"Very easy rider: Google plans robotic motorbike." That's the title of an article in the U.K.'s Sunday Times from last week. As far as we know, Google isn't planning anything of the sort. What the Times was talking about were some comments by Ron Medford, the Director of Safety for Google's Self-Driving Car Program, about California's recently adopted Regulations for Testing of Autonomous Vehicles by Manufacturers. Google wasn't the only one to make comments on the regulations, either, and we'll take a look at a few of the more contentious ones.
So here's how this all started. Late last year, the California Department of Motor Vehicles asked for public comment on its proposed autonomous vehicle testing regulations. A bunch of interesting people contributed to try to influence the regulations, including Google's Ron Medford, who is a former deputy director of the U.S. National Highway Traffic Safety Administration. Medford sent the DMV an email and also showed up to a public hearing.
One of the major issues that Medford (and others) had were with the section defining vehicles specifically excluded from autonomous testing on public roads. These included all kinds of trailers, motorcycles, vehicles with interstate operating authority, and vehicles weighing more than 10,001 pounds. Those last two refer to commercial vehicles, like trucks. Google didn't like this restriction, and neither did some of the other commenters on the regulations:
Although Google is not currently testing any of these vehicles excluded under this section, we believe that the section should be deleted in its entirety, as any such exclusion unnecessarily restricts future innovation. It is certainly possible that future testing could include motorcycles or larger commercial vehicles. If some innovator can demonstrate that testing autonomous technology on such vehicles is safe, then they should be allowed to test. The DMV should not preemptively foreclose potential avenues of an evolving technology, but should instead review every testing permit application on its own merits.
—Ron Medford, Director of Safety, Self-Driving Car Program, Google
The prohibition on the testing of commercial vehicles should be removed. If DMV has safety concerns with respect to testing commercial vehicles it should specify additional regulatory requirements applicable to these vehicles.
—Nicole Barranco, Director of State Government Relations, Volkswagen Group of America
The regulations should allow the testing of buses. Inclusion of buses would create jobs in the 36th Assembly district.
—Steve Fox, Assembly Member, 36th District
The California DMV's response is as follows:
The Department believes that the testing of commercial vehicles on public roads involves safety, driver training, and driver qualification issues that should be addressed by a separate rulemaking proceeding.
The DMV doesn't seem to be against commercial vehicles (or motorcycles) necessarily, they're just saying that it takes some different skills to drive these vehicles, so if people want to start making autonomous ones, the regulations may have to be a bit different as well.
The motorcycles thing is fun to think about, but commercial vehicles with the potential for autonomy are much more important. And arguably, they'd be easier to implement from a technological standpoint, since they tend to travel on well-defined routes between the same places over and over again. This is even more true with buses, although the human interaction aspect might be tricky.
The other big issue that many different commenters (mostly manufacturers) had with the regulations were the requirements for accident reporting and that "disengagements of autonomous mode" be reported to the DMV (in addition to any accidents that happen). Nobody was against reporting accidents, but Google and others only wanted to have to report accidents when the car was driving autonomously. The DMV was having none of it, so all accidents (whether a human was in control or not) are going to be reported. Also, the DMV wanted a detailed record of every time a human had to take over from the system, which both Volkswagen and Google objected to:
The Department should require reporting only of those instances of “disengagement of the autonomous mode” that were unplanned or unexpected. Other instances of disengagement that are routine or expected given the state of the prototype automated driving system under test need not be reported.
—Anthony Cooke, Volkswagen Group of America
Disengagement does not provide an effective measure of vehicle safety. Disengagement during testing is a normal part of the testing process. Test drivers will feel pressure to reduce the number of disengagements.
—Ron Medford, Director of Safety, Self-Driving Car Program, Google
This time, the DMV agreed:
The Department has modified the regulation to require the reporting of disengagements when there is a failure of the autonomous technology or the driver determines that the safe operation of vehicle requires the immediate disengagement of the technology. In both of these instances the continued safe operation of the vehicle requires that the autonomous technology be disengaged. The purpose of allowing testing is to ensure that the eventual operation of the vehicles by the public is safe. Obtaining information about when the safe operation of the vehicle requires the deactivation of the autonomous technology is essential to determining whether it is safe for the public at large to operate the vehicles.
In other words, as long as a human doesn't have to take over because the autonomous system screwed up somehow, it's fine.
This last comment on one is interesting by itself, from Subaru:
Third parties should not be allowed to retrofit vehicles with autonomous technology; the definition of manufacturer should be limited to vehicle manufacturers.
—John Frooshani, Safety Activities Manager, Subaru of America
This would make things very, very difficult for startups like Cruise, and we'd like there to be an option for third parties to challenge the automotive industry by bringing something to market faster. Fortunately, this is also too restrictive for the DMV, who is willing to include retrofitters in its definition of "manufacturer":
This suggestion is inconsistent with the definition of “manufacturer” in Vehicle Code section 38750(a)(5) which specifically includes parties that modify a vehicle by “installing autonomous technology to convert it to an autonomous vehicle after the vehicle was originally manufactured.”
Reading through all of these comments (they're public, you're welcome to have a look yourself), you get the sense that the DMV did a reasonably good job at listening to what people had to say, taking those criticisms and opinions into account, and ending up with a regulatory framework that has a shot at being as effective as it needs to be to maintain safety without needlessly stifling innovation.
We're optimistic that testing regulations will happen for commercial vehicles (and motorcycles, for what it's worth) if there's enough interest from manufacturers. This whole autonomous vehicle business seems frustratingly slow for those of us who are more focused on the technology, but considering the state of, you know, government, we've actually made a lot of progress.
Much of this can be attributed to the fact that autonomous cars are already being tested on public roads and that the DMV has no choice but to catch up, and we expect to start seeing a similar thing happen with the FAA and UAVs. If this pace of progress in robotics keeps up, the government is going to get dragged into the present whether it likes it or not.