A new letter sent to the US National Highway Traffic Safety Administration (NHTSA) confirms that Apple is investing heavily in autonomous vehicles. It comes as little surprise. The letter asks for Apple to be treated as equal to firms that are already operating in the space. It’s a high demand and one that might stir up a little controversy, especially given Apple’s lack of history in the industry. Indeed, there seems to be more evidence that Apple isn’t even building a car.

In fact, if you had asked me a year ago if I thought Apple was building its own car, I would have said yes. After all, last February, Tim Cook said that the wait for the fruits of Apple’s investments in autonomous driving would be worth it, comparing the anticipation to a child waiting for Santa on Christmas Eve. Now, it seems like Apple has started to cut down on its original “Project Titan” plans, instead focusing on technology that might be used to power autonomous vehicles built by other companies.

The letter to the NHTSA was written by Apple’s head of product integrity, Steve Kenner, according to BBC. Apple told BBC that the letter was drafted because Apple felt that it needed to voice its opinion to create “best practices in the industry.” Kenner also confirmed Apple has been making “heavy investment in machine learning and autonomous systems.” Kenner seems to be trying to get Apple ahead of the ball, too, well aware that the company is going to face increased competition from automakers and other companies that are already well-known in the space.

Specifically, the letter asks the NHTSA to create a level playing field for all firms, no matter how long they’ve been working on autonomous products.

“Established manufacturers and new entrants should be treated equally,” Kenner said, according to BBC. This is probably Apple’s way of asking the NHTSA to give Apple a say in creating some of the fledgling autonomous car industry’s new standards, even though firms like Google, Tesla, Volvo, Uber, Ford and others are building autonomous systems and testing, often in the public eye, with status updates from companies like Google on how well tests are performing.

I’m not sure I agree with Apple’s request, though I’m well aware I don’t get to call the shots.

Apple needs to come public with its car plans first

I would understand if there’s hesitation from the NHTSA to allow for Apple to help set ground rules if it can’t show what it’s working on. Take Google and Tesla, for example. Both firms are much more transparent in the sorts of tests they’re running, what the cars are capable of and, especially, what sort of mistakes are made. In June, Google said it will now report every time one of its autonomous vehicles gets in a car crash during testing. That allows us to see what works and what doesn’t, and to at least begin to understand how autonomous vehicles work. Tesla’s Autopilot features are already live on the roads, so its accidents are already very public and, in fact, a bit scary.

Apple’s used to calling the shots, even in industries where it doesn’t have a history of participation. Take the iPhone launch back in 2007, for example. Apple got AT&T to agree to exclusively sell its new phones without any control of the product whatsoever. Verizon famously turned that offer down, preferring to be in control of the products it sells. AT&T ultimately made the right decision and earned new customers as a result of the iPhone’s success.

This isn’t a phone. It’s a death box that will approach 80mph.

An Apple Car, or even just software and hardware developed by Apple for autonomous cars, isn’t the same as a phone. Lives are at risk and so it should not just be developed in secret and sold to the public. It needs to be developed in the open where everyone can seem, and I think only then does Apple have the right to set ground rules on the same playing field as companies who do test opens.

If we’re going to put our trust into car systems that are capable of making potentially life or death decisions in a split second, shouldn’t we know how well the internal tests are going? After all, we’re the ones who will be at risk when we decide to get behind the wheel.