IEEE Technology and Society Magazine - March 2018 - 67

causally important in crashes. Different social groups,
with different interests in AV success or failure, might
have different substantive views about these factors,
and thus might disagree about different test methods
or particular studies. Again, the controversy may not be
settled by simply appealing to "the evidence" because
different sides might disagree about what counts
as evidence. To understand the political implications
of this epistemological conclusion, let us turn now to
the controversy over climate change.

Controversy and Policy
Based on work by historians and social scientists [19]-
[21], the climate controversy can be understood as
a scientific proxy for climate policy specifically and
environmental policy more generally [22]. Climate sci-
ence and policy are tightly linked in the way we think
about climate issues: the fact of anthropogenic cli-
mate change is generally regarded as a sufficient, and
indeed urgent, reason to adopt cap-and-trade policies,
promote the development of sustainable energy sourc-
es, and generally reduce the use of fossil fuels. In [23],
Howe calls this science communication-policy strategy
"the forcing function of knowledge," and argues that it
has not just failed, but indeed backfired. The tight link
between science and policy gives opponents of cli-
mate policies a strong incentive to oppose the science
as well. Denying the science knocks out the single
largest pillar supporting the policy. It's therefore
unsurprising that prominent climate skeptics have
received substantial support from the fossil fuels
industry [24], [25].
When it comes to AVs, my concern is that we are
careening towards a similar scientific proxy dispute. As
we saw above, U.S. DOT's regulatory framework barely
even mentions the potential economic fallout from
AVs, and instead focuses entirely on safety. Without
complementary policies that would, for example, facili-
tate retraining and early retirement, professional driv-
ers - especially through organizations such as the
Teamsters union - have a strong economic incentive
to delay or prevent the adoption of AVs. Then, insofar
as federal and state regulators view AVs only in terms
of safety, AV opponents will have strong incentives to
criticize safety studies. The tight link between climate
science and climate policy motivates criticisms of cli-
mate science; in a similar way, the safety argument cre-
ates a tight link between AV safety and rapid AV
adoption; and so we might expect similar motivated
criticisms of AV safety studies. And the safety studies,
as we saw above, are unlikely to be completely immune
to criticism.
At the same time, AV manufacturers have a strong
economic incentive to promote the rapid adoption of
march 2018

∕

AVs, and thus a strong incentive to minimize regula-
tion. In a policy context where regulation depends
only on safety, this gives AV manufacturers a strong
incentive to manufacture certainty about AV safety
studies, that is, to create the appearance of expert
consensus and overwhelming scientific evidence. In
other words, the safety argument's tight link between
safety and policy leads us to expect AV manufacturers
to fund expert panels of roboticists and mechanical
engineers who will endorse their preferred safety stud-
ies and criticize research that indicates that AVs are
less safe. The safety of AVs may become a scientific
proxy for an economic conflict between professional
drivers and robotics manufacturers who are trying to
replace them.
At an extreme, AVs could be caught in an intracta-
ble proxy war, with one side producing ever "more and
better" safety studies, the other side perpetually find-
ing subtle "mistakes" that "invalidate" the studies, and
the technology itself caught in regulatory limbo until it
is simply abandoned or one side forces through a
major regulatory change. Whatever the actual safety of
AVs - and whatever one thinks about whether they
should be widely adopted, and how quickly - a pro-
tracted proxy war is likely to consume substantial legal,
regulatory, and scientific resources that could be more
useful elsewhere.
At this point, it might be objected that there is a
major disanalogy between climate change, on the one
hand, and AV safety, on the other. There is a near con-
sensus among climate scientists that climate change is
happening, it is caused primarily by anthropogenic
greenhouse gas emissions, and that it is already having
serious negative impacts on human societies and the
natural environment [26]. While there are uncertainties
about many important and technical details of climate
change - such as the precise amount of warming
expected from a given increase in atmospheric carbon
dioxide concentration - there is essentially no serious
scientific objection to the three claims made in the previ-
ous sentence. Today, "sophisticated" criticisms of cli-
mate science either reiterate arguments that have
already been answered or exaggerate the importance of
the detail-level technical uncertainties [19]. By contrast,
as I discussed above, there is substantial, reasonable,
scientific and engineering uncertainty surrounding the
safety of AVs. Indeed, we are still in the process of devel-
oping the various candidate approaches that might be
used to assess AV safety.
But this disanalogy between climate change and
AVs actually supports my point. The case of climate
change shows us that an overwhelming expert con-
sensus is politically insufficient to drive policy. Even
if - though this seems unlikely, short of manufacturing

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