The document you linked to says no such thing, as several other people have stated in the autonomous forum.
Here is what the document says:
"An autonomous vehicle is operating or driving in autonomous mode when it is operated or driven with the autonomous technology engaged."
It clearly does not matter if the driver has the hands on the wheel or anywhere else on the car. If the technology is running and controlling the car on California roads, then they need to report it.
.
Uggg, you're going to make me transcribe the locked pdf?
You quoted the second half of the definition of autonomous mode.
"Autonomous mode" means an
autonomous vehicle,
as defined by this article, that is operated or driven
without active physical control by a natural person sitting in the vehicle's driver's seat.
(Rest as you quoted).
I make the case that if the SW requires a torque input resulting from the driver's hand on the wheel (which must track steering changes) that is an active physical control. However, this argument is secondary to the base defense.
As defined by this article:
"autonomous vehicle ": means any vehicle equipped with technology that has the capability of operating or driving the vehicle without the active physical control or monitoring of a natural person, whether or not the technology is engaged,
excluding vehicles equipped with one or more systems that enhance safety or
provide driver assistance but are
not capable of driving or operating the vehicle
without the
active physical control or
monitoring of a natural
person.
Which is why AP miles are not not reportable. Hands on wheel forces, at a minimum, the monitoring clause thus excluding AP vehcles from being considered "autonomous vehicles". No AV, no "Autonomous mode", no AM, no reporting.
So, swap EAP with FSD and keep nag (non-driving torque input + monitoring nag). Why is it required to report?