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	<title>
	Comments on: NHTSA to mandate accelerator overrides	</title>
	<atom:link href="https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/feed/" rel="self" type="application/rss+xml" />
	<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/</link>
	<description>Chronicling the high cost of our legal system</description>
	<lastBuildDate>Fri, 27 Apr 2012 16:24:49 +0000</lastBuildDate>
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		<title>
		By: Fox 2!		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-153191</link>

		<dc:creator><![CDATA[Fox 2!]]></dc:creator>
		<pubDate>Fri, 27 Apr 2012 16:24:49 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-153191</guid>

					<description><![CDATA[David Schwartz

So long as the mandate only applies to new designs, it will have near-zero cost

No, the cost accrues whether it is for new cars or for retrofitting existing vehicles. It may not be called out as a line item in somebody&#039;s budget and schedule, but the cost is there and allocable to that function. Functions, requirements and lines of code are countable, and industry standard cost models will tell how much and how long it took to implement them.]]></description>
			<content:encoded><![CDATA[<p>David Schwartz</p>
<p>So long as the mandate only applies to new designs, it will have near-zero cost</p>
<p>No, the cost accrues whether it is for new cars or for retrofitting existing vehicles. It may not be called out as a line item in somebody&#8217;s budget and schedule, but the cost is there and allocable to that function. Functions, requirements and lines of code are countable, and industry standard cost models will tell how much and how long it took to implement them.</p>
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		<title>
		By: Mannie		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-153160</link>

		<dc:creator><![CDATA[Mannie]]></dc:creator>
		<pubDate>Fri, 27 Apr 2012 14:23:12 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-153160</guid>

					<description><![CDATA[This just makes used cars more attractive.  I keep saying my next &quot;new car&quot; is going to be a 57 Chevy.  I can still work in them.  I can&#039;t identify half the parts on a new car.]]></description>
			<content:encoded><![CDATA[<p>This just makes used cars more attractive.  I keep saying my next &#8220;new car&#8221; is going to be a 57 Chevy.  I can still work in them.  I can&#8217;t identify half the parts on a new car.</p>
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		<title>
		By: David Schwartz		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-153048</link>

		<dc:creator><![CDATA[David Schwartz]]></dc:creator>
		<pubDate>Fri, 27 Apr 2012 06:34:28 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-153048</guid>

					<description><![CDATA[Fox 2! That would be  a good argument if we were talking about mandating it be added to existing cars. So long as the mandate only applies to new designs, it will have near-zero cost. (And near-zero benefit, because anyone designing  a new throttle system today would likely include it anyway if for no other reason than to avoid having to justify to a jury why you didn&#039;t include it.)]]></description>
			<content:encoded><![CDATA[<p>Fox 2! That would be  a good argument if we were talking about mandating it be added to existing cars. So long as the mandate only applies to new designs, it will have near-zero cost. (And near-zero benefit, because anyone designing  a new throttle system today would likely include it anyway if for no other reason than to avoid having to justify to a jury why you didn&#8217;t include it.)</p>
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		<title>
		By: Fox 2!		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-152997</link>

		<dc:creator><![CDATA[Fox 2!]]></dc:creator>
		<pubDate>Fri, 27 Apr 2012 02:58:06 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-152997</guid>

					<description><![CDATA[Bill Alexander

&quot;it just takes a small amount of computer code to accomplish the lockout&quot; 

This will be what DO-178 calls Level A code - life critical. Which is not cheap, even for a single line. And no Level A function is carried out in a single line of code. This will probably require 5 to 10 requirements, 50 to 100 lines of code, 20 hours of reviews, and probably 50 hours of test development and qualification testing. Plus additional testing on every  computer produced. And that assumes that all the functionality can be incorporated into one computer. Double or triple that if two or more computers have to be involved (e,g., throttle/brake pedal monitoring, fuel injection, anti-lock brake module). 

There is no such thing as a &quot;simple&quot; code change.]]></description>
			<content:encoded><![CDATA[<p>Bill Alexander</p>
<p>&#8220;it just takes a small amount of computer code to accomplish the lockout&#8221; </p>
<p>This will be what DO-178 calls Level A code &#8211; life critical. Which is not cheap, even for a single line. And no Level A function is carried out in a single line of code. This will probably require 5 to 10 requirements, 50 to 100 lines of code, 20 hours of reviews, and probably 50 hours of test development and qualification testing. Plus additional testing on every  computer produced. And that assumes that all the functionality can be incorporated into one computer. Double or triple that if two or more computers have to be involved (e,g., throttle/brake pedal monitoring, fuel injection, anti-lock brake module). </p>
<p>There is no such thing as a &#8220;simple&#8221; code change.</p>
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		<title>
		By: Bill Alexander		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-152951</link>

		<dc:creator><![CDATA[Bill Alexander]]></dc:creator>
		<pubDate>Thu, 26 Apr 2012 23:50:53 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-152951</guid>

					<description><![CDATA[Actually, on fly by wire cars, which I expect they all are or soon will be, it just takes a small amount of computer code to accomplish the lockout. If that part of the computer fails, it will probably be during a complete computer failure, at which time the car goes into a get to the side of the road mode.]]></description>
			<content:encoded><![CDATA[<p>Actually, on fly by wire cars, which I expect they all are or soon will be, it just takes a small amount of computer code to accomplish the lockout. If that part of the computer fails, it will probably be during a complete computer failure, at which time the car goes into a get to the side of the road mode.</p>
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		<title>
		By: Jim Collins		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-152923</link>

		<dc:creator><![CDATA[Jim Collins]]></dc:creator>
		<pubDate>Thu, 26 Apr 2012 22:06:22 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-152923</guid>

					<description><![CDATA[So what happens when the accelerator lockout malfunctions and causes an accident?  I have always been taught that the KISS (Keep It Simple, Stupid) principle is best.  Now the addition of a lockout just increases the number of possible malfunctions, without adding any real benefit.]]></description>
			<content:encoded><![CDATA[<p>So what happens when the accelerator lockout malfunctions and causes an accident?  I have always been taught that the KISS (Keep It Simple, Stupid) principle is best.  Now the addition of a lockout just increases the number of possible malfunctions, without adding any real benefit.</p>
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		<title>
		By: Ron Miller		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-152917</link>

		<dc:creator><![CDATA[Ron Miller]]></dc:creator>
		<pubDate>Thu, 26 Apr 2012 21:37:37 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-152917</guid>

					<description><![CDATA[DEM, the clear point of my post is that they are not all the same.   Few people agree there should be no oversight and not safety criteria for cars.   There is sharp disagreement to be sure.  But it is entirely accurate to say that most people believe there should some standards even those who are generally against standards elsewhere.  Why?  Because information about what is safe  is not perfect or linear and having someone set minimal standards is necessary.   

If you disagree, it does not mean you are wrong and it hardly forecloses discussion of the matter.  Nothing I have said suggests or implies that it does.]]></description>
			<content:encoded><![CDATA[<p>DEM, the clear point of my post is that they are not all the same.   Few people agree there should be no oversight and not safety criteria for cars.   There is sharp disagreement to be sure.  But it is entirely accurate to say that most people believe there should some standards even those who are generally against standards elsewhere.  Why?  Because information about what is safe  is not perfect or linear and having someone set minimal standards is necessary.   </p>
<p>If you disagree, it does not mean you are wrong and it hardly forecloses discussion of the matter.  Nothing I have said suggests or implies that it does.</p>
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		<title>
		By: Ron Miller		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-152888</link>

		<dc:creator><![CDATA[Ron Miller]]></dc:creator>
		<pubDate>Thu, 26 Apr 2012 18:51:00 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-152888</guid>

					<description><![CDATA[Ron Miler is the alias I use so I&#039;m incognito here.  You guys broke the freaking code.  If I had know this place was filled with Columbos, I would have one with Don Miler.  (Also, can&#039;t we all just agree that any play on Jerry&#039;s Kids is a bad idea?  Can I just get that from you guys?  I don&#039;t ask much, really)

In far too many instances, government is going to be inefficient by its inherent nature.  There is no doubt about this.  I still think it is a regrettable mistake to paint the individual employees with a single defamatory brush.  Many departments of the federal government are really hard to get into and have unbelievable qualified people.  (The State Department comes to mind.)  We should be focusing on trying to understand the efficacy limitations of government in general and do the best we can to overcome them.  Because that is the real problem.  It is not, in my humble opinion, the employees themselves.]]></description>
			<content:encoded><![CDATA[<p>Ron Miler is the alias I use so I&#8217;m incognito here.  You guys broke the freaking code.  If I had know this place was filled with Columbos, I would have one with Don Miler.  (Also, can&#8217;t we all just agree that any play on Jerry&#8217;s Kids is a bad idea?  Can I just get that from you guys?  I don&#8217;t ask much, really)</p>
<p>In far too many instances, government is going to be inefficient by its inherent nature.  There is no doubt about this.  I still think it is a regrettable mistake to paint the individual employees with a single defamatory brush.  Many departments of the federal government are really hard to get into and have unbelievable qualified people.  (The State Department comes to mind.)  We should be focusing on trying to understand the efficacy limitations of government in general and do the best we can to overcome them.  Because that is the real problem.  It is not, in my humble opinion, the employees themselves.</p>
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		<title>
		By: DEM		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-152886</link>

		<dc:creator><![CDATA[DEM]]></dc:creator>
		<pubDate>Thu, 26 Apr 2012 18:42:30 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-152886</guid>

					<description><![CDATA[Most Americans – the vast, vast majority – believe there there should be safety requirements placed on car makers. Where we differ is the question of degree. So the debate among reasonable people is how stringent these requirements should be. 
_____________________________

And with this, Ron has placed the notion to consumer self-protection and individual responsibility beyond the scope of reasonable debate.  None of us can decide whether want to buy a car without airbags -- that decision belongs to the government.  From seatbelts to airbags to override systems designed to keep inattentive drivers from accelerating when they mean to brake, it&#039;s all the same thing, right?]]></description>
			<content:encoded><![CDATA[<p>Most Americans – the vast, vast majority – believe there there should be safety requirements placed on car makers. Where we differ is the question of degree. So the debate among reasonable people is how stringent these requirements should be.<br />
_____________________________</p>
<p>And with this, Ron has placed the notion to consumer self-protection and individual responsibility beyond the scope of reasonable debate.  None of us can decide whether want to buy a car without airbags &#8212; that decision belongs to the government.  From seatbelts to airbags to override systems designed to keep inattentive drivers from accelerating when they mean to brake, it&#8217;s all the same thing, right?</p>
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		<title>
		By: Richard Nieporent		</title>
		<link>https://www.overlawyered.com/2012/04/nhtsa-to-mandate-accelerator-overrides/comment-page-1/#comment-152871</link>

		<dc:creator><![CDATA[Richard Nieporent]]></dc:creator>
		<pubDate>Thu, 26 Apr 2012 17:54:10 +0000</pubDate>
		<guid isPermaLink="false">http://overlawyered.com/?p=29291#comment-152871</guid>

					<description><![CDATA[Lighten up Ron; you know we love you. I think you picked a particularly bad week to defend government employees, with all of the scandals/inappropriate behavior at the GSA, SS, and TSA that has made the news. I am sure that you realize that the negative comments being made about government workers is hyperbole; however, there are too many “bad apples” to ignore. These folks do not seem to realize that as public servants they are not supposed to be screwing (both figuratively and literately) the public. When it comes to the TSA employees it would appear that they enjoy abusing people and that their management does not give a damn. When was the last time you heard that a TSA employee was fired for inappropriate behavior? To add insult to injury, only government employees get the &quot;dreaded&quot; punishment of leave with pay when their illegal/inappropriate behavior is made known. Why is Mr. Neely still employed at GSA? If he worked for a private company, he would have been fired immediately.]]></description>
			<content:encoded><![CDATA[<p>Lighten up Ron; you know we love you. I think you picked a particularly bad week to defend government employees, with all of the scandals/inappropriate behavior at the GSA, SS, and TSA that has made the news. I am sure that you realize that the negative comments being made about government workers is hyperbole; however, there are too many “bad apples” to ignore. These folks do not seem to realize that as public servants they are not supposed to be screwing (both figuratively and literately) the public. When it comes to the TSA employees it would appear that they enjoy abusing people and that their management does not give a damn. When was the last time you heard that a TSA employee was fired for inappropriate behavior? To add insult to injury, only government employees get the &#8220;dreaded&#8221; punishment of leave with pay when their illegal/inappropriate behavior is made known. Why is Mr. Neely still employed at GSA? If he worked for a private company, he would have been fired immediately.</p>
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