During a federal public hearing, autonomous vehicle makers voiced recommendations for the structure and content that should be required in a safety assessment letter required for each highly autonomous vehicle system.
Technology often outpaces our ability as a society to come up with accepted norms of how it can be used. This no doubt has rung true for autonomous vehicles.
While Google has been logging miles in its own autonomous vehicles for more than half a decade, the National Highway Traffic Safety Administration (NHTSA) just released its regulations for highly automated vehicles (HAVs) in September 2016.
Included in the document are issues of crash liability, regulatory language and how to approach distracted driving. It also lays out what responsibilities the states will have while outlining the role the U.S. Department of Transportation (U.S. DOT) and the rest of the federal government will play.
What has brought about considerable feedback was the provision for vehicle manufacturers to voluntarily submit a safety assessment letter to the U.S. DOT’s Office of the Chief Counsel for each HAV system. The policy lists 15 points that should be considered and "checked off" before any public implementation of the technology.
Federal Safety Self-Checklist
The policy is currently issued as guidance, and is “not intended for states to codify as legal requirements for the development, design, manufacture, testing and operation of automated vehicles.” During a public hearing on the policy on Nov. 10, representatives mostly from vehicle manufacturers voiced recommendations for the structure and content that should be required in the letter.
Overall three main recommendations surfaced:
Perhaps the greatest barrier to innovation is the unknown element of future regulations that could be imposed. Without knowing all of the rules in their final form, questions remain about how fast tests can be enacted and how long the application process would take. In many ways, companies are suppressed by the lack of regulations. Once guidelines are set, that allows for the real exploration and pushing the technology beyond current limits.
In the current draft of the letter, the policy states that each section be explained and signed off by an appropriate authority on the subject. This could lead to having 15 different people sign off the same document, which some argue is an unnecessary amount of regulatory hassle.
“We think the letter should be signed by one official who has authority over all of the areas rather than having separate signatures,” said Dan Smith from the Google Self-Driving Car Project, noting that by requiring only one signature, the process will move much more smoothly and allow the industry to grow unfettered.
The policy states that a data-recording and data-sharing policy should be worked out with relevant standards-creating bodies in order to hasten the process of deployment. This is because sharing data will help manufacturers understand mistakes made by other developers and reduce mistake duplication.
“We would suggest that NHTSA creates a dedicated microsite [a separate site or area within your site with targeted content for a specific purpose] that allows sharing,” said Ford's Curt Magleby. “The site and exchange of information should be simple and straightforward.”
This comment was echoed by several attendees concerned over the loss of confidential business information and trade secrets.
The overall consensus voiced by the group was to make the safety assessment letter's regulations as simple as possible, while still ensuring safety standards. Trying to balance the line of pushing innovation while creating appropriate safety guidelines is every party’s goal.
Several representatives called for a one-page literal check sheet, while others requested the list have a brief explanation for each point. One popular suggestion was for a simple checklist to be submitted, and NHTSA could then request as much information as needed.
Another point vocalized by the group was to require a low threshold as to when a new letter would need to be issued. In the policy, manufacturers would be required, “to submit a new safety assessment letter to the agency when any significant update to a vehicle or HAV system is made.”
Representatives argued that nearly every time a vehicle is tested, some form of code is tweaked — and issuing a new letter after each tweak would be illogical.
“Only if an SAE level [of autonomous vehicle] is changed should manufacturers be required to send a new letter,” argued the Toyota Research Institute's Kevin Ro.
And for Google's Smith, “We think simplicity is key,” he said. “The basic point of the letter will be to contain enough sufficient information that the agency and any reader can be able to determine whether the processes are reasonably addressed in each area.”