Highlights:
* The manufacturer has in place and has provided the department with evidence of the manufacturer’s ability to respond to a judgment or judgments for damages for personal injury, death, or property damage arising from collisions or accidents caused by the autonomous vehicles produced by the manufacturer in the form of an instrument of insurance, or a surety bond... That's the key condition. If it crashes, the manufacturer is financially responsible and has to carry insurance or post a bond, just like human drivers.
* The manufacturer shall identify any commonly-occurring or restricted conditions, including but not limited to: snow, fog, black ice, wet road surfaces, construction zones, and geo-fencing by location or road type, under which the vehicles are incapable of operating in the autonomous mode and certify that the vehicles are incapable of operating in autonomous mode under those conditions. Reasonable enough.
* The manufacturer shall certify in the application that the subject autonomous vehicles are equipped with an autonomous technology data recorder that captures and stores autonomous technology sensor data for all vehicle functions that are controlled by the autonomous technology at least 30 seconds before and at least 5 seconds after or until the vehicle comes to a complete stop after a collision That's like the air bag data recorder cars have now, but more comprehensive.
* Certification that the vehicle complies with the “Vehicle Performance Guidance for Automated Vehicles” in the National Highway Traffic Safety Administration’s Federal Automated Vehicles Policy This is the national policy.[2] It's not very restrictive; it's mostly self-certification. This is where there's a big distinction between NHTSA levels 1 (basic auto-brake) and 2 (auto-brake plus lane keeping), and levels 3 and above. Basic concept: at levels 1 and 2, the driver must pay attention and systems must not let the driver stop paying attention. This is the "hands on the wheel" requirement. At level 3 and above, the driver doesn't need to pay attention in autonomous mode, and if anything goes wrong, the manufacturer is responsible.
* The national requirements require a "safety assessment letter" from the manufacturer to the NHTSA answering questions in a few key areas:
Data Recording and Sharing
Privacy
System Safety
Vehicle Cybersecurity
Human Machine Interface
Crashworthiness
Consumer Education and Training
Registration and Certification
Post-Crash Behavior
Federal, State and Local Laws
Ethical Considerations
Operational Design Domain
Object and Event Detection and Response
Fall Back (Minimal Risk Condition)
Validation Methods
* DMV reserves the right to revoke the self-driving license of a system that drives badly.
Passing certification gets a sticker for each car, like the stickers for low-emissions vehicles.
All this is far less restrictive than what's required for light aircraft.
Tesla needs to qualify for a license. Time to put up or shut up.
[1] https://www.dmv.ca.gov/portal/wcm/connect/211897ae-c58a-4f28... [2] https://one.nhtsa.gov/nhtsa/av/av-policy.html