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The documentation that the NHTSA is requesting are things that would already exist for a properly designed product. They are not asking for it to be generated de novo (and in fact, it cannot be done in that manner if they are operating under a proper design process).

This letter is designed to give pause to (e: previously I wrote "kill") a company operating with complete disregard for proper operations in a regulated industry.



This letter is designed to kill a company operating with complete disregard for proper operations in a regulated industry.

We are in entire agreement, but people cannot believe in the superposition of this and "Oh that's just some simple questions from the regulator."

Edit to add: Quoted bit appears to have changed after my quote. I think the old version remains accurate.


They're asking for documentation that any serious vendor would already have. That we believe this would kill comma.ai is really more a testament to our priors that George doesn't keep anything resembling rigorous test documentation.


And even then it wouldn't have to kill comma.ai, it could simply lead to Hotz selling the company to a party willing to dot the i's and cross the t's but retain the technology and Hotz himself as a partner/minority shareholder/employee.


Sorry, I thought I was in and out before anyone had seen my comment. I added a clear edit mark to fess up.

I originally wrote "kill" to mirror your original comment, but I changed it because it (as I perceive the word) presumes a level of intent that I don't think NHTSA operates with: I don't think that NHTSA has any intent to destroy this company. In fact, if comma.ai reached out to NHTSA, I would expect NHTSA to assist (within reason) in answering the letter.

I do think that these are straightforward questions for a group that has its act together. Part of having one's act together in a regulated environment is maintaining open lines of communication with regulators, so that questions would be asked should come as no surprise. Keeping up to date with the regulatory environment would also be expected, and given the recent autonomous driving publication the content and scope of these questions should come as no surprise.

If these questions kill the company, I don't see that as being the fault of NHTSA, I see that as being the fault of whoever is in charge of regulatory affairs at comma.ai.




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