the President. In the days before mass media allowed every voter to actually see the candidates, one can understand this. The system technically just lets each state pick its electors, and they thought the governor or state house would do it.

Later, states started having popular votes (again only of land owning white males) to pick the electors. They did revise the rules of the college (12th amendment) but they kept it because they were federalists, strong advocates of states' rights. They really didn't imagine the public picking the President directly.

There have been few postings this month since I took the time to enjoy a holiday in New Zealand around speaking at the SingularityU New Zealand summit in Christchurch. The night before the summit, we enjoyed a 7.8 earthquake not so far from Christchurch, whose downtown was over 2/3 demolished after quakes in 2010 and 2011. On the 11th floor of the hotel, it was a disturbing nailbiter of swaying back and forth for over 2 minutes -- but of course swaying is what the building is supposed to do; that means it's working.

Right now Uber, Lyft and traditional taxis are competing. But in the robocar world of the future, when large fleets of cars operate as taxis and replace car ownership for many, how will they compete with one another. Will there be a monopoly in each town, or just a couple of companies? Can we have dozens? Does the biggest fleet win?

I have a new major article on the subject. I also welcome comments on other ways these services might find a competitive edge.

Read Competition in the Robotaxi world

HBO released a new version of "Westworld" based on the old movie about a robot-based western theme park. The show hasn't excited me yet -- it repeats many of the old tropes on robots/AI becoming aware -- but I'm interested in the same thing the original talked about -- simulated experiences for entertainment.

The new show misses what's changed since the original. I think it's more likely they will build a world like this with a combination of VR, AI and specialty remotely controlled actuators rather than with independent self-contained robots.

One can understand the appeal of presenting the simulation in a mostly real environment. But the advantages of the VR experience are many. In particular, with the top-quality, retinal resolution light-field VR we hope to see in the future, the big advantage is you don't need to make the physical things look real. You will have synthetic bodies, but they only have to feel right, and only just where you touch them. They don't have to look right. In particular, they can have cables coming out of them connecting them to external computing and power. You don't see the cables, nor the other manipulators that are keeping the cables out of your way (even briefly unplugging them) as you and they move.

This is important to get data to the devices -- they are not robots as their control logic is elsewhere, though we will call them robots -- but even more important for power. Perhaps the most science fictional thing about most TV robots is that they can run for days on internal power. That's actually very hard.

The VR has to be much better than we have today, but it's not as much of a leap as the robots in the show. It needs to be at full retinal resolution (though only in the spot your eyes are looking) and it needs to be able to simulate the "light field" which means making the light from different distances converge correctly so you focus your eyes at those distances. It has to be lightweight enough that you forget you have it on. It has to have an amazing frame-rate and accuracy, and we are years from that. It would be nice if it were also untethered, but the option is also open for a tether which is suspended from the ceiling and constantly moved by manipulators so you never feel its weight or encounter it with your arms. (That might include short disconnections.) However, a tracking laser combined with wireless power could also do the trick to give us full bandwidth and full power without weight.

It's probably not possible to let you touch the area around your eyes and not feel a headset, but add a little SF magic and it might be reduced to feeling like a pair of glasses.

The advantages of this are huge:

• You don't have to make anything look realistic, you just need to be able to render that in VR.
• You don't even have to build things that nobody will touch, or go to, including most backgrounds and scenery.
• You don't even need to keep rooms around, if you can quickly have machines put in the props when needed before a player enters the room.
• In many cases, instead of some physical objects, a very fast manipulator might be able to quickly place in your way textures and surfaces you are about to touch. For example, imagine if, instead of a wall, a machine with a few squares of wall surface quickly holds one out anywhere you're about to touch. Instead of a door there is just a robot arm holding a handle that moves as you push and turn it.
• Proven tricks in VR can get people to turn around without realizing it, letting you create vast virtual spaces in small physical ones. The spaces will be designed to match what the technology can do, of course.
• You will also control the audio and cancel sounds, so your behind-the-scenes manipulations don't need to be fully silent.
• You do it all with central computers, you don't try to fit it all inside a robot.
• You can change it all up any time.

In some cases, you need the player to "play along" and remember not to do things that would break the illusion. Don't try to run into that wall or swing from that light fixture. Most people would play along.

For a lot more money, you might some day be able to do something more like Westworld. That has its advantages too:

• Of course, the player is not wearing any gear, which will improve the reality of the experience. They can touch their faces and ears.
• Superb rendering and matching are not needed, nor the light field or anything else. You just need your robots to get past the uncanny valley
• You can use real settings (like a remote landscape for a western) though you may have a few anachronisms. (Planes flying overhead, houses in the distance.)
• The same transmitted power and laser tricks could work for the robots, but transmitting enough power to power a horse is a great deal more than enough to power a headset. All this must be kept fully hidden.

The latter experience will be made too, but it will be more static and cost a lot more money.

Yes, there will be sex

Warning: We're going to get a bit squicky here for some folks.

Westworld is on HBO, so of course there is sex, though mostly just a more advanced vision of the classic sex robot idea. I think that VR will change sex much sooner. In fact, there is already a small VR porn industry, and even some primitive haptic devices which tie into what's going on in the porn. I have not tried them but do not imagine them to be very sophisticated as yet, but that will change. Indeed, it will change to the point where porn of this sort becomes a substitute for prostitution, with some strong advantages over the real thing (including, of course, the questions of legality and exploitation of humans.)

Comma.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:

1. There are many elements of this letter which would also apply to Tesla and other automakers which have built supervised autopilot functions.
2. 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.
3. 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.
4. 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.
5. 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.

It's no secret that I've been a critic of the NHTSA "levels" as a taxonomy for types of Robocars since the start. Recent changes in their use calls for some new analysis that concludes that only one of the levels is actually interesting, and only tells part of the story at that. As such, they have become even less useful as a taxonomy. Levels 2 and 3 are unsafe, and Level 5 is remote future technology. Level 4 is the only interesting one and there is thus no taxonomy.

I frequently say that there is no "internet of things." That's a marketing phrase for now. You can't go buy a "thing" and plug it into the "internet of things." IoT is still interesting because underneath the name is a real revolution from the way that computing, sensing and communications are getting cheaper, smaller and using less power. New communications protocols are also doing interesting things.

We learned a lesson on Friday though, about why using the word "internet" is its own mistake. The internet -- one of the world's greatest inventions -- was created as a network of networks where anything could talk to anything, and it was useful for this to happen. Later, for various reasons, we moved to putting most devices behind NATs and firewalls to diminish this vision, but the core idea remains.

Attackers on Friday made use of growing collection of low cost IoT devices with low security to mount a DDOS attack on DYN's domain name servers, shutting off name lookup for some big sites. While not the only source of the attack, a lot of attention has come to certain Chinese brands of IP based security cameras and baby monitors. To make them easy to use, they are designed with very poor security, and as a result they can be hijacked and put into botnets to do DDOS -- recruiting a million vulnerable computers to all overload some internet site or service at once.

Most applications for small embedded systems -- the old and less catchy name of the "internet of things" -- aren't at all in line with the internet concept. They have no need or desire to be able to talk to the whole world the way your phone, laptop or web server do. They only need to talk to other local devices, and sometimes to cloud servers from their vendor. We are going to see billions of these devices connected to our networks in the coming years, perhaps hundreds of billions. They are going to be designed by thousands of vendors. They are going to be cheap and not that well made. They are not going to be secure, and little we can do will change that. Even efforts to make punishments for vendors of insecure devices won't change that.

So here's an alternative; a long term plan for our routers and gateways to take the internet out of IoT.

Our routers should understand that two different classes of devices will connect to them. The regular devices, like phones and laptops, should connect to the internet as we expect today. There should also be a way to know that the connecting devices does not want regular internet access, and not to give it. One way to do that is for the devices to know about this, and to convey how much access they need when they first connect. One proposal for this is my friend Eliot Lear's MUD proposal. Unfortunately, we can't count on devices to do this. We must limit stupid devices and old devices too.

California Hearings

Wednesday, California held hearings on the latest draft of their regulations. The new regulations heavily incorporate the new NHTSA guidelines released last month, and now incorporate language on the testing and deployment of unmanned vehicles.

When people vote, what do they think it will accomplish? How does this affect how they vote, and how should it?

My apologies for more of this in a season when our social media are overwhelmed with politics, but in a lot of the postings I see about voting plans, I see different implicit views on just what the purpose of voting is. The main focus will be on the vote for US President.

The vast majority of people will vote in non-contested states. The logic is different in the "swing" states where all the campaign attention is.

I had hoped I was done ranting about our obsession with what robocars will do in no-win "who do I hit?" situations, but this week, even Barack Obama in his interview with Wired opined on the issue, prompted by my friend Joi Ito from the MIT Media Lab. (The Media Lab recently ran a misleading exercise asking people to pretend they were a self-driving car deciding who to run over.)

The social networks have access (or more to the point can give their users access) to an unprecedented trove of information on political views and activities. Could this make a radical difference in affecting who actually shows up to vote, and thus decide the outcome of elections?

I've written before about how the biggest factor in US elections is the power of GOTV - Get Out the Vote. US Electoral turnout is so low -- about 60% in Presidential elections and 40% in off-year -- that the winner is determined by which side is able to convince more of their weak supporters to actually show up and vote. All those political ads you see are not going to make a Democrat vote Republican or vice versa, they are going to scare a weak supporter to actually show up. It's much cheaper, in terms of votes per dollar (or volunteer hour) to bring in these weak supporters than it is to swing a swing voter.

The US voter turnout numbers are among the worst in the wealthy world. Much of this is blamed on the fact the US, unlike most other countries, has voter registration; effectively 2 step voting. Voter registration was originally implemented in the USA as a form of vote suppression, and it's stuck with the country ever since. In almost all other countries, some agency is responsible for preparing a list of citizens and giving it to each polling place. There are people working to change that, but for now it's the reality. Registration is about 75%, Presidential voting about 60%. (Turnout of registered voters is around 80%)

Scary negative ads are one thing, but one of the most powerful GOTV forces is social pressure. Republicans used this well under Karl Rove, working to make social groups like churches create peer pressure to vote. But let's look at the sort of data sites like Facebook have or could have access to:

• They can calculate a reasonably accurate estimate of your political leaning with modern AI tools and access to your status updates (where people talk politics) and your friend network, along with the usual geographic and demographic data
• They can measure the strength of your political convictions through your updates
• They can bring in the voter registration databases (which are public in most states, with political use allowed on the data. Commercial use is forbidden in a portion of states but this would not be commercial.)
• In many cases, the voter registration data also reveals if you voted in prior elections
• Your status updates and geographical check-ins and postings will reveal voting activity. Some sites (like Google) that have mobile apps with location sensing can detect visits to polling places. 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.

Now imagine more complex queries aimed specifically at GOTV, such as: "My friends who match me politically but are not scored as likely to vote" or "My friends who match me politically and are not registered to vote." Possibly adding "Sorted by the closeness of our connection" which is something they already score.

After 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.

After my initial reactions and Overall Analysis here is a point by point consideration of the elements from NHTSA's 15 point certification list for robocars. See also the second half and the whole series

Let's dig in:

Data Recording and Sharing

These regulations require a plan about how the vehicle keep logs around any incident (while following privacy rules.) This is something everybody already does -- in fact they keep logs of everything for now -- since they want to debug any problems they encounter. NHTSA wants the logs to be available to NHTSA for crash investigation.

NHTSA also wants recordings of positive events (the system avoided a problem.)

Most interesting is a requirement for a data sharing plan. NHTSA wants companies to share their logs with their competitors in the event of incidents and important non-incidents, like near misses or detection of difficult objects.

This is perhaps the most interesting element of the plan, but it has seen some resistance from vendors. And it is indeed something that might not happen at scale without regulation. Many teams will consider their set of test data to be part of their crown jewels. Such test data is only gathered by spending many millions of dollars to send drivers out on the roads, or by convincing customers or others to voluntarily supervise while their cars gather test data, as Tesla has done. A large part of the head-start that leaders have in this field is the amount of different road situations they have been able to expose their vehicles to. 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.

Instead this offers the ability to build something that all vendors want and need, and the world needs, which is a high quality simulator where cars can be tested against real world recordings and entirely synthetic events. The data sharing requirement will allow the input of all these situations into the simulator, so every car can test how it would have performed. This simulation will mostly be at the "post perception level" where the car has (roughly) identified all the things on the road and is figuring out what to do with them, but some simulation could be done at lower levels.

These data logs and simulator scenarios will create what is known as a regression test suite. You test your car in all the situations, and every time you modify the software, you test that your modifications didn't break something that used to work. It's an essential tool.

In the history of software, there have been shared public test suites (often sourced from academia) and private ones that are closely guarded. For some time, I have proposed that it might be very useful if there were a a public and open source simulator environment which all teams could contribute scenarios to, but I always expected most contributions would come from academics and the open source community. Without this rule, the teams with the most test miles under their belts might be less willing to contribute.

Such a simulator would help all teams and level the playing field. It would allow small innovators to even build and test prototype ideas entirely in simulator, with very low cost and zero risk compared to building it in physical hardware.

This is a great example of where NHTSA could use its money rather than its regulatory power to improve safety, by funding the development of such test tools. In fact, if done open source, the agencies and academic institutions of the world could fund a global one. (This would face opposition from companies hoping to sell test tools, but there will still be openings for proprietary test tools.)

Privacy

This section demands a privacy policy. I'm not against that, though of course the history of privacy policies is not a great one. They mostly involve people clicking "I agree" to things they don't read. More important is the requirement that vendors be thinking about privacy.

The requirement for user choice is an interesting one, and it conflicts with the logging requirements. People are wary of technology that will betray them in court. Of course, as long as the car is not a hybrid car that mixes human driving with self-driving, and the passenger is not liable in an accident, there should be minimal risk to the passenger from accidents being recorded.

The rules require that personal information be scrubbed from any published data. This is a good idea but history shows it is remarkably hard to do properly.