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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 peopl
by gavman 10y ago
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.
- hartator 10y agoI 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.
- gavman 10y agoBy "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
- xiphias 10y agoActually 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.
- robotresearcher 10y ago$21K per day. Four months to consume $3M entirely.
- takno 10y agoThe fine was up to $21k per day subject to a maximum of $105k
- chowwesley 10y agoActually, the maximum is $105MM.
- abduhl 10y ago"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.
- erikpukinskis 10y agoProof 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?
- TeMPOraL 10y agoIt'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.
- lutorm 10y agoWell, humans have absurdly stupid corner cases during actual use, too. It depends on how small the corner is, I think.
- thfuran 10y agoYes and humans require certification before they are permitted to drive vehicles on public roadways.
- strathmeyer 10y agoTo get that certification, do they test you first, or do they wait for you to screw up and then take it away from you??
- mikeash 10y agoThe 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."
- lutorm 10y agoWell, 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...)
- mikeash 10y agoHow 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....
- lutorm 10y agoI 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.
- HCIdivision17 10y agoThe 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.
- david-given 10y agoNot 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?
- DanBC 10y agohttps://en.wikipedia.org/wiki/Inert_gas_asphyxiation 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-fatality/ http://maritimeaccident.org/2014/08/safespace-argoninert-gas...
- david-given 10y agoTrue, 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?
- dilemma 10y agoNo, they claim it to be AI. It's in the name.
- zeveb 10y ago> 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.
- celticninja 10y agoThe US government is not the only government.
- deleted 10y ago[deleted]
- chme 10y agoI 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.
- scblock 10y agoI'm surprised you haven't learned yet that the constitution grants authority to congress to pass laws, which include laws related to safety.
- zeveb 10y ago> 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.
- jcoffland 10y agoYou 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.