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Apple Asks California DMV to Make Changes to Autonomous Vehicle Testing Policies
In a letter, Apple says it is "investing heavily in the study of machine learning and automation, and goes on to say the company is "excited" about the potential of automated systems in many areas, including transportation.
The company then proposes that the DMV "amend or clarify" its positions in the areas of disengagement reporting, definitions, and testing without safety drivers. Apple is concerned that inconsistency in how permit holders reports disengagements can lead to media coverage that causes public confusion and misunderstanding. Apple wants disengagement reports to cover times when a driver takes control of a vehicle to prevent a crash or traffic violation, and little else.
Apple suggests the following changes to the disengagement reporting requirements to achieve an objective set of data to accurately and clearly inform the public about the safety of the automated vehicles being testedApple two weeks ago was granted a permit for testing autonomous vehicles on public roads, and has already begun to do so. The company has three Lexus SUVs equipped with sensors and cameras, presumably running the autonomous driving software the company has been working on for the last several months. Those SUVs have been spotted on Cupertino roads this week.
A disengagement should be defined as an unexpected event or failure that requires the safety driver to take control of the vehicle in order to prevent a crash or traffic violation.
A disengagement should not be reported for the following:
- Operational constraints where either the safety driver has been trained to disengage the system, or when the system detects the constraint and disengages automatically. For example, a system that requires the safety driver to navigate through a construction zone.
- System errors or failures. For example, a software bug or sensor dropout that does not affect the safe operation of the system.
- Discretionary decisions made by the safety driver. For example, when the safety driver perceives a vehicle is approaching too quickly and opts to disengage the system.
- Any tests that are planned to result in a disengagement.
- The end of a test or experiment.
Additionally, the proposed requirement in §227.50(b)(3)(B)(vi) to describe the type of incident that would have happened without the disengagement should be removed. It requires speculation about future events that have not occurred.
By participating in the DMV's Autonomous Vehicle Testing Program, Apple will need to publicly share many details about its testing process, which will make it difficult to keep development on the software under wraps.