This letter is designed to kill the company. That is a result I support, but, the people saying "This letter is designed to kill the company" are entirely correct.
I think that he could have gotten away with showing a substantial effort towards answering the questions and getting some kind of experimental license to verify the technology is viable, I emphatically do not believe that the goal was to 'kill the company' given that all these questions have - for the automotive industry - reasonable answers and that if Hotz was serious about this that he should not have been totally blindsided by this request.
If he was then he should probably have researched the space a bit better before embarking on the project, it's one thing to be a 'hot hacker' but it's quite another to go into this business without the required knowledge about what being in that business will entail.
Trying to imagine SpaceX/Elon Musk backing out of the rocket business because 'the paperwork is just too damn complicated and lawyers are no fun', ditto for Tesla, Google or any other party that is trying to re-vamp some branch of industry.
If the tech is for real the reporting requirements are a reasonable extra cost to be born by the company, the amount of money available for this tech would dwarf the cost of the reporting.
You can respond pretty much with anything that accurately answers the questions. If they want more detail, they can then ask for it.
I don't get where this strange idea that if he doesn't provide 100k pages, he's going to be subject to a fine immediately comes from. It's 100% completely and totally wrong.
If he literally answers the questions, he's fine. If they want more detail, they can ask for it.
The letter is not designed to kill the company, and the people who think so have probably never dealt with any regulatory agency.
My source on this, btw, is that i've dealt with many regulatory agencies many times.
They aren't psychos, even when they are adversarial.
To give you an example, when involved in a pretty adversarial issue with the DOJ, i cannot say they were anything but professional.
When the DOJ wanted more info on something we said "hey, can we just sit down for an hour and chat", and they'll usually say "great, let's do it", and then maybe they'll say a few weeks later "hey, thanks for doing that, we have some more questions about x, can we set up another hour" and so on. Are they always like this? No. (am i the most experienced person in the world? also no, it's also not what i do anymore at all, but this was my experience with pretty much every agency, every time)
But the vast majority of the time, they literally are just trying to gather info to decide what to do.
It's only when they are trying to actually get a particular result that things change. But you'll pretty much know when that happens, and this ain't it.
The only agency i've ever seen just be outright hostile is the CPSC.
The NHSTA, in my experience, is pretty much one of the most level headed and professional agencies you will find.
If you have actual evidence to the contrary, where they have "shut a company down", i'd love to see it.
https://www.nhtsa.gov/staticfiles/communications/pdf/Honda-r...
If I were one of his investors I'd be pissed right now.
This letter is designed to give pause to (e: previously I wrote "kill") a company operating with complete disregard for proper operations in a regulated industry.
We are in entire agreement, but people cannot believe in the superposition of this and "Oh that's just some simple questions from the regulator."
Edit to add: Quoted bit appears to have changed after my quote. I think the old version remains accurate.
I originally wrote "kill" to mirror your original comment, but I changed it because it (as I perceive the word) presumes a level of intent that I don't think NHTSA operates with: I don't think that NHTSA has any intent to destroy this company. In fact, if comma.ai reached out to NHTSA, I would expect NHTSA to assist (within reason) in answering the letter.
I do think that these are straightforward questions for a group that has its act together. Part of having one's act together in a regulated environment is maintaining open lines of communication with regulators, so that questions would be asked should come as no surprise. Keeping up to date with the regulatory environment would also be expected, and given the recent autonomous driving publication the content and scope of these questions should come as no surprise.
If these questions kill the company, I don't see that as being the fault of NHTSA, I see that as being the fault of whoever is in charge of regulatory affairs at comma.ai.