California Hearings

Wednesday, California held hearings on the latest draft of their regulations. The new regulations heavily incorporate the new NHTSA guidelines released last month, and now incorporate language on the testing and deployment of unmanned vehicles.

The earlier regulations caused consternation because they correctly identified that nobody had sufficient understanding of unmanned vehicle operations to write regulations, but incorrectly proceeded to forbid those vehicles until later. Once you ban something, it's very hard to un-ban it. The new approach does not ban the vehicles, but attempts instead to write regulations for them that are too premature.

Comment from developers of the vehicles reflected sentiment that all the regulations are premature. California worked together with NHTSA on their regulations, and incorporated them. In particular, while NHTSA's regulations lay out a 15 point list of functional domains that creators of vehicles should certify, the federal regulations technically declare this certification to be optional. A vendor in submitting a report can explicitly state they decline to certify most of the items.

California suggests that this certification might be mandatory here. For all my criticism of NHTSA's plan, they do have an understanding that it is still far too early to be writing detailed rules for vehicles that don't yet exist, and left these avenues for change and disagreement within their regulations. The avenues are not great -- I feel that vendors will be concerned that truly treating the regulations as voluntary will will be done at their peril -- but at least they exist.

Several vendors also pointed out the serious problems with traditional regulatory timelines and the speed of development of computer technologies. The California regulations may require that a car be tested for a year before it is deployed. On the surface that sounds normal by old standards, but the reality of development is very different. Pretty much all the vendors I know are producing new builds of their vehicle software and testing them out on the roads the next day -- with trained safety drivers behind the wheel. The software goes through extensive "regression testing," running through every tricky situation the team has encountered anywhere, as well as simulated situations, but the safety driver is there to deal with any problem not found with that testing.

Vendors won't release into production cars with only one night of testing, but neither can they wait a year. This is particularly true because in the early days of this technology, new problems will be found during deployment, and you want to get the fixes out on the road as quickly as is safe to do. An arbitrary timeline makes no sense.

This is just the start of the problems. While one may argue that it was always going to be hard for startups and tinkerers to develop these cars, these regulations (and the federal ones) put more nails in the coffin of the small innovator. The amount of bureaucracy, the size of the insurance bonds and many other factors will make it hard for teams the size of the DARPA challenge teams who kickstarted this technology and make it real to actually play in the game. The auto industry has a long history of allowing tinkerers to innovate, even at the cost of relaxing safety requirements applied to them. We may end up with a world where only the big players can play at all, and we know that this is generally not good at all for the pace of innovation.

Delivery Robots

The new regulations allowing unmanned vehicles might seem to open doors for delivery robots like we're working on at Starship. Unfortunately they seem aimed primarily at large vehicles. Since California rules define the sidewalk as part of the street, these regulations might end up demanding a small, slow, light delivery robot still comply with the bulky Federal Motor Vehicle Safety Standards (which are meant for passenger cars) and is impossible without major exceptions being made. (More reading is needed to tell if this is truly how this will play out.)

Tesla says all future cars will have full sensor suite

Tesla has declared that all their future cars, including the lower cost Model 3, will include the full suite of radars, cameras and other sensors needed for self driving. That's good news, though the Tesla sensor suite, lacking LIDAR, is not currently sufficient for a full self-driving car. Tesla is making a bet of sorts that by the time this becomes in play, cameras and radars will be sufficient to make an acceptably safe system. If not, they will have to stick with autopilot function on those cars. Since there is strong evidence that LIDAR will be inexpensive in a couple of years, I don't believe anybody should plan to deploy their first (and riskiest) robocars without every sensor that's at all affordable. Why make it less safe than you could just to save a few hundred dollars?

Today, Tesla can't do that because no production low cost LIDAR is available. Most other teams are betting it will be. In the future, when cost becomes a bigger issue, vendors will decide to eliminate sensors based on cost.

Apple might have changed their plans

Apple hasn't said anything official about their rumoured car project. All we know has come from leaks and from looking at who has been hired or who has departed. (I do know one secret thing about the Apple car -- it will only work if you have a new iPhone.) Many rumours came out this week that Apple may have cancelled plans to actually make an Apple Car, and instead will take an approach more like Google -- building the software and self-driving systems and letting others worry about car manufacture. That is a good strategy, so Apple is hardly out of the game, but it does mean it's less likely the world will see a car with the particular Apple flair and marketing genius.

The relationship between powerful self-drive system developers (like Apple, Google and Uber) and car manufacturers will be an interesting one. Car makers are used to being in charge, owning the process and owning the customer. So are these hi-tech companies. But many companies will do "contract manufacturing" in auto. If Apple shows up with a purchase order for 100,000 cars to be built to their spec, there are many companies who will take the order, even if the high end Daimlers and Toyotas of the world won't. So just as Apple doesn't build the iPhone and gets Foxconn to do it, the fact that Apple will stick to the software systems doesn't mean their design will not appear in a car.

Here is a summary of Apple car rumours.