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Comment by logfromblammo | Hacker News Reader

Wow. I guess the first thing I'd do is file a FOIA request to see any Special Orders they may have sent to Apple, Uber, Google, Tesla, GM, Ford, Mercedes Benz, Volkswagen, Audi, Nissan, Toyota, BMW, and Volvo, and for copies of any documentation received from those companies that would be responsive to the demands in their own order or the order to comma.ai . Then I'd also request an extension in the time to respond until such time as the documents responsive to the FOIA request have been produced and read.

It would be so much easier to respond if you could just do exactly the same thing that the larger players did.

Unless, of course, those other companies didn't have to produce any such documentation. In that case, clearly, every last company working on autonomous vehicle functions would have to receive a substantially similar order, post haste. We wouldn't want anyone crying about selective enforcement, after all.

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Something tells me that serious companies involved in this space never received any Special Orders because they reached out to and worked with the NHTSA from the start, rather than trying to fly under the radar and then being shocked! Shocked! When the government actually noticed them.

This seems to make sense, given how I'm in the past few years starting to realize how things actually work in the world..

Why do that when you could just get the information directly from the NHTSA [1]? I expect all those companies have been in communication with regulators from the beginning and produced plenty of documentation. Besides, they can't do the same thing the large players did since they aren't in control of developing the entire vehicle.

[1] http://www.nhtsa.gov/nhtsa/av/av-policy.html

I read a bit of that, and it looks like the document you linked does not support the threat to fine $21k/day for not responding to the Special Order.

There is quite a lot of "voluntary" in there, along with "future regulation". I would guess that a lot of the voluntary safety assessment letters they get essentially say, "this is not entirely safe in absolute terms, but is definitely safer than an inattentive human driver."

How is that going to help him? You think the odds are that a company like Nissan has less documentation than he has?

Also: secret commercial information is exempt from FOIA.

1. Look at what they did to satisfy the regulators. 2. Respond in as similar a manner as possible.

The commercial info is not necessary. They need to learn and follow the forms and protocols, and at least pretend to to be respectful when kissing the ring. If GeoHotz ran a restaurant, I wouldn't want him to be the one talking to the health inspector, either. He has the wrong personality for it. You really want the schmooziest suck-up in the company to do that stuff.

I fully expect that all the companies with compliance departments have reams and bales of responsive documentation. As comma.ai appears to be clueless with respect to regulators, the more sample material that they can look at to crib the correct answers, the less likely it is that regulators would summarily drop the axe rather than try to work with them in a reasonable manner.

"Kissing the ring"? They want his test documents, not his fealty.

They want his compliance, or his $21k/day. The document is all stick and no carrot. And it is a big, federal regulatory agency stick. I think "kissing the ring" applies.

You also they often have very common procedures for these types of letters, right? Usually brought on by court cases, etc. For example:

http://www.fda.gov/ICECI/ComplianceManuals/RegulatoryProcedu...

They also generally warn of fines ahead of time, because otherwise they get people arguing due process.

Seriously, this is not that uncommon. Note the fine warnings in all of these special orders:

http://www.documentcloud.org/documents/1349845-n-h-t-s-a-spe...

https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&c...

http://www.safercar.gov/staticfiles/safercar/recalls/Special...

http://www.autosafety.org/sites/default/files/imce_staff_upl...

etc

It would be so much easier to respond if you could just do exactly the same thing that the larger players did.

The FOIA route is appealing because it feeds into a sense of perceived indignation.

But the most important thing to copy from the large players is never going to be spelled out in their submissions.

I'll let everyone in this thread in on the secret: hire someone that specializes in quality management systems.

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