Related, but not linked. Regulations:
[3]
https://www.dmv.ca.gov/portal/file/adopted-regulatory-text-pdf/
So, starting from [3], which contains the regulations that define what "disengagement" means. Point 227.50 defines the concept and the reporting associated with it. Now
@Doggydogworld , from what I can see under [1] and [3], there's a lot of Waymo vehicles that operate under the DMV permits and there seems to be a mix of driverless and "with test driver" reported as per DMV regulations.
This DMV web page has links to their different AV programs and permits. If you follow the links for "Testing with a Safety Driver" and "Driverless Testing" they show requirements to report collisions and disengagements. But the
Autonomous Vehicle Deployment Program page has no such requirements.
Your Regulations PDF spells out the Testing Program collision and disengagement reporting in sections 227.48 and 227.50 on pages 17 and 18. Scroll down a bit further to page 20: "Article 3.8. Deployment of Autonomous Vehicles" and you'll see no such reporting requirements. Once you graduate from Testing to Deployment you stop reporting disengagements and collisions to DMV (you have to report collisions to NHTSA, though)..
Also note p18 of your PDF defines disengagement as "a deactivation of the autonomous mode .....". So even if the deployment program required disengagement reporting, it would not cover the Fleet Response events
@Usain is talking about because the vehicle stays in autonomous mode.
Now, even considering the different reporting regulations for the CPUC vs DMV (which I'm not clear on yet),
CPUC is a whole different bureaucracy with different hoops to jump through. They mostly deal with fares. Companies will sometimes deploy free Robotaxis to the public under their DMV Deployment permit, but to charge fares you need deployment permits from both DMV and CPUC.
.....there is still, in my opinion, enough information in the DMV reports to be able to compute a "miles driven between disengagements under city conditions" for Waymo. It might not be all the vehicles, but it's over ~250 of them.
Lots of issues here. First, as noted above a Fleet Response interaction and a disengagement are two completely things under DMV rules. Disengagement is a safety thing - e.g. safety driver jerks the wheel or hits the brake to avoid a collision or the vehicle pulls over and bricks itself until human help shows up. Fleet Response is the car asking "are the two left lanes blocked" and a remote human clicking Yes or No. The autonomous system never disengages. Cruise at least early on was rumored to have a FR event every few miles, but their disengagement reporting was something like once every 30k miles.
There's another issue. Once you Deploy you almost certainly still run a Testing Program to validate new s/w releases, expand the geofence, etc. Testing is designed to push the envelope. It should trigger far more disengagements per mile than normal driving.
Tesla avoids all this bureaucracy for now. They are several years away from deploying robotaxis in CA. IMHO they'll first deploy somewhere in Nevada.
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