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Comment by Analemma_ | Hacker News Reader

He's currently throwing a temper tantrum on Twitter, and all because the NHTSA wanted to ask him a few questions about the product (you can see it here: https://www.scribd.com/document/329218929/2016-10-27-Special...). Like, how dare the government try to have basic standards for multi-ton hunks of metal hurtling down the highway without human input.

I've been trying to convince people lately that Silicon Valley isn't all delusional technolibertarian assholes, but guys like this sure aren't making my case easy.

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Exactly. The NHTSA memo seems extremely reasonable to me. If you're going to put to market a product where the smallest malfunction could easily kill many people (both those using your product and those around them), answering a couple regulation questions seems like a small hurdle to pass. Nothing here is saying "we want to shut you down", it's saying "we want to make sure you pass the most basic safety standards". That's an obvious part of a government's duty to keep it's citizens safe.

I feel $21,000 fine per day sounds pretty like "we want to shut you down". He never presented comma.ai as an autopilot but as a very smart line assist and adaptive cruise control.

By "we want to shut you down" I meant the NHTSA isn't presenting him with so many regulations and requirements that meeting them is impossible, effectively ending the product. They are definitely using the fine to force him to comply with their request to meet the very minimum bar of answering their questions about his product. This, as mentioned, makes total sense to me in terms of what government should do to protect the safety of its citizens.

Edit: grammar

Actually even the $21k fine should be nothing if he got $3M in venture capital. What's questionable is whether somebody can build safely an almost-self-driving car without a good team and with many years of experience in the field.

$21K per day. Four months to consume $3M entirely.

The fine was up to $21k per day subject to a maximum of $105k

Actually, the maximum is $105MM.

"As you are undoubtedly aware, there is a high likelihood that some drivers will use your product in a manner that exceeds its intended purpose."

The government appears well aware of this hand waving garbage that companies are trying with "it isn't really autopilot, keep your hands on the wheel wink." This is exactly government's job and is a fabulous example of a government reacting to ongoing events that have proven that so-called autopilot systems are inherently a danger to the public at this stage.

Proof that so-called autopilot systems are a danger to the public would be evidence that they perform worse than the average driver. I haven't seen such evidence, what are you referencing?

It's the other way around - you need a proof that they perform comparable to an average driver during expected use, and they do not have absurdly stupid corner cases during actually expected use.

Well, humans have absurdly stupid corner cases during actual use, too. It depends on how small the corner is, I think.

Yes and humans require certification before they are permitted to drive vehicles on public roadways.

To get that certification, do they test you first, or do they wait for you to screw up and then take it away from you??

We know, being humans, and that we have the ability to process lots of complex information in a way that's very difficult for computers to replicate. Hard AI doesn't actually exist (yet). We also have a 100 years of humans driving cars worldwide so we understand well what they're good at and what they're not, so laws & safety designs take all of this into consideration.

Each computer system will be encountering new, diverse things in the real world without a good understanding of how they'll perform. There are lots of crazy hard problems here that no one has solved yet. So to suggest we just automatically trust it because humans make mistakes is foolish when the consequences are so high. If someone came out with a surgery "autopilot" tomorrow, would you suggest it start giving triple bypass surgeries right away without FDA approval because humans make errors too?

One of the features of the common human firmware is self-preservation instinct. It lets us trust that our fellow drivers, while still prone to mistakes, won't generally make obviously suicidal errors. Can one say the same about a new ML algorithm running on some board designed half a decade ago? How exactly would one know, without a thorough audit?

They test you first, but if despite passing the test you screw up sufficiently badly later they decertify you.

It's a belt-and-suspenders system.

We've been dealing with those corner cases for thousands of years and we know them pretty well. Given that we all run on pretty much the same hardware and firmware (with minor differences), you could say humans have been thoroughly tested for few millennia, including a hundred or so years of road testing.

So yeah, I a bit of thorough testing of a completely new hardware running completely new software isn't too much to ask for.

so we should wait till a statistically-significant percentage of people die before we tell everyone, "yep, definitely dangerous. Lets add some regulation" ?

I wonder if they could shut him down on the basis of car insurance requirements and the legal definition of "driver". If "driver" is defined as the "person" inputting control commands, then either you dont consider the computer a person, and then nobody is legally "driving" the car, or else the software somehow meets the definition of a "person" or driver, in which case its an unlicensed driver operating the vehicle and insurance may not have to cover it.

The NHTSA has been a strong proponent of self-driving technology and has gone out of its way to make sure there is a path to doing it legally, without pulling the legal 'gotcha' that you described here.

The device would probably be SAE Level 2, and should be regulated as such.

When you measure the safety of autonomous cars by counting the miles they travel, and not counting the miles that they intentionally avoid or defer to a human, you have succeeded in creating a metric that looks like it's useful for comparison, but is actually completely meaningless. It's like measuring typing speed while ignoring typos.

Until autonomous vehicles are subject to the full spectrum of conditions that human drivers face, incidents/mile is not a meaningful measure of comparative safety. And until then, the burden of proof should be on the creators.

Not true. Lots of accidents happen in "good" conditions because humans suck at driving.

The way you compare, is you give a self driving car to a person, and compare actually usage for that person, and see if owning a self driving car increases or reduces accidents for that person.

Being perfect only half the time is still revolutionary.

I have a 100% perfect safety record over probably hundreds of thousands of miles of driving a class B truck with my knees instead of my hands, using cruise control, on straight empty highways in Nevada, Idaho, and Utah, with perfect weather and good road conditions. There's nothing revolutionary about my ability to perfectly drive with my knees...I just very carefully selected the conditions where I was willing to do it.

You may have that perfect safety record, but other people don't.

People still crash every day in good conditions. That's thousands of lives that could be saved with our imperfect, sunny weather on the highway only self driving car.

You underestimate how bad human drivers are even in perfect conditions.

You are completely missing the point, so I'll try explaining via a Reductio ad absurdum hypothetical.

Lets say that Semi-Autonomous Cars are currently tested on about 80% of the tasks that humans currently face in the real world, and that through some feat of engineering and design we don't have to worry about the ridiculously messy transitions between Autonomous Mode and Human Mode.

And let's say that for those 80% of tasks, the Semi-Autonomous Cars have a 0.05% accidents/100k miles incident rate.

And let's also say that Humans on average have a 1% accidents/100k miles incident rate.

What you're telling me is that the Semi-Autonomous car has a much better safety record, so give us Semi-Autonomous RIGHT NOW OR WE'RE ALL GONNA DIE!!!

But what I'm telling you is that you don't know enough to make that decision yet, because you don't know exactly how well humans do on the 80% that Semi-Autonomous cars currently handle, you merely know the average accident rate over the current 100% of scenarios. For all you know, Human drivers could have their average 1% accident rate as a result of a 0.0% accident rate for that 80% subset and a 5% accident rate on the remaining 20% that Semi-Autonomous cars can't handle. And if that were the case, then forcing us all to use Semi-Autonomous cars would actually increase the average accident rate from 1% to 1.004%.

Until you fully understand what Semi-Autonomous Cars are capable of, AND know how well human drivers do on that restricted subset, you can't definitively say that current technology is better than humans.

I understand what you are saying, I am just disagree with the facts.

"Human drivers could have their average 1% accident rate as a result of a 0.0% accident rate for that 80% subset "

No they couldn't, because they don't.

I am asserting that for this specific 80% of perfect conditions, humans are still terrible drivers. And that being better than them is EASY, because of just how terrible humans are at driving (even in "perfect conditions").

> No they couldn't, because they don't.

The numbers were deliberately exaggerated to make the point. The fact stands though that until you know what the numbers are, the best answer is not easy to come by.

> I am asserting that for this specific 80% of perfect conditions, humans are still terrible drivers. And that being better than them is EASY, because of just how terrible humans are at driving (even in "perfect conditions").

And I am asserting the opposite: that the appearance of safety of autonomous vehicles is the result of highly selective conditions with near laboratory levels of control, the likes of which are so monumentally easy to handle that even humans, as shitty and inattentive as they are at driving, can handle with comparative levels of safety. And I certainly think it's possible that computers will lag behind humans for another 20-50 years while we slowly develop the massive body of fast-heuristics research necessary to make NP-complete planning decisions with the speed and capability of even below-average humans.

The frequency with which an autonomous driving system relinquishes control is one important metric for estimating the actual risk. Measures like this are better and faster than using the actual tally of catastrophic events, because there is more, and more frequent, information. Engineers working in high-risk fields have been doing this sort of analysis for decades, and there is no reason to make an exception for autonomous road vehicles.

>>humans suck at driving

Proof?

Well, roughly every driving week or so...

Just two days ago, driving on a roundabout some lady enters the roundabout right in front of my car. Fortunately it was a two lane roundabout and the left lane was empty so I could swerve to avoid crashing into her left hand side door (I was coming straight at her).

At the traffic light I asked her if she had not seen me and she went 'Seen what? Where?', so apparently she had not seen me at all, which is pretty impressive given that I was less than 5 meters away from her when it happened.

This sort of thing happens with some regularity. All it takes for a situation like that to turn into an accident with possibly a fatality is for me also not to pay attention.

beyond the obviousness of what you have overlooked, its also worth pointing out that not all autonomous car usage will be substitutive. What if i just send my autonomous car to go take a picture of something? I might not have done it before, but now I will because it only costs a few cents/mile and none of my time.

Another really cool use case will be sending your car to drive around the block for an hour or go back to your house and park, while you are going out to places. Beats paying the $10 to park for an hour.

Lots of interesting effects there, all the way up to basic urban land-use decisions.

Suddenly the price people will pay for parking is going to be closely related to the price of gas. The maximum value of a parking space in the city is basically the cost to send the car back out to some suburban parking garage during the day and have it come back in later for you. My guess is that the market-clearing price is going to be a lot lower than it is today. Lots of urban parking structures might end up getting repurposed for other uses, if you can't fill them at hundreds of dollars per space per month.

In the short run I could see the average self-driving car's gas usage being higher than a conventional car's, but in the longer run the same self-driving features might make fully electric cars more palatable. Long charging times don't really matter if you can let the car go and charge itself while you're at work, for e.g.

And if that place that it goes to charge itself happens to have a pile of solar and wind, even better! Way easier to do a bit installation in a less populated area than right in the centre of downtown.

>inherently a danger

Can you expand on how they are an inherent danger, rather than a possible danger? I only challenge you because Tesla has published several occasions where Autopilot has possibly saved lives by auto-braking.

> Can you expand on how they are an inherent danger, rather than a possible danger?

I do not believe those words (inherent & possible) are in any way mutually exclusive. They might even mean the same thing when describing a latent danger. So I do not quite understand the basis of your challenge. Also, I'm not parent poster.

My understanding of inherent might not be right, then. I think of it as "it is definitely a danger, and thus can only be described as dangerous," which I would argue is not mutually exclusive with possible but is mutually exclusive with "not always dangerous and maybe even anti-dangerous."

So what I mean is, the autopilot could turn out to be safer than manual, in my mind, so how is it "inherently" dangerous.

A swimming pool in your backyard is an inherent danger. That doesn't mean anyone will be injured or killed, but a deep body of water with sheer walls is inherently dangerous.

It would nonetheless also be accurate to describe it as a possible danger, because the danger only manifests in certain circumstances.

> So what I mean is, the autopilot could turn out to be safer than manual, in my mind, so how is it "inherently" dangerous.

That could well be the case but I don't think it eliminates the inherent danger. Maybe it's less dangerous, but cars on the road are just kind of dangerous in general.

I think it's also very generous to assume that the early auto pilot car systems we have today are necessarily safer than human drivers. Emergency braking is almost certainly a net gain. Self driving might be or might not be. A self driving add-on cooked up by geohot? I'm doubtful it's yet gone through the kind of engineering rigor we'd expect of a system like this.

It's inherently dangerous because it's a bunch of hardware and software that take over a 2 ton vehicle to turn it into a software guided missile. That's an inherently dangerous set-up that will need a lot of thinking to keep it safe for general use.

Just like a piano suspended from a rope is inherently dangerous. The danger may not manifest at all for that to be the case.

"So what I mean is, the autopilot could turn out to be safer than manual, in my mind, so how is it "inherently" dangerous."

In the same way that the ocean is still inherently dangerous even if you're wearing a life jacket, or how airplanes are still inherently dangerous even though aircraft autopilot systems are effectively mainstream at this point.

My statement was that "ongoing events that have proven that so-called autopilot systems are inherently a danger to the public at this stage". The important part to note is "at this stage" where at this stage refers to this stage of development and implementation.

Contrary to Tesla's publishing several occasions where Autopilot has possibly saved lives, there have been concrete incidents where people have died while Autopilot is being used. Tesla has backed away from these incidents with the same hand waving that NHTSA has specifically touched on here: that the user is exceeding the system's design purpose.

In this context ("at this stage"), where consumers have historically and will most likely continue to exceed these systems' design purposes and operate them outside of their intended scope, it seems very clear to me that these systems are inherently dangerous to the public. That is, there is no way to make these systems not a danger to the public in their current form.

The NHTSA are fine with auto-braking - indeed, they want it to be standard on all cars in the future[1]. What they're not OK with is companies marketing glorified cruise control as a self-driving feature. Elon Musk likes to lump his implementation of both under the same "Autopilot" umbrella for PR reasons, but you can have the former without the latter - indeed, I'm pretty sure the most prominent example he gave of the former saving a life was wityh the latter switched off.

[1] http://www.autoblog.com/2016/03/17/nhtsa-iihs-20-automakers-...

Yes. There are a number of federal agencies that are a shit-show at best but I can't remember a time in my adult life when I was disappointed in NHTSA.

The NTSB also does amazing work, though it's the smallest Federal agency (~400 people), which I think probably helps greatly.

NTSB has awesome investigators. Some of the smartest people I've met and worked with in my life. They are very serious and dedicated, while having to put up with a lot of roadblocks, nonsense, and other issues from both corporate America and other government agencies.

Can confirm at least though many years ago, the internal NTSB IT staff/programmers/DB were a joke. I guess that's just government though and like much of government, they relied a lot on outside contractors. For years they were a ColdFusion shop, so I'll let your mind start there.

The fine is only if they fail to provide the requested information by the deadline given. The information requested is not that great and the deadline is entirely reasonable, so the fine is very much not "we want to shut you down," just "we want you to provide this information."

Well, the information requested, if you read the actual definitions, uses a lot of "any" and "all", so if you take that literally it's not exactly an elevator pitch style description they are asking for.

"Describe in detail the features of the comma one"

and

"Provide a detailed description of the conditions under which you believe a vehicle equipped with comma one may operate safely ... [and] a detailed description of the basis for your response to [the previous question] including a description of any testing or analysis..."

and

"Describe in detail any steps you have taken to ensure that the installation of the comma one ... does not have unintended consequences..."

I'm not saying the request is unreasonable, but to say that "the information requested is not that great" isn't really true. To completely answer those questions would take a lot of effort. (Assuming of course that he's done such testing. His canceling the product rather than respond makes you think he realized his answers would not be credible...)

How much is "a lot"? This seems like a couple of engineer-days if it gets down into the dirty details, which isn't huge.

Ironically, if he hasn't done any such testing, the answers would be much easier to generate. "We haven't done any." Not that the NHTSA would take it well....

I could imagine taking a week to do it, and he has 11 days.

I've been involved in writing similar descriptions to provide to NASA, and when you get down to exactly how each module works and need to enumerate every branch, it ends up being a lot of work.

He would have had 11 days to produce something. If he'd wanted to play ball, he could have produced something in the way of a response, then waited for a response to that requesting clarification, then provided more information, etc. I've dealt with similar agencies and often as long as you are being cooperative, the "clock" is fairly easy to reset.

It would appear that he didn't have any interest in cooperating at all, though. Which inevitably leads me to wonder if it's not more of a face-saving maneuver; better to blame failure on the pesky regulators than admit your technology isn't up to the investor pitches you might have made.

I would have assumed that anyone serious about releasing this type of product would have made contact with the relevant government departments and worked with them along the way to ensure they meet the requirements.

Also, the documentation being asked for is something the company should be able to put together fairly easily because they ought to have asked and answered these questions along the way to building the product.

Yeah, determining the requirements of a product you are attempting to produce ought not to be left to the end of design.

Requirements for a product? Sounds too much like a waterfall.

Have you ever considered establishing product direction through use cases branded as "stories" and pulling them out of your ass every two weeks?

These people are too far down the rabbit hole to "get" it :p

The fine is punative. Noncompliance is often not acceptable when it comes to safety and environmental regulations. When I worked in plants, you can bet there were only two groups that would put the fear of God in operations: OSHA and the local environmental regulations agency. Fines could be thousands per hour (or per infraction, which could be collected hourly). Even if it's unreasonable (and for damn sure it can be - Argon metering was my personal worst hated), you better comply until you successfully sue or negotiate it down.

And it is likely necessary. Meeting regulations is far harder and more expensive than just the feel good that you met the reqs. If there wasn't a stick held up as a credible threat, plants would just trash everything. Not because they're evil, but because plants simply can't care - they aren't people. Thusly these agencies are impersonal and brutal in kind.

Not to dispute your point, which I agree with, but --- argon metering? How can that be a safety or environmental hazard? You don't want to lose it overboard because it's expensive, but it's a noble gas, so it should be inert, right? What am I missing?

https://en.wikipedia.org/wiki/Inert_gas_asphyxiation

It can displace air, causing death.

Here's one example of a death, although here they deliberately put the argon in there: http://maritimeaccident.org/2014/08/safespace-argoninert-gas...

True, but so can nitrogen, propane, neon, carbon dioxide, hydrogen and flourine (although you'd need to be pretty unlucky to survive long enough breathing flourine to asphyxiate).

I know argon is denser than air at STP, and so tends to accumulate in enclosed spaces --- but propane is even denser. (Leading cause of catastrophic accident in yachts: gas explosion. It's not like you can have a hole in the bottom to let the gas out in the event of a leak.) And any plant which deals with liquid gasses is going to prioritise ventilation anyway, which should easily deal with any gas buildup.

The parent sounded like there was something specific to do with argon which made the regulators tetchy, and I wouldn't have thought that asphyxiation risk would be enough. Am I wrong?

Propane has a very strong odor added to it (by the propane manufacturers), which means it'll be pretty damn obvious the moment you enter a propane-rich environment.

No, they claim it to be AI. It's in the name.

> That's an obvious part of a government's duty to keep it's citizens safe.

Which article of the Constitution is that? I don't seem to recall it.

The US government is not the only government.

I am not from the US, but they surely have some legislation that makes building and selling killing machines, without at least some government controlled safety checks, illegal.

>killing machines You mean like guns?

In my slightly sarcastic definition "killing machines" are every machine that causes people to die.

I'm surprised you haven't learned yet that the constitution grants authority to congress to pass laws, which include laws related to safety.

> I'm surprised you haven't learned yet that the constitution grants authority to congress to pass laws, which include laws related to safety.

Have you actually read Article I, Section 8? You'll have to squint very, very hard to see any authority to pass laws related to safety in it. That's because it's simply not there. The state governments, of course, do have that power, and the Congress arguably has power to regulate cars used in interstate commerce.

But there's simply no constitutional scope for safety regulation of cars built & used in only one state.

Have you read the NHTSA letter? They talk about prohibiting interstate commerce if the product doesn't meet safety standards.

Instead of nitpicking, let's focus on the actual issue. The NHTSA didn't order Hotz to shut it down, it merely asked about the safety of the product, which led to Hotz shutting it down himself.

You say this in a snide way as if it would be a good thing if governments didn't try to keep us safe.

It also raises the question of what you think the Bill of Right's purpose is.

And this is how "asshole" gets associated with "libertarians". In order to maximize personal freedom, you need property rights and people to enforce those rights. Just because the government's powers have grown well-beyond what's specified in the Constitution doesn't mean it shouldn't have certain powers.

I believe it's in the Preamble:

"We the People of the United States, in Order to form a more perfect Union, establish Justice, insure domestic Tranquility, provide for the common defence, promote the general Welfare, and secure the Blessings of Liberty to ourselves and our Posterity, do ordain and establish this Constitution for the United States of America."

Keeping its citizens safe would likely fall under general welfare.

Correct.

The Preamble doesn't delegate any power from the several states to the United States, though.

The Commerce Clause is often invoked in this type of regulation

You think a threat of $21k fines per day is reasonable. This pretty much guarantees that small businesses can't compete in this market. The financial risk is too high.

If you can't pay 21k in fines, you definitely can't afford the engineering and safety testing required.

$21k per day would add up fast.

That letter was an easy out for him. When you boast about your tech and it doesn't deliver on the promise (and don't forget the Musk challenge), it looks much better if your exit is caused by government interference than if you were to quit on your own. It's kind of less of a failure.

Granted, it's a huge stretch for him based on the language of the letter, but that's how I read the situation.

I think you've nailed it. In his demo video, Hotz said he aims to do 99% of driving. Musk said, "99% is easy, 99.9999% is hard."

It may have been part of the strategy all along. I always found the schedule really aggressive. He announced it with big fanfare in late summer at TC Disrupt with availability end of 2016. I don't think he ever thought that was realistic.

I tweeted a joke yesterday that the Engineering Society had changed it's slogan to 'Move fast and kill people', I'm pretty happy that NHTSA has its feet solidly planted on terra firma and requires a bit of process around releasing something as important as self driving vehicles.

The more software becomes mission critical the more we will need level headedness and quality rather than tantrums.

Not mission critical, rather life critical. I've worked on several life critical systems as a security researcher, helping to develop controls in tightly controlled environments to keep people safe. Work on software controlled switches in industrial machines mostly.

As I've followed these developments and those of Google and Tesla I've been wondering at times if I live in some alternate universe. The level of diligence and care that must go into systems which have the potential to maim an kill are nothing to laugh at. They require serious engineering which takes time. You can find the best and smartest humans on the planet and they'll still fail at building reasonable controls for life critical systems in controlled environments. When you are building these controls for life critical systems which will operate in the diversity of our roadways, honestly the task gets very hard.

I'm not against progress and I do think that self-driving cars are the future. However, it may be wise for those trying to march towards that future at breakneck speeds to take a step back and consider that these systems should first be implemented as backups to humans. Develop the solutions through preemptive braking and accident avoidance where humans are still very much engaged in the driving activities or focus on building expertise in controlled environments. On that note, kudos to Google for doing just that. Their first phase has focused on low speed situations and have been restricted very much to lab work whereby they have paid employee's serving as observers and backup.

i understand where you're coming from, but there is a counter argument to what you're saying, which is that although there may be some dangers to things like the comma one and tesla autopilot, their release may save more lives than they edanger, having a net positive to humans. humans are pretty bad at driving

This is an ends justify the means argument. How many lives have been saved TO DATE with self driving cars? How many lives will be saved IN THE FUTURE with self driving cars?

What is the acceptable casualty rate to get from where we are now to where you think we will be in the future. Is your family an acceptable casualty? If not, then why is mine?

"Is your family an acceptable casualty?" is a pointless question. It can be applied equally well to the opposite argument: what is the acceptable casualty rate for not advancing safety in this way? Is your family an acceptable casualty?

Continuing on with the status quo is just as much of an action and a choice as pushing forward with automation. Both choices are going to get people killed. We can either evaluate the choices and choose the one that seems better, or we can ignore the question and possibly have more people die than is necessary, but there's no option where your family isn't at risk.

This argument is a red herring. We know the current casualty rate and have accepted it. Nobody gets into a car with the illusion that it's 100% safe.

And if technology reduces that casualty rate, why does the fact that it's new suddenly make it unacceptable?

I didn't say that. My question was: what is the casualty rate currently and what is the casualty rate in the self-driving car future? I am asking what you think this reduction actually is and how high of a price you're willing to pay to see that reduction. I am specifically asking what you think the reduction is so that we can have a discussion on 1) whether that is a realistic reduction and 2) whether that is, in turn, worth the price. It has nothing to do with whether or not it's new.

Is that reduction a result of self driving or advances in other safety (airbags, seat-belts, crumple zones)?

It is clear that your mind is already made up and that you are a self driving car evangelist. Please endeavor to approach these debates with an open mind and in good faith.

My mind is made up only because I'm pretty sure the casualty rate will be sharply lower. Humans are horrible at driving.

As for your question, you basically destroyed the conversation when you asked "Is your family an acceptable casualty?" If you just wanted numbers, you shouldn't have made it personal like that. That's all my point is here.

> As for your question, you basically destroyed the conversation when you asked "Is your family an acceptable casualty?" If you just wanted numbers, you shouldn't have made it personal like that. That's all my point is here.

This is a really fair point but I also don't think it's a bad thing to say this. I think people distance themselves from possible problems by calling things a numbers game but they don't factor in the fact that they could be part of those numbers.

If I say that 27000 people per year die from listening to Mambo Number 5 then I say that we can lower that to 15 if we remix it to take out the deadly frequency but we will have to test it on 20 people to find which is the deadly frequency for sure. That sounds great. A couple people might die but what's that to save 27000/year?

Well, take that and say we will have to test it on 20 people and 5 of those will be your family. That makes the decision a lot harder. Logically it's exactly the same but emotionally instead of "people" it's 15 "people" and 5 of your family.

So, it's important to mention it could be your family because if someone was alright with it because they are looking at the pure numbers, they should be brought back to the reality that we all actually live in a little.

I agree with the effects but I disagree with the desirability! We should be making these choices rationally. Taking an action which causes some people to die but saves a more overall is typically a good thing. Asking, "what if it's your family?" just makes it harder to make the correct choice, and that makes it more likely for your family to be a casualty.

I guess this all boils down to what you think of the Trolley Problem. I'm one of those who say, yes, of course you pull the lever if you have no way to save everybody, it's obviously better.

> Continuing on with the status quo is just as much of an action and a choice as pushing forward with automation

Of course, but public perception is, you know... not largely logic-oriented. Whether or not you personally find @abduhl's argument convincing, there's still that emotional hurdle you'd have to clear to convince significant numbers of people to sign up.

Of course. But acknowledging and working with that illogical public understanding of things doesn't mean I can't argue against it when I encounter it online.

I don't necessarily disagree with you but one thing that I think a lot of people are seeing is you are relinquishing control of your car to a computer. When I think of computers I often think of things that I CAN MAKE WORK but that aren't inherently trustworthy. Sure they're great for things like math and stuff but when I try to run a new piece of software I expect crashes and they generally happen. NOT ALL SOFTWARE. But a good bit of first gen software.

So do I really want untested first gen software released without extreme safety standards and heavy testing? No. Do I think the net result of that happening would be a safer driving experience? No. Give me the iOS 9 or so of self driving car software or the unix. Not the Amazon Fire phone.

I totally agree on this. Putting my life in the hands of software makes me nervous. I've seen how software is made. But I do it anyway....

I'm not sure if it's entirely relevant here, since the comment above presumes that these systems are safer than humans, and the reply doesn't seem to be questioning that.

I think it's very likely that these systems will rapidly become far better than human drivers, and probably already are in the domains where they're meant to be used. But we definitely can't just take that on faith and hope it's being done properly.

To estimate your questions, probably no lives have been saved so far through self driving, possibly one extra guy killed in the Telsa crash which you could say was maybe half the systems fault and half the driver not following instructions.

In the future, 1.2m people die a year so say self driving reduces that to 0.2m/year, that's a million lives saved per year.

You family is thousands of times more likely to die in a conventional motor accident than due to a self driving vehicle. If unnecessary red tape slows things down and causes 100k extra deaths is that ok? Even if someone you know is amongst the 100k?

That said there's an argument system like Hotz's should be tested first. That's probably not going to slow things that much.

If unnecessary red tape slows things down and causes 100k extra deaths is that ok?

That's an imaginary scenario. You have no idea if that's the way it plays out. Let me give you another scenario: the first self-driving cars kill a bunch of people, and no one wants to touch them for years after they finally become safe; delaying the adoption of cars, and causing millions of additional people to die.

Very unlikely. Self-driving cars are potentially enormously profitable; with such profitable products I think you'll find that the opinion of an outraged public matters somewhat less than it customarily does.

As a great man once said, "Not taking any action is also an action."

That's even MORE of a reason for the NHTSA to ask these questions. If the first-to-market autopilot system is too dangerous, that will destroy the public's trust in any future autopilot system, no matter how much of a net benefit it provides.

It's like how IUDs (birth control device) are disproportionately unpopular in the United States despite many benefits - all because of one particular brand that caused infections with horrible repercussions:

http://www.motherjones.com/blue-marble/2012/09/why-are-iuds-...

I hate this bullshit argument that 'humans are pretty bad at driving.' Yes there's a wide distribution of driving skill levels, and this is dependent on the cars people drive and their maintenance records. But please don't lump me in the same bag as obviously shitty drivers, of which I've seen scores of.

Google I'm totally cool with. They've been at this a long time and still don't seem very close to actually releasing a product.

I like Tesla's and what Elon's accomplished has been impressive but he seems hellbent on "winning the race" to release a self driving car and that worries me.

It's a good concern to have, but I also worry about waiting too long here. At the end of the day, there's going to be problems that the testing would have never found regardless of how much testing there is, and we need to be psychologically prepared for that.

It took airplanes a long time to become safe (through a long and scary process), and now they're safer than my front porch. Whatever the outcome, self driving cars will very likely be safer than human drivers, and that means more lives are saved than lost, even with the occasional horrific problem. It is entirely plausible that self driving cars are already safer than human ones.

I wish it were possible to buy a Tesla without any autopilot features except basic cruise control, because I know how damnably difficult the edge cases are for a self-driving car, and I'm perfectly capable of driving a car manually, thank you very much. Tesla's cars are so good I'd almost be willing to pay more for one without autopilot.

Almost.

While driving, you have to do a double-pull on the lever to activate the autopilot, a single pull just activates the basic cruise control. So you can still buy one and just never activate it.

Alternatively, earlier editions of Model S shipped without autopilot, which was then sold as an aftermarket upgrade as late as this spring (when autopilot was an optional $2,500 package on a new Model S).

Fair enough re: the older Teslas. As to the new ones, even if I never activate autopilot I'm still driving around in a massive autopilot data collection engine for Tesla Corp, which bugs me.

Reminds me of wanting to buy a TV without all the "smart" stuff. In that situation modularity is preferred by most people with at least minimal tech-inclination. I actually encountered some cases of manufacturers charging more for a lesser, non-smart panel.

A car is a bit more complicated to leave stuff out I am sure and the volumes far different. It would likely require at least more resources to have separate parts of lines for some of that as well as different check procedures as so on. But like you said, paying more could help offset that, though it's a gamble for the manufacturer.

I'm more in the camp of please do not release anything driving a car until you guys can figure out how to secure basic software, keep websites running, parse input properly, and so on. In other words, I'd rather them wait decades if that's what it takes.

Personally, I'd rather be killed by a person rather than a person's dumb choice trusting technology. What concerns me in all these situations is that I did not at any point agree or vote to allow someone in a self-driving car to drive on the same road as me. Until they can mathematically prove 100% it is safe in all conditions and situations, I'm not buying things like "driver assist" if a big part of the justification is that AI is better than a human driver (if so, then why assist?). Others may disagree, so be it - I'm a weird guy. I also hate cruise control. And fat-free ice cream.

This. There is a huge amount of safety evaluations, precautions, training and failsafes we have to go through just for using a Class 4 laser at work in a controlled environment, where the worst possible outcome is permanently blinding someone working with it.

For a machine with the potential to easily maim and kill, to be completely autonomously operated in a chaotic environment where it interacts not just with other computer controlled machines but also with humans, even children, I honestly hope that the amount of safety precautions required will grow very quickly.

I've worked on CNC mills and lathes, design of the logic and the hardware driving the servos as well as some fuel estimation software for airplanes.

The degree of care that went into the e-stop design of the lathe and mill controller and the number of checks and tests of the fuel estimation software are stuff that I'm (hopefully justified) proud of, that's not stuff to cut any corners with. In both cases that took me longer than Hotz claims to have spent on creating the whole self driving car code, there is no way you can do this safely with that mentality. It is absolutely irresponsible to take that attitude towards systems like this, life is not a video game with 3 more lives if you lose this one (or cause others to lose theirs).

If 10,000 people were killed on the way to making driverless cars safe, and this wild west approach ended up getting them into mass market use a few years earlier, it would save the lives of thousands of people overall.

Is this a bad thing? Is it not justified by utilitarianism?

That would kill the driverless car concept.

See, we already have cars, it's not like we're going from 'horses and buggies' to cars, it is going from one good solution to an even better one and even though there is a risk at being stuck at the present local maximum for a little longer going down in order to find the peak of this particular mount improbable would not be an acceptable path for the majority of the public.

And without having a time machine or a functional crystal ball you won't know if it is 10K, 100K or a few million people that get killed before you get it right so the bar has been set at 'it needs to be better than the present level before it is acceptable'.

> If 10,000 people were killed on the way to making driverless cars safe, and this wild west approach ended up getting them into mass market use a few years earlier, it would save the lives of thousands of people overall.

This is a perfect example of the biggest and IMO most compelling critique of utilitarianism -- namely, that it's too susceptible to bullshitting.

People decide what they want to do, then completely invent (or, in more sophisticated cases, carefully fabricate) numbers and time-frames in order to hide their unethical opportunism behind the facade of objective moral assessment.

This is especially problematic when you have to estimate things that are pretty much impossible to estimate without completely bullshitting. For example, "number of people killed by not following certain safety standards", or "impact on time-to-completing of some particular safety standard". We're talking about a novel technology, so there's no way anyone has even remotely high confidence in a sufficiently bounded estimate of these numbers. It's all just bullshitting.

> Is thus a bad thing? Is it not justified by utilitarianism?

These are two VERY different questions.

Lots of things are susceptible to misuse. That doesn't invalidate them unless they are in fact misused.

Moreover I don't see how you can conclude on a whim what's possible to estimate and what is not. Given these things take expertise in the relevant field and more than just casual analysis.

Finally, it's not like there is a small margin of error. Can you even really comprehend 30,000 deaths every single year caused by conventional cars and drivers? This is fricking 9/11 times ten happening every year, and you're not even willing to consider that speeding up r&d might save a few lives?

I would absolutely consider speeding up R&D to save that number of lives. I'm 100% behind self-driving cars. I think self-driving cars will eventually reduce the number of road deaths significantly.

I don't think the case has been made yet that today's tech will reduce the number of road deaths. I don't think it's unreasonable to be skeptical of the claim "this works great, trust me".

I'm very skeptical from no-name nobodys like Hotz running comma-ai and very non-skeptical of companies like Tesla.

> Moreover I don't see how you can conclude on a whim what's possible to estimate and what is not

Yes, exactly. Like in so many cases, coming up with good values for the parameters is often the most difficult part of the analysis... that was exactly my point!

> Given these things take expertise in the relevant field and more than just casual analysis.

Except in this case, there are a lot of experts, and they all seem to be taking roughly the same approach.

> Finally, it's not like there is a small margin of error

It's not clear to me, at this point, what your assumptions even are. What percentage of those deaths would be prevented by self-driving technology? How many new types of accidents would be caused by self-driving technology? By what percentage would that number decrease if the regulatory environment were more friendly? And what's your basis for these numbers?

Also, it's perhaps telling that there really hasn't been a single example of regulators preventing self-driving up until this one, which is rather extreme. Google, Uber, and the scattering of startups and car companies have all taken a more cautious road to deployment of entirely their own making.

> and you're not even willing to consider that speeding up r&d might save a few lives?

There's a big difference between speeding up r&d and rushing unproven tech to market.

So what do you propose as a guiding principle in place of utilitarianism?

Your scenario would save lives, but we have no way of knowing if we are in that scenario.

If you know that after ten thousand deaths, the technology will be good enough to start saving more lives every year, then your utilitarian argument works. The problem is that you can't possibly ever know that in advance. It's equally plausible that the last 0.001% will take decades to solve, or even remain out of reach indefinitely. Then you just threw away ten thousand lives for nothing.

This is why the burden of proof needs to be on the new system, and why the precautionary principle applies.

Have you considered your desire for process in context of the Trolly problem? https://en.wikipedia.org/wiki/Trolley_problem

In other words, is it acceptable to move fast, knowing it will cause deaths, if we could be certain the net lives saved would be greater?

I think it's fair for a regulatory agency to ask a company to at least count how many people are on either track before releasing their product.

I'm happy NHTSA is getting involved and regulating this, however the skeptic in me wonders if they're doing it for purely altruistic reasons or if the big software players in the industry are essentially lobbying for it to help them with the regulatory capture side. Apparently thats all the rage these days, position your business so as to make competition illegal or as financially cumbersome as you possibly can.

> I'm pretty happy that NHTSA has its feet solidly planted on terra firm

Makes sense, since they regulate the activity that is the 4th largest cause of death in the US.

Holtz's Twitter rant is at [1].

Cruise Automation was very lucky to be acquired by GM before they got a similar letter. Similarly, Otto being acquired by Uber. They were both proposing to sell similar add-on systems. Their valuations would have been much lower after receiving such letters.

NHTSA has it right. "It is insufficient to assert, as you do, that 'your product does not remove any of the driver responsibilities from the task of driving'. As you are undoubtedly aware, there is a high likelihood that some drivers will use your product in a manner that exceeds its intended purpose."

Did Tesla got a similar letter? They have exactly that problem and exactly the same excuse. Tesla claims “Autopilot is an assist feature. You need to maintain control and responsibility of your vehicle.”

Here are three dashcam videos of Teslas crashing on autopilot. These are the three where there was a stopped vehicle partially blocking the left edge of the lane, and the Tesla plowed right into it. Tesla blames the driver. Looks like the NHTSA isn't buying that.

[1] https://twitter.com/comma_ai [2] https://www.youtube.com/watch?v=rJ7vqAUJdbE [3] https://www.youtube.com/watch?v=xoSNw_n1Xgk [4] https://www.youtube.com/watch?v=qQkx-4pFjus

> Did Tesla got a similar letter?

Did Mercedes? Did Volvo? They have the same systems in place in production vehicles.

Mercedes even advertised their vehicles as autonomous.

http://blog.caranddriver.com/mercedes-benz-pulls-e-class-ad-...

> Here are three dashcam videos of Teslas crashing on autopilot.

Glad you had the opportunity to bash Tesla.

Yeah, they probably didn't - because large auto companies have time and resources devoted to safety and compliance.

And bribery

Bribery to overlook certain numbers and results perhaps, but I think it'd be a unlikely to hear that the NHTSA just completely skipped on all regulatory checks entirely, which is what geohot wants.

I meant it more in the sense of bribery to get the regulators to squeeze the little guys as they always do. Big companies love regulation because it kills their competition and lets them progress at their glacial and expensive pace.

If bribery was an option would VW have gone to such lengths to hide true emissions rather than slipping someone a backhander?

> Did Tesla got a similar letter? They have exactly that problem and exactly the same excuse.

Is it the same problem? One is an aftermarket kit vs being built-in to the car.

Tesla probably has a dozen people whose sole job is to interact with NHTSA.

Tesla does, and there has been some back and forth of personnel employment between NHTSA and Tesla as well as both have seemingly intentionally poached from each other.

Doesn't really surprise me. I mean, where else do we expect NHTSA to get people qualified to regulate self-driving cars from? I'd rather they came from industry than just not have any background at all.

Academia? where they have for many years gotten a lot of the expertise to write regulations (in all parts of government). There are tons of industry experts invovlved in these processes...but don't assume that NHTSA has no experts in this, Tesla didn't invent the self driving car, they just sold it. Research on it has been going on since the 80s and much of the delay came down to legal rather than technical issue in years past.

Are you sure that they didn't get similar letters? If Tesla or others got a letter like this they wouldn't have publicized it, they would've just actually answered it. There's no way in my mind that Tesla didn't talk to regulators about their stuff at all.

Also, Tesla likely has many dozens of millions of drive miles into validating their perception and control models. Comma.ai does not.

The level of rigor Tesla has applied to this problem, as cavalier as it may seem at times in the news, is many, many times that which was applied to what Comma.ai is building.

Tesla's mode == aggressive, but diligent.

Comma's mode == aggressive, and flippant.

I wrote the below less than 12 hours ago for another post still currently on the front page and it is just as appropriate here with the simple change of a company name. The arrogance of our industry seems to be growing.

>One of the biggest flaws of the tech industry is the belief that being a tech expert is enough to disrupt other industries in which they don't have any expertise. Sometimes they get lucky and it works despite something like Uber's or Airbnb's total ignorance of the law. Sometimes it fails like with numerous cryptocurrency companies relearning why the finance industry has so many dang regulations. Seems like comma.ai is falling in the latter camp.

There's still time for AirBnB and Uber to fall in the latter camp. Some have more runway than others.

Come on... Hotz doesn't really represent anyone but George Hotz. He is a very unique individual that was blessed with a very mathematical mind but very little social grace.

Sure, but every individual is part of a pattern, and our outgroup is becoming more convinced that there's one pattern in particular at play here.

Take a look at the front page of Hacker News right now: in addition to this story, there's "Soylent halts sales of its powder as customers keep getting sick" and "Uber drivers win employee rights case" (presumably over Uber's fierce opposition). With 30 items on the front page, that means we've got 10% of the news in our field which could plausibly be parsed by outsiders as "technolibertarian assholes". I've been watching public opinion of the Bay Area startup scene gradually eroding in the last half-decade or so, and this is a big part of the reason; it's a real problem that we need to start thinking about.

I don't think this can be fixed. Silicon Valley thinks its the solution, when its more the problem. You can't drastically disrupt major pieces of the economy, expect to keep large swaths of the pie for yourself, and having no safety net, those who used to have jobs end up disenfranchised and permanently economically disadvantaged.

It's the exact same thing as the banking crisis, only with a bit of a techno sauce. See, if it works then they'll make bank, if it doesn't society will pick up the cost.

It's a bet without much of a downside.

Privatize the profits, socialize the failures.

It's not just outsiders who take this view.

I was hoping you'd show up in this thread ;)

It's definitely not just outsiders as you (and I) can attest; I went with that line of argument to try and convey some sense of urgency about the problem. It's easy to dismiss internal dissent about SV libertarian groupthink as not important, but "outsiders" have the potential to bring the party to an end if they collectively get really grumpy about what we're doing. I thought that might be more motivation.

Unfortunately for all of us, this will likely continue until people get killed in large enough numbers for some common sense to prevail.

Here's something I always wonder about humans; Why is it only groupthink when you disagree with it?

And we've now, at the behest of these companies, redefined statists down to:

- thinks it's OK for neighbors and local government to have a say in whether people run a hotel next door, possibly sharing a roof or even a wall

- thinks it's OK to require pretty reasonable background checks ala Austin for taxi drivers

- thinks it's OK to have some safety regulations around self driving cars sharing our roads beyond hey, it worked in my car on this specific stretch of road so, you know, yolo

Congratulations, by waiting a year to implement self driving cars, through overly burdening government regulations, you just killed ten thousand people.

What about those people? The people who WILL die in car accidents next year unless we do something about it. Screw them, right?

This isn't a self-driving car. It's a driver assist. It depends on an alert driver behind the wheel. What we're learning is that these systems can, in some circumstances, be the worst of both worlds --- a human driver lulled into complacency by technology that was not designed to handle complicated road conditions autonomously --- a system that itself generates both human and machine error.

There's an interesting similarity with Air France 447 in your description -- a crash caused by information overload and the normal assist system going into an alternate mode.

Noone is arguing about the benefits of self-driving technology in general.

The question at hand is: Does this specific piece of equipment actually work as described, and move us towards that goal, or is it a piece of cobbled together junk that will cause more accidents? If you want to sell this specific piece of equipment on the consumer market, you'd better have a good answer to that question, and be able to back it up with more than "hey, it worked for me this morning!"

my god, idlewords couldn't have written this better

How about just not caring on "correcting" people's impressions of our culture? It seems like it's a challenge any way, probably because it's a fool's errand. Yeah a lot of people who are brilliant don't give af, why get suckered into believing this is a bad thing? In fact, you don't have to have an opinion about it.

It has definitely been a noticeable problem much earlier than that, my guess probably a half-decade after the dot com bubble burst. I was in school at Palo Alto Senior High School and I gradually began to notice really offensive trends in the way "silicon valley people" acted. When I left school the damage was already done. I remember one of the last examples I saw before college was in a Facebook group called "humans of Palo Alto" (which I objected to from the start), there was a picture of two men in nice clothing holding cardboard signs that said "need venture capital money". Their quote was "you know the Drake song 'started from the bottom now we're here'? Well, that's about us"

The Uber lawsuit doesn't fit in that pattern. Cab companies are also being used over the same issue[1], since drivers were always considered contractors. Uber followed the established model there, it's not an example of SV arrogance.

[1] http://articles.chicagotribune.com/2014-03-26/news/chi-suit-...

He's a good hacker but he's not particularly mathematical...

But when startup and engineer community praises him and puts him on a pedestal, doesn't it say something about them (us) as well?

I don't think we should be proud of a country that scares genius away.

Wow, thank you for posting the document. That seems like an incredibly reasonable response compared to what I'd expect from a US gov organization. They're basically ensuring he's done due diligence that the product he's selling isn't going to kill/harm people... I found the whole thing extremely polite and reasonable.

Since he hasn't done the due diligence he's throwing a fit. Sigh... Looks like self-driving isn't something that can be accomplished Today without a good amount of resources.

I can't believe the nerve of some of these Silicon Valley randroids. If they're so great, why do they think a little bit of regulation is going to kill them?

At a guess the list of questions showed Hotz just how far away he really was from having a shippable product and since the 'fun' bit was over it caused him to throw in the towel. Prototyping stuff and proof of concepts are fun, productizing much less so. Moving to China will not really change that.

And, the list of requests in the special order are not ridiculous at all. They are a bunch of basic questions that I would hope someone making driver-assist hardware would be able to answer.

I second that. Having worked with blockchain companies, I have seen much scarier letters than this and if the blockchain messes up no one dies.[1]

[1] At least not as a direct cause/effect relationship.

The first three roughly boil down to "please send us a copy of the manual".

Which is something he should have in a pretty much finished form if he's about to release a product.

Is this a joke? If not, you clearly didn't read the letter; it's more than "a little regulation", it's a huge set of requests on an unreasonably short timeline.

With regard to the more general point of your post, even if it's nominally possible to eke out a profit under overburdening regulation, you're still allowed to take a principled stand against it.

The timeline is not unreasonable at all.

They were planning to ship by the end of the year -- obviously the regulator should get involved before it's in the hands of users.

I've seen requests from regulators before. If you don't have or can't produce exactly what they asked, you call them up and tell them some parts will take longer. The point is to have a dialogue; the threat of sanctions is just to make sure you work with them.

Two weeks is not reasonable for the demands made in the letter. That, plus a $21,000/day penalty, is a clear "fuck you".

Two weeks are totally reasonable. If you intend to sell the thing in less than two months, that information should already be ready

Why would you have all the random crap the NHTSA demanded ready to go if this wasn't a pre-existing regulation?

What's random about it? It's basically:

- What's in the installation + operating manual? - Items 1-3

- Is it safe? Did you do testing? How? Items 4-6

- What vehicles does it work on? What happens if you screw up during installation? Items 7-8

- What happens if an owner screws up and puts in an unsupported car? Item 9

- Did you think about whether this keeps the car compliant with other safety regulations? In particular, did you think about the legality of blocking/removing the mirror? Did you do testing? Items 10-12

- When are you selling/shipping it? Items 13-14

- Anything else you want us to know? Item 15

Every single item is a completely reasonable question to ask. I'd certainly hope comma.ai knew the answer to each of these questions before they sold it to the public.

Again, if 2 weeks wasn't enough time, then negotiate with them and give them what you have. Threats of daily fines are often boilerplate that get tacked on to ensure that people take the request seriously; I'd challenge anyone to find an example where the regulatee cooperated with the regulator in good faith and still got fined for not responding.

#10-12 is gg. Removing the mirror for your device? Wat?

The requested things are pre-existing regulation requirements, simply worded with leading questions to prevent unnecessary back-and-forth.

For one of many examples, public information seems to show that his device affects the rear view mirror in a manner that violates specific pre-existing regulations, they ask him how does it affect the rear view mirror and how does it comply with those regulations.

There are only two reasonable responses for such a question - (a) he submits the evidence he has (and had before receiving that letter!) that his product is compliant with these regulations; or (b) he acknowledges that right now he cannot demonstrate that the product is safe and will not sell the product.

For such devices, documentary evidence (including testing results, and all other "random crap" requested) is an integral component of the device - if you don't have all this done, attempting to sell the product is prohibited. That is pre-existing regulation.

There's no $21,000/day penalty. That's the statutory maximum possible. If NHTSA wants to fine Hotz they would have to propose a fine, let him respond with a defense, and then convince a court that it is the most reasonable solution to impose the fine amount recommended. There's no way on earth it would come to anything like $21,000/day.

It's an unreasonably short timeline if you're a bakery owner. Not when you're about to release a driver-assist hardware. He should have most of the required documents and information already prepared, or else he really has no business being anywhere near car hardware.

He chose the launch date without making sure he was legal first.

I think this is the most sane, non-politicized way of stating what happened here. You can speculate as to the motives of the regulator (short timeframe, high costs, certain friends), but the fact of the matter is this was a major flaw in his plan which he didn't see coming.

[edit] unless his real plan was to go to China all along...

Do I have to check with every relevant government agency for permission every time I do something? If an endeavor not specifically outlawed, it should be presumed legal.

If the endeavor is selling a product for use in a highly regulated industry where the failure case is death, then of course you have to work with regulatory agencies. It's not like the automotive industry is a mysterious minefield hidden in uncharted territory.

If he couldn't answer these very basic questions 2 months away from shipping these things, WTF is he even doing. If he hadn't proactively initiated communications with NHTSA long before now, WTF is he even doing. These are all excruciatingly, painfully obvious things to do, and the fact that it never occurred to him to do them brings into question his judgement about pretty much everything, from technical issues to basic life choices. At this point I don't think I'd trust this guy to mow my lawn, much less develop autonomous vehicle software. His reaction to all of this and how he deals with adversity is just as revealing about his competence as everything he's done so far.

> WTF is he even doing

Trying to innovate without being encumbered by the glacial pace of government regulatory bodies?

His refusal to put up with the NHTSA is an indicator of a low tolerance for bullshit, not incompetence.

His particular endeavour is specifically outlawed (e.g. blocking the rear view mirror). The NHTSA is simply trying to establish whether or not he complies with the existing regulations - clearly, he doesn't.

Wat. If you intend to sell it as a product. Yes. Yes you do.

Double so if it's a product that is very likely to kill its owner.

And square all that, if your products is either used every day or can cause large amount of death, accidentally.

If you read the letter, it's a lot more than "answering a few questions".

He gets two weeks to provide an enormous amount of detailed information about the product, I assume under threat of legal consequences if any of it contains an error, interspersed with lots of reminders that they can and will close down his business if they feel like it.

Yeah it seems a lot of the community here thinks that if he just threw together a few bullet points in an email response the NHTSA would sit back, say "Okay, great have fun!" and not, you know, make a big deal out of it. I, uh, disagree.

I more thinking "why the hell doesn't he have the answers already?"

This, it's not a secret that NHSTA is interested in self-driving cars and would be asking the serious questions that he should already have responses for.

Having mentioned this elsewhere, I have first-hand experience going between SMEs and X/Y/Z bureaucratic entities for half a decade and there's a big difference between "having the answers you think are satisfactory" and "providing answers that they think are satisfactory." GI Joe pointed this out long ago in that "Knowing is half the battle" and putting it into a work product that accomplishes its task is the other half of the battle in this case (with no guarantees the responses provided will end the inquiry / threat of fines).

That doesn't really answer the question. You don't need first-hand experience to know that government red tape is onerous. It was flatly predictable that the NHTSA -- the government agency concerned with roadway safety -- would make such inquiries. So why didn't Comma work with the NHTSA and get their blessing before announcing a release date?

I mean yeah, it sucks that the government is so darn picky about things, but that's not an excuse to just skip the process. They should have hired someone like you from the start to ensure that their ducks were in a row when they were ready to release.

We'll never know, because he's not even trying.

Here's a nicely readable transcript of what they wanted:

https://news.ycombinator.com/item?id=12817061

None of them sound particularly difficult to answer. Maybe they are difficult to answer in sufficient detail to satisfy the NHTSA, but you can always start out by answering them as best you can, and then seeing if they want more. There are people on the other end of this letter, not some unthinking machine. Toss off a quick response and say, "If you have any other questions or need further detail on the answers given here, please feel free to contact me at any time."

If he gave them the docs he certainly has on this stuff, and said "i am glad to sit down and walk you through any other answers or questions you may have", they'd be fine with it as an initial response.

I think you have pretty much already assigned a negative agenda to NHTSA, when they've just requested some info.

While they may have followups if they don't like the answers they get, of all the agencies you find, NHTSA is not one that tends to have a serious pre-bias towards anyone.

Yeah, the extremely short timeline here combined with excessive fines puts this squarely in "F-You" territory.

I agree that the fines are set at a level more appropriate for a large corporation, but I looked at the questions, and they're all things I would want to know as a customer, and I would expect for them to mostly already know (e.g. "What weather conditions have you tested this in?").

There's only one question which could be considered too broad, which is compliance with safety standards, but it's generously worded as a yes or no question. He could simply answer "no, I haven't analyzed my product against against the safety standards".

As others have pointed out, the short timeline is mainly due to Hotz himself and his plan for putting the product on the market so quickly.

They specifically state in the instructions "If you are unable to respond because you do not have all or any of the precise information needed to respond, provide an estimate." This would imply that they are willing to postpone the fine given that he is actually putting together the required documentation. The required documentation is not even excessive, he should know most of that stuff off hand and should definitely have documentation for it if he's planning a release this year.

I don't see a problem with that. In fact, I want government regulators to do that. He should have anticipated this process, and been working with them since the beginning.

With that kind of talk, only those "well connected" can readily do that.

Hmm. Regulatory capture? Yeah. That.

If by 'well-connected', you mean people who have the means and resources to properly test their products, then I agree.

"Product" ? I'm seeing a demo he wasn't selling.

And when a big govt stick comes a'knocking, unless you're also big and well connected, you will get shut down.

This was clear as a way to "do insane amount of documentation in a laughably short timeframe, or fuck your business with a fine-stick."

Yeah, GeoHotz is an ass, but this is inane. Great way to kill small businesses.

So what would you have the regulator do here--wait until the product is on the market first?

He's publicly stated they were aiming for year-end release.

That may be what he stated. I can say that I plan to launch pigs from a catapult tomorrow. Doesn't make it true.

I would understand filing that documentation prior to selling. But I'm also familiar with using "Filing with govt" as a tool of oppression that large companies try to pass as a barrier of market entry. Lawyers are rather expensive, and requiring more volumnous paperwork requires more lawyers.

And speaking of that, what is the repercussions of what you send to NHTSA? Say he sends something inaccurate or glosses over details. What is the liability of sending something wrong to govt? Hmm...

Yes. Wait till he's selling them. And when there's a claim, act on it. Not before.

One problem with that model is that if the product ends up being unsafe and someone dies, it becomes the regulator's fault that they failed to prevent an unsafe product from being marketed and sold in the first place. Heads will roll.

We as a democratic society decided awhile ago that the benefit of knowing a car product was probably safe outweighs the frictional burden of testing them before they can be sold.

There's a lot of insinuation here that the regulator is actively trying to kill his product, but no evidence. This seems like a run-of-the-mill request, one that the NHTSA probably sends out thousands of times a year to various automakers and auto parts suppliers.

As a counterpoint, I'm sure Tesla has gotten these letters as well, but the NHTSA didn't prevent them from putting AutoPilot on the market.

> what is the repercussions of what you send to NHTSA? Say he sends something inaccurate or glosses over details.

The letter specifically says that estimates are ok. There's nothing wrong with telling the regulator 'We're not sure yet, give us a month to figure it out please?'.

If that was true, then they could have left off the "or else, pay $21k/day for noncompliance". I've seen plenty of big-companies use forced compliance to kill smaller and more agile upstarts.

I remember the tactics used to kill most butcheries and local meat shops. Same games, with onerous and idiotic requirements of "compliance" that the big guys can do. Of course, the big companies got legislation to enforce their standing.

This is not opening a dialogue, this is a shakedown to kill a product.

The $21k is standard regulatory boilerplate and simply notes the maximum statutory rate.[1] If the NHTSA really wanted his company dead, they'd have already gone to a judge to get an injunction to shut him down.

Yes, regulatory capture exists, and incumbents often benefit from it. But I'm having trouble seeing how this particular case is a 'shake down' -- the NHTSA is simply asking him to follow the law, which he should be doing anyway.

[1] https://www.federalregister.gov/documents/2016/03/01/2016-04...

When he kills a bunch of people in China, you're going to feel silly about having made this comment.

Guy can't navigate the regulatory environment in the US, goes to China ... this is the setup for a joke.

So it's ok for people to die because a business couldn't be bothered to test if their product passed the most basic of safety criteria? Because that's what you're saying.

Yes, being "well connected" is critical to working with regulatory agencies. A minimum of 56 kbps is recommended.

Seriously, with agencies like the FAA, FCC, EPA, FDA, NHTSA, etc. you can just call them up and you will be connected to a regulator who can help you with every step of getting your product past regulatory requirements. The Small Business Administration also has a lot of people dedicated to helping entrepreneurs with regulatory oversight.

> He gets two weeks to provide an enormous amount of detailed information about the product

Which either he should have readily available, since he's the creator, or he should have known, since he should be able to demonstrate the safety of the device.

> I assume under threat of legal consequences if any of it contains an error

Usually you hand over what you have, then you negotiate with the regulator for a time frame to answer the more difficult questions. If you're unsure about something, tell the regulator up front.

The correct response is not to throw a tantrum and shut everything down.

> interspersed with lots of reminders that they can and will close down his business if they feel like it

That's the textbook definition of 'regulation'.

> > they can and will close down his business if they feel like it

> That's the textbook definition of 'regulation'.

Right, and it's one of the big problems I have with this form of regulation.

I think it violates the idea of "Rule of Law", as opposed to "Rule of Man", which was one of the major factors behind the rise of modern free society.

Can you explain? You seem to be implying that you believe that the NHTSA is capriciously making demands of Comma but not to other similar companies in a similar stage of market-readiness.

They certainly could, which is part of my point. Whether they do or not depends on the honesty, bias, and personal ambitions of the people running the agency.

The empirical experience is that regulatory agencies over time gravitate towards favoring the big established players in the industry they're regulating.

The economist term is "Regulatory Capture".

> honesty, bias, and personal ambitions of the people

As long it's humans that write and execute laws, this is strictly unavoidable. It doesn't depend on the particular details of how we do regulation.

Under Rule of Law, one set of humans write the laws. If you break them another set of humans decide on your guilt and punishment.

Set 1 (legislators) can and do write laws to favor and disfavor individual actors, and I agree that that is in part unavoidable.

Set 2 (judges and juries) are appointed randomly after it's become a legal matter, so it's impossible for any inappropriate influence in either direction before that.

And there is no "set 3" of regulators that issue orders during the day-to-day running of the business.

So I think you're right that this problem always exist, but in my estimation it's a few orders of magnitude bigger under a "Rule of Man" regulation scheme.

> no "set 3" of regulators that issue orders during the day-to-day running of the business

You mentioned 2 branches of government, the legislative and judicial. But the third branch, the executive, does (in part) exactly what you described above.

Taken to the logical extreme, your view means we should replace every government adminstrator with a court, including for mundane decisions like whether to grant a marriage license. That system would be horribly inefficient and probably not much more consistent or effective since random people off the street won't have the domain knowledge a regulator has.

Also, regulators are representatives of the people and are subject to laws just like everyone else. The escape hatch of the legal system is always available -- if you think the regulator got it wrong, then take it to a court, and a judge and jury decides who is right.

The marriage license argument is textbook strawman. That is not regulation of an industry, and you know it.

I agree, but you proposed a stringent definition for 'Rule of Law' that seemed to eliminate the possibility of government regulators possessing independent decision-making authority over citizens and businesses alike.

I mean, how do even mundane things like zoning codes and work permits work in this universe where there are no regulators and gov't bureaucrats? Everything must go through a court? Why are you so sure a group of 12 random people will come to decisions more effectively than a bureaucrat in a domain that requires specialized knowledge?

In any case, I fully agree that sometimes regulators, or regulations are bad. But this particular case is an example of regulation working as designed. The NHTSA has been at the forefront of working with the self-driving car industry to make sure there is a legal path to developing, testing, and releasing this tech. Textbook example of regulators doing their job without imposing undue burdens on the regulated industry.

> how do even mundane things [...] work in this universe where there are no regulators and gov't bureaucrats?

I talked about regulators. You added bureaucrats on your own.

Perhaps NHTSA is a great organization. I know nothing about them specifically. I'm talking about general principles.

> Why are you so sure a group of 12 random people will come to decisions more effectively than a bureaucrat in a domain that requires specialized knowledge?

I'm saying they'll be more impartial. Don't know about effective.

You seem to be critiquing the idea of a government run by people and the idea that congress can defer rule making authority to people more educated in the particulars of an industry than the congress at large.

I'm fine with government run by people.

Giving some people a lot of discretionary power of others does worry me a lot. It might well be unavoidable sometimes, but it's really naive to not see the potential for abuse.

The calculation needs to be "if this agency is run by the usual corruptible and imperfect people like you and me, will it be a net gain for society?", rather than the "assume a selfless set of civic minded experts..." mindset I think a lot of people have.

Not quite. Regulatory capture doesn't mean you like the big companies, it means you like the industry you regulate. So if you regulate coal mines, you probably think coal mines are good, whether they're large or small. If you're a highway regulator, it probably means you think highways are pretty awesome, but that doesn't mean you think only Detroit muscle cars should be allowed on the highway.

I disagree.

One of the common ways this works is that the regulator keeps adding more and more complex regulations.

It's counterintuitive that a major company welcomes or instigates added regulations that will cost $20M/year to comply with. But since that makes it more expensive to start competing companies, they can make a lot more money from their increasingly secure oligopoly position.

How do you think regulations get enforced?

> The correct response is not to throw a tantrum and shut everything down.

I think the correct response is to work with them 110%. Having that government body happy with you isn't a bad thing - you could become the reference spec for self-driving if you please them to an appropriate degree.

He's got two weeks to provide the detailed information he should already have or a reason why he doesn't have it. He could even provide an estimate (see instruction #4 in the Special Order). The threat of legal consequences is if any information/reason is missing or if the order is completely ignored. Getting your company shut down by the government only comes after a lot of back and forth communication and is usually due to willful negligence on the company's part.

This is why lawyers exist, and the job they are trained to do. A competent one would have told Hotz on Day 1 that this letter was coming, and would already have the documents ready in a folder with a little pink ribbon bow.

Considering the gravity of what they're building, they should already have detailed answers to all these questions. They shouldn't have launched a startup without spending massive time and effort ironing out these details. Two weeks is plenty of time to organize your thoughts.

If he doesn't already know the answers to these questions, he's got no business selling this product. Everything that they're asking for—essentially the owner's manual, product requirements, and test methodology—would be readily at hand for any serious operation.

You can't just wire up an Arduino to the CAN bus of a 4,000-pound missile and sell it on the open market willy-nilly.

"You can't just wire up an Arduino to the CAN bus of a 4,000-pound missile and sell it on the open market"

best self-driving comment ever.

He has announced the release of the product, was taking orders for it and said it was going to be shipping by the end of the year [1]

The timeframe here is driven by Hotz who apparently has not had any communication with the relevant regulatory agencies. Any attorney he hires would tell him "Okay lets push back the release to mid next year while we work with the NHTSA on resolving their concerns" and the NHTSA would probably be perfectly fine with working with him.

"Move fast and break shit" doesn't count when you're putting lives at risk.

lots of reminders that they can and will close down his business if they feel like it - yes and they should.

[1] https://electrek.co/2016/09/14/comma-ai-claims-to-have-packa...

First of all, he's not being asked for an "enormous amount of detailed information". He's being asked some really simple questions about how his product complies with existing regulatory requirements. Which apparently, it doesn't. Worse still, by abandoning the product he's made it clear that he had no intention of complying with existing regulations and has an astounding disregard for his customer's safety.

completely agree man. I'm pretty positive his organization failed to reach out to the NHTSA for product approval and now he's upset that they recommend pulling the product before it is tested in their VRTC facility in Washington. [1]

[1] http://www.nhtsa.gov/Research/Vehicle-Research-&-Testing-(VR...

> He's currently throwing a temper tantrum on Twitter

He said the NHTSA made "no attempt at a dialog". What does he call that letter? Ridiculous.

I agree. I love how he thinks NHTSA should take a test drive. This is delusional thinking. It's going to be nearly impossible for an SV startup to create aftermarket parts for automobiles because the US dept of transportation is not interested in beta releases. Him being known as an "iphone hacker" probably doesn't help his cause. One accident induced bug could cripple the driver and startup. Sure, SV loves disruption, but the US dept isn't delusional.

The problem is that they (Silicon Valley) think the reason their startups move so fast is that they are some sort of new meritocracy, and that other industries move slowly because they're held back by a "good old boys' club" mentality.

The truth is that rapid advancements in software development happen because most software has a failure rate which would be considered appalling in any real engineering discipline.

Yeah because his tech probably can't do 1/5 of what hes claimed it can and the NHSTA would've found that out almost immediately.

this all a pr move by andreeseen/horowitz to pump all their holdings in companies doing selfdriving tech. they prolly knew he'd never succeed.

jus odd to throw in the towel after the gov comes knockin esp after a $3 mil investment like these investors are smart are we honestly supposed to believe they didn't know this was going to happen

eh or maybe $3mil ain't nothing and they's jus threw it at him because jus maybe he could do it if not it's a win win

probably both.

Did he delete all of his tweets? Just found his verified account and it's empty.

https://twitter.com/comma_ai

I've been trying to convince myself that it's possible that some day people won't be tribalistic assholes constantly playing us v. them in situations that don't need it at all, and posts like yours leave me sad and shaking my head knowing it's way, way in the future.

Sure, but now he left from China. It's our lost not his.

Why does he have to answer that. It's just research for now?

Wasn't he just soliciting beta testers on Twitter? That doesn't sound like "research".

Beta testers on the road with self driving cars amongst unsuspecting regular drivers, what could possibly go wrong?

My read on this tweet[0], retweeted by Comma.ai, is that they will be shipping an actual product by the end of the year, so I could see why the NHTSA would want answers before then.

[0] https://twitter.com/anakkurt/status/785677337819947008

It's the government that's stifling innovation by burying it with so called regulations to the benefit of the monolithic automotive industry.

His follow up tweets imply he's moving on to China, since they're less likely to be a major hamper of innovation.

And we wonder why the United States' influence is in decline...

For once this really isn't that. I've watched the whole 'comma' saga with some amazement that he'd actually take out his barely ready for closed road testing pile of cobbled together stuff out on a public road.

Really, this sort of thing should be done in a much more controlled environment before pulling the trigger on releasing it on the unsuspecting public.

Read the bloomberg article and be amazed.

> China [...] less likely to be a major hamper of innovation

Another way to look at it: western foreigner looks to beta test a product with the lives of Chinese citizens. I'm not sure how well that's going to go over.

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