I think the big difference is that Tesla requires hands on the wheel, and none of the other AV companies do. (As far as I know.)
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CA DMV "revisiting" approach towards Tesla FSD
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Daniel in SD
(supervised)
The DMV is not going to pull their permit, they're investigating whether Tesla is circumventing the whole permit system. In the Uber case they simply deregistered all the vehicles making them illegal to drive on CA public roads.Agree that is a concern. We will have to see if electric shock therapy from Tesla heating coils are necessary.On a more realist note, perhaps long term FSD beta revoke if software detects non monitoring of roadway would alleviate the concern and any real problem if it exists.
Agree. The problem with Ca DMV is if you give them an inch, they will take a foot. If they capriciously decide Tesla isn't safe then they will yank the permit.
If only they knew that "one weird trick"!
Just touch the wheel every 30 seconds and you're exempt from AV testing regulations. haha.
Sure, California Code of Regulations was amended to regulate testing of autonomous vehicles because legislators wanted to ensure safe operations of vehicles in particular those operating "in autonomous mode on public roads in California."
FSD Beta button has an explicit checkbox for the user to confirm that "I understand that… FSD Beta does not make my car autonomous" probably carefully worded by Tesla legal team. So Tesla is telling CA DMV that "FSD Beta" design intent is Level 2, and owners are acknowledging that it's Level 2, yet legislators want CA DMV to classify a Level 2 system as Level 3+ to enforce regulations?
Daniel in SD
(supervised)
I don't see how that changes the safety.
Also, the design intent is clearly driverless operation. Elon said a few weeks ago that disengagement data from FSD beta will be used to prove when it's ready to be driverless later this year.
I don't know how we argue up and down that the SAE Levels make little sense and borderline don't matter but use them as a defense when we're talking reporting requirements for the testing being done.
This is by far the most capable autonomous system in a consumer vehicle and Tesla reports a grand total of zero autonomous miles driven annually. I would probably refer to the exemption for Tesla as underregulation and this move merely returning it to a state of normoregulation.
This is by far the most capable autonomous system in a consumer vehicle and Tesla reports a grand total of zero autonomous miles driven annually. I would probably refer to the exemption for Tesla as underregulation and this move merely returning it to a state of normoregulation.
The real question is whether that happens before or after MCU1 owners get the option to join.
Daniel in SD
(supervised)
The SAE levels are literally included in the CA regulations.
And of course the relevant passage from J3016
And the relevant precedent from Uber's testing program
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Uber dismissed warnings about its illegal self-driving test for months, emails show
California DMV urged Uber to get into compliance four months before it launched its short-lived experiment in self-driving
www.theverge.com
You're right though that the DMV probably has the authority to regulate L2 systems anyway.
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The point is that California's "Testing of Autonomous Vehicles" explicitly does not apply to Level 2 systems such as Autopilot/Autosteer/"FSD Beta." If Tesla wants to have a "Deployment of Autonomous Vehicles" in California, then yes they will need to get a permit that requires the manufacturer to conduct tests and validations and be satisfied of those safety results, but even then it seems like Level 2 miles or simulated miles could be sufficient to self-satisfaction to deploy Level 4.
They matter to CA DMV because the law says "… meets the definition of Levels 3, 4, or 5 of the SAE…"
Daniel in SD
(supervised)
CA DMV "revisiting" approach towards Tesla FSD
There is no real difference between FSD Beta testing and what a hundred other AV companies are doing in California. I think the big difference is that Tesla requires hands on the wheel, and none of the other AV companies do. (As far as I know.)
teslamotorsclub.com
That would be quite an outcome with Tesla: Deregistering all vehicles with FSD beta
Terminator857
Active Member
Which Elon long term FSD statement has been true? If you say: "because Elon said" then the opposite is true.
In this case we can be confident that: disengagement data will NOT be used to prove it is ready to be driverless later this year.
Daniel in SD
(supervised)
Everyone underestimates the difficulty of FSD and AI in general. It's crazy how overoptimistic even very smart people are about it even after 65 years of missed timelines.
But Elon is smarter than me so maybe he's right this time.
Seems like Uber's system had an "autonomous mode" vs "manual mode" as reported in Behind the wheel of Uber's new self-driving car, which hits the road todayAnd the relevant precedent from Uber's testing programUber dismissed warnings about its illegal self-driving test for months, emails show
California DMV urged Uber to get into compliance four months before it launched its short-lived experiment in self-driving
There were three lights on the dash to indicate the mode you were in, and two buttons — one silver and the other red — on the console between the driver’s seat and passenger seat to engage and disable autonomy, respectively.
Does FSD Beta have an autonomous mode?
Daniel in SD
(supervised)
FSD Beta is the beta version of the autonomous mode.
It's pretty obvious from the article that Uber's system was very much beta too.
Tesomega
Member
I don't have access to BETA, and will not have FSD product delivered to me without approval. So I support this.
That's not how Tesla described it in their CA DMV email "Autonomous Mode Disengagements for Reporting Year 2020" referring to "FSD Beta" as "City Streets."FSD Beta is the beta version of the autonomous mode.
As you know, Autopilot is an optional suite of driver-assistance features that are representative of SAE Level 2 automation (SAE L2). Features that comprise Autopilot are Traffic-Aware Cruise Control and Autosteer. Full Self-Driving (FSD) Capability is an additional optional suite of features that builds from Autopilot and is also representative of SAE L2. Features that comprise FSD Capability are Navigate on Autopilot, Auto Lane Change, Autopark, Summon, Smart Summon, Traffic and Stop Sign Control, and, upcoming, Autosteer on City Streets (City Streets). While we designed these features to become more capable over time through over-the-air software updates, currently neither Autopilot nor FSD Capability is an autonomous system, and currently no comprising feature, whether singularly or collectively, is autonomous or makes our vehicles autonomous. This includes the limited pilot release of City Streets.
Elsewhere in that document multiple times, Tesla answered many CA DMV questions about "FSD" features including: "we made abundantly clear that City Streets does not make the vehicle autonomous and that the driver is responsible for being fully attentive at all times."
Tesla is well aware of California's requirements around autonomous vehicles:
Please note that Tesla’s development of true autonomous features (SAE Levels 3+) will follow our iterative process (development, validation, early release, etc.) and any such features will not be released to the general public until we have fully validated them and received any required regulatory permits or approvals.
Daniel in SD
(supervised)
I don't think anyone is contesting that Tesla told the DMV that their system is a driver-assistance feature.
They literally claim to be a year away from FSD and yet FSD Beta is not a beta version of that software? I don't believe it.
And again how is the safety of testing FSD Beta any different from other autonomous vehicle testing?
There seems to be a clear disconnect between what Tesla tells the CA DMV and what Elon has been saying. That letter to the DMV basically says that all of "FSD" is not autonomous but don't worry, we will seek a permit when we do develop autonomous driving. But Elon talks about the current "FSD" like it will evolve into true autonomy soon. For example, he talks about how "FSD" will get so good that Tesla will actually ban the driver from intervening. It seems pretty clear to me that Tesla is trying to have it both ways. Basically, Tesla wants to be able to develop and test their autonomous driving without any regulations because it still requires driver supervision and only follow regulations when they deem it autonomous, when it does not need driver supervision anymore (as Elon has said they will seek regulator permission to remove driver supervision when they deem it ready). But that is not how regulations are supposed to work. You are supposed to follow the regulations WHILE the system is being developed and tested not AFTER it has been developed and tested.
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I can't see Tesla making the driver fill out a mandatory survey explaining each disengament after every drive. So, I have to figure that if California makes the determination that the current FSD Beta makes the vehicle autonomous, and requires disengament reporting, that Tesla would just disable FSD Beta on all non-Tesla owned vehicles in California. (Maybe all Tesla owned ones as well, and move all testing out of state.)
Tesla can collect disengagement data from FSD Beta cars automatically and then organize and send that data to the CA DMV. There would be no need for drivers to fill out surveys.
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