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You have presented a lower bound on deaths. You can establish that it is at least as dangerous as X. To demonstrate safety you need to establish a credible upper bound, then you can credibly assert it is at most as dangerous as X.

Even if we do not attempt to estimate the true underlying rate, there are over 1,000 reported crashes that Tesla has declined to investigate. The upper bound can not be tightened further than that without investigation or a robust predictive/statistical model. Even underestimating the credible upper bound at 1,000 fatalities constitutes a material number of deaths as that would be many times less safe than a human driver.

You need to tighten the upper bound before your assertions that there have not been a material number of deaths are credible.




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