A Snapshot of Cruise Crash Reporting Transparency: July & August 2023

A comparison of California Cruise robotaxi crash reports between the California DMV database and the NHTSA SGO database reveals significant discrepancies in reporting. 31 crashes reported to NHTSA do not appear in the California DMV database. This includes seven unreported injury crashes. Of special note is the Cruise crash with a fire truck that caused serious injury to an occupant of the Cruise robotaxi does not appear as a California DMV crash report. To be sure, Cruise might not be legally required to file these reports, but the situation reveals an apparent lack of transparency.

Comparison Results:

39 crashes were identified across both databases for the date-of-crash months of July 2023 through August 2023. The comparison was performed on October 28, 2023, so there was adequate time for all such crashes to have been reported.

Each database was missing one or more crashes found in the other database:

• 39 crashes in the NHTSA base, including 8 also found in the CA DMV database.
• 31 crashes reported to NHTSA were not in the California DMV database
• The California DMV database was in particular missing SEVEN (7) crash reports which indicated an injury had occurred or might have occurred.

1. NHTSA 30412-5968: Other car ran a red light striking Cruise; passenger of other vehicle treated on scene for minor injury.
2. NHTSA 30412-5982: Other car ran into Cruise; passenger of other vehicle transported by EMS for further evaluation. Possible injury ("unknown" injury status).
3. NHTSA 30412-6144: Cruise crash with fire truck; serious injury reported to passenger
4. NHTSA 30412-6145: Cruise reversing contacted cyclist; minor injury reported to cyclist
5. NHTSA 30412-6167: Cruise rear-ended after braking; minor injury reported to other vehicle driver
6. NHTSA 30412-6175: Cruise hit pedestrian crossing in front of it (said to be crossing against light); moderate injury to pedestrian
7. NHTSA 30412-6270: Cruise hit from behind after stopping to yield to pedestrian in crosswalk; minor injury to passengers inside AV

Two crashes involved non-motorists:

• 30412-6145 with a cyclist
• 30412-6175 with a pedestrian

Why the Disparity?

The thing that makes this complicated is that CA DMV does not require reporting crashes for "deployment" operation -- just for "testing" operation. Apparently when the regulations were written they did not anticipate that companies would "deploy" immature technology, but that is exactly what has happened.

It is difficult from available information to check how Cruise is determining which crashes must be reported to California DMV (testing) and which do not have to be reported (deployment). In practice it might boil down to a management decision which ones they want to report, although there might be some less arbitrary internal decision criterion in use.

CA DMV should require all companies to provide them with unredacted copies of all NHTSA SGO reports to provide improved transparency. For the foreseeable future, making a distinction between "testing" and "deployment" with no driver in the vehicle serves no useful purpose, and impairs transparency. If there is no driver it is a deployment, and should be held to the standards of a production vehicle, including reporting both crashes and driving behavior that puts other road users at undue risk. This is true for all companies, not just Cruise.

Other notes:

• CA DMV reports have the street names, yet Cruise redacts this same information from reports filed with NHTSA claiming it is "confidential business information." It is difficult to understand how information publicly reported by California can be classified as "confidential."
• The NHTSA database does not have the date of the crash, although the California database has that information.
• Crashes considered were for reported incident dates of July & August 2023, considering only uncrewed (no safety driver) operation.
• It is our understanding that Cruise is not required to report all crashes that occur during deployment to California DMV. So it is possible that these reporting inconsistencies are still in accordance with applicable regulations.
• All crashes on this spreadsheet in the NHTSA database list the "driver/operator type" as "Remote (Commercial / Test)" so it is not possible to distinguish whether the vehicle was considered in commercial service at the time of the crash. 
• At the time of this posting the tragic Oct. 2nd severe injury crash that involved a Cruise robotaxi dragging a pedestrian who had been trapped under the vehicle has also not been reported, while another crash on Oct 6th has. There is nothing on the Oct 6th CA DMV form to indicate that the reported crash was specific to a testing permit vs. deployment permit.

Review status: 

This data has not been peer reviewed. Corrections/additions/clarifications are welcome to improve accuracy. The data analysis results are included below.

Google Spreadsheet link:  https://docs.google.com/spreadsheets/d/1o9WWzMpiuum-QHZk9goY68gnBZuRC1InxUSMa7-h4DU/edit?usp=sharing

Data sources: 

• NHTSA SGO ADS Incident Report Data through Sept. 15, 2023
• California DMV Autonomous Vehicle Collision Reports as of Oct 13, 2023.

Updated 10/30/2023 to incorporate three more crash reports found in a wider search of the SGO database. All CA DMV crash reports have now been identified in the SGO database.