Response to DoT Policy on Highly Automated Vehicles

[While DoT has since published revised draft policies, the original draft policy and my response are still relevant to provide an overall picture about critical needs for self-driving vehicle safety.]

I've prepared a draft response to DoT/NHTSA on their proposed policy for highly automated vehicle safety.

EE Times article that summarizes my response

The topics I cover are:
1. Requiring a safety argument that deals with the challenges of validating machine learning
2. Requiring transparent independence in safety assessment
3. Triggering safety reassessment based on safety integrity, rather than “significant” functionality
4. Requiring assessment of changes that can compromise the triggering of fall-back strategies
5. Characterizing what “reasonable” might mean regarding anticipation of exceptional scenarios
6. Assuring the integrity of data that is likely to be used for crash investigations
7. Diagnostics that encompass non-collision failures of components and end-of-life reliability loss
8. More uniform codification of traffic rule exceptions
9. Ensuring the safety of driver-takeover strategies for SAE Level 2 systems

Document pointers:
Comments either to this blog or to my university e-mail are welcome.  
         koopman - at -


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