Oh I came across this. More nuanced than most stuff I have seen.

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Brinda A. Thomas, Ph.D.
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Data scientist and policy advocate
May 15
A Closer Inspection of Tesla’s Autopilot Safety Statistics
Source: Tesla, Inc.

The automotive industry is at the beginning of a grand experiment. If
completely successful, humanity could be ushered into a new economy
<https://www.sfchronicle.com/news/article/Robot-cars-may-kill-jobs-but-will-they-create-12410820.php>where
driving is a hobby, only for sunny days along clear roads with a view. The
struggles and tedium of the daily commute could be handled by autonomous
vehicles, traffic accidents could fall to nil, passengers could focus on
working and relaxing in their mobile offices, and the elderly, disabled,
and blind could have considerable mobility and autonomy. If a complete
failure, automobile companies would have invested billions of dollars in
computer vision, sensors, and automated driving systems only to have no
effect on or actually increase the number of traffic accidents and
fatalities by introducing new risks. This would cause a public backlash,
and requiring regulators to impose a slow, costly review process that slows
the pace of innovation so that after an initial roll-out to a few hundred
thousand vehicles, further roll-outs are halted. Then, autonomous vehicle
technology may follow the same path as the U.S. nuclear power industry,
which has stopped building new power plants since the Three Mile Island
accident in 1979. Which scenario or whether something in between unfolds
depends on good design, as well as careful understanding and communication
of the safety of autonomous driving technology and the path from partially
autonomous to fully autonomous vehicles. And understanding the safety of
autonomous vehicles (AV) is a very thorny statistics problem.

Recent fatal and injury-producing crashes involving vehicles with Tesla’s
Autopilot and Uber’s self-driving pilot have led to significant
disagreement among experts, reporters, automakers, and regulators about
safety statistics for partial autonomy technologies[1]. Tesla, in
particular, has made recent headlines after two crashes and 1 fatality with
its Autopilot-equipped partial autonomy vehicles in the past few months.
Tesla claims that its technology is 3.7x safer
<https://www.tesla.com/blog/update-last-week%E2%80%99s-accident> than the
existing U.S. vehicle fleet, stating a fatality rate of 1 death per 86
million miles for conventional vehicles versus 1 death per 320 million
miles for Autopilot-equipped vehicles, but many experts question the
methodology and data behind these statistics. In this article, I’ll review
the data, methods, and the three main criticisms of Tesla’s methodology for
conventional vehicle fatality rates, provide my best estimates, and make
recommendations for regulators and automakers on the safety of autonomous
vehicles. I don’t have access to data to verify the fatality rate for Tesla
Autopilot-equipped vehicles but the company has promised to release public
Autopilot safety data in future quarters.

*1.* *What’s* *an Autopilot mile?*

One informal complaint I’ve heard among analysts is the question of which
miles should be included as an ‘Autopilot mile’ in Tesla’s statistic of 1
fatality per 320 million miles. Some analysts argue that one should only
compare miles driven in a vehicle with Autopilot engaged to manually-driven
vehicle-miles to obtain a fatality rate. Instead, Tesla’s methodology
includes all miles driven with an Autopilot-enabled vehicle, whether or not
the functionality was engaged.

I agree with Tesla’s methodology on Autopilot mileage because the road
conditions under which a partial autonomy system is rated for operation
(highways, clear lane markings, etc) are systematically different from
manually-driven miles. If one only used Autopilot-enabled miles in the
fatality rate calculation, a comparable baseline of miles for a manual
vehicle driven under similar road conditions would be difficult to obtain
and there are already considerable gaps in the vehicle mileage data needed
to compute good partial autonomy safety statistics (more below).

Because the characteristics of manually-driven miles in Autopilot-enabled
vehicles are very different than the miles driven in a manually-driven
vehicle — more curves, poor lane markings, rain or poor-visibility weather,
etc. — it could be possible that crashes are *more*likely to occur when an
Autopilot-enabled vehicle turned over operation to the driver, because road
conditions were worse. If that hypothesis were true, these types of crashes
should be included as an Autopilot crash, as it pertains to the road
coverage of Autopilot and the hand-off between autonomous and manual
control, which is related to Tesla’s design choices.

So, unless the owner of an Autopilot-enabled vehicle never or rarely chose
to enable the functionality, the proper comparison for fatality rate safety
statistics should be made between Autopilot vehicles and all other vehicles.

*2.* *What are comparable vehicles and fatalities?*

Another criticism
<https://www.csmonitor.com/Business/In-Gear/2016/1014/How-safe-is-Tesla-Autopilot-A-look-at-the-statistics>
of
Tesla’s Autopilot safety statistics is aimed at its choice of comparable
baseline vehicles in the 1 fatality per 86 million miles statistic.
Analysts believe this statistic was obtained from the Insurance Institute
for Highway Safety (IIHS)’s general statistics
<http://www.iihs.org/iihs/topics/t/general-statistics/fatalityfacts/state-by-state-overview/2016>
on
fatal crashes, which includes all fatalities (driver, passenger,
pedestrian) from accidents by all vehicle types (automobiles, pickups and
SUVs, trucks and buses, motorcycles, etc), to arrive at a 2016 total rate
of 1.16 fatalities per 100 million miles, or 1 fatality per 86 million
miles. Criticisms that this is an ‘apples to aardvarks’ comparison are fair.

There are two main factors that contribute to vehicle fatalities: the
number of crashes per vehicle, and the number of passengers or pedestrians
involved in each crash[2]. While the number of crashes per vehicle is
related to Autopilot design, the number of passengers in the vehicle is
essentially random. The ideal calculation of the fatal crash rate statistic
should be the ratio of any crash with one or more driver, passenger, or
pedestrian fatality to the number of miles traveled per vehicle. In
addition, vehicles of similar classes should be compared, i.e. large luxury
sedans vs. the Model S, large luxury SUVs vs. the Model X, and mid-size
luxury sedans vs. the Model 3, as the demographics and driving patterns of
drivers of these sub-classes of vehicles should be similar.

Unfortunately, these ideal data are not reported by the IIHS, which either
reports all fatalities, not broken out by vehicle sub-class, or driver-only
fatality rates <http://www.iihs.org/iihs/topics/driver-death-rates> by
vehicle models and sub-classes. If one uses the overall rate of 29–32
driver deaths per million vehicle-years for all vehicles, and 11,000
<https://www.afdc.energy.gov/data/10309> miles driven per year per vehicle,
that corresponds to a driver fatality rate of one per 340 million to 380
million miles[3]. However, the fatality rate for any crash that included
pedestrian, passenger, or driver deaths could be higher. According to the
2016 IIHS crash death by type
<http://www.iihs.org/iihs/topics/t/general-statistics/fatalityfacts/gender>
statistics
just under 60% of vehicle fatalities involve a driver, when including all
vehicle types but excluding fatalities involving truck drivers/passengers,
bicyclists, and motorcyclists. If so, the fatal crash rate could be one per
210 million to 230 miles if we included vehicle crashes with other types of
fatalities. But we don’t know for sure because the IIHS doesn’t track fatal
crash rates by vehicle, only driver death rates. By this last estimate,
Autopilot has about the same to 35% lower fatal crash rates than any
conventional vehicle at this time.

Why does my estimate differ so much from Tesla’s reported baseline for
conventional vehicles of 1 in 86 million miles? Partly because Tesla
includes all deaths for all vehicle types for conventional vehicles which
is not a fair comparison with Autopilot-equipped vehicles, and partly
because that simple arithmetic calculation should not be used because it
doesn’t tell the whole truth and misses the bigger business and public
policy problem.

*3.* *Lies, Damned Lies, and Statistics*

If life is a simulation, a simple arithmetic calculation of the miles per
fatality statistic is the outcome of a single run, a single roll of the
dice. If a butterfly flapped its wings in China and an autonomous vehicle
accident occurred earlier or later in time, a snapshot of the miles per
fatality statistic calculated immediately after an accident would cloud our
crystal ball. That one fatality per 320 million miles statistic for
Autopilot should really be calculated using the same methodology (called
Poisson regression) that IIHS used to determine the driver fatality rate of
29–32 per million vehicle-years for conventional vehicles. A Poisson
regression is used to model independent random events in time, like fatal
accidents, as a function of exposure, such as miles traveled per vehicle to
obtain a probabilistic estimate of fatality rate. However, IIHS was only
able to obtain a narrow range of driver fatality rate estimates (29–32 per
million car-years) for the entire population of vehicles in the U.S. The
driver fatality rates for some less-common vehicles makes and models
(including some of the large luxury vehicles that could be compared with
Tesla Autopilot-enabled vehicles), while shown on the IIHS website, have
such large (confidence interval) ranges that the average driver fatality
rate figures are useless for decision-making.
Source: RAND Corp
<https://www.rand.org/blog/articles/2017/11/why-waiting-for-perfect-autonomous-vehicles-may-cost-lives.html>
.

Policymakers, automakers, and the general public need to get comfortable
with the uncomfortable fact that over 8 billion of miles
<https://www.rand.org/pubs/research_reports/RR1478.html> will have to be
driven with partially-autonomous vehicles before we have statistical
confidence that autonomous vehicles are 20% better than humans, according
to RAND[4]. In the short term, we cannot be certain that partially
autonomous vehicles are safer than drivers, but automakers and customers
who think the technology can improve over time will take a risk to invest
in it or use it.

There are consequences in delaying the roll-out of autonomous vehicle
technology. RAND has developed a useful decision analysis tool
<https://www.rand.org/blog/articles/2017/11/why-waiting-for-perfect-autonomous-vehicles-may-cost-lives.html>
to
allow anyone to compare the timing of a partial-autonomy roll-out, the
safety of the technology (from half-as-safe to almost perfect), and the
lives saved over the course of several decades, assuming that by 2060,
almost perfect fully-autonomous vehicles are rolled out to the majority of
the vehicle fleet in the U.S. This model shows that rolling out just as
safe or a little safer partially-autonomous vehicles by 2020 will save
160,000 more lives over 50 years than a scenario that waits until 2025 to
roll out almost perfect autonomous vehicles. Delaying the roll-out of
partially-autonomous vehicles costs lives. This conclusion assumes that (1)
automakers make steady progress in improving the safety and reliability of
their partially autonomous vehicles and (2) drivers are comfortable enough
with monitoring the partially-autonomous vehicles so that new sources of
error associated with the transition to and from manual and autonomous
control do not increase fatality rates. Automakers and regulators should do
everything to verify and ensure that these assumptions are true. RAND finds
that the most lives can be saved if partially autonomous vehicles are
rolled out after they are 10% better than human drivers, and from the
publicly available data, Autopilot appears to be performing at least at
that level, if not better.

*Recommendations for Regulators and Automakers*

NHTSA has been a strong supporter of the transition to autonomous vehicles
throughout the years because of its potential benefits for safety and
productivity for all and increased mobility for the disabled, blind, and
elderly. It would be highly beneficial to development of autonomous vehicle
technology if NHTSA coordinates the collection and analysis of safety
statistics using the Poisson regression methodology used by IIHS for
conventional and partially autonomous vehicles. These statistics should be
developed for the specific vehicle classes that are likely to see partial
autonomy features in the coming years, i.e. mid-size and large sedans and
SUVs. These data are vitally important so that the automotive industry and
the general public know where partial autonomy technologies stand relative
to conventional vehicles, so that individual drivers can make informed
purchasing decisions.

Similarly, automakers should collect and report on safety statistics on
partially-autonomous vehicles, including counts of fatal and non-fatal
crashes, airbag deployments, fender benders, near-misses, manual overrides
of vehicles, as well as miles driven with autonomy-enabled vehicles and
non-autonomy-enabled vehicles. Over time, as vehicle fleets gain enough
mileage, safety statistics could be computed using the Poisson regression
methodology.

According to RAND’s study, ‘developers of this [partial autonomy]
technology and third-party testers cannot drive their way to safety’ with
small fleets of ~100 vehicles driving 24 hours a day. Large-scale trials of
100s of thousands of vehicles would have to operate for multiple years
before to obtain the mileage necessary to have confidence in better than
human performance of a partial autonomy system. Researchers have proposed
simulation and testing approaches of hardware and software to obtain
autonomous driving safety data without on-the-road mileage. For example,
Mobileye has been developing open-source rules
<https://arxiv.org/pdf/1708.06374.pdf>for how a partially-autonomous
vehicle should handle the 37 main pre-crash cases in NHTSA’s accident
database
<https://www.economist.com/science-and-technology/2018/05/12/how-do-you-define-safe-driving-in-terms-a-machine-can-understand>.
Functional testing to ensure that partially autonomous systems follow these
rules would help to clarify system capabilities for drivers and limit
manufacturers’ liability (though some legal experts question this approach
<https://medium.com/@safeselfdrive/the-blame-game-mobileyes-mathematical-formula-for-av-safety-proves-only-that-self-driving-cars-b2c2b109bef7>).
Regulators will have to work with manufacturers to develop and review these
alternative safety tests and adapt regulations accordingly on the road to a
self-driving future.

Notes: The author is a data scientist, former Tesla employee with no
involvement with Autopilot development, and holds TSLA stock. This article
was written with no input from Tesla. All views are my own.

[1] Some companies (e.g. Waymo/Google) argue that partial autonomy systems
will never be safer than human driving and promote the development of fully
autonomous vehicles, complete with no steering wheel, only. That debate is
outside the scope of this article.

[2] Treatment of crashes involving pedestrians is not just a statistics
problem, it is a legal problem outside the scope of this article. With
conventional vehicles, the driver is fully responsible for pedestrian
crashes, but with partial- and fully-autonomy vehicles, the liability and
insurance costs is a shared responsibility between drivers and automakers
depending on the level of autonomy claimed or achieved. This is an area
that requires a lot of further study and the development of custom
insurance products.

[3] Note that the correct number to use of this type of analysis is
vehicle-miles traveled per vehicle, as opposed to vehicle-miles traveled
per licensed driver as in Figure 4–4 in this FHWA reference
<https://www.fhwa.dot.gov/policyinformation/pubs/pl08021/pdf/onh_chap4.pdf>
(because
people could drive multiple cars), or vehicle-miles traveled per capita
<https://www.enotrans.org/article/vmt-hits-nominal-high-approaches-time-per-capita-mark/>
(because
not all people drive), to quantify the exposure to the risk of a fatal car
accident per vehicle.

[4] Less on-the-road mileage is needed if safety statistics on other types
of road accidents, like non-fatal crashes, fender benders, and near-misses
can be obtained. However, data on minor accidents and near-misses are
spotty.

   - Self Driving Cars
   <https://medium.com/tag/self-driving-cars?source=post>
   - Safety <https://medium.com/tag/safety?source=post>
   - AI <https://medium.com/tag/ai?source=post>
   - Regulation <https://medium.com/tag/regulation?source=post>
   - Policy <https://medium.com/tag/policy?source=post>

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180
Responses
Applause from Brinda A. Thomas, Ph.D. <https://medium.com/@mc2maven>
 (author)
[image: Go to the profile of David Ng] <https://medium.com/@dng_16133>
David Ng
<https://medium.com/@dng_16133?source=responses---------0-31--------------->
May 18
<https://medium.com/@dng_16133/just-looking-at-averages-might-be-sufficient-for-policy-decisions-but-as-a-driver-i-want-to-know-39d45c1d80e6?source=responses---------0-31--------------->

Just looking at averages might be sufficient for policy decisions, but as a
driver, I want to know a little more. For example, I tend to drive
defensively. Let’s say that a Tesla equipped with Autopilot is 10% safer
than the average driver, but I’m 100% safer than the average driver. In
that case, if I owned a Tesla, I would be safer driving with…
<https://medium.com/@dng_16133/just-looking-at-averages-might-be-sufficient-for-policy-decisions-but-as-a-driver-i-want-to-know-39d45c1d80e6?source=responses---------0-31--------------->
Read more…
5
2 responses
<https://medium.com/@dng_16133/just-looking-at-averages-might-be-sufficient-for-policy-decisions-but-as-a-driver-i-want-to-know-39d45c1d80e6?source=responses---------0-31---------------#--responses>
Conversation with Brinda A. Thomas, Ph.D. <https://medium.com/@mc2maven>.
[image: Go to the profile of RTG] <https://medium.com/@artigarg>
RTG
<https://medium.com/@artigarg?source=responses---------1---------------->
May 16
<https://medium.com/@artigarg/brinda-great-summary-of-many-of-the-issues-involved-in-gauging-autopilot-safety-1fd207cfc8cd?source=responses---------1---------------->

Brinda, great summary of many of the issues involved in gauging autopilot
safety. A couple of things come to mind:

   - As with most transportation safety concerns, transitions — in this
   case autonomous to manual — are the gravest source of error. There are
   well-known case studies of aircraft accidents that occurred because of…

<https://medium.com/@artigarg/brinda-great-summary-of-many-of-the-issues-involved-in-gauging-autopilot-safety-1fd207cfc8cd?source=responses---------1---------------->
Read more…
1 response
<https://medium.com/@artigarg/brinda-great-summary-of-many-of-the-issues-involved-in-gauging-autopilot-safety-1fd207cfc8cd?source=responses---------1----------------#--responses>
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Brinda A. Thomas, Ph.D.
<https://medium.com/@mc2maven?source=responses---------1---------------->
May 16
<https://medium.com/@mc2maven/hi-good-points-brought-up-ef49d6634461?source=responses---------1---------------->

Hi — good points brought up. Aircraft autopilot systems are a good case
study for partially autonomous vehicles, and that industry has invested in
a lot of simulation training for pilots to manage the hand-off between
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passenger vehicles because outside of the driver’s license test and…
<https://medium.com/@mc2maven/hi-good-points-brought-up-ef49d6634461?source=responses---------1---------------->
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David Ng <https://medium.com/@dng_16133>
Just looking at averages might be sufficient for policy decisions, but as a
driver, I want to know… I’d be curious to know how a Tesla with Autopilot
compares to a driver with a comparable automobile if that driver is in the…
[image: Go to the profile of Brinda A. Thomas, Ph.D.]
<https://medium.com/@mc2maven>
Brinda A. Thomas, Ph.D.
<https://medium.com/@mc2maven?source=responses---------2---------------->
May 26
<https://medium.com/@mc2maven/a-distribution-is-also-important-for-policymakers-so-that-would-be-a-better-way-to-show-iihss-c56d95e9f1c0?source=responses---------2---------------->

A distribution is also important for policymakers, so that would be a
better way to show IIHS’s safety statistics. Individual drivers should also
be able to view the distribution, and make risk assessments about their own
safety vs. an autonomous system for themselves. (Accurately or not — you
know the saying about everyone thinking that they’re an above average
driver…)
<https://medium.com/@mc2maven/a-distribution-is-also-important-for-policymakers-so-that-would-be-a-better-way-to-show-iihss-c56d95e9f1c0?source=responses---------2---------------->

On Fri, Jun 1, 2018, 7:33 AM Curt Raymond <curtlud...@yahoo.com> wrote:

> On the one hand I can't disagree with you on the safety front, our species
> is singularly bad at accurately judging risk, look at all the people afraid
> to fly but willing to drive for instance.
>
> On the other hand I like driving and some joy would be lost should I not
> be able to. Also how is a self-driving car going to deal with my cabin 3/4
> mile from the road?
>
> As for heavy traffic, our poorly designed cities and lack of public
> transport are largely to blame. When I go to LA I end up driving from LAX
> to Burbank which takes too long in the best of times. I'd love to be able
> to take the train but its so terribly inconvenient its actually easier to
> drive. Someday when the rail extension to the airport is done it might be
> feasible, I look at it each time I'm there and it seems like progress is
> being made but only when measured against the fact that I've been making
> this trip for a decade, the month to month progress seems to be essentially
> zero...
>
> -Curt
>
> On Friday, June 1, 2018, 1:42:04 AM EDT, Karl Wittnebel via Mercedes <
> mercedes@okiebenz.com> wrote:
>
>
> The bar is set fairly low in terms of human controlled car accident rates
> and humans coping with unexpected failures.
>
> There seems to be a greater willingness to accept human errors than machine
> errors. Not sure this is entirely rational.
>
> Humans are really bad drivers. If a machine can do it reliably better then
> bring it on. When I am old, I dont think I will be saying I wish I spent
> more time driving. The best car is the one you never have to drive, so you
> can spend your limited time on earth doing more interesting stuff.
>
> Think of all the consciousness wasted by people sitting in stop and go
> traffic, concentrating on the bumper ahead. And the negative effects on
> stress and mood. What a drain on humanity.
>
> Why is a human running a red light and t boning me so much better than a
> machine doing it? Or a machine wrecking my car instead of me somehow worse?
> What matters is the overall performance across the population vs current
> technology.
>
> Ultimately the costs and benefits of these things will speak for
> themselves. I'm pretty sure the machines are already better. Waymo has
> driven millions of miles on public roads now. Fiat just sold them another
> 20k minivans to use as driverless taxis. You dont buy 20,000 minivans
> unless you are pretty sure about what you are going to do with them.
>
>
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