California Department of Motor Vehicles discusses the future of self-driving cars

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Autonomous technology based on relationships
with manufacturers, academics, law enforcement,
and other regulators
Interview with Brian Soublet, Department of Motor Vehicles
Brian Soublet is the Deputy Director and
Chief Counsel with the California
Department of Motor Vehicles (DMV) - a
service oriented organization and state-
level government agency with a high
amount of public contact and visibility.
Mr. Soublet is responsible for creating a
process for companies like Google,
Nissan, Mercedes Benz, and the rest of
the automakers to test out cars that
feature autonomous technology and for
regulations that will govern how the
public can operate these cars.
Mr. Soublet, what is your role at DMV California and how are you involved with
functional safety and self-driving cars?
Each Division of the DMV is headed by a Deputy Director. I am the Deputy Director of
the department’s Legal Affairs Division and the Chief Counsel. The Legal Affairs Division
is responsible for the DMV’s regulation of the automotive industry.

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This includes implementing the discipline imposed on occupational licensees such as
automobile sales people, automobile dealerships, and automobile manufacturers.
We also provide legal advice and perform in-house counsel services that include
drafting and analyzing legislation, legal research, advice on policy and procedure,
major procurement actions, contract review, and liaison with the California Attorney
General's Office on civil cases in which the department is a party. I provided the legal
advice for the drafting of California’s autonomous vehicle regulations and I supervise
the process of getting those regulations approved and implemented.
My involvement with functional safety is directly related to the work we are doing to
craft regulations for the general deployment of automated vehicles on public roads.
California law requires automobile manufacturers to apply to the DMV for a permit to
deploy automated vehicles. That application process includes certifications by the
manufacturer that the vehicle’s automated technology is safe and meets federal motor
vehicle safety standards.
There are no federal motor vehicle safety standards, consequently the department
needed to find a way to determine that automated vehicles are safe for deployment
and we began to look into things like independent third party certification and
exploring the concept of functional safety as a mechanism for determining whether a
vehicle is safe for deployment on public streets.
What is the biggest concern for California DMV with all emerging driving technologies
and their future applications, more specifically self-driving cars?
Our biggest concerns are: whether the vehicles are safe for operation by the general
public; how the vehicles will be secure from cyber-attacks; how private information
related to the operators and owners will be treated; and, how the vehicles will adapt to
changes in the law.
ISO 26262 has been described as the “state-of-the-art standard” when it comes to
Functional Safety for automotive vehicles even though best practices of the industry are
legally irrelevant.

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Based on your experience, how does the standard practically support the
manufacturers in case of a product recall in the States?
Since early 2013 we struggled with the concepts of “self-certification” and “third party
certification.” In the United States the National Highway Traffic Safety Administration
(NHTSA) is responsible for regulating the safety of vehicles. NHTSA sets the safety
standards and vehicle manufacturerscertify that they meet those standards. However,
NHTSA has not developed safety standards for autonomous technology, so we began
to question whether we should simply accept a manufacturer’s certification of safety or
whether we should have some independent third party step in and certify that the
vehicles are safe.
Image below: Brian Soublet with concept car Mercedes-Benz F-015:

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We soon learned that the problemwith third party certification is that we would have to
come up with the standards that the third party would be using to measure the
performance of the vehicles.
We began looking at ISO 26262 as the foundational standard for determining safety;
however weunderstood it to be a standard for functional safety in automotive systems
design that assumes there is a driver in the vehiclecapable of taking control. California
law contemplates that there may be systems that do not rely on a driver inside the
vehicle, moreover manufacturers are already using 26262 in design process.
We believe that there must be a safety regime that assures that risk assessment has
been completed and the safety design carried out, so we are now thinking that the
focus should be on whether the manufacturer has a process and procedure to identify
and assess potential harms caused by malfunctioning behavior and to develop and
implement strategies to mitigate those hazards. I can’t speak to how 26262 would
support a manufacturer in a safety recall, mainly because the DMV is not involved in
safety recalls.
In the upcoming conference, we will be hearing from you about regulating the
deployment of autonomous vehicles on public streets. What shall we expect to hear
from you?
Car and Driver magazine described our efforts to promulgate regulations for the
deployment of autonomous vehicles on public streets as “daunting and
unprecedented.” You will hear about how the California took on that task. You will get
an explanation of what the enabling statute enacted by the California legislature
requires the DMV to include in the regulations and how some of those requirements
have been challenging to meet.

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I will explain the process that we have used educate ourselves about autonomous
technology based on creating relationships with manufacturers, academics, law
enforcement, and other regulators. You will also get a preview of what we are
considering to include in the deployment regulations.
Mr. Soublet, thank you very much.

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California Department of Motor Vehicles discusses the future of self-driving cars

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California Department of Motor Vehicles discusses the future of self-driving cars