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.
When people vote, what do they think it will accomplish? How does this affect how they vote, and how should it?
My apologies for more of this in a season when our social media are overwhelmed with politics, but in a lot of the postings I see about voting plans, I see different implicit views on just what the purpose of voting is. The main focus will be on the vote for US President.
The vast majority of people will vote in non-contested states. The logic is different in the "swing" states where all the campaign attention is.
I had hoped I was done ranting about our obsession with what robocars will do in no-win "who do I hit?" situations, but this week, even Barack Obama in his interview with Wired opined on the issue, prompted by my friend Joi Ito from the MIT Media Lab. (The Media Lab recently ran a misleading exercise asking people to pretend they were a self-driving car deciding who to run over.)
The social networks have access (or more to the point can give their users access) to an unprecedented trove of information on political views and activities. Could this make a radical difference in affecting who actually shows up to vote, and thus decide the outcome of elections?
I've written before about how the biggest factor in US elections is the power of GOTV - Get Out the Vote. US Electoral turnout is so low -- about 60% in Presidential elections and 40% in off-year -- that the winner is determined by which side is able to convince more of their weak supporters to actually show up and vote. All those political ads you see are not going to make a Democrat vote Republican or vice versa, they are going to scare a weak supporter to actually show up. It's much cheaper, in terms of votes per dollar (or volunteer hour) to bring in these weak supporters than it is to swing a swing voter.
The US voter turnout numbers are among the worst in the wealthy world. Much of this is blamed on the fact the US, unlike most other countries, has voter registration; effectively 2 step voting. Voter registration was originally implemented in the USA as a form of vote suppression, and it's stuck with the country ever since. In almost all other countries, some agency is responsible for preparing a list of citizens and giving it to each polling place. There are people working to change that, but for now it's the reality. Registration is about 75%, Presidential voting about 60%. (Turnout of registered voters is around 80%)
Scary negative ads are one thing, but one of the most powerful GOTV forces is social pressure. Republicans used this well under Karl Rove, working to make social groups like churches create peer pressure to vote. But let's look at the sort of data sites like Facebook have or could have access to:
Of course, for the social site to aggregate and use this data for its own purposes would be a gross violation of many important privacy principles. But social networks don't actually do (too many) things; instead they provide tools for their users to do things. As such, while Facebook should not attempt to detect and use political data about its users, it could give tools to its users that let them select subsets of their friends, based only on information that those friends overtly shared. On Facebook, you can enter the query, "My friends who like Donald Trump" and it will show you that list. They could also let you ask "My Friends who match me politically" if they wanted to provide that capability.Now imagine more complex queries aimed specifically at GOTV, such as: "My friends who match me politically but are not scored as likely to vote" or "My friends who match me politically and are not registered to vote." Possibly adding "Sorted by the closeness of our connection" which is something they already score.
After my initial reactions and Overall Analysis here is a point by point consideration of second set of elements from NHTSA's 15 point certification list for robocars. See my series for other articles or the first half of the list.
In this section, the remind vendors they still need to meet the same standards as regular cars do. We are not ready to start removing heavy passive safety systems just because the vehicles get in fewer crashes. In the future we might want to change that, as those systems can be 1/3 of the weight of a vehicle.
They also note that different seating configurations (like rear facing seats) need to protect as well. It's already the case that rear facing seats will likely be better in forward collisions. Face-to-face seating may present some challenges in this environment, as it is less clear how to deploy the airbags. Taxis in London often feature face-to-face seating, though that is less common in the USA. Will this be possible under these regulations?
The rules also call for unmanned vehicles to absorb energy like existing vehicles. I don't know if this is a requirement on unusual vehicle design for regular cars or not. (If it were, it would have prohibited SUVs with their high bodies that can cause a bad impact with a low-body sports-car.)
This seems like another mild goal, but we don't want a world where you can't ride in a taxi unless you are certified as having taking a training course. Especially if it's one for which you have very little to do. These rules are written more for people buying a car (for whom training can make sense) than those just planning to be a passenger.
This section imagines labels for drivers. It's pretty silly and not very practical. Is a car going to have a sticker saying "This car can drive itself on Elm St. south of Pine, or on highway 101 except in Gilroy?" There should be another way, not labels, that this is communicated, especially because it will change all the time.
This set is fairly reasonable -- it requires a process describing what you do to a vehicle after a crash before it goes back into service.
This section calls for a detailed plan on how to assure compliance with all the laws. Interestingly, it also asks for a plan on how the vehicle will violate laws that human drivers sometimes violate. This is one of the areas where regulatory effort is necessary, because strictly cars are not allowed to violate the law -- doing things like crossing the double-yellow line to pass a car blocking your path.
After my initial reactions and Overall Analysis here is a point by point consideration of the elements from NHTSA's 15 point certification list for robocars. See also the second half and the whole series
Let's dig in:
These regulations require a plan about how the vehicle keep logs around any incident (while following privacy rules.) This is something everybody already does -- in fact they keep logs of everything for now -- since they want to debug any problems they encounter. NHTSA wants the logs to be available to NHTSA for crash investigation.
NHTSA also wants recordings of positive events (the system avoided a problem.)
Most interesting is a requirement for a data sharing plan. NHTSA wants companies to share their logs with their competitors in the event of incidents and important non-incidents, like near misses or detection of difficult objects.
This is perhaps the most interesting element of the plan, but it has seen some resistance from vendors. And it is indeed something that might not happen at scale without regulation. Many teams will consider their set of test data to be part of their crown jewels. Such test data is only gathered by spending many millions of dollars to send drivers out on the roads, or by convincing customers or others to voluntarily supervise while their cars gather test data, as Tesla has done. A large part of the head-start that leaders have in this field is the amount of different road situations they have been able to expose their vehicles to.
Recordings of mundane driving activity are less exciting and will be easier to gather. Real world incidents are rare and gold for testing. The sharing is not as golden, because each vehicle will have different sensors, located in different places, so it will not be easy to adapt logs from one vehicle directly to another. While a vehicle system can play its own raw logs back directly to see how it performs in the same situation, other vehicles won't readily do that.
Instead this offers the ability to build something that all vendors want and need, and the world needs, which is a high quality simulator where cars can be tested against real world recordings and entirely synthetic events. The data sharing requirement will allow the input of all these situations into the simulator, so every car can test how it would have performed. This simulation will mostly be at the "post perception level" where the car has (roughly) identified all the things on the road and is figuring out what to do with them, but some simulation could be done at lower levels.
These data logs and simulator scenarios will create what is known as a regression test suite. You test your car in all the situations, and every time you modify the software, you test that your modifications didn't break something that used to work. It's an essential tool.
In the history of software, there have been shared public test suites (often sourced from academia) and private ones that are closely guarded. For some time, I have proposed that it might be very useful if there were a a public and open source simulator environment which all teams could contribute scenarios to, but I always expected most contributions would come from academics and the open source community. Without this rule, the teams with the most test miles under their belts might be less willing to contribute.
Such a simulator would help all teams and level the playing field. It would allow small innovators to even build and test prototype ideas entirely in simulator, with very low cost and zero risk compared to building it in physical hardware.
This is a great example of where NHTSA could use its money rather than its regulatory power to improve safety, by funding the development of such test tools. In fact, if done open source, the agencies and academic institutions of the world could fund a global one. (This would face opposition from companies hoping to sell test tools, but there will still be openings for proprietary test tools.)
This section demands a privacy policy. I'm not against that, though of course the history of privacy policies is not a great one. They mostly involve people clicking "I agree" to things they don't read. More important is the requirement that vendors be thinking about privacy.
The requirement for user choice is an interesting one, and it conflicts with the logging requirements. People are wary of technology that will betray them in court. Of course, as long as the car is not a hybrid car that mixes human driving with self-driving, and the passenger is not liable in an accident, there should be minimal risk to the passenger from accidents being recorded.
The rules require that personal information be scrubbed from any published data. This is a good idea but history shows it is remarkably hard to do properly.
The recent Federal Automated Vehicles Policy is long. (My same-day analysis is here and the whole series is being released.) At 116 pages (to be fair, less than half is policy declarations and the rest is plans for the future and associated materials) it is much larger than many of us were expecting.
The policy was introduced with a letter attributed to President Obama, where he wrote:
There are always those who argue that government should stay out of free enterprise entirely, but I think most Americans would agree we still need rules to keep our air and water clean, and our food and medicine safe. That’s the general principle here. What’s more, the quickest way to slam the brakes on innovation is for the public to lose confidence in the safety of new technologies. Both government and industry have a responsibility to make sure that doesn’t happen. And make no mistake: If a self-driving car isn’t safe, we have the authority to pull it off the road. We won’t hesitate to protect the American public’s safety.
This leads in to an unprecedented effort to write regulations for a technology that barely exists and has not been deployed beyond the testing stage. The history of automotive regulation has been the opposite, and so this is a major change. The key question is what justifies such a big change, and the cost that will come with it.
Make no mistake, the cost will be real. The cost of regulations is rarely known in advance but it is rarely small. Regulations slow all players down and make them more cautious -- indeed it is sometimes their goal to cause that caution. Regulations result in projects needing "compliance departments" and the establishment of procedures and legal teams to assure they are complied with. In almost all cases, regulations punish small companies and startups more than they punish big players. In some cases, big players even welcome regulation, both because it slows down competitors and innovators, and because they usually also have skilled governmental affairs teams and lobbying teams which are able to subtly bend the regulations to match their needs.
This need not even be nefarious, though it often is. Companies that can devote a large team to dealing with regulations, those who can always send staff to meetings and negotiations and public comment sessions will naturally do better than those which can't.
The US has had a history of regulating after the fact. Of being the place where "if it's not been forbidden, it's permitted." This is what has allowed many of the most advanced robocar projects to flourish in the USA.
The attitude has been that industry (and startups) should lead and innovate. Only if the companies start doing something wrong or harmful, and market forces won't stop them from being that way, is it time for the regulators to step in and make the errant companies do better. This approach has worked far better than the idea that regulators would attempt to understand a product or technology before it is deployed, imagine how it might go wrong, and make rules to keep the companies in line before any of them have shown evidence of crossing a line.
In spite of all I have written here, the robocar industry is still young. There are startups yet to be born which will develop new ideas yet to be imagined that change how everybody thinks about robocars and transportation. These innovative teams will develop new concepts of what it means to be safe and how to make things safe. Their ideas will be obvious only well after the fact.
Regulations and standards don't deal well with that. They can only encode conventional wisdom. "Best practices" are really "the best we knew before the innovators came." Innovators don't ignore the old wisdom willy-nilly, they often ignore it or supersede it quite deliberately.
Some players -- notably the big ones -- have lauded these regulations. Big players, like car companies, Google, Uber and others have a reason to prefer regulations over a wild west landscape. Big companies like certainty. They need to know that if they build a product, that it will be legal to sell it. They can handle the cost of complex regulations, as long as they know they can build it.
The long awaited list of recommendations and potential regulations for Robocars has just been released by NHTSA, the federal agency that regulates car safety and safety issues in car manufacture. Normally, NHTSA does not regulate car technology before it is released into the market, and the agency, while it says it is wary of slowing down this safety-increasing technology, has decided to do the unprecedented -- and at a whopping 115 pages.
Some people have wondered about my forecast in the spreadsheet on Robotaxi economics about the very low parking costs I have predicted. I wrote about most of the reasons for this in my 2007 essay on Robocar Parking but let me expand and add some modern notes here.
Today, researchers estimate there are between 3 and 8 parking spots for every car in the USA. The number 8 includes lots of barely used parking (all the shoulders of all the rural roads, for example) but the value of 3 is not unreasonable. Almost all working cars have a spot at their home base, and a spot at their common destination (the workplace.) There are then lots of other places (streets, retail lots, etc.) to find that 3rd spot. It's probably an underestimate.
We can't use all of these at once, but we're going to get a great deal more efficient at it. Today, people must park within a short walk of their destination. Nobody wants to park a mile away. Parking lots, however, need to be sized for peak demand. Shopping malls are surrounded by parking that is only ever used during the Christmas shopping season. Robocars will "load balance" so that if one lot is full, a spot in an empty lot too far away is just fine.
When robocars need to park, they'll do it like the best parking valets you've ever seen. They don't even need to leave space for the valet to open the door to get out. (The best ones get close by getting out the window!) Because the cars can move in concert, a car at the back can get out almost as quickly as one at the front. No fancy communications network is needed; all you need is a simple rule that if you boxed somebody in, and they turn on their lights and move an inch towards you, you move an inch yourself (and so on with those who boxed you in) to clear a path. Already, you've got 1.5x to 2x the density of an ordinary lot.
I forecast that many robotaxis will be small, meant for 1-2 people. A car like that, 4' by 12' would occupy under 50 square feet of space. Today's parking lots tend to allocate about 300 square feet per car. With these small cars you're talking 4 to 6 times as many cars in the same space. You do need some spare space for moving around, but less than humans need.
When we're talking about robotaxis, we're talking about sharing. Much of the time robotaxis won't park at all, they would be off to pick up their next passenger. A smaller fraction of them would be waiting/parked at any given time. My conservative prediction is that one robotaxi could replace 4 cars (some estimate up to 10 but they're overdoing it.) So at a rough guess we replace 1,000 cars, 900 of which are parked, with 250 cars, only 150 of which are parked at slow times. (Almost none are parked during the busy times.)
Robocars don't park, they "stand." Which means we can let them wait all sorts of places we don't let you park. In front of hydrants. In front of driveways. In driveways. A car in front of a hydrant should be gone at the first notification of a fire or sound of a siren. A car in front of your driveway should be gone the minute your garage opens or, if your phone signals your approach, before you get close to your house. Ideally, you won't even know it was there. You can also explicitly rent out your driveway space for money if you wish it. (You could rent your garage too, but the rate might be so low you will prefer to use it to add a new room to your house unless you still own a car.)
In addition, at off-peak times (when less road capacity is needed) robocars can double park or triple park along the sides of roads. (Human cars would need to use only the curb spots, but the moment they put on their turn signal, a hole can clear through the robocars to let them out.)
So if we consider just these numbers -- only 1/6 of the time spent parking and either 4 times the density in parking lots or 2-3 times the volume of non-lot parking (due to the 2 spots per car and loads of extra spots) we're talking about a huge, massive, whopping glut of parking. Such a large glut that in time, a lot of this parking space very likely will be converted to other uses, slowly reducing the glut.
To add to this glut, robocars can be the best parking customers you could ever imagine. If you own a parking lot, you might have sold the space at the back or top of your lot to the robocars -- they will park in the unpopular more remote sections for a discount. The human driver customers will prefer those spots by the entrance. As your lot fills up, you can ask the robocars to leave, or pay more. If a high paying human driver appears at the entrance, you can tell the robocars you want their space, and off they can go to make room. Or they can look around on the market and discover they should just pay you more to keep the space. The lot owner is always making the most they can.
If robocars are electric, they should also be excellent visitors, making little noise and emitting no soot to dirty your walls. They will leave a tiny amount of rubber and that's about it.
All of this will be driven by what I give the ironic name of the "spot" market in parking. Such markets are already being built by start-ups for human drivers. In this market, space in lots would be offered and bid for like any other market. Durations will be negotiated, too. Cars could evaluate potential waiting places based on price and the time it will take to get there and park, as well as the time to get to their likely next pickup. A privately owned car might drive a few miles to a super cheap lot to wait 7 hours, but when it's closer to quitting time, pay a premium (in competition with many others of course) to be close to their master.
Tesla's spat with MobilEye reached a new pitch this week, and Tesla announced a new release of their autopilot and new plans. As reported here earlier, MobilEye announced during the summer that they would not be supplying the new and better versions of their EyeQ system to Tesla. Since that system was and is central to the operation of the Telsa autopilot, they may have been surprised that MBLY stock took a big hit after that announcement (though it recovered for a while and is now back down) and TSLA did not.