These Are The 15 Questions That Caused George Hotz to Cancel Comma.ai
George Hotz announced he was cancelling the Comma One project last week in response to an information request from the National Highway Traffic Safety Administration. At first glance, this might appear to be a bit of government overreach. However, once you start digging into the letter, it’s apparent the questions are reasonable and easy to answer.
The main goal of the questionnaire is to assess the safety of the Comma One device. NHTSA set a deadline of November 10th to receive the response or Hotz would risk a $21,000 a day fine. Hotz claims that the letter was threatening.
Lets look at the questions in detail and see how they break down.
The letter starts out with an explanation of the facts that NHTSA currently has along with references to the Comma.ai blog. It ends the first page with the following emphasised statement:
We are concerned that your product would put the safety of your customers and other road users at risk. We strongly encourage you to delay selling or deploying your product on the public roadways unless and until you can ensure it is safe.
The statement clearly asks for the product to be delayed and does not prevent Hotz from selling it in the future. The letter continues by stating assertions Hotz makes about the nature of the product are not enough to validate the safety of it and finished with the deadline and fine amounts. The special order follows with a set of 15 questions, examined below.
1. Describe in detail how the comma one is installed in a vehicle and provide a copy of installation instructions for the comma one.
The first question is simple enough and asks for the installation instructions and an explanation of how the device is installed. For a device that is set to hit the market in less than a month, Hotz should surely have some installation instruction already written up and ready to send out.
2. Describe in detail that advanced driver assistance features of comma one, including how those features differ from the existing features of the vehicles in which the comma one is intended to be installed.
This requests a breakdown of the features and how they improve upon the products currently installed in the vehicles in which Comma.ai is targeting. Many of these features have already been explained by Hotz in his presentations, so this should be something that’s easy for him to put together. The second part of the question might be a bit harder to answer, but it’s still feasible since he stated his system is an aftermarket improvement.
3. Describe in detail how a vehicle driver uses the comma one and provide a copy of user instructions for the comma one.
Providing an answer for this question should be easy enough. A user manual, much like the instruction manual mentioned above, should already describe the details on how a user may engage the system with less than a month until product launch.
4. Provide a detailed description of the conditions under which you believe a vehicle equipped with comma one may operate safely. This description must include:
a. The types of roadways on which a vehicle equipped with comma one may operate safely;
b. The geographic area in which a vehicle equipped with comma one may operate safely;
c. The speed range in which a vehicle equipped with comma one may operate safely;
d. The traffic conditions in which a vehicle equipped with comma one may operate safely;
e. The environmental conditions such weather or time of day in which a vehicle equipped with comma one may operate safely; and
f. The amount and type of driver inputs necessary for a vehicle equipped with comma one to operate safely.
This one gets into a bit more detail but is reasonable enough and mostly asks for detail on whether this can be operated on all roads or if it’s more of a highway device. It also asks how external conditions will impact it and what the driver will need to in response.
5. Provide a detailed description of the basis for your response to Request No. 4, including a description of any testing or analysis to determine safe operating condition for a vehicle equipped with comma one.
This one asks for some analysis and proof for the answer to the question above. Comma.ai should be able to provide it from the logs of its test vehicle.
6. Describe the steps you have taken or plan to take to ensure the safe operation of a vehicle equipped with comma one, including but not limited to automated shutoff of comma one features and owner education.
The automated shutoff and hand-off is a big part of autonomous vehicle development, so it’s fair to ask this question. Hotz should be able to answer this easily as his hand-off procedure was recently praised by testers who’ve been inside the test vehicle.
7. Provide a list by make, model, model year or year of production of each vehicle for which you support or anticipate supporting use of the comma one.
I asked this question along with multiple others on this page in a request to Hotz after the TechCrunch presentation. I was able to find some basic information on the comma.ai blog, but this is a question that he should be able to answer on the spot without much analysis.
8. Describe in detail any steps you have taken to ensure that installation of the comma one in any supported vehicle does not have unintended consequences on the vehicle’s operation.
This is a good question since Hotz appeared to be pushing code in an ad-hoc manner over the CAN-BUS and was not cooperating with American Honda to verify this would not have unintended consequences. If he did in fact have supporting data showing why his device would not interrupt other operations of the vehicle, Hotz should be able to answer this question easily.
9. Describe the functionality of comma one, if any, if installed in an unsupported vehicle.
This is important since Hotz was planning to use an OBD II device that would plug into supported vehicles. Since this is a universal standard, the device could be plugged into any other vehicle and could cause unintended consequences since Hotz was forcing messages over the CAN-BUS.
10. Have you done any analysis or testing of the impact or potential impact of comma one on the vehicle’s compliance with FMVSS? If yes, please describe the analysis or testing in detail and provide supporting documentation. If no, describe why not.
Federal Motor Vehicle Safety Standards cover design, construction, performance, and durability requirements for motor vehicles and any safety-related components, systems, and design features. The Comma One falls into this bucket since it would be controlling braking and other safety functions. At this point in the launch cycle, Comma.ai should at least have a general overview of how it will impact or improve the regulated safety features when installed.
11. Describe in detail how the comma one impacts a vehicle’s rearview mirror, including whether it requires removal of the rearview mirror or the extent to which it block or obstructs the rearview mirror.
12. State your position on how the comma one does or does not affect a vehicle’s compliance with FMVSS No. 111, Rearview mirrors (49 C.F.R. 571.111), and provide any supporting information or documentation to support your position.
The rearview-mirror replacement appeared to be illegal and NHTSA thought the same based on the questions above. It’s possible Hotz would be able to get by with using the screen as the mirror, but we’ll never know since he cut off communication with NHTSA immediately.
13. State the date on which you currently plan to begin selling the comma one, and provide a list of all retailers and/or website through which you anticipate selling the comma one.
Hotz already announced he would sell before the end of the year, so all he needed to do here was provide an exact date to NHTSA.
14. State the date on which you currently plan to begin shipping the comma one.
This is also a simple question and could be based on the date above depending on how long it would take to produce the initial batch of devices.
15. Provide any other information which you believe supports the safety of the comma one.
The last questions allows Hotz an open-ended platform to provide as much supporting documentation as he would like to prove his case and does not limit him in any fashion. The fines set in the request also clearly state that they will only be enacted if a response is not received by November 10th. There is nothing in the letter that states he must cancel the product or even have a full plan to be compliant by that date. This special order appears only to be a request to start the compliance process with NHTSA.
Based on how simple the questions are, and the knowledge I have even as an outsider, I believe the request could have been completed in a day. Instead, Hotz chose to let his ego show again, posted the document publicly, and cancelled the product.
He had lots of great ideas that could’ve been beneficial to the industry. Maybe he’ll share some of them when he decides to join the grown-ups and fill out a simple information request.
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