In a 15 Jan 2021 article in EE Times (Electronic Engineering Times), automotive technology expert Egil Juliussen analyzed the 9 November 2020 advance notice of proposed rulemaking (ANPRM) from the National Highway Traffic Safety Administration (NHTSA) concerning autonomous vehicles.
What does it mean?
As stated on the NHTSA website, “Our mission is to save lives, prevent injuries, and reduce economic costs due to road traffic crashes, through education, research, safety standards, and enforcement.” Also, “NHTSA issues Federal Motor Vehicle Safety Standards (FMVSS) to implement laws from Congress. These regulations allow us to fulfill our mission to prevent and reduce vehicle crashes.” Thus, the purpose of this advance notice is to seek input on the development of FMVSS to regulate autonomous vehicles in a way that promotes safety.
The legal website Lexology provides a helpful summary of the ANPRM, noting that the NHTSA proposes to focus on the capabilities of the automated systems in four functions: sensing (receiving information), perception (analyzing that information to reach conclusions about what it sees), planning (making decisions), and control (actually driving).
What does it mean for you?
The most important statement in the EE Times article is this seemingly innocuous explanation of terms: “To describe autonomous vehicle hardware and software, NHTSA is using the terminology, `Automated Driving System (ADS).’ I will also use `ADS’ instead of autonomous vehicle (AV) in the rest of this column.”
If an engineer is designing an autonomous vehicle (AV), the assumption is that the vehicle will function within the existing driving infrastructure. The phrase Advanced Driving System (ADS) contains that wonderful word “system” suggesting a new approach in which the entire transportation system is changed to support autonomous driving.
As early as 2005, Automated Guided Vehicles (AGVs) were introduced into factories by laying down magnetic tape they can follow. While current versions do not require such support, they still function within a limited environment and their use is accompanied by five key rules: keep travel routes clear, never walk directly in front of an AGV, always allow them the right of way, stay out of the danger zone, and raised objects may not be recognized. Despite ambitious claims, the environment must still adapt to the AGV and it does not operate in the same environment as a human driven vehicle.
Thus, driving long distances could be more easily automated though designing lanes to be used by automated vehicles, as is being explored in Michigan (certainly an automobile friendly location) and other places.
One of the difficult parts of autonomous driving is to predict what other vehicles will do, especially ones being driven by humans. Limiting the environment to only automated vehicles provides an easier problem to solve. The word “system” also suggests coordination among automated vehicles, in which they share navigation information, but also share information about their intentions.
The NHTSA’s announcement of the ANPRM does not give any indication that NHTSA is thinking about the larger transportation system in their use of the phrase “Advanced Driving System,” since the announcement uses phrases like “ADS-equipped vehicle” implying that the system lies totally within the vehicle. Also, its definition of ADS (“the hardware and software that are, collectively, capable of performing the entire dynamic driving task on a sustained basis, regardless of whether it is limited to a specific operational design domain”) does not support the interpretation of “system” that I am using.
However, I confidently predict that automated driving will be successful – and safe – only to the degree that changes to the transportation system are made to support this new technology and to the degree that such vehicles are operated in autonomous mode only in environments that have been adapted to them.
Interestingly, the National Society for Professional Engineers (NSPE) issued a statement and several policy guides on autonomous vehicles which emphasizes the systems aspects embodied in the transportation infrastructure: professional engineers must have “a leading voice in ensuring that the same attention to safety and reliability that went into the built transportation infrastructure is incorporated into autonomous vehicles and smart transportation systems.”
The lesson is that every new technology requires changes to a larger system to be successful. Any decision maker contemplating the introduction of a new technology into an organization should always be asking questions about how that system – especially the humans in the system – will have to adapt to the technology.
Where can you learn more?
The Association for Unmanned Vehicle Systems (ah, there is that word again) is a professional organization supporting professionals in the field and publishes a magazine called Unmanned Systems.