It's no secret that I've been a critic of the NHTSA "levels" as a taxonomy for types of Robocars since the start. Recent changes in their use calls for some new analysis that concludes that only one of the levels is actually interesting, and only tells part of the story at that. As such, they have become even less useful as a taxonomy. Levels 2 and 3 are unsafe, and Level 5 is remote future technology. Level 4 is the only interesting one and there is thus no taxonomy.

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.)

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.

Crashworthiness

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.)

Consumer Education and Training

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.

Registration and Certification

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.

Post-Crash Behavior

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.

Federal, State and Local Laws

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:

Data Recording and Sharing

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.)

Privacy

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.

What's good?

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.

The Glut of Parking

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.

Small size and Valet Density

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.)

Many more spaces available for use

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.

Ability to move in response to demand

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.

The "spot" market

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.

The vision of many of us for robocars is a world of less private car ownership and more use of robotaxis -- on demand ride service in a robocar. That's what companies like Uber clearly are pushing for, and probably Google, but several of the big car companies including Mercedes, Ford and BMW among others have also said they want to get there -- in the case of Ford, without first making private robocars for their traditional customers.

In this world, what does it cost to operate these cars? How much might competitive services charge for rides? How much money will they make? What factors, including price, will they compete on, and how will that alter the landscape?

Here are some basic models of cost. I compare a low-cost 1-2 person robotaxi, a higher-end 1-2 person robotaxi, a 4-person traditional sedan robotaxi and the costs of ownership for a private car, the Toyota Prius 2, as calculated by Edmunds. An important difference is that the taxis are forecast to drive 50,000 miles/year (as taxis do) and wear out fully in 5 years. The private car is forecast to drive 15,000 miles/year (higher than the average for new cars, which is 12,000) and to have many years and miles of life left in it. As such the taxis are fully depreciated in this 5 year timeline, and the private car only partly.

Some numbers are speculative. I am predicting that the robotaxis will have an insurance cost well below today's cars, which cost about 6 cents/mile for liability insurance. The taxis will actually be self-insured, meaning this is the expected cost of any incidents. In the early days, this will not be true -- the taxis will be safer, but the incidents will cost more until things settle down. As such the insurance prices are for the future. This is a model of an early maturing market where the volume of robotaxis is fairly high (they are made in the low millions) and the safety record is well established. It's a world where battery prices and reliability have improved. It's a world where there is still a parking glut, before most surplus parking is converted to other purposes.

Fuel is electric for the taxis, gasoline/hybrid for the Prius. The light vehicle is very efficient.

Maintenance is also speculative. Today's cars spend about 6 cents/mile, including 1 cent/mile for the tires. Electric cars are expected to have lower maintenance costs, but the totals here are higher because the car is going 250,000 miles not 75,000 miles like the Prius. With this high level of maintenance and such smooth driving, I forecast low repair cost.

Parking is cheaper for the taxis for several reasons. First, they can freely move around looking for the cheapest place to wait, which will often be free city parking, or the cheapest advertised parking on the auction "spot" market. They do not need to park right where the passenger is going, as the private car does. They will park valet style, and so the small cars will use less space and pay less too. Parking may actually be much cheaper than this, even free in many cases. Of course, many private car owners do not pay for parking overtly, so this varies a lot from city to city.

(You can view the spreadsheet directly on Google docs and download it to your own tool to play around with the model. Adjust my assumptions and report your own price estimates.)

The Prius has one of the lowest costs of ownership of any regular car (take out the parking and it's only 38 cents/mile) but its price is massively undercut by the electric robotaxi, especially my estimates for the half-width electric city car. (I have not even included the tax credits that apply to electric cars today.) For the taxis I add 15% vacant miles to come up with the final cost.

The price of the Prius is the retail cost (on which you must also pay tax) but a taxi fleet operator would pay a wholesale, or even manufacturer's cost. Of course, they now have the costs of running a fleet of self-driving cars. That includes all the virtual stuff (software, maps and apps) with web sites and all the other staff of a big service company ranging from lawyers to marketing departments. This is hard to estimate because if the company gets big, this cost will not be based on miles, and even so, it will not add many cents per mile. The costs of the Prius for fuel, repair, maintenance and the rest are also all retail. The taxi operator wants a margin, and a big margin at first, though with competition this margin would settle to that of other service businesses.

The past period has seen some very big robocar news. Real news, not the constant "X is partnering with Y" press releases that fill the airwaves some times.

Uber has made a deal to purchase Otto, a self-driving truck company I wrote about earlier founded by several friends of mine from Google. The rumoured terms of the deal as astronomical -- possibly 1% of Uber's highly valued stock (which means almost $700M) and other performance rewards. I have no other information yet on the terms, but it's safe to say Otto was just getting started with ambitious goals and would not have sold for less than an impressive amount. For a company only 6 months old, the rumoured terms surpass even the amazing valuation stories of Cruise and Zoox.

While Otto has been working on self-driving technology for trucks, any such technology can also move into cars. Uber already has an active lab in Pittsburgh, but up to now has not been involved in long haul trucking. (It does do local deliveries in some places.) There are many startups out there calling themselves the "Uber for Trucks" and Otto has revealed it was also working on shipping management platform tools, so this will strike some fear into those startups. Because of my friendship with Otto's team, I will do more commentary when more details become public.

In other Uber news, Uber has announced it will sell randomly assigned Uber rides in their self-driving vehicles in Pittsburgh. If your ride request is picked at random (and because it's in the right place) Uber will send one of their own cars to drive you on your ride, and will make the ride free, to boot. Of course, there will be an Uber safety driver in the vehicle monitoring it and ready to take over in any problem or complex situation. So the rides are a gimmick to some extent, but if they were not free, it would be a sign of another way to get customers to pay for the cost of testing and verifying self-driving cars. The free rides, however, will probably actually cause more people to take Uber rides hoping they will win the lottery and get not simply the free ride but the self-driving ride.

GM announced a similar program for Lyft -- but not until next year.

Ford also goes all-in, but with a later date

Ford has announced it wants to commit to making unmanned capable taxi vehicles, the same thing Uber, Google, Cruise/GM, Zoox and most non-car companies want to make. For many years I have outlined the difference between the usual car company approaches, which are evolutionary and involve taking cars and improving their computers and the approaches of the non-car companies which bypass all legacy thinking (mostly around ADAS) to go directly to the final target. I call that "taking a computer and putting wheels on it." It's a big and bold move for Ford to switch to the other camp, and a good sign for them. They have said they will have a fleet of such vehicles as soon as 2021.

At the recent AUVSI/TRB conference in San Francisco, there was much talk of upcoming regulation, particularly from NHTSA. Secretary of Transportation Foxx and his NHTSA staff spoke with just vague hints about what might come in the proposals due this fall. Generally, they said good things, namely that they are wary of slowing down the development of the technology. But they said things that suggest other directions.

Today, Robin Chase wrote an article wondering if robocars will improve or ruin our cities and asked for my comment on it. It's a long article, and I have lots of comment, since I have been considering these issues for a while. On this site, I spend most of my time on the potential positive future, though I have written various articles on downsides and there are yet more to write about.

At the recent AUVSI/TRB symposium, a popular research topic was platooning for robocars and trucks. Platooning is perhaps the oldest practical proposal when it comes to car automation because you can have the lead vehicle driven by a human, even a specially trained one, and thus resolve all the problems that come from road situations too complex for software to easily handle.

Today I want to look at some implications of Tesla's Master Plan Part Deux which caused some buzz this week. (There was other news of course, including the AUVSI/TRB meeting which I attended and will report on shortly, forecast dates from Volvo, BMW and others, hints from Baidu, Faraday Future and Apple, and more.)

In Musk's blog post he lays out these elements of Tesla's plan

• Integrating generation and storage (with SolarCity and the PowerWall and your car.)
• Expand into trucks and minibuses
• More autonomy in Tesla cars
• Hiring out your Tesla as a robotaxi when not using it

Except for the first one, all of these are ideas I have covered extensively here. It is good to see an automaker start work in these directions. As such while I will mostly agree with what Tesla is saying, there are a few issues to discuss.

Electric (self-driving) minibus and Trucks

In my article earlier this year on the future of transit I laid out why transit should mostly be done with smaller (van sized) vehicles, taking ad-hoc trips on dynamic paths, rather than the big-vehicle, fixed-route, fixed-schedule approach taken today. The automation is what makes this happen (especially when you add the ability of single person robocars to do first and last miles.) Making the bus electric can make it greener, though making it run full almost all the time is far more important for that.

The same is true for trucks, but both trucks and buses have huge power needs which presents problems for having them be electric. Electric's biggest problem here is the long recharge time, which puts your valuable asset out of service. For trucks, the big win of having a robotruck is that it can drive 24 hours/day, you don't want to take that away by making it electric. This means you want to look into things like battery swap, or perhaps more simply tractor swap. In that case, a truck would pull in to a charging station and disconnect from its trailer, and another tractor that just recharged would grab on and keep it going.

The success of carpool apps

The cell phone ride hail apps like Uber and Lyft are now reporting great success with actual ride-sharing, under the names UberPool, LyftLines and Lyft Carpool. In addition, a whole new raft of apps to enable semi-planned and planned carpooling are out making changes.

It's not surprising there is huge debate about the fatal Tesla autopilot crash revealed to us last week. The big surprise to me is actually that Tesla and MobilEye stock seem entirely unaffected. For many years, one of the most common refrains I would hear in discussions about robocars was, "This is all great, but the first fatality and it's all over." I never believed it would all be over, but I didn't think there would barely be a blip.

There's been lots of blips in the press and online, of course, but most of it has had some pretty wrong assumptions. Tesla's autopilot is a distant cousin of a real robocar, and that would explain why the fatality is no big deal for the field, but the press shows that people don't know that.

Tesla's autopilot is really a fancy cruise control. It combines several key features from the ADAS (Advance Driver Assist) world, such as adaptive cruise control, lane-keeping and forward collision avoidance, among others. All these features have been in cars for years, and they are also combined in similar products in other cars, both commercial offerings and demonstrated prototypes. In fact, Honda promoted such a function over 10 years ago!

Tesla's autopilot primarily uses the MobilEye EyeQ3 camera, combined with radars and some ultrasonic sensors. It doesn't have a lidar (the gold standard in robocar sensors) and it doesn't use a map to help it understand the road and environment.

Most importantly, it is far from complete. There is tons of stuff it's not able to handle. Some of those things it can't do are known, some are unknown. Because of this, it is designed to only work under constant supervision by a driver. Tesla drivers get this explained in detail in their manual and when they turn on the autopilot.

ADAS cars are declared not to be self-driving cars in many state laws

This is nothing new -- lots of cars have lots of features to help drive (including the components used like cruise controls, each available on their own) which are not good enough to drive the car, and only are supposed to augment an alert driver, not replace one. Because car companies have been selling things like this for years, when the first robocar laws were drafted, they made sure there was a carve-out in the laws so that their systems would not be subject to the robocar regulations companies like Google wanted.

The Florida law, similar to other laws, says:

The term [Autonomous Vehicle] excludes a motor vehicle enabled with active safety systems or driver assistance systems, including, without limitation, a system to provide electronic blind spot assistance, crash avoidance, emergency braking, parking assistance, adaptive cruise control, lane keep assistance, lane departure warning, or traffic jam and queuing assistant, unless any such system alone or in combination with other systems enables the vehicle on which the technology is installed to drive without the active control or monitoring by a human operator.

The Tesla's failure to see the truck was not surprising

There's been a lot of writing (and I did some of it) about the particulars of the failure of Tesla's technology, and what might be done to fix it. That's an interesting topic, but it misses a very key point. Tesla's system did not fail. It operated within its design parameters, and according to the way Tesla describes it in its manuals and warnings. The Tesla system, not being a robocar system, has tons of stuff it does not properly detect. A truck crossing the road is just one of those things. It's also poor on stopped vehicles and many other situations.

Tesla could (and in time, will) fix the system's problem with cross traffic. (MobilEye itself has that planned for its EyeQ4 chip coming out in 2018, and freely admits that the EyeQ3 Tesla uses does not detect cross traffic well.) But fixing that problem would not change what the system is, and not change the need for constant monitoring that Tesla has always declared it to have.

Today at Starship, we announced our first pilot projects for robotic delivery which will begin operating this summer. We'll be working with a London food delivery startup Pronto as well as German parcel company Hermes and the Metro Group of retailers, plus Just Eat restaurant food delivery to trial on-your-schedule delivery of packages, groceries and meals to people's homes.

Executive Summary: A rundown of different approaches for validation of self-driving and driver assist systems, and a recommendation to Tesla and others to have countermeasures to detect drivers not watching the road, and permanently disable their Autopilot if they show a pattern of inattention.

The recent fatality for a man who was allowing his car to be driven by the Tesla "autopilot" system has ignited debate on whether it was appropriate for Tesla to allow their system to be used as it was.

Tesla's autopilot is a driver assist system, and Tesla tells customers it must always be supervised by an alert driver ready to take the controls at any time. The autopilot is not a working self-driving car system, and it's not rated for all sorts of driving conditions, and there are huge numbers of situations that it is not designed to handle and can't handle. Tesla knows that, but the public, press and Tesla customers forget that, and there are many Tesla users who are treating the autopilot like a real self-driving car system, and who are not paying attention to the road -- and Tesla is aware of that as well. Press made this mistake as well, regularly writing fanciful stories about how Tesla was ahead of Google and other teams.

Brown, the driver killed in the crash, was very likely one of those people, and if so, he paid for it with his life. In spite of all the warnings Tesla may give about the system, some users do get a sense of false security. There is debate if that means driver assist systems are a bad idea.

There have been partial self-driving systems that require supervision since the arrival of the cruise control. Adaptive cruise control is even better, and other car companies have released autopilot like systems which combine adaptive cruise control with lane-keeping and forward collision avoidance, which hits the brakes if you're about to rear end another car. Mercedes has sold a "traffic jam assist" like the Telsa autopilot since 2014 that only runs at low speeds in the USA. You can even go back to a Honda demo in 2005 of an autopilot like system.

With cruise control, you might relax a bit but you know you have to pay attention. You're steering and for a long time even the adaptive cruise controls did not slow down for stopped cars. The problem with Tesla's autopilot is that it was more comprehensive and better performing than earlier systems, and even though it had tons of things it could not handle, people started to trust it with their lives.

Tesla's plan can be viewed in several ways. One view is that Tesla was using customers as "beta testers," as guinea pigs for a primitive self-drive system which is not production ready, and that this is too much of a risk. Another is that Tesla built (and tested) a superior driver assist system with known and warned limitations, and customers should have listened to those warnings.

Neither is quite right. While Tesla has been clear about the latter stance, with the knowledge that people will over-trust it, we must face the fact that it is not only the daring drivers who are putting themselves at risk, it's also others on the road who are put at risk by the over-trusting drivers -- or perhaps by Tesla. What if the errant car had not gone under a truck, but instead hit another car, or even plowed into a pedestrian when it careened off the road after the crash?

At the same time, Tesla's early deployment approach is a powerful tool for the development and quality assurance of self-drive systems. I have written before about how testing is the big unsolved problem in self-driving cars. Companies like Google have spent many millions to use a staff of paid drivers to test their cars for 1.6 million miles. This is massively expensive and time consuming, and even Google's money can't easily generate the billions of miles of testing that some feel might be needed. Human drivers will have about 12 fatalities in a billion miles, and we want our self-driving cars to do much better. Just how we'll get enough verification and testing done to bring this technology to the world is not a solved problem.

A Tesla blog post describes the first fatality involving a self drive system. A Tesla was driving on autopilot down a divided highway. A truck made a left turn and crossed the Tesla's lanes. A white truck body against a bright sky is not something the MobilEye camera system in the Tesla perceives well, and it is not designed for cross traffic.

With Mobility on Demand, you don't buy a car, you buy rides. That's certainly Uber's plan, and is a plan that makes sense for Google, Apple and other no-car companies. But even Daimler, with Car2Go/Car2Come, BMW with DriveNow and GM with Lyft plan to sell you a ride rather than a car, because it's the more lucrative thing to do.

So what does that car of the future look like? There is no one answer, because in this world, the car that is sent to pick you up is tailored to your trip. The more people traveling, the bigger the car is. If your trip does not involve a highway, it may not be a car capable of the highway. If your trip is up to a mountain cabin, it's more like an SUV, but you never use an SUV to go get a bottle of milk the way we do today. If it's for a cruise to the beach on a sunny day, the roof may have been removed at the depot. If it's for an overnight trip to a country home, it may be just beds.

I outlined many of these changes in this article on design changes in cars but today I will focus on the incredibly cheap and simple design of what should become the most common vehicle made, namely the car designed for a short urban trip by one person. That's 80% of trips and around 45% of miles, so this should be a large fraction of the fleet. I predict a lot of these cars will be made every year -- more than all the cars made today, even though they are used as taxis and shared among many passengers. What does it look like?

Small

A car for 1-2 people will be small. It will probably be around 1.5m wide, narrow enough that you can fit two in a lane, and have it park very efficiently when it has to wait. If it's for just one person, it won't be very long either. For two people, there will be a "face to face" configuration which is longer and an "tandem" configuration which is a bit shorter. The 2 person vehicles aren't a lot bigger or heavier than the one person, so they might be the most common cars, since you can serve a solo rider fairly efficiently with one, even if not perfectly efficient.

A car that is so narrow can't corner very fast. A wide stance is much more stable. There are a few solutions to that, including combinations of these:

• The wheels bank independently, allowing the vehicle to lean like a motorcycle when in corners. This is the best solution, but it costs some money.
• Alternately it's a two wheeler, which is also able to lean, but has other tricks like the LIT Motors C-1 to stay upright.
• It's electric, and has all the batteries in the floor, giving it a very low center of gravity. (One extreme example of this is the Tango, which uses lead batteries deliberately to give it that stability.)
• It never goes on fast roads, so it never needs to corner very fast, and its precision robot driving assures it never corners so fast as to become unstable, and it plans its route accordingly.

Not super aerodynamic

The car already has a big win when it comes to aerodynamic drag by only being half-width. The non-highway version probably gives back a bit of that because you don't need to worry as much about that if you are not going fast. Energy lost to drag goes up with the square of velocity. So a 30mph car has 1/4 the drag of a 60mph car, and 1/8th the drag of a similar car of full width. The highway car needs to be shaped as close to a "teardrop" as you can, but the city car can get away with being a bit taller for more comfortable seating and entry/exit.