Part of this standard involves safety cases for development and testing. I am hopeful that the effort recognizes that the use of public shadow and safety driving to develop these systems is untenable, for a variety of reasons, and has and will harm people, being used as unnecessary test subjects, for no value added. I believe the case can be made that 99.9% of this can be replaced with aerospace/DoD simulation technology and systems engineering practices. I would be glad to demonstrate this level of simulation technology meets the needs of the industry and addresses several significant technology gaps in most of the systems currently being used in this industry. Those involving real-time and the fidelity of various models.

SAE Autonomous Vehicle Engineering Magazine — End Public Shadow/Safety Driving

https://www.nxtbook.com/nxtbooks/sae/ave_201901/index.php

Common Misconceptions about Aerospace/DoD/FAA Simulation for Autonomous Vehicles

https://medium.com/@imispgh/common-misconceptions-about-aerospace-dod-faa-simulation-for-autonomous-vehicles-2b3ad84b0aa1

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