You're listening to There Auto Be A Law, the
Center for Auto Safety podcast with Executive
Director Michael Brooks, Chief Engineer Fred
Perkins, and hosted by me, Anthony Cimino. For
over 50 years, the Center for Auto Safety has
worked to make cars safer. Hey, folks. Thanks
for coming back. Today is Wednesday, July 15th.
I hope everyone's having a wonderful day. Fred
is out. He's being a test driver for Waymo this
week. No, I'm kidding. That'd be amazing, though.
And in his place, we have a frequent guest of
the show. Phil Copeman's back. Hi, Phil. Hey,
great to be back. We're glad you're here because
we've got questions for you. We've, you know,
behind the scenes, we have very specific questions
for you and we're going to get to them. But first,
let's start off with some news out of NHTSA.
So NHTSA, as everybody knows, the National Highway
Traffic Safety Administration, and their current
head is a guy who came out of Apple. He's a lawyer,
and they've always been very kind of hands -off
around AV companies, and the administration's
view is very laissez -faire. Let's go ahead,
and this last week, he put out a letter, and
I'm going to quote from some of it. It says,
Every second matters when law enforcement officers,
firefighters, or paramedics are answering a call
because lives are on the line. That is why human
drivers who impede these operations are subject
to fines and even jail time. NHTSA is today issuing
a call to action for AV developers and operators
to immediately focus their resources on fixing
this issue. We expect you, AV operators, to prioritize
first responder interactions and will schedule
meetings with driverless automated driving system
developers by month's end to hear your solutions.
NHTSA has already been active in this space and
will continue to exercise our enforcement authority
for developers that do not address significant
safety concerns. Public trust on our roads is
earned, not given. I mean, that sounds like Jonathan
Morrison is a big fan of the show. That's my
takeaway. What do you guys think? This is the
most we've seen NHTSA do in a while on autonomous
vehicles, seriously. I mean, they've done some
stuff, but this is huge. I've heard people saying
that they've not seen anything like this. I haven't
been paying that close attention to NHTSA for
30 years, like Michael has, so we'll see what
he says. Yeah, I mean, there's kind of a, I guess
they're kind of speaking out of one side of their
mouth here. I mean, NHTSA is saying. We will
continue to exercise our enforcement authority
in these situations. You know, what they're not
saying is what they're saying there is we're
going to continue to look at these things through
recalls as they already have. What they're not
saying is we're going to put into play a full
swath of safety metrics in regulation that you
guys have to certify to. What they're saying
here is, you know, we're going to continue to
go down this path of plotting towards a recall
that may or may not work, as we've seen. And
at the same time, like what why the focus here
on police and emergency responders? Why didn't
Waymo get a letter like this when they were passing
school buses or driving into floods? Why? You
know, we've seen this administration continually
try to align itself with law enforcement for
political reasons. And they're kind of doing
the same thing here. And my question is, you
know, why aren't you addressing all of these?
other circumstances that are happening with AVs
that happen to normal people on the roads, right?
Well, that's fair. Let me try and argue it the
other way, because there's some good news here,
but everything you said is fair, Michael. But
let me try and bring the other side. The other
side is, if you assume, and this is what you're
having trouble with, if you assume that the only
thing they're allowed to do is regulatory recalls,
right? That from the rulemaking... It's it's
we want heaven forbid they should stifle anyone's
innovation. Right. So they're getting rid of
the stifling innovation and there are, you know,
the rules are it's, you know, open season. Put
those suckers on the road. OK. And so they've
decided the administration's decided that's the
path they want to take. But given that's the
path you want to take, the only stick they have
left, you know, that's carrot. The only stick
they have left is recalls. OK. And I agree with
you. I'd like to see. more than that one stick.
But given that's where we are, you know, let's
say the administrator decides that's sort of
the playing field, the hand he's been dealt,
he has to play that hand, right? What he's doing
is he's, I mean, why aren't school buses in there?
Because there's already a recall on school buses,
right? There's no point putting anyone on notice
because there's already a recall on school buses.
There's already a recall on construction zones.
There's already a recall on some other things,
right? So we've seen those recalls already. Now,
there's a separate problem, which is, by the
way, the recalls don't work. I'm going to come
back to that at my gas life. But set that aside.
You know, if the thing you can do is recalls,
then he's put everyone to notice that, by the
way, we consider messing with emergency responders
a risk to safety we're not going to tolerate.
And so he's setting policy, just like we know
that stalling on a highway is a recall. You can
argue that coming to a stop in a travel lane
is or is not dangerous. You know, people argue
this all the time. Robot taxis, what do they
do? They come to stop in a travel lane, right?
But NHTSA has a longstanding policy that if you're
going to stop in a travel lane, that's a recallable
offense. And it's one that we had to fight to
get put into place. But you got it. You got it.
It's there, right? And so this is, I see this
as a policy statement saying, okay, just like
stopping on a highway. is unsafe no matter what
you argue, messing with emergency responders
now is in that bin. So expect there to be, we
sort of let you slide by before, but enough is
enough. We're going to recall for messing with
emergency responders. So this is sort of declaring
some new turf for recall. So that's great. It
goes, there's a limited amount that accomplishes,
but it's a positive development. That's the way
I look at it. I mean, I think it's positive in
the sense that the administration is willing
to speak out against the industry. I just find
it very peculiar that that only happens when
you when when the vehicles are interfering with
their kind of pet partners in law enforcement.
Well, yeah, all these other situations we see
where they've been silent. Well, the question
is, is this maybe this was the easiest step and
there's another step coming. The question is,
is this the only step or is it not? Of course,
you're going to. you're going to pick the low
-hanging fruit, right? And it's hard to argue
that blocking ambulances is okay. This is sort
of the easiest piece they could bite off, so
they did it. And we'll see. Now, the other observation
is this has been going on for literally years,
right? Parking in firehouse driveways. So what
changed? Well, the other thing I want to point
out is that how many years has it been since
NHTSA had an administrator who was there other
than to do a quick EV deal? Three administrative,
like what, 10 years, more than 10 years, right?
When you say quick EV deal. No, he's the first
confirmed guy for a long time, right? Yeah, we
had a confirmed guy who was there for three or
four months and he did some EV stuff and then
he left, right? Yeah, they had a lot of, yeah,
there was, that was Steve Cliff came from me.
They were bringing people from CARB over to do
the fuel economy. He's a CARB guy and he was
there and he did his thing and that's cool. But
that had nothing to do with. With like AVs, right?
So set aside. Right. How many years without an
administrator? Like more than 10, right? That's
been a long time since they've had confirmed
administrators. Not acting administrators. Because
Ann Carlson after Cliff was not confirmed, right?
And then Sophie after Ann Carlson was not confirmed.
And before Cliff. Right. How do you confirm the
right? So you had all these administrators and
and I don't know how it works at NHTSA, but in
other places when you're acting, you're told,
all right, you're in charge. Don't break anything
till we get a real administrator. Right. And
so so now we have a real administrator. And so
he it one explanation for why it took so long
to do something about emergency vehicles is we
didn't really have a confirmed administrator
and they didn't maybe maybe they didn't feel
they had the power to really do that. Don't know.
Good question for Anne Carlson, if you can get
her on the show. But I'm really glad to see that
with a confirmed administrator, they're starting
to take those bites, right? Now, the question
is, what happens next? And the question I parked
to the side is, by the way, if the recall doesn't
work, what happens then? But again, that's my
gaslight. We're going to get there. Yeah, that's
kind of what I want to know is because the, you
know, the administrator, you know, Morrison says,
that is why human drivers who repeat these operations
are subject to fine and even jail times. NHTSA
doesn't have that kind of enforcement capability,
right? Well, not for human drivers either. No,
no, that's the thing. Yeah, that's the thing.
He's putting this out there as kind of, hey,
this is the way the world works and this is what
we're going to do, but we don't have the ability
to do that. They can just do recall, right? And
meanwhile, manufacturers are lobbying behind
the scenes to, you know, essentially... prevent
states from enforcing those types of laws against
them as well. Right. So that's an area where
we need to watch out for. Right. Yeah. Yeah.
State state preemption by federal laws, which
don't cover driving behavior, are going to be
a problem. Right. Right. Absolutely. And it's
a it's a doesn't have the resources to be in
the business of issuing traffic tickets for going
through red lights. Right. It just can't do that.
No. No, and they shouldn't be. No, that's not
their role. It never has been. And we need to
preserve state rights in those areas because
it's traditionally what the state's traditionally
regulated driver performance, right? Well, it's
simple that NHTSA regulates equipment. States
regulate what I'm going to call driver behavior.
And there's a muddy middle in the middle when
the driver's a piece of equipment. And the way
I look at it is NHTSA should be able to regulate
the ability of the... computer driver to behave
properly, but the states should be able to retain
the right to apply corrective force when they
don't behave properly. If NHTSA says, well, this
thing can't stop at red light, doesn't have the
ability to stop at red lights because it doesn't
even see them, okay, sure, that's a NHTSA thing.
But if it passes a test and it stops at 10 red
lights in a row, what's NHTSA supposed to do?
And if it misses one red light in a thousand,
you have a computer that almost right, you know,
misses one red light in a thousand. Well, the
states ought to be able to issue traffic tickets
for that one in a thousand. Right. I mean, I'm
excited by what happens next because I'm very
naive and hopeful that he'll bring in these manufacturers
and they'll say, yes, we're going to fix everything.
Are you really? I am. I like to think very positive
in the world. No, I think they're going to show
up with a suitcase full of money. Like, you know,
they're talking to FIFA referees like this. There
you go. Infantino gate. You're younger than I
am. And you're pretty cynical, at least as cynical
as I am. So I don't know. Let me say a word about
how this really works, though. So the thing,
the most important part of that letter was. basically
all the car companies being called to the, the
AV companies being called to the principal's
office, right? It's like, you're going to meet
with us this month. Now they, these guys meet
with NHTSA on a regular basis. They just wrote,
but they got called to the principal's office.
Okay. And the way this works is now I've never
actually worked at NHTSA. Again, if you get an
ex -NHTSA person, they can provide all the fine
shading here. But my understanding is these guys
meet all the time and that's good. That's appropriate.
Why use a hammer when a quiet conversation will
solve the problem? Makes sense, right? But these
guys are being put on notice and not just with
a letter, but in person. Hey, guys, you can't
mess this up. And it's basically a soft power
play. A lot of what NHTSA does isn't by... hammering
on companies. It's having conversations saying,
you've got to get on top of this or else we're
going to have to hammer you later. And so this
is the first step in a long -term escalation
on this issue that ultimately ends up with investigations
and recalls. But I hope, and I'm sure NHTSA hopes,
and one assumes the manufacturers hope, it doesn't
have to get there. It's like, fix the problem.
Just, hey guys, here's your chance. Fix the problem
so we don't have to pull out our hammer. So that's
what's really going on. The letter doesn't sound
like it does anything, but what's really going
on is it's starting up the cycle of escalation.
Yeah, I think it's good in that obviously I think
this has happened because it's become a lot more
prevalent in the news of, hey, this is what's
happening with Waymo and specifically Waymo because
they're the biggest player. Of course it's more
prevalent. They're scaling up. Yeah. Once in
a thousand. happens occasionally to 10 cars.
It happens every day to a thousand cars. It is
very simple. Or the example I like to use is
if you have something that happens once a year,
you can blow it off and say it's only once a
year and maybe nobody even sees it, right? Right.
Well, if that's once a year with a hundred cars,
when you go to 10 ,000 cars, that's twice a week.
All of a sudden people notice. Yep. And that's
one of the things I constantly repeat around
some of the exemptions that the industry is seeking,
where they want to deploy 90 ,000 vehicles all
at once on the road. I mean, that's where we're
going to start seeing the biggest problems, I
think, if that happens. Yeah, if you have an
exemption and you put 100 cars in the road and
you have a rare thing, and by the way, this only
works if you plan on getting lucky most of the
time. And, you know, let's say 1 % of the failures
are dangerous and 99 % of the failures are benign.
And you pay attention and you fix after the 99
% of the errors, you probably get lucky, right?
But when you put 100 ,000 cars on the road, you're
going to get such a flood of problems that that
1 % is still going to happen all the time and
be dangerous, right? It's a numbers game. Flood,
he says. Yeah, let's jump into that. So, Phil,
you wrote a good sub stack piece. expanding on
this specific letter more. And I'm going to quote
from yours. Uh, no, no, this is, this is my,
this is one of my favorite things. And I'm going
to cross examination. No, no, no, no. The cross
examination is coming up and it's not really
that it's, we have some confusion. So, uh, quoting
from you, the endlessly repeated AV industry
mantra that computers don't drive drunk most
necessarily extend to. They also don't get a
free pass just because metrics might show that
drunk or otherwise impaired humans struggle with
emergency response situations. I love that, and
I hope that comes – that's what we were just
talking about, that this comes forward and real
progress happens there. But my question is, and
I know Michael has the same thing, so there's
the emergency response situations, which we'd
call an edge case, right? Incorrectly call it
edge. Well, incorrectly depending who you talk
to. And that's I think that's what we're getting.
Yeah, that's what we get into because we go back
to the NHTSA letter and read the part Jonathan
had wrote about edge cases. Yeah, I think, you
know, that kind of underlies some of this confusion
that I think everyone's experiencing to some
extent. Right. So around edge cases. So my hope
is that you can expand on what. What do you see
is what is, what exactly is an edge case? I think
the, the typical nomenclature is that, Hey, it's
something that's very rare and unexpected and
no one could possibly train for. Right. But that's
not how we're seeing it used from AV companies
in particular. Well, that's what AV wants you
to believe. Yeah. Right. So please. All right.
All right. So this, this ends up being a towel,
right? Sorry, Fred. Hope you enjoy it. I'm pinch
-hitting for Fred. Okay. All right. So let's
do this slightly long version because hopefully
this sort of puts people's minds in the right
place. And I did an article on this, and you
can put a point in the show notes to this, but
let me sort of give the quick version, right?
Back at the dawn of time when there was analog
electronics, but computers weren't a thing, which
is before I was born. Barely. Okay. What you
had was you had components that would work properly
in a range of conditions, but would have trouble
beyond that range. Okay. And so you might have
a circuit that works between three volts and
five volts, but doesn't work below three volts
and burns up above five volts. Okay. And you
might have something that works at... above freezing,
but below boiling or something like that for
temperature. So you'd have temperature ranges,
you have voltage ranges. And what you would do
is say, well, this thing's supposed to work between
4 .5 and 5 .5 volts. That was a really common
back in the day, four and a half to five and
a half volts is supposed to work. And you would
test it at 4 .5 volts or 4 .49 or whatever. You
test it at 4 .5 and 5 .5. And if both of them
worked, you'd say, okay, it probably works in
between. And so. The low voltage cutoff was an
edge and the high voltage cutoff was the edge.
And they didn't have to work beyond that, but
you want to make sure they work right on the
boundary. Right. Okay. And for temperature, you
tested it freezing. You tested it at whatever
the maximum temperature, probably not boiling,
probably like 120 Fahrenheit or something like
that. And there's also vibration. They had these
chambers in automotive called shake and bake
chambers where you'd rattle this electronics
around. Okay. And you take the temperature down
to the minimum and you take the temperature up
to the maximum and you'd see if they could work
for 10 ,000 hours or whatever it was. You know,
it's fun. Okay. So edge cases were a minimum
or maximum specification. And a corner case was
a pair, lowest voltage and highest temperature,
stuff like that. So combinations of edge cases.
All right. And so that's sort of the history.
Now, computers come along and people in software
talk about edge cases, but it's a little weird.
Because if you have a number, if you have an
integer, there's a minimum that can be represented
and a maximum that can be represented. So you
test the minimum and the maximum in software.
But also zero is a special number because division
by zero really ruins your day. Okay. And that's
not an edge at all. It's this discontinuity in
the middle. So you can call it an edge case,
but it's not really an edge anymore. It's just
a special value. Division by zero is bad. One
is fine. Minus one is okay. Zero blows up. All
right. They can still call them edge cases, but
they aren't edges in the analog electronic sense.
They're a boundary between behaviors, but not
necessarily a minimum or maximum. So now you
get self -driving cars and they say, well, there's
edge cases, okay? And then, so software in general
mutated edge case from a value -based thing to
being, well, it's a rare combination of conditions.
And the self -driving car guys wholeheartedly
embrace this. They say edge case is a rare combination
of conditions. Now, there's an intuition here
that breaks, okay? If you believe that the testing
conditions represent the environment precisely,
then you can say that you should be able to handle
everything that's common correctly and the only
thing left are the things that are rare. Right.
Right? And the things that are left that are
rare are probably not simple things. They're
probably combinations of things. All right. So
you might see a stop sign on a pole. And you
might see a school bus. You might not have seen
a stop sign on a school bus, which means something
completely different than a stop sign on a pole.
Yeah. Right? Okay. And so you can call those
edge cases if you want, but it's no longer the
original meaning. It's rather unique combinations
that you sort of haven't dealt with. Now, if
you believe that you're diligent and always fix
everything you see the first time you see it,
that there's a failure, then what you expect
is edge cases that you fail on to be rare. But
that's not what we're seeing. What we're seeing
is failures of things that happen all the time,
right? And there's some intuition. If it's rare,
then people wouldn't have thought of it. That
intuition is broken in the notion you fix them
all is broken. So we're seeing things like floods
and construction zones that robotaxis, autonomous
vehicles struggle with, even though they've seen
them a bunch of times. They just haven't really
fixed it. And by the way, it's very challenging
to fix. But saying, well, it's an edge case,
so we're going to ignore it. Well, we're back
to scale. If you have 10 robotaxis, in fact,
there's a story from Waymo's early days back
when they're Google. They didn't worry about
construction zones because they're so rare. Are
you kidding me? You know, I'm in the Northeast
where there's two seasons. There's winter and
road construction. Exactly. I'd like to live
in that part of the country. But they're in California
where they don't get to get winter road damage
and a bunch of other things. And also with 10
cars, maybe road construction is relatively rare.
OK, so this is the other thing people say, well,
it can't be an edge case because I've seen it.
Well, if you have 10 cars and you haven't seen
it from the point of view of a computer, it's
an edge case because it's never seen it. Right.
But people have a lot more awareness and also
people learn by hearing stories and reading news
articles, which cars learn by they if they've
taken on the road. So there's there's two fallacies
that arise here. Well, it's an edge case, so
it's rare. So it doesn't matter. I'm sorry. Now
there's three. Oh, I'm on a Python skit. One
is just because it rare is rare doesn't mean
it's not severe. Power outages, earthquakes,
sure, they're rare, but that doesn't mean you
can ignore them because they're rare because
it isn't about frequency. It's about risk. And
risk is a combination of severity and frequency
in its basic form. OK, the next one is just because
you haven't seen it doesn't mean you shouldn't
expect it. I have no idea how many I'm going
to come up with. I'm just going to keep spitting
them out, okay? I'm loving this. Just because
you haven't seen it doesn't mean you can't expect
it. There's this standard, UL4600, that lists
all this. Did you think of this? And part of
the reason is so you can fix it before you actually
mess up in the real world, okay? Another one
is even if you have training data, if you don't
have enough training data, it may sort of dissolve
into the statistical noise. You may not learn
the less you need to learn. Okay. So, you know,
if you have one bad day and a bunch of good days
and you're 99 .9 % accurate, well, yeah, that's
because you ignored the bad day. That's a problem.
See the previous comment about severity, right?
And in other words, so there's a bunch of issues,
but when people say it can't be an edge case,
they're thinking if they've seen it, it's not
an edge case. And I understand that's intuitive,
but it's... They're thinking they haven't seen
it's an iEdge case. And the car companies are
saying it's rare, so it doesn't matter. They're
ignoring severity. But what you have to look
at it is from the point of view of the car. The
computer in the car, either it knows how to do
something or it doesn't. Right? It's either trained
or it's not. And so if it gets something wrong,
that means from the car's point of view, it's
an iEdge case. It's something it hasn't seen
enough to learn the lesson. And it could be a
very common scenario where we're all like. Duh,
we know how to do that. In the early days, we
found that people wearing yellow were an edge
case. Why is that? Because it hadn't trained
in rain and it hadn't trained in construction
zones. And that's where people wear yellow. Other
than yellow raincoats and high -vis vests, you
don't see a lot of yellow on people, right? Yellow
must mean road sign because people don't wear
yellow. Why? Because I've never driven in the
rain and I don't drive in construction zones.
If I wear yellow, I look like the sun. So I now
wear bright blue instead of yellow. It's just
one of my personal quirks. Oh, no. The bright
blue raincoat, not the yellow one. There's not
a lot of bright blue in nature, right? Yeah,
there's not, but at least it's blue. You know,
at least they don't look like a road sign. Right.
But this is a problem that I run into with kind
of the Silicon Valley mindset where it's this
very myopic view, whereas if I haven't seen it,
it doesn't exist. And they're the ones training
these babies. This is almost a religion in the
data science. machine learning community and
engineering and a bunch of other things. There's
like in the agile, they say, well, you're never
going to don't put in something you don't need
because you're not going to need it later. Only
do stuff you care about. Right. And so in data
science, I've seen a number of folks say, well,
what is it? The data was set you free. Only look
at the data, ignore everything that isn't in
the data because it's not in the data doesn't
exist. And if what you're trying to do is build
a web app and get it up and running. And, you
know, and if 1 % of users aren't served the 99
% payer bill, I get why you look at that. But
again, that ignores severity, right? So, yeah,
we finally come down to my definition of an edge
case. It is no longer minimum or maximum or combinations,
okay? An edge case, the only definition that
works is an edge case is something the car has
not been trained to do well enough. There's not
enough training data. Now, you may say that's
sort of a circular argument. It's like, well,
that's where they forced us by using all these
excuses, right? Sure. You know, an edge case
is something that needs more training data to
fix, assuming more training data will fix it,
which is a whole different discussion, okay?
Yeah. Now, if you look back at Administrator
Morrison's letter, what's interesting is he's
not saying, he's not actually saying edge cases
are okay or edge cases are bad. What he's saying
is... Stop using edge case as an excuse because
we don't buy it. So he's not weighing on what
an edge case might be or might not be. What he's
really saying is calling it an edge case doesn't
get you off the hook. And that's fair. I completely
support that. Saying, well, it's an edge case.
What are we supposed to do? It's like, well,
if it's a high severity edge case, you're supposed
to fix it before you go on the road or have a
plan. Why don't they have a... Just a very simple
heuristic built into these systems. Say, hey,
if you come across something you don't understand,
move to a minimal risk condition. Well, they
kind of do, but it's not working. Well, with
like road flooding, they claim that's an edge
case and they're like, let's drive through it,
which is. I mean, isn't it a how do you know
what you don't know type of question there? Yes,
exactly. So what they're doing, different rant,
also an article that I did. I had five articles
that really hit a lot of current topics with
Junko Yoshida and I have this podcast, podcast
sub stack. Yeah, we need to push your podcast.
Yes, it's a great podcast. We'll have a link
to it. So this is extremely relevant because
one of my articles is edge cases. And what we
do is we have a podcast where I write an article,
we do a podcast, and then Junko writes an article.
You know, as a set, we hit five different topics
and one of them was edge cases, right? And we
had a guest. We had Kristen Poland from NTSB
on as a guest. That was amazing. We had historian
Peter Norton on as a guest and that was season
one. So yes, please put the pointer, plug it.
They're all there. And season two starts this
fall. We're going to have five more episodes
and we need to get guests and all this stuff.
So we're funded for another season for this fall
and then we'll see what happens. But going back
to edge cases, where we are is edge cases are
things where they don't have enough training
data to fix it, assuming more data can fix it.
And if you say you don't have enough training
data, well, then you need to get more training
data if it's high severity. It's that simple.
Claiming it's an edge case is a description of
why it failed. It's not an excuse. Well, it's
rare, so it doesn't matter. Well, you know, earthquakes
are rare. It doesn't mean... They don't matter.
Power outages are rare. Power outages are rare.
Floods are rare. This is kind of where the whole
thing gets discombobulated. We're talking about
events that are rare when whether something's
an edge case or not has almost zero to do with
the rarity of the event. It has everything to
do with whether the computer is capable of handling
it. In a perfect world. The unhandled edge cases
are so rare, you've never even seen them to train
on them. If you take a pure machine learning
approach, the way you look at it is you only
train on stuff you see. You don't go looking
for trouble, okay? And so in edge cases, the
stuff that hasn't happened yet, so you didn't
train on it, okay? And from a technical point
of view, I'm okay with that definition, but there's
two issues. One is there's stuff that has happened
that they still didn't train enough on. Right.
And the other one is if you care about safety,
you have to think about things that haven't happened
yet because it's not OK to kill someone to learn
the lesson if it was an obviously foreseeable
lesson. Right. I mean, there's some things you
just, wow, never thought of that one. The stuff
I've seen is like, well, didn't occur to me.
OK. And some of them are very subtle. So yesterday,
yesterday I was driving by a fire truck that
opened its doors and there were stop signs painted
on the inside of the cab doors. Oh, that's a
new one. Never saw that one before, but I get
it. I get, you know, they don't want you driving
past a fire truck while the crew's climbing.
It's like, okay, that's interesting, right? That
was an edge case for me personally. But, you
know, if I were in the AV business and I were
talking to firefighters, I hope I would have
noticed that when I was taking a station tour
and program my cars to stop for fire trucks and
the doors are open. Right. Yeah. And that's another
weird stop sign, right? It's not the same as
a stop sign. Okay. Different rant. Stop signs
have the following meanings. I can have more
fun by doing Q &A, but I'm mindful of time. I
have fun with journalists with this sometimes.
Okay. So one meaning of a stop sign, stop sign
on a pole in the ground means stop and then go,
right? Stop sign on a pole that is being held
by hand, but is not in the ground. as opposed
to a stop sign in the ground that has someone's
resting their hand on, completely different,
right? But if the stop sign is not actually planted
in the ground and just resting on the ground,
that means stop and stay stopped because that's
a construction worker directing traffic and you're
waiting for it to spin around at the slow, okay?
Another stop sign is a stop sign held by a person
on a paddle and that depends on if they're serious
about it or not. If they're serious about the
stop, you stop and say stop because that's the
school crossing guard. But if the stop sign is
sort of dangling by their side, they're not serious
and you ignore it. That's a tough one. But that
is the semantics, right? It makes you wonder
if we need to not reinvent. the vehicles to interpret
the stops, but reinvent the stop signs to be
more accurate, right? Like a stop go sign has
maybe a green border and the stop stop sign,
you know. But it's stop on both sides. So school
crossing guards, it has to be stop on both sides,
not slop slow, right? Okay. Now, you know, if
it's upside down by their side, it's pretty obvious.
People can figure this out. And if they're not
sure, they slow down and the guard, you know,
the guard's out in the middle of the road. There's
a bunch of contextual clues. But we're not done
yet. There's stop sign in a school bus, which.
Which never means stop and go. It either means
stop and stay stopped if it's rotated out. But
if it's flattened against the school bus, it
means disregard, even though you can see it,
right? Yep. Okay. So I was saying earlier, edge
cases are about contextual clues. I mean, you
thought a stop sign was just a stop sign. No
way, man. It's super complicated. Right. And
that's your stop sign. Let's explain people how
to yield. Okay. People wonder why you owe 4 ,600,
300 pages long. It's like, you have no idea how
much stuff you have to deal with for this stuff.
Oh my word. That one isn't even in there. It
just says stop signs. It's, but you're supposed
to know all this. You're supposed to figure this
out. I love that. So we know AVs are going to
continue to have this problem with edge cases.
It's not going away. It may be what they define
as an edge case. Yeah, well, I mean, it may be
the thing that prevents, you know, prevents the
industry from, I think it definitely is the thing
that's preventing the industry from moving as
quickly as their investors want them to. Yeah,
rare events, heavy -tailed rare events are the
technical thing, the biggest technical challenge
for the industry. And the biggest non -technical
challenge is acceptance of people, you know,
that they make mistakes and it gets complicated,
right? Yeah, and it looks like, you know, we're
not, I mean. judging by what we're continuing
to see as, you know, Waymo tests and as other
companies put their vehicles out on the road
to test, we're not seeing these events go down.
We're seeing them go up. Is there, you know,
I don't know, is this, is it a fundamental problem
to the future of autonomous vehicles here? Well,
well, kind of, yeah. Let me do my gas light if
I can. Yeah, good. We're going to go into that
next. Perfect. Let's tease it up. All right.
Let's do it. One of the things to be careful
of is if you have a constant failure rate and
you double the number of cars, you're going to
see twice as many bad things happen, right? And
so be careful saying we're seeing more events.
Well, is that because there's more cars? More
cars is different than the technology getting
worse, right? But if you're seeing more events,
it's clearly a failure of the technology to improve
fast enough. to keep the events under control
as they scale, right? Now, which brings me to
my gaslight. The gaslight, I thought about 10
ways to go at this, so I'm just going to take
a shot. We'll see where we end up, all right?
But the gaslight is the notion that geofencing
is going to solve edge cases, right? Well, doesn't
it just kind of ignore them? No, it just puts
them aside. Well, yeah. So I told you there's
a bunch of ways this goes, right? So this can
be interactive, but I have a certain place I
want to go, right? So one of the things people
say is, have said since the beginning, is if
there's something you can't do, geofence it out
or exclude it from your ODD. So if you don't
know how to do traffic lights, don't drive on
roads with traffic lights. Well, that makes sense.
Okay? Sure. I mean, interstate highways without
traffic lights is a viable way to deploy, right?
You don't have to do traffic lights on an interstate
highway, except for a few places. There's an
Indian reservation where there's a traffic light
in the middle of an interstate highway. Geofence
that guy out. Okay. But it's still viable because
that's a pretty well -characterized situation.
But then it gets trickier when you say we can't
do floods, so we're going to geofence out places
that are flooded. Or we can't do emergency response
scenes. We're going to geofence out emergency
response scenes. And the problem with that is
it takes time to set up the geofence. And when
you had 10 cars, it probably worked. When you
have a city flooded with cars, see what I did
there? You have a city flooded with cars, and
now there's floodwater, all right? The chance
of a car wandering into the area with the floodwater
in the next five minutes is quite high. Yeah.
Right. And so what we saw with Waymo is they
had a recall for floods and the recall didn't
work. OK. Actually, they had a fix for floods
and the recall didn't work and the fix didn't
work. I don't remember the exact sequence. And
the story they told in the I think was in the
recall letter, which was really interesting,
was, well, and I'm going to paraphrase and read
into it what was probably going on. OK, because
they. You know, they're always a little bashful
in these reports. Do not admit ever doing anything
bad. But apparently what happened was their plan
for floods was the cars still don't know how
to not drive into floodwaters. Their plan was
when the National Weather Service issues a flood
alert, they set up a geofence for low -lying
areas that are prone to flooding and tell the
cars to stay away. Well, that's not a bad thing.
You know, that's like a 90 % plus solution, but
it's not 100%. Yeah. I mean, it relies on accurately
mapping all the areas where floods might be occurring,
right? Which is tough. And their excuse for why
they drove into floodwaters, the Weather Service
didn't get the alert out until after the flooding
had started. And one of their cars drove into
it between the time the flooding started and
the alert went out. They didn't quite do it,
but, you know, blaming the National Weather Service
is not an excuse for driving into floodwaters.
No. They didn't actually say that, but they sort
of led you up in that direction, right? And we
also have seen stuff now, that one's documented.
We've seen school bus incidents go down in Austin,
but not eliminated. There was one that happened
in March, and now we're into summer break, okay?
And I speculate. because in fact, I said this
was a possible way to help things out back when
it was happening, was Austin's had an app, a
phone app for like 10 years that tells you where
the school buses are, which is great for parents.
You know, where's my bus? Oh, my bus is 30 minutes
late. I'm not going to go stand out in 120 degree
heat waiting for my bus, you know, wait till
it comes. It's a tracking. All the buses have
trackers and they track an app. And if I were
Waymo on day one, I would have said I'm having
trouble with buses. I'm going to do a mobile
keep out zone around every bus so I don't run
into them. But the app's not going to be perfect.
Transponders are going to die. You know, who
knows? Stuff goes wrong. So these kind of...
Keep -out zones for transient, mobile, things
that aren't a stop sign set in cement, right?
Even those change, but less frequently, right?
Things that are very, very variable. Doing keep
-out zones is like a B -plus kind of solution.
Yeah, it's only as good as the technology underlying
what's behind it, right? And the data, there's
always a response time to, well, we'll set up
a response for construction zones. Part one,
it may take a while. There may be delay and some
car is going to wander into it. OK. And part
two, sometimes there's ad hoc stuff that isn't
even reported to the city. A tree branch falls
down and somebody sets up a cone. It's not going
to be in the city database in 30 seconds. Right.
Or there's a big truck trying to back out of
a driveway and there's some folks in vests who
are directing traffic. And that's not going to
be in the city database. Right. And a water main
breaks is never going to be covered by the NWS.
Or a bridge, yeah, water main break or a place
that usually doesn't flood floods today because
reasons, right? You know, because it's winter
and there was a bunch of snow that melted. Who
knows, right? So it catches the majority of them,
but it doesn't catch all of them. So the gaslight
is anyone who says, well, we're going to have
a database and or. vehicle to infrastructure
or vehicle to vehicle warnings about weird stuff
that happens. And it's like a 90 % plus solution,
but it's not 100 % partly because it will never
be perfectly accurate. And partly because the
first car that gets there still has to deal with
something that it hasn't been told about. And
what if that first car is a river taxi? So if
you have a system that's like within a factor
of 10 of where you need it to be, it's really
good, but occasionally has trouble. Then arguing,
well, this central database gives us that last
factor of 10 that we need to squeeze out. Okay,
completely. It's going to reduce your exposure,
right? And maybe what's happened with Waymo,
again, speculating is maybe they're not running
past school buses because their system of keeping
away from them is pretty good, but it's not perfect.
And sure enough, one of the times it didn't work,
they ran past, one got caught. It tells me they
have more work to do. On the other hand, I'm
glad to see it wasn't dozens a month. That's
improvement. This is a good thing. But the gaslight
specifically is anyone who tells you that telling
cars what to stay away from is 100 % solution,
not buying it. I like that as your gaslight.
I think it's a very bold one because you did
come on this show months ago and we were talking
about the school bus problem and we're like,
yeah, we can just geofence school buses. So you've
essentially called yourself out a little bit
as a gaslight. I and everyone else have been
saying geofencing works and we were wrong. Yeah,
that's... I mean, I wouldn't want to say I was
wrong until we saw it, but it turns out in the
real world, it doesn't work. And we had a recall
based on it not working. Well, so everyone thought,
including me, that it was going to be good enough.
We're all wrong. I mean, that's going to be a
tough gaslight to beat. Michael, what do you
got? Well, I'm going with Waymo since Fred's
not here to do it. I'll take Waymo this week.
And Mike, I'm basically responding to a blog
post they put out. I believe it was last week
where July 7th, they are they are proclaiming
that not all miles are equal. Why time and location
matter when benchmarking autonomous safety and
touting a couple of, you know, once again. Hold
on, Mike. I didn't know that not all miles were
equal. Really? Really? Oh, come on. I mean, that's
my whole point here, Phil. You know, you were
going to win Gaslight, not anymore. This is nonsense.
Like NHTSA and everyone in the traffic safety
community have been looking at time and location
when looking at vehicle safety for decades now.
And Waymo is kind of coming out here and pretending
they just discovered this problem and they're
using it to benchmark their vehicles, despite
the fact that virtually everyone who has criticized
Waymo's safety data has pointed out. You know,
where and when they're conducting these studies
is a big part of the problem. So just for that,
I'll end briefly on this or quickly on this.
You know, this is nonsense. Waymo is pretending
to have discovered something that we've all known
about for decades and touting it as some type
of, you know, something they're doing in their
safety when, in fact, it's something they should
have been considering the whole time. This is
not some new discovery. They should have been
dealing with this for 10 years or more now. Since
Fred's not here, I have to ask, so Michael, does
this mean that miles in a Piggly Wiggly parking
lot are different than miles in other parking
lots? You know, since we do not federally track
at all miles in Piggly Wiggly parking lots, maybe.
What time of day is it? What season? What's the
weather like? Is the Piggly Wiggly open? Yeah,
it's a good point. It has the Piggly Wiggly closed.
I'm going to my gaslight is going to be just
like Michael. I'm not going to change, but I'm
going to slightly different perspective. And
this is going to be, as I mentioned earlier,
the myopic view of Silicon Valley software engineers.
If I'm not aware of it and I just discovered
it, I am Christopher Columbus. I've discovered
something brand new and I've dealt with this
for forever. I remember. 20 plus years ago, some
software engineer who was really well known said,
hey, I built this amazing web scraper using Ruby
on Rails and we'll go out and we'll pull down
all of your website content and do this thing.
And and my response was W get, which was just
like, yeah, this was built 20 or not that 10
years earlier, like all of this stuff has been
in there. And that's the view of unfortunately
what I see a lot with with engineers out in California
where they don't do. any sort of historical work
to see what came before, what tools already exist,
what information's there. So example - Is that
because if you didn't invent it, you can't sell
it? You don't even know if it's that cynical.
I think it's just lazy. It's not reading the
manual. It's a weird quirk of computer science.
So for example, if I was a Waymo engineer, if
I used a tool called Google, I could have put
in - Traffic crashes by time of day and city
study. And I discovered, hey, NHTSA has publicly
made all of this data that Waymo just discovered
online going back 15, 20 years. So that's my
gaslight is I stick with Michael and Waymo and
the lazy, lazy, laziness of people just to use
their own tools. That's my takeaway. But I'm
going to have to say that, Phil, you do win because
you, called out yourself as a gaslighter. Can't
beat that. Yeah, that's still pretty good. Yeah,
that's our gaslight rants. I wanted to go back
to one thing around edge cases before we leave
that. Because looking at it, you know, we often
talk about remote drivers here as well. Like,
is a remote driver... A potential solution, a
mitigation. What's the role of the remote driver
and the actual humans here who can, you know,
as a remote driver can go into a situation that
the computer and the vehicle can't properly interpret?
That may be a very common situation that a remote
driver can and assist the vehicle. I mean, are
remote drivers almost necessary at this point?
Yes. That was another topic joke when I covered,
but let me unpack that, okay? For years, I thought
that edge cases were the limit to being able
to deploy Robotaxis, that you had to solve edge
cases to deploy Robotaxis, and I just didn't
see how you could do it because of the statistical
issues. There's just so many rare things with
high severity. How do you catch them all? It's
like you're hunting Pokemon. You're playing Pokemon
Go. There's an infinite number of Pokemon. How
in the world do you catch them all? And the industry
was saying, well, we're going to catch enough
that we're going to just not sweat. If you go
from 40 ,000 people dead a year to 40 on U .S.
highways, people are going to suck up the 40
because it's a thousand times better. That was
basically their argument. And I said, I don't
see how you get there, but you're the guys spending
tens of billions of dollars. Maybe you get there.
They didn't get there. So they declared defeat
on edge cases. Edge cases have kicked their butt.
OK. They can't do it. So what was the plan instead?
The plan is remote assistance. That every time
there's an edge case, remote assistance comes
in to unpack their edge case and fix it for them.
That's the good news. And if they can make that
work, that's the only way we get viable robotaxis
anytime soon. Because edge cases, they just couldn't
solve them. So they use remote assistance. Remote
assistants are not a temporary one -year crutch.
They're a forever thing. Okay. Until they develop
artificial general intelligence, which doesn't
exist yet and won't exist. Probably in my lifetime.
Okay. We'll see. Not in my lifetime. I plan to
live a long time, but I still think. I'm not
that old. All right. So we're going to need remote
assistance forever. And that's okay because it
isn't about purity of autonomy. It's about making
a business case that you can deploy the technology
safely with few enough people you make a profit.
And I'm okay with that. All right. But here's
the catch. For this to work, I have an article
that goes into more detail. At a high level,
for this to work, three things have to happen.
The first thing is the car has to know it's in
trouble. All right. So you've reduced. Let me
come back to that one. First is the car has to
know it's in trouble. The second, it has to be
able to ask for help. And the third is the remote
person has to be able to help it. All three of
these are challenges. And we've seen all three
during the big blackout. We actually saw all
three of these things be a problem. Okay. So
the, and during 4th of July, actually during
4th of July, we saw all three of these, right?
So it has to know it's in trouble. Well, we saw
Waymo drive over fireworks because it didn't
know that it could catch it on fire. And it didn't
ask, presumably didn't ask for help. Okay. At
least some of these things, it's not asking for
help. It's just making a mistake. And we've reduced
the, it has to know how to drive safely everywhere,
which is an impossible problem. to the merely
extremely difficult problem if it has to know
when it doesn't know what to do, which you still
have to train it to know not what to do. But
there's a reason for optimism that knowing that
it's not in your statistical database is a different
question than, have you been trained on? Being
able to say, I'm not sure, is different than
saying, oh yeah, I know that thing I've never
seen and I'll get it right. So they have to...
The emphasis is no longer on training on everything.
The emphasis is on being able to, with extremely
high accuracy, know that it hasn't been trained
on it, ask for help, part one. Okay, this is
the only way robotaxis and autonomous trucks
are viable. The only way. Has to know when it's
in trouble. And I'm going to say every embarrassing
picture we've seen is a failure of one of these
three things. It drove into floodwater without
stopping and asking for help. Well, it didn't
know it was in trouble, okay? Part two is it
has to be able to get help. Well, if the communications
network is overloaded because 4th of July or
because earthquake or because blackout or because
whatever, flooding, it's not going to be able
to get a data link, right? And I'm told that
you can reserve dedicated bandwidth on data links,
but they don't do it because money. And by the
way, you have to worst case that, which brings
us to number three. which is even if it knows
it's in trouble and gets itself to a safe waiting
position before it gets in so deep it can't be
rescued, right, easily. And it has a data link
to a remote operator. The remote operator has
to, first of all, be there. So they have, I think
Waymo has a few dozen operators on at any time.
So if 200 robo -taxis all get stuck at the same
time because blackout, somebody's going to be
last. One of the emergency responder complaints
was they waited almost an hour for a remote assistant
to tell them to connect with them because they
were overloaded. Right. So so there has to be
enough of them. And so you need is a call center
problem. You know, your your crisis is important
to us. Please wait for the next available. Right.
It's where you end up. And so but but if people
can die and in cars in bad situations, you can
end up there. What do you need to do? Well, you
need you need to have a surge plan. To have surge
staffing for when the crisis hits and you can't
predict it, it's just all of a sudden, I got
200 cars, they're stuck. What's our plan? And
even if you do have the operators, they have
to have the ability to extricate the car. And
a lot of times that involves driving the car
out of the way, which is very tricky to do safely
remotely. And Waymo says, Waymo most of the time
says we don't do that. That's not true. They
have some operators who can do it, but they're
reluctant to use that for good reason. All right.
Well, so every time you see a firefighter or
police officer get in a Waymo and move it, that
means the remote operator wasn't able to fix
the problem. But if we if we want a million of
these things instead of 100 of these things,
they have to be good at knowing when they're
getting into trouble. There has to be the ability
to reach out to remote operators and the remote
operators have to have the ability to get them
out of the situation without waiting an hour
for a tow truck. Now, now, if you had a million
robotaxis. And one robot taxi a day somewhere
in the U .S. needed a tow truck. Human cars need
tow trucks, too. I'm OK with that. But that's
not what we're seeing. What we're seeing is at
a scale massive enough to really disrupt emergency
operations. And this is why NHTSA put out that
letter. Now, we've seen that with these. I think
it was in Texas where there's the police officer
trying to get into the Waymo and the Waymo operators
like, what's your name? What's your badge number?
Can you repeat that to me? And the cops like
open the door. I need to move this immediately.
What was your how do you spell your name? What
kind of shoes are you wearing? No, it should
be. Hold your badge up to the camera. OK, you're
good to go. Right. I mean, it's yeah, it's mind
blowing. So one more just update before we go
into recalls. We have an update on one of my
favorite topics. That's right. New York City
congestion pricing. So, you know, the big doom
and gloom New York City congestion pricing, it's
going to cause the end of humanity. And instead,
what they've shown is that traffic speeds have
improved, which is great. Congestion has dropped.
Traffic to restaurants and businesses has improved.
Now there's a study. I'm going to quote from
a Jalopnik article. A new academic paper published
on Monday found that ambulance travel times within
the congestion zone have improved by 63 to 70
seconds. adding to the laundry list of benefits
of congestion pricing. I hope it's not news to
you that traffic moves faster when there are
fewer cars on the road. And 60 to 70 seconds
doesn't sound like a lot, but when you're trying
to save somebody's life, that is massive. I've
spoken to first responders and they've said at
times the only time they've saved somebody's
life is because we pick them up and the hospital
was a block and a half away. They said if the
hospital was two blocks away, that person didn't
live. So another huge benefit to congestion pricing.
Have there been any identifiable negatives to
congestion? I mean, we've heard and talked about
a lot of the positives, but have we seen any
of the objections that were put in front of congestion
pricing when they were putting it into play?
I don't even hear. Have we seen any of that happen?
I don't even hear people complaining about the
fee. Like, that's the thing. And it's, you know,
it's nine bucks or whatever. I mean. I, I, I,
I personally don't hear any complaints about
it, except when I look at my easy pass bill and
wonder why my wife's driving into congestion
zone. Now, sometimes she has to on Saturdays.
So we heard a lot of objection to this idea when
it was being propped up and put into play. But
since then, it's really hard to object to. Yeah,
it's it's been great. I mean, New Jersey was
the biggest one who was objecting to it at first.
And I think they've, you know, their their governor
is kind of. Been quiet on it now because he's
like, oh, people on New Jersey transit buses,
their commutes cut, you know, 20 minutes. They're
not really going to complain. And with that,
let's jump into a couple of recalls. How's that
sound, guys? That sounds great. Sounds great.
First up, Kia, 462 ,869 vehicles, the 2020 to
2024 Telluride. And this is an external impact
with excessive force to the front power seat
side cover and or seat slide knob may cause the
power seat switch to become dislodged, internally
misaligned or otherwise damaged. And this can
lead to overheating of a seat motor, increasing
the risk of fire while driving or while parked.
Oh, no, that's not a good. Is this a park outside?
No, it's not a park outside. It was a. Oh, it
is a park outside. I think it is. I think we've
got two park outsides this week. Hold on. Is
this a pants on fire recall? Is that what I'm
hearing? It looks like it is. Yeah, your pants
will get on fire. Also, it looks like, you know,
an external impact with excessive force to the
power seat side cover and slots. I mean, yeah,
you bumped it. What else? What are they talking
about there? I assume if a car drove into you,
but in that case, you're parking outside at a
repair place. I think it's an edge case because
you bumped it. We could not possibly have ever
seen someone bumping it hard enough to do that.
No one has ever bumped a button in their life.
Next up, Honda 325 ,588 vehicles, the 2018 to
2020 Honda Odyssey. Water can enter the rear
view camera assembly. Yeah, I got you there.
It's a different rear view camera than we typically
seen, which is software. This one actually has
a physical cause, which is water and corrosion.
Again, edge case. No one water. You know, it
doesn't go to the path of least resistance ever.
OK, so this one looks like so owners owners are
going to hear about this in late August. I think
they've got to replace a part on the camera.
So this one. I think they're going to have to
get a difference. It looks like they are getting
a different supplier, Sony, to do a different
design for the component here. So that's actually,
they're getting that done pretty quick for a
new component in a little over a month. So compared
to the four recalls we looked at last week, where
owners may be waiting until mid -27 to get a
fix, this is pretty good. Yeah, well, Ford's
not having any recalls this week. And the last
recall, Chrysler. 12 ,592 vehicles, the 2026
Ram 1500. The premium headlamp assemblies may
experience intermittent parking lamps and daytime
running lights and illumination. What's happening
here? Their lights are going on and off. Parking
lamps and DRLs, which turn off or flicker when
not intended, may reduce. Okay. Yeah. Oh, so
it sounds like a short. This looks like another
one where they're going to have this. Similar
to last week where it's going to be a while.
Owners are going to get an interim notification
at the end of this month. But there is no final
notification date and no indication of when the
repair will be available. Oh, boy. And with that,
thank you, Phil, for joining us. I suggest everyone
go listen to the Phil and Junko on AV Safety
podcast. One of our favorites. You know, go to
autosafety .org and click on Donate. And next
week, Fred should be back. Is Fred back from
being a crash test dummy next week? Is he back?
I assume it depends on how the crash test goes,
right? Okay, fair enough. And with that, thanks,
everybody. We'll be back next week. Bye -bye.
Thank you. Bye. For more information, visit www
.autosafety .org.