At risk of being snarky, I'm not sure 'engineering company' is the right moniker. They're an R&D shop making bleeding edge research available on a homebrew platform that can interface with recent vehicles to provide a level 2/3 driver assistance package.
The stuff required to pass the regulators is the long, slow, boring process of pushing reliability and failure modes into "safe" territory, while documenting the fact. This is the 'engineering' part. Making a system that works (probably, most of the time) isn't engineering, it's hacking.
They are hackers. Geohot, the founder did iPhone and Play Station jailbreaking in the past. I wouldn't buy any safety critical equipment from them.
They motto could be literally: go fast and break things.
Regulatory capture is a thing. Regulators, at least in part, exist to maintain a barrier to entry for any new players trying to enter a field dominated by large players.
Several major tech companies only exist because they broke rules in their early days. And most people agree the outcome was a net benefit to society.
Next time you drive, look around you at some of the other drivers. The ones with cell phones in their hands are more dangerous than someone with a comma.ai dev kit.
Fun story: I wanted to build a hypermilling coach/trainer system about 10 years ago and got to the point of having a poor mans ACC in a Scion. It didn’t brake though, only coasted to lose speed (thus requiring driver input). So I got the wild idea of tapping into the electronic brake distribution system to apply brake pressure when I needed to slow down. I figured out the system and was ready to tap into it when I had a dream that night. I was on the highway and all of a sudden two wheels decided to lock up from braking too hard. I stopped all testing on that car on public roadways after that.
My current car is hacked to provide lane centering when lane assist is on, but it’s still operating within the bounds of the factory electronic steering (so it can’t self drive/make 90 degree turns)
As are people with 15 year old rusted hoopties, drivers who had a fight with their significant other, disagreement with a colleague or whose sports team just lost, drivers who slept poorly the last few nights, drivers who are ill and taking cold medicine, cars with lamps out, worn tires, worn ball joints, bad shocks, no ABS, no vehicle stability control, etc.
I’m okay with enthusiasts repairing and modifying their cars and driving them on public roads, because I’d rather have that than a world where only certified cars, maintained at certified dealers, using only certified parts are permitted on the roads.
Maybe you're not a "car person". Apply the same principles to whatever field you have passion for. Only certified Intel parts may be added by Intel technicians to Intel computers, which must run only certified operating systems. Or only certified Edison lightbulbs may be added to certified Edison light fixtures by certified Edison technicians. Only certified firmware may be run on devices you're being allowed to rent from the certified manufacturer.
> but it’s still operating within the bounds of the factory electronic steering
That's Comma AI's approach. Their hardware spoofs the stock computer so it can send commands to the car's active safety systems. So there are some stock limitations, like the steering torque, that openpilot doesn't bypass.
That's true, but how much oversight is really applied to the existing software systems on modern vehicles? Did national regulators review the design and coding on the electronic stability controls? I doubt it. Is the CAN bridge between the entertainment system and the critical systems bus (with ABS, ESC, power steering etc.) suitably hardened to protect against hackers (hint: no.) Who has reviewed the electrically assisted power steering?
Most things in a modern car are controlled by software that's far more opaque than OpenPilot. Don't get me wrong, a lot of their software and hardware architecture choices scare the heck out of me, but at least it's transparent.
You're already driving on roads shared with garbage solution like tesla's '''autopilot''' this thing is no different other than the creators not being able to afford the regulatory bribe to deploy it.
It's a completely different product with a much wider number of configurations that end-users have to piece together from Wiki pages and packages they download themselves, loaded onto hardware they've installed in their cars with zero oversight from anyone qualified.
> end-users have to piece together from Wiki pages and packages they download themselves
Which makes it a ton safer than '''autopilot''' because by the time those users are done installing it they have a pretty clear understanding of its capabilities and limitations.
vs. the endless videos of morons driving tesla in '''autopilot''' mode with hands off the wheel because it's an incomprehensible black box of magical self-driving capability for them.
The regulator hasn't stopped tesla autopilot from causing accidents. It's just a competitive moat.
Comma is bragging about 6 million miles drive. Tesla's Autopilot has over 2 billion miles driven. This has two cameras (EDIT: and apparently 1 radar that already exists in the vehicle). Tesla's has 12 cameras, 12 sonars, and 1 radar. This is backed by a company that apparently has received $8 million in funding. Autopilot is backed by a company with a market cap of $84 billion. You are welcome to your opinion of Tesla's product, but if that is garbage, I can't image the word you should use to describe this because the two products are in no way comparable.
You're listing specs which are a proxy for how much money the incumbent has, and saying that the regulatory barrier should be set at those specs for some reason.
None of those specs give any indication to the relative safety of the two systems though. And this is exactly what incumbents want. They want a small player to have to match their massive cash holdings to enter their market, even if the small player has a better product.
Here's some food for though: Tesla has been slapped with multiple lawsuits for misleading advertising of Autopilot. Regulators all agree that Autopilot is just an SAE level 2 system, same like those found on much cheaper cars with far less hardware and none of the marketing oversell.
I listed miles driven. That is a direct indicator of safety.
I also listed the number and type of inputs each system has. This might correlate with money, but it clearly also correlates with safety. One simple example, it is impossible for the Comma system to have 360 degree visual coverage of what is around you with just two cameras in the locations they are in.
You are already sharing a road with people who are constantly distracted, drunk, or other. I would say the roads would be a much better place if there were more people who had a computer driving them.
On one hand yes, on the other the company wouldn't exist. Regulators are important, but they also serve incumbent interests as they raise the barrier to entry for newcomers. It's a way to pull the ladder up behind you once you've achieved success. I don't know how we can better balance those seemingly conflicting aspects.
Aaaaand that's why Americans need to pay 500 bucks for an insulin injector pen while Indians pay 10 bucks for the same device.
The problem with regulatory capture and arguing it's a good thing, is that there's a downside/cost to the barrier it creates. And often that downside outweighs the upside.
To be clear, no one is arguing regulation shouldn't exist. Just that the nature of regulation is to be captured by incumbents and serve a purpose orthogonal to protecting the people.
I didn't say regulatory capture is a good thing. I said that barriers to entry can be good in certain instances. In the instance of medical devices, the problem in the US has nothing to do with barriers to entry. If you can drive across the border to Canada and buy an identical product for a fraction of the price it would cost in the US, that isn't because the barrier to entry is too high in the US. The product already exists and is being produced, it just costs more due to a broken healthcare industry.
No, Americans are paying 500 bucks for a pen precisely because of regulatory capture. None of the manufacturers of the cheaper version have been successful in jumping the regulatory barrier to entry which the incumbents lobbied for, and tens of thousands of Americans suffer for it each year.
I have a hard time believing e.g. most european countries have less regulation in the medical sector than the US. Probably less corruption/"lobbying" (because corporate campaign distribitions are more strictly regulated in most other countries), but corruption quite different from regulation, even if both affect how law gets written.
> Aaaaand that's why Americans need to pay 500 bucks for an insulin injector pen while Indians pay 10 bucks for the same device.
I can't speak for insulin injectors, but I know for a fact that the reason Indian pharmaceuticals are often times massively cheaper is because they ignore patents by which the majority of the world abides.
Now in many cases, the patent system is set up for incumbents who have enough legal muscle to develop and patent isomers, metabolites, or "extended release" versions of successful drugs which are losing their patent privileges. But that's not the whole story. We know that some patents and copyrights are needed to encourage investment in R&D.
India (used to?) just blindly copy drugs, ignore paying royalties, and take the profits. I haven't ever been on any blockbuster meds developed natively in India. Have you?
Taking another angle, when it comes to a product that could so easily save a net of 10s of thousands of Americans every year once fully developed, barriers to entry might be counter-productive.
(I’m actually fairly bearish on level 5 self-driving being “close”, but if it was, speeding that up would almost surely be worth throwing the switch on the trolley tracks for both the lives saved and the reduction in wasted attention of those who would have otherwise used a lot of their lifetime driving.)
I can never really understand this argument. Why can't we carefully craft regulations to scale in their burden with the company's ability to bear said burden in some way? Scale with revenue or head count numbers? Similar to how income at the lowest bracket isn't taxed, to lessen the burden on people much less able to pay.
Because (a) then you'd end up with things like pacemakers designed by sole operators because their regulatory burden would be that much lower than what a biomedical engineering firm would face, and (b) any such system would be trivial to game anyway.
We can, but usually it's the established encumbents who are helping draft the language of the legislation (which is better than politicians with no expertise working alone) and they are not incentived to encourage the kind of regulation you propose.
The stuff required to pass the regulators is the long, slow, boring process of pushing reliability and failure modes into "safe" territory, while documenting the fact. This is the 'engineering' part. Making a system that works (probably, most of the time) isn't engineering, it's hacking.