> The correct response is not to throw a tantrum and shut everything down.

I think the correct response is to work with them 110%. Having that government body happy with you isn't a bad thing - you could become the reference spec for self-driving if you please them to an appropriate degree.

> > they can and will close down his business if they feel like it

> That's the textbook definition of 'regulation'.

Right, and it's one of the big problems I have with this form of regulation.

I think it violates the idea of "Rule of Law", as opposed to "Rule of Man", which was one of the major factors behind the rise of modern free society.

Can you explain? You seem to be implying that you believe that the NHTSA is capriciously making demands of Comma but not to other similar companies in a similar stage of market-readiness.

They certainly could, which is part of my point. Whether they do or not depends on the honesty, bias, and personal ambitions of the people running the agency.

The empirical experience is that regulatory agencies over time gravitate towards favoring the big established players in the industry they're regulating.

The economist term is "Regulatory Capture".

You seem to be critiquing the idea of a government run by people and the idea that congress can defer rule making authority to people more educated in the particulars of an industry than the congress at large.

I'm fine with government run by people.

Giving some people a lot of discretionary power of others does worry me a lot. It might well be unavoidable sometimes, but it's really naive to not see the potential for abuse.

The calculation needs to be "if this agency is run by the usual corruptible and imperfect people like you and me, will it be a net gain for society?", rather than the "assume a selfless set of civic minded experts..." mindset I think a lot of people have.

> honesty, bias, and personal ambitions of the people

As long it's humans that write and execute laws, this is strictly unavoidable. It doesn't depend on the particular details of how we do regulation.

Under Rule of Law, one set of humans write the laws. If you break them another set of humans decide on your guilt and punishment.

Set 1 (legislators) can and do write laws to favor and disfavor individual actors, and I agree that that is in part unavoidable.

Set 2 (judges and juries) are appointed randomly after it's become a legal matter, so it's impossible for any inappropriate influence in either direction before that.

And there is no "set 3" of regulators that issue orders during the day-to-day running of the business.

So I think you're right that this problem always exist, but in my estimation it's a few orders of magnitude bigger under a "Rule of Man" regulation scheme.

> no "set 3" of regulators that issue orders during the day-to-day running of the business

You mentioned 2 branches of government, the legislative and judicial. But the third branch, the executive, does (in part) exactly what you described above.

Taken to the logical extreme, your view means we should replace every government adminstrator with a court, including for mundane decisions like whether to grant a marriage license. That system would be horribly inefficient and probably not much more consistent or effective since random people off the street won't have the domain knowledge a regulator has.

Also, regulators are representatives of the people and are subject to laws just like everyone else. The escape hatch of the legal system is always available -- if you think the regulator got it wrong, then take it to a court, and a judge and jury decides who is right.

The marriage license argument is textbook strawman. That is not regulation of an industry, and you know it.

I agree, but you proposed a stringent definition for 'Rule of Law' that seemed to eliminate the possibility of government regulators possessing independent decision-making authority over citizens and businesses alike.

I mean, how do even mundane things like zoning codes and work permits work in this universe where there are no regulators and gov't bureaucrats? Everything must go through a court? Why are you so sure a group of 12 random people will come to decisions more effectively than a bureaucrat in a domain that requires specialized knowledge?

In any case, I fully agree that sometimes regulators, or regulations are bad. But this particular case is an example of regulation working as designed. The NHTSA has been at the forefront of working with the self-driving car industry to make sure there is a legal path to developing, testing, and releasing this tech. Textbook example of regulators doing their job without imposing undue burdens on the regulated industry.

> how do even mundane things [...] work in this universe where there are no regulators and gov't bureaucrats?

I talked about regulators. You added bureaucrats on your own.

Perhaps NHTSA is a great organization. I know nothing about them specifically. I'm talking about general principles.

> Why are you so sure a group of 12 random people will come to decisions more effectively than a bureaucrat in a domain that requires specialized knowledge?

I'm saying they'll be more impartial. Don't know about effective.

Not quite. Regulatory capture doesn't mean you like the big companies, it means you like the industry you regulate. So if you regulate coal mines, you probably think coal mines are good, whether they're large or small. If you're a highway regulator, it probably means you think highways are pretty awesome, but that doesn't mean you think only Detroit muscle cars should be allowed on the highway.

How do you think regulations get enforced?