Mr. Krafcik

I am a former aerospace engineer and lead a group called Professionals for Responsible Mobility. Our goal is to ensure that the path to creating autonomous vehicles, and the associated connected technology, occurs as fast and as safely as possible. Among our concerns is that many organizations in the industry are not on the right path. They are using inefficient and unsafe methods to create the technology and exaggerating their progress. All for the purposes of being first, satisfy egos and competing for funding.

The most significant issue being that most of the AV makers are using public shadow driving for AI, engineering and test vs aerospace level simulation. That process would not only never result in autonomy, due to the one trillion miles at an expense of over $300B, it would create thousands of avoidable casualties as the shadow driving moves from benign scenarios to those that are complex and dangerous. We are also concerned that far too many companies, as well as NHTSA and the NTSB, are of the incorrect belief that L2+ and L3 can be made safe. NASA, Clemson University, the University of South Hampton, Volvo, Ford, Chris Urmson, and even Waymo itself, has said it cannot be made safe and that level 3 needs to be skipped.

We have found Waymo’s progression in the past couple of months to be encouraging. You announced you were skipping L3. Then you announced you are moving toward more simulation. But then recently you announced you would remote control vehicles when the systems did not know what to do. And that practice would be used in your efforts in Phoenix and now with various organizations. Especially those with members who have special needs. This leaves us a bit confused and concerned.

In order to meet the objectives of actually creating an autonomous vehicles and keeping people as safe as possible, aerospace level simulation would need to be used the vast majority of the time for AI, engineering and testing. Followed by test tracks. That would leave public shadow driving used only to validate the simulation or in very isolated cases when test tracks could not be used. And when those situations did occur they would be in controlled situations. Not unlike a movie set. Given this remote control could only be used in extremely rare circumstances as that process would significantly exaggerate the issues with public shadow driving by adding situational awareness delay. Said another way, the scenario matrix for the geofenced locations should be complete. The vehicles would be a geofenced L4 and the remote operations would be in truly extenuating circumstances. If this is the case we would request that scenario matrix be made available for review. And that it is reviewed by a group of industry professionals from the government to insurance companies, traffic engineers, academics and even the public.

If your technology has gotten to the point that proper due diligence has been done we would like to help support your efforts. If it has not, we would like to work with you to help you get it there.

Michael DeKort

Professionals for Responsible Mobility

Systems Engineer, Engineering/Program Management -- DoD/Aerospace/IT - Autonomous Systems Air & Ground, FAA Simulation, UAM, V2X, C4ISR, Cybersecurity

Systems Engineer, Engineering/Program Management -- DoD/Aerospace/IT - Autonomous Systems Air & Ground, FAA Simulation, UAM, V2X, C4ISR, Cybersecurity