Uber: Use ‘a simple, effective policy’ before Pa. task force plan on self-driving car testing becomes official

One official wants a new definition of driver, fewer demos to go to PennDOT and less data collection by the state.

Uber's unveil of driverless cars to Pittsburgh passengers.

Uber's unveil of driverless cars to Pittsburgh passengers.

Jared Wickerham/ For The Incline
MJ Slaby

If PennDOT wants a policy on self-driving cars now, an Uber official says they should keep it simple and not follow the recommendations of a state task force right away.

When the state does take those recommendations into consideration, the same Uber official —Shari Shapiro, Uber’s head of public affairs for Pennsylvania and Delaware — has “several substantive concerns” with the draft and advised changes to the definition of driver and to remove proposed requirements for some demonstrations and PennDOT’s ability to collect milage data.

On Tuesday, the state’s Autonomous Vehicles Testing Policy Task Force gave its report to PennDOT Secretary Leslie S. Richards. The recommendations focused on safety for human drivers in other cars, as well as keeping self-driving car development and testing in Pennsylvania.

The proposed recommendations from the task force depend on future legislation. An online public forum is scheduled for 7 to 8 p.m. Dec. 12 before more public feedback is collected on final recommendations through Jan. 12.

Uber’s response

An Uber spokesman declined to comment Tuesday, but the 96-page document of task force recommendations includes comments from Shapiro. She is one of two Uber employees on the 20-person state task force. The other is Ashwini Chhabra, head of policy development for Uber. General Motors, which bought self-driving car software Cruise Automation earlier this year, is also represented on the task force by GM Director of Public Policy Jeffrey Perry.

Uber rolled out its pilot offering self-driving cars to riders in Pittsburgh in September.

Shapiro’s comments make up five pages of a 21-page appendix titled “other viewpoints” which are comments —mostly from task force members — “submitted at the conclusion of the process. These statements are included within the report for future evaluation and discussion.”

In the comments, Shapiro had “several substantive concerns with the current draft policy” and asked PennDOT to go for “a simple effective policy” if they want one now.

She stressed that the task force’s work was “worthwhile and will help expedite efforts to implement any later-adopted legislation.” But it should be set aside until there is legislative action, Shapiro said.

Her suggested policy was two parts: First, that PennDOT “supports and encourages” self-driving car testing in the state. Second, that the term “driver” should include an automated driving system as well as a human. Her feedback also addresses multiple areas of proposed PennDOT oversight.

These are the highlights:

Cars are people, too

At several points in her feedback, Shapiro’s comments repeat that the definition of driver should include the automated driving system as the driver in some circumstances. It also asks that for the purpose of the policy, “person” includes an automated driving system in the definition.

“We believe the relevant laws have flexibility and that there are reasonable interpretations that the law does not require a driver in every vehicle, and would not require any such driver to be a natural person,” Shapiro’s comments read.

More demos, more burden

Shapiro expressed concern about demonstration requirements when the vehicles are updated to handle new conditions: “A demonstration whenever the HAV (highly automated vehicles) is able to operate in new conditions would be quite burdensome.”

The Uber official goes on to write that PennDOT’s ability to request a demonstration to investigate a complaint or ensure legal compliance would be enough in that case.

Don’t restrict platooning

The recommendations restrict platooning “to two commercial or three passenger vehicles,” but that can expand based on a request from the testers to PennDOT. Shapiro said that shouldn’t happen.

Platooning is using “equipment, device, or technology” to allow for one or more self-driving cars  to operate autonomously “while coupled or joined to a lead vehicle via a wireless connection in a caravan or motorcade.”

‘Commercially sensitive information’

Shapiro also advised that PennDOT doesn’t need to collect the total number of miles and hours because they “do not provide any relevant data regarding the safety issues that PennDOT would be overseeing and could reveal commercially sensitive information.”

Jump to page 55 to read Shapiro’s comments: