I’ve spent the past decade building and managing teams that operate prototype self-driving cars and trucks at several companies, and I now head vehicle operations at Pronto. Some of you may have read the email I sent several Uber executives last year, which was recently in the media. In that email, I voiced concerns with Uber ATG’s testing practices and offered suggestions for improvement. Two days after I left the company, an Uber test vehicle fatally hit a pedestrian. I’m writing again to hopefully elevate the safety conversation in our industry and to offer suggestions on how I think we can do better.

We drive too many miles, which puts lots of people at risk

In the early days of self-driving vehicles, we thought that more time on the road meant greater progress and likelihood of success. ‘‘Total miles driven” became an important metric for judging progress, and unfortunately it remains a central theme to this day. Companies deploy hundreds of prototypes to collect low value miles, but don’t seem able to make use of the collected data. In reality, total miles driven is a leading indicator of how likely a self-driving vehicle program is to cause injury or property damage. The unjustified focus on “total miles driven” puts pedestrians and the motoring public at risk and undermines a real safety conversation. High quality miles are what we need, not countless vehicles driving for the sake of driving. Self-driving prototypes should only be deployed on a limited basis; safety claims should not be anchored to the absolute number of miles driven or simulated; and companies that drive many miles on public roads should be open to routine and unannounced, independent, third party safety audits based on total miles driven.

And so we injure too many people

Source: My calculations are based on; i) the SHRP 2 dataset, which controls for unreported crashes in the general driver population, ii) the 2017 and 2018 California DMV disengagement reports for self-driving tests, and iii) the DMV crash reports (from which we have excluded crashes with no damage and some one-off instances such as golf balls hitting a car). Crashes classified as “injury” are “SHRP — Level 1” accidents, while “property damage only” “SHRP — Level 2 and 3.”

Taken as a whole, companies that have registered with the California DMV for AV test permits are involved in more injury crashes and product damage-only crashes than the average driver. In 2017 and 2018, prototype self-driving cars were involved in over 100 incidents in California alone, most of which were in autonomous mode. This is insane considering most autonomous vehicle testing occurs outside of California. I want to underscore that an industry built on road safety potential, with professional safety drivers behind the wheel (whose job is to ensure the safe operation of a vehicle), is somehow ending up in crashes more frequently than average drivers in regular vehicles. The reason this is not widely known is because our industry masks the data instead of implementing practical safety solutions.

But — when we get into crashes, we point fingers at others

Self-driving programs should focus on preventability rather than at-fault collisions. The further implication is that AVs drive well, but human drivers crash into them. Generally, self-driving vehicles with safety drivers do a good job at avoiding collisions where they would be found at-fault. However, they are significantly worse at avoiding crashes that should be preventable. This is because self-driving technology has not advanced enough and safety drivers don’t intervene early enough.

Safety theater causes real problems

The miles per disengagement metric is a bad metric for measuring progress and is not meaningful in terms of safety. Companies inflate their miles per disengagement to appear further along and use their own absurd definitions of what a disengagement is — effectively erasing thousands of safety-related disengages. Companies that report their disengages honestly appear much further behind. Furthermore, this metric incentivize safety drivers to not disengage in unsafe situations.

Relying on the wrong metrics or not looking at real data has unfortunately propelled us into the realm of safety theater — meaning creating the illusion of safety instead of actually delivering on safety. This type of safety rhetoric is more harmful than helpful. For example, NHTSA provides an appropriate forum with its voluntary safety assessments, but companies misuse this well-intentioned process as a public relations tactic to submit glossy safety brochures with little substance. Companies should take these reports seriously and report on real safety efforts by showing that if they are driving many miles, their collision rates are better than human drivers. They should also be able to justify the number of miles driven, not just proudly declare that they have been driven. Autonomous vehicle companies have a responsibility to speak up about efforts they are making to address safety.

In addition, proclamations by AV executives that fall into the categories of general safety platitudes, mixed with bogus disengagement numbers, and brashly optimistic product launch dates create the perception that prototype vehicles are safer and further along than they actually are. Such statements are dangerous because they create an environment at some companies that they must win a race to autonomy or else close their doors. This thinking wrongly motivates companies to deploy hundreds of test vehicles prematurely and at the expense of safety. It is important that we have real conversations about the current capabilities of the technology and how far it still has to go.

So why Pronto?

Given my concerns with safety in my industry, some may ask why I’m working at Pronto and, specifically, with Anthony Levandowski, who has dealt with a lot of criticism with regards to safety. I’ve worked with Anthony for a long time and I know that some of Anthony’s comments and actions on safety have been taken out of context or were inaccurately portrayed. All that being said, I do not think that Anthony has gotten everything right with respect to AV safety. He has made mistakes and said brash things. But, Anthony is someone who is always looking to improve himself. What I value most about him on safety is that he doesn’t resort to safety theater. He is committed to getting AV safety right. All of us at Pronto are. At the end of the day the only way to improve road way safety is to deliver a safe product. Anthony and Pronto are on schedule to launch a Level 2 system which will make the trucking industry safer. And that is why I am excited to be at Pronto.