NHTSA, several automakers, academics and others are misleading us about the safety of L3 autonomy and shadow/safety driving

Please refer to this report

https://www.nhtsa.gov/sites/nhtsa.dot.gov/files/812182_humanfactorseval-l2l3-automdrivingconcepts.pdf

The outcome of this report is negligent. Whether it is gross negligence has to be determined.

This report leads those reading it, policy makers, the public, the press etc into believing ALL you have to do to safely let people shadow/safety drive (L2/L3) is give them warnings to take control and that control is ONLY defined as physically engaging with the steering wheel, brakes etc. Other than unplanned lane keeping issues it does not test how effective that control is in handling scenarios especially urgent ones. Why did they stop there? Is it a coincidence that the companies fielding L3 vehicles, like GM, Mercedes and Google, were part of the test? Is this an effort to mislead those downstream into supporting or approving this activity or to buy the vehicles? What role did this play in how Tesla, NHTSA and the NTSB handle the Joshua Brown tragedy? Is this driving industry policy and law?

NASA. Clemson and University of South Hampton tests went to that next step. They ran scenarios and observed and measured how effective people were at taking the appropriate action AFTER “taking control”. They found it is not possible to provide alerts or any other coaxing mechanism to coerce people into reliably and consistently paying attention properly so they can do the right things after “taking control”. In most cases the humans over reacted and made the wrong decisions. They found it took 7 to 24 seconds to regain situational awareness to make the right decisions. 7 seconds alone is an eternity in a vehicle. This is clearly evident in the air disasters NASA and others refer to. NASA, Volvo, Ford, Waymo and Chris Urmson were right for saying L3 has to be skipped.

Shadow /Safety Driving or L2+/L3 is dangerous and should not be permitted or used except in regulated, controlled and approved circumstances. This also means it should not be used to attain L4 or L5. We should switch to aerospace level simulation.

I will be taking this up for action with those in the report, relevant organizations, the press, lawmakers, NHTSA, NTSB, DoT IG and others.

(The NTSB is due to release its findings on the Tesla/Brown tragedy on Sept 12th. The finished report is already circulating. They cannot complete that finding without knowing this information.)

Update 8–23–2017

Waymo has now switched to simulation from shadow driving and is using MCity’s process to create core scenarios. Just a short time ago Waymo announced Level 3 should be skipped. Waymo is doing this for a reason. Others should pay attention.

Links to other reports mentioned

My article on the perils of Shadow/Safety Driving

Autonomous Levels 4 and 5 will never be reached without Simulation vs Public Shadow Driving for AI

My Background — I am a former systems engineer, engineering and program manager for Lockheed Martin. I worked in aircraft simulation, the Aegis Weapon System, NORAD and on C4ISR for the US Coast Guard and DHS. I worked in Commercial IT. Including cybersecurity. I also received the IEEE Barus Ethics Award for whistleblowing regarding the DHS/USCG Deepwater program post 9/11

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