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California DMV code 227.02 defines an autonomous vehicle as one that has a remote operator, and 227.38(b)(1) demands a continuously maintained and monitored two-way link from the operating business to the vehicle, even when not being operated.

https://www.dmv.ca.gov/portal/file/adopted-regulatory-text-p...

I didn't see any language demanding that the vehicle become inoperable in a cellular dead zone, but if their paramount concern is to shield themselves from liability, then having the car disengage is one way to ensure that.

For residents of San Francisco that were personally affected by this, consider writing a polite note to the DMV asking them to ensure that this incident is included in this winter's upcoming disengagement reports (227.50) from Cruise, and share your point of views — both on how you expected autonomous vehicles to behave when cellular communication is disrupted, and on whether you think that the existing guidelines are sufficiently clear about that scenario. <autonomousvehicles@dmv.ca.gov>




> I didn't see any language demanding that the vehicle become inoperable in a cellular dead zone, but if their paramount concern is to shield themselves from liability, then having the car disengage is one way to ensure that.

If I block a bunch of roads with cars I am violating CVC, at least once per car, and would get fined every time. I'd also possibly get penalties on my license.

For example, say I'm driving down the road and start feeling tired. I realize that it's unsafe for me to continue driving. Can I just stop where I am and have a nap and claim I have shielded myself from liability?


CVC violations and license penalties are not liabilities. Both you and self-driving cars should earn penalties for that behavior, and honestly I'd like to see Cruise ticketed for the CVC violations documented above.

However, by coming to a stop in the middle of the road and having a nap, you are maximally protected from any damages or harm you might otherwise incur. If someone runs into you, they will be partially at fault; and, as you are stopped, you cannot run into someone else. From a purely selfish standpoint, that would be a completely appropriate choice to make.

Fortunately, the points system used in California for individual drivers issues penalties for non-harmful, non-destructive violations so individual drivers will still be penalized for taking purely selfish actions (like parking in the middle of the street, though YMMV region-to-region). There are too many drivers and not enough workers at the DMV to converse with every individual about their year of 'disengagements' while on public roadways, for the DMV to define protection of the commons by "once a year, we ask you for a self-audit of your fuckups", as they do with autonomous driving companies today.

I don't have an opinion on whether that is the best possible outcome or not right now — but it's as close as I can describe how things are today, and why you should not expect to minimize liability like an autonomous vehicle does without penalty. I hope this is of some use to your question.


Yeah, I’ve wondered if Cruise and Waymo get tickets for this stuff. But if they do, paying them is probably not a big expense for these large companies.


What, if any, fine or other punishment is Cruise expected to receive?


I don't know, as it wasn't interesting to me; and, I don't recommend contacting the DMV for retaliatory purposes. Others are welcome to speak to this if they know more, though.

Personally, I want to see the DMV define expectations for autonomous cars with respect to interrupted cellular service, so that Cruise and others cannot simply just park in the middle of the street as the selfish-lowest-liability choice. It's possible the DMV will define an expectation of the car coming to a stop, or continuing to operate for up to five minutes, or whatever.

I also feel like Cruise's disengagement report has a chance of containing materially-interesting data around why they disengaged — for example, can their cars operate without a cellular connection at all, or are they dependent on The Cloud?


> Personally, I want to see the DMV define expectations for autonomous cars with respect to interrupted cellular service

The rules for self driving cars should be at least the same as for people. If things differ at all, it should be making them harsher - people get a heavily restricted degree of latitude as we recognize human brains suffer fatigue, etc but computers don't suffer those issues.

Similarly liability (civil and criminal) for dangerous, unsafe, or simply incorrect driving shall be with the driver. With a self driving vehicle, that is the manufacturer. The whole reason for the "driver must pay attention while self driving" is to liability shift from the manufacturer of an unsafe product to the purchaser.


I agree that "stopping in the middle of the street" should be discouraged. Certainly one solution is to remove the liability for continuing to drive. Another is to increase the liability (if insufficient) for stopping in the middle of the street.




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