At a recent public comment hearing before the California Department of Motor Vehicles, numerous car manufacturers and tech firms urged the state to ease proposed regulations for the testing of autonomous vehicles, or AVs. Some even went as far as to suggest that such rule-making be left solely to the National Highway Traffic Safety Administration.

However, some safety and consumer groups, as well as city governments, pushed for a more cautious and local approach. The dozens of filings to the DMV, made as part of the public comment period, were only made available on Friday.

One of the more interesting proposals came from the San Francisco Municipal Transportation Agency, which oversees the city's public transit infrastructure. In its nine-page letter, the MTA noted that autonomous vehicles must be able to navigate "pedestrians, buses, cable cars, bicyclists, and trucks" and that there be "maximum transparency" with private companies that wish to deploy autonomous cars. To that end, San Francisco wants local police to be able to access, without a warrant, "the autonomous technology data and/or video recordings... immediately... in the event of a collision."

Tilly Chang, the agency’s executive director, wrote:

In addition to addressing interactions following a collision, the requirements need also define how law enforcement officers will interact with vehicles in situations such as parking and traffic violations, and ensure all AV operation enables and supports that interaction. San Francisco also suggests that the requirement for the manufacturer to review and update the law enforcement interaction plan "on a regular basis" is not specific enough.

Paul Scullion, a manager with the Association of Global Automakers, wanted California to get out of the autonomous-car regulations business and cede that responsibility entirely to NHTSA.

"Our concern is that if each state were to impose [its] own regulatory regime [that it] would delay the deployment of lifesaving technology," he said during the April 25 hearing in Sacramento, California. "The current approach remains problematic."

Scullion's trade group, in written comments, argued that:

Dealers and eventually consumers could face a circumstance where they cannot sell or operate certain AVs in California even though they are perfectly legal in other states. Similarly, given the broad definition of "deployment," which is discussed in more detail below, a consumer from outside California could be prevented from crossing the state border in an automated vehicle that was legally purchased in another state.

Tesla, for its part, took issue with several of the state's suggested provisions, including a ban on "the sale of a production, non-autonomous vehicle on the basis of previous use as an autonomous test vehicle."

"This prohibition appears to have been written without consideration for vehicles that were used as autonomous test vehicles but contain only production hardware and, once loaded with production software, are indistinguishable from production vehicles," Matthew Schwall, Tesla’s director of field performance engineering, wrote in the company's six-page letter to the DMV.

He argued:

This is the case with many Tesla autonomous test vehicles. Because current Tesla vehicles come standard with the sensing and computational hardware necessary for full self-driving capability, Tesla only has to load software on the vehicles in order to make them capable of autonomous testing. Tesla can then return the vehicles to production condition by re-loading production software.

But, Schwall continued, if such a Tesla vehicle was tested on California public roads, the company would be unable to resell that vehicle. If the DMV were to go forward with this rule, Schwall concluded, it would "incentivize Tesla and other auto manufacturers in the same situation to invest AV testing resources outside of California."

Uber, for its part, pushed the agency to allow customers to pay for autonomously driven test rides, which the proposed regulations as currently written insist should be free.

Meanwhile, the Automobile Club of Southern California suggested that during this initial testing phase, there be a required rule that a human in the car be able to intervene and take over driving.