[ttmb]

This regulation is saying that if you did build an autonomous Russian roulette revolver, there's no requirement to outfit it with a pistol grip and a trigger.

If there is a fully driverless (not driving itself with a human still in it) truck - as companies tell us is their goal - it does not increase or decrease safety to have or not have a seat and a steering wheel in it.

The argument here is that building an autonomous Russian roulette revolver is a stupid thing to do, which is orthogonal.

[lordfrito]

This.

I have some experience in navigating NHTSA when bringing new automotive tech to market. The following reflects my experience.

When working on cutting edge tech that have associated hazards (cars hurt people) what companies want is a clear set of standards to meet, as this goes a long way to showing due-diligence when things go wrong and lawsuits start showing up. But with new tech there are no standards, no generally accepted way of doing things. So how do you know if the system is capable/safe-enough to deploy in volume on our roads? How do you know you've done enough due diligence to confidently launch new tech without putting your company at financial risk? Let's face it, a big enough software bug (and associated liability) could potentially put Tesla completely out of business. When dealing with hazardous new tech, the threat of recalls and lawsuits weighs heavily on a company's decision making process.

When it comes to new tech, NHTSA is in no position to answer these questions. And they know it. If they knew better then they'd be the ones driving innovation. As it stands under capitalism the innovators are all working for private companies hoping for the big pay out. Knowing this, it would be counterproductive for NHTSA to say "we know better than to let a self driving car on the road". They don't know better and they don't want to get in the way of innovation.

So instead NHTSAs job is to setup a regulatory framework and set of rules to help these companies bring tech to market, while helping identify/limit bad actors. When lessons are learned (ex. ABS systems provide a clear benefit, and should generally do X Y and Z) these lessons get integrated back into the regulations as a guide to all players in the space. The regulations and standards improve over time as more-and-more millions-of-miles are driven and the tech/algorithms mature.

In my experience, NHTSAs attitude seems to be best summarized as: Innovation is good for America and the last thing we want to do is stop you from developing cool new things. But we have no idea what your new tech should/shouldn't do. The risk is all on you, your company ultimately bears the legal responsibility for your products. You'll have to determine if your product is ready for market all on your own -- and failure carries a high price tag. Now... if/when the tech matures, and the industry seems to generally agree that "new tech X" should include "X Y and Z" as part of the safety/risk equation, then we'll add that to the regulatory framework. But until the tech matures and the clear path forward is known we don't want to stifle innovation.

This is about the best you can do in this situation. ADAS is new, and no one knows where we'll end up. No one, including you and me, knows if these systems can be deployed safely. Personally I don't trust ADAS systems, and believe the financial risk would be too high to risk my company. But what do I know?

It seems that the message being sent here is: "We're ready to start dealing with cars that don't have human controls. Best of luck to all those who dare play in the space."