Tell me, which regulator "certifies" AEB/FCW? To what rule set?Makes sense if it's regulatory. I imagine they have to recertify all the cars given the AEB/FCW function will function differently without radar, and it may be that the new Model 3/Y was the first to get certification and then they will work their way through the other models.
The NHTSA agrees it is not them, and they oversee the FVMSS.
Cars are self certified in the USA by the manufacturer. The NHTSA only gets involved if that ends up not being true and the public could be harmed. Cars are not like Aircraft or Medical equipment which are required to gain approval from the regulator before release.
If this were true, Tesla would need to recertify every single time they changed AP code that could impact AEB/FCW in any way.
Note this is not true in other countries, and Tesla has specifically said they are keeping radar in those markets. Almost like they are using the low regulation market in the USA/Canada as a testing ground.
Additionally, Tesla runs the same code in the AP computer on the 3/Y as they do the S/X. Why could they "certify" the 3/Y before the S/X? You'd also think Tesla, who loves to harp on regulators slowing things down, would have called them out as the block instead of saying "Model 3 and Model Y are our higher volume vehicles. Transitioning them to Tesla Vision first allows us to analyze a large volume of real-world data in a short amount of time, which ultimately speeds up the roll-out of features based on Tesla Vision."