Emails between Tesla and CA DMV on Smart Summon, FSD

[Bitdepth]

considering I've only started 1 DM in 2020... hey @diplomat33 how are you doing buddy?

You are dragging the level of discuss in this forum down mate. If you aren't interested in discussing the content of the post then simply ignore and move on. I've noticed you make a habit of disliking any post that is critical of tesla heck the post does not even have to be critical of tesla, if you dislike the person you dislike every post they make even if the post is informative.

 

[mikes_fsd]

I've noticed you make a habit of disliking any post that is critical of tesla heck the post does not even have to be critical of tesla

Interesting, you know my thought process for liking or disliking something? The rating is "Disagree" and when I rate something "Disagree" I go with the Merriam-Webster definition of "to differ in opinion" Definition of DISAGREE

But thank you for taking the time to give your advice/opinion.

 

[Bitdepth]

Interesting, you know my thought process for liking or disliking something? The rating is "Disagree" and when I rate something "Disagree" I go with the Merriam-Webster definition of "to differ in opinion" Definition of DISAGREE

But thank you for taking the time to give your advice/opinion.

Call it what you want. I'm just pointing out what I see. There is a group of people who are intent on turning any discussion on the subject of autonomous vehicle into Vs Tesla discussion. You disagree with or dislike any post that does not extol the awesomeness of Tesla. A lot of people on the forum own Teslas but they can also be objective when discussing certain topics.

On a different note, I took it upon myself to rehost the file if a mod can kindly replace the link in the OP. I've scanned the link with VirusTotal which uses 79 malware engines to scan the link and it came out clean.
VirusTotal

Link to new host
Gofile

 

[mikes_fsd]

You disagree with or dislike any post that does not extol the awesomeness of Tesla.

Looks to me like you're revealing your own internal bias.

Now, I'm going to point you to the advice your gave me just a few minutes back:

If you aren't interested in discussing the content of the post then simply ignore and move on.

 

[ChrML]

If you read in between the lines of these emails, you see that Tesla is pretty chaotic.

DMV asked for a response by 20.March, Tesla sent their response 24.March. DMV gets all the self-driving information from the news and Tesla's launch events, has to ask Tesla for information. Tesla cancelling the Smart Summon demo the same day as it was supposed to be held because "it wasn't ready for demo" etc...

However that's pretty typical for fast-moving innovative companies like Tesla. Same reason they were ignoring open-source licenses for a good while, or stealing art (such as the old Sentry logo). It gets things done when you always do things first without hesitation, and ask later .

 

[timewasted]

It is a FOIA request, there is no copyright that he can claim on it, you can download the email and upload, but sending traffic to a person/service that is basically a cyberbully seems kinda wrong.

Here's another person who's a well known cyberbully that we should probably not send traffic to.

I guess you've never dealt with the short-sellers on Twitter, they show up out of nowhere, and spam your thread with all kinds of nasty crap.
In fact, I shut down my original (2008) twitter account because it became useless trying to post anything.

You mean like how the Tesla faithful came out in force to try to bully Dr. Erica Pan and the Alameda County Public Health Department?

 

[Tam]

Aren't they only required to report L3+ testing on public roads?

And isn't smart summon explicitly intended for use in private parking lots?

1) In theory, it is intended for private parking lots but if it is too private such as my big driveway then Tesla doesn't have the map for that parking lot.

Thus, I have to find a summonable private parking lot where everyone can have "public" access including civilians and police such as a shopping mall parking lot.

2) Regardless of the above public or private parking lots, the California Annual Disengagement clearly spell outs "parking facility" without clarifying which is which:

Page 23 of 40

"(B) The circumstances or testing conditions at the time of the disengagement including:

(i) The location: interstate, freeway, highway, rural road, street, or parking facility."

3) If "parking facility" excludes private Commerical lots, then there are still official public parking lots for governments' buildings, schools, parks...

That means, Tesla then needs to filter out the private Commerical lots and report summons at local, state, Federal parking lots.

 

[Knightshade]

Thanks for the link- it points out 2 other reasons enhanced summon doesn't count-

An autonomous test vehicle does not include vehicles equipped with one
or more systems that provide driver assistance and/or enhance safety
benefits but are not capable of, singularly or in combination, performing
the dynamic driving task on a sustained basis without the constant control
or active monitoring of a natural person.

The feature currently requires active monitoring of a natural person (hence why you must be in visual range of the car and be holding down the summon button)


and

“Dynamic driving task” means all of the real-time functions required to
operate a vehicle in on-road traffic, excluding selection of final and
intermediate destinations, and including without limitation: object and event
detection, recognition, and classification; object and event response;
maneuver planning; steering, turning, lane keeping, and lane changing,
including providing the appropriate signal for the lane change or turn
maneuver; and acceleration and deceleration

Navigate a parking lot is not operating in "on-road traffic"



Oh, and the original reason is right at the top-

A motor vehicle shall not be operated in autonomous mode on public roads
in California except as permitted under Vehicle Code section 38750 and the
regulations in this article.

Public, not private.


And for reporting it specifically cites that heading as:

Reporting Disengagement of Autonomous Mode

Where again, Tesla can not consider summon to be "autonomous mode" since it's not intended for use on public streets and requires active natural person supervision.


it also tells you where it defines road/parking types-

“Public road” means “highway” as defined in Vehicle Code section 360,
“offstreet public parking facility” as defined in Vehicle Code section 4000, and
“street” as defined in Vehicle Code section 590.

The fact you have to report where disengagements happen seems to imply they mean for vehicles operating L3+ on public roads.... which an L2 tesla with summon is not.

 

[Mardak]

I wonder if we haven't seen many updates to Smart Summon because each time will require another round of demonstrations and approvals with the CA DMV?

 

[diplomat33]

I wonder if we haven't seen many updates to Smart Summon because each time will require another round of demonstrations and approvals with the CA DMV?

I think it would probably depend on how substantive the updates are. I doubt Tesla needs to get approval from the CA DMV for every minor performance improvement. But anything substantive like not requiring the person to hold down the button on the app or enabling Smart Summon on private roads, would almost certainly require the CA DMV to approve it before release.

I think the lack of significant updates to Smart Summon is more likely due to Tesla prioritizing other features right now, like Traffic Light Control.

 

[Tam]

I wonder if we haven't seen many updates to Smart Summon because each time will require another round of demonstrations and approvals with the CA DMV?

There's no hint that each Smart Summon Software Updates requires DMV approval.

There was no Smart Summon before but when DMV saw reports of complaints of near misses and parking lot accidents, that's when DMV wants to know what's going on and asked for a demo.

 

[Tam]

...The fact you have to report where disengagements happen seems to imply they mean for vehicles operating L3+ on public roads.... which an L2 tesla with summon is not.

There are 2 issues here:

1) There are parking lots that are subject to the California Vehicle Codes. So if Autonomous Vehicles operate on those lots, they need to be included in the Disengagement Report.

Also, an example of Commercial Shopping Parking Lot who consents for police to enforce California Vehicle Codes is Walnut Creek Supercharger, CA where the police came to ticket/tow a Ford Mustang that was blocking the charger.

2) Remote Operator is for Autonomous Vehicles:

California does allow Remote Operator but it is part of Autonomous Vehicles.

If it is part of manual L0, L1, L2 driving for example, a car without any driving assistance is L0 but it can be driven remotely by a Remote Operator who can manually brake, accelerate, steer, honking horn... as remote technology has been achieved for years without the need for Autonomous,

However, to qualify for Remote Operator, the car must be capable of L3 or above.

In summary:

Tesla does not have to report Summon Disengagement if it's done in private parking lots that do not participate in California Vehicle Codes (some private lots want police to enforce the codes and they would consent for that.)

Tesla does have to report Summon Disengagement if it's done in parking lots that do participate in California Vehicle Codes (all local, state , Federal properties and some private lots that want police to enforce the codes and they would consent for that.)

Smart Summon is L2 if there's no Remote Operator and the driver must practice hands-on-wheel. That way, there's no need for Summon Disengagement.

Smart Summon is L3 if there's no driver inside the car to practice hands-on-wheel and it is controlled by Remote Operator instead. That means Tesla needs to do report disengagements for parking lots that are subject to California Vehicle Codes.

 

[Knightshade]

There are 2 issues here:

1) There are parking lots that are subject to the California Vehicle Codes. So if Autonomous Vehicles operate on those lots, they need to be included in the Disengagement Report.

But a Tesla is not an autonomous vehicle under the definitions in the link you provided- even when using summon- because it remains under constant supervision of an operator (and also does not operate L3+ autonomously at all on public roads which again aren't the same thing as "parking lots police can write tickets in")

2) Remote Operator is for Autonomous Vehicles:

California does allow Remote Operator but it is part of Autonomous Vehicles.

If it is part of manual L0, L1, L2 driving for example, a car without any driving assistance is L0 but it can be driven remotely by a Remote Operator who can manually brake, accelerate, steer, honking horn... as remote technology has been achieved for years without the need for Autonomous,

However, to qualify for Remote Operator, the car must be capable of L3 or above.

Summon doesn't involve a remote operator- you're not directly steering the vehicle or anything.

It does involve "active monitoring of a natural person." though which means it does NOT meet the requirements for autonomous vehicles as cited earlier.

Thus no need to report disengagements. Even if they happen in parking lots CHP can write a ticket.

Tesla does have to report Summon Disengagement if it's done in parking lots that do participate in California Vehicle Codes (all local, state , Federal properties and some private lots that want police to enforce the codes and they would consent for that.)

Nope- because it's not operating as an autonomous vehicle on a public road. (that's TWO reasons, so if either is true they need not report- and both are true- again "parking lot cops can enforce laws" is not a public road)

Smart Summon is L3 if there's no driver inside the car to practice hands-on-wheel and it is controlled by Remote Operator instead. That means Tesla needs to do report disengagements for parking lots that are subject to California Vehicle Codes.

Again- nope.

You don't need "hands on wheel" to be L2.

Caddys system is L2 and hands off for example.

The key definition is that it's not an autonomous vehicle.

Again the definition EXCLUDES being autonomous if they require EITHER:

"the constant control or active monitoring of a natural person"


Smart summon explicitly requires active monitoring of a natural person"

That's why you can only use it in line of sight of the vehicle for example.

So it's not autonomous. Thus no need to report disengagements.

 

[Knightshade]

I think the lack of significant updates to Smart Summon is more likely due to Tesla prioritizing other features right now, like Traffic Light Control.

Also possibly the AP re-write which reverse summon apparently requires- so one would assume the rewritten code for that would be relevant to an improved version of summon too

 

[diplomat33]

Also possibly the AP re-write which reverse summon apparently requires- so one would assume the rewritten code for that would be relevant to an improved version of summon too

Yes, since the rewrite is stitching together all the camera views, I would assume it would impact smart summon quite a bit. Hopefully, the rewrite will bring a big improvement to smart summon.

 

[Tam]

...Summon doesn't involve a remote operator- you're not directly steering the vehicle or anything...

A moving car needs someone or something to basic driving skills such as steering, speeding, braking, honking the horn, monitoring for the traffic, turning on signals...

Summon Owner outside of the car can only do the manual braking but cannot do the rest of the function of a driver such as to turn on the left turn signal.

Since the owner can only do 1 thing: braking, the rest must be performed by somebody. Since there's nobody is in the car to do the rest so the car must rely on the algorithm from Tesla itself.

Thus, Summon is an Autonomous design (absence of human inside the car to perform speed braking, steering, monitoring for obstacles...)

 

[Knightshade]

Thus, Summon is an Autonomous design (absence of human inside the car to perform speed braking, steering, monitoring for obstacles...)

Except, it's not.

You can tell because it explicitly does not meet the definition of autonomous listed in your own source.



One more time

An autonomous test vehicle does not include vehicles equipped with one
or more systems that provide driver assistance and/or enhance safety
benefits but are not capable of, singularly or in combination, performing
the dynamic driving task on a sustained basis without the constant control
or active monitoring of a natural person.

Bold added to point out -

Since smart summon requires active monitoring of a natural person it is, by definition, not included in the definition of an autonomous test vehicle.

Note the use of OR there- if EITHER of those is required- then it's NOT an autonomous vehicle.


The remote operator stuff is irrelevant since, again, the car isn't autonomous under the definition given.

 

[Tam]

Except, it's not.

You can tell because it explicitly does not meet the definition of autonomous listed in your own source.



One more time




Bold added to point out -

Since smart summon requires active monitoring of a natural person it is, by definition, not included in the definition of an autonomous test vehicle.

Note the use of OR there- if EITHER of those is required- then it's NOT an autonomous vehicle.


The remote operator stuff is irrelevant since, again, the car isn't autonomous under the definition given.

That is fair that Summon is currently not Autonomous because it requires monitoring.

To fulfill that monitoring requirement, the driver needs to be inside of the car and not outside of the car.

When it says "dynamic driving task" it is not talking doing that task with a "Remote Operator".

When the monitoring is done outside of the car as it is practiced in Smart Summon and is currently designed, then it is "Remote Operator" who can abort the algorithm and since it is "Remote Operator", it's Autonomous.

 

[Knightshade]

That is fair that Summon is currently not Autonomous because it requires monitoring.

To fulfill that monitoring requirement, the driver needs to be inside of the car and not outside of the car.

Nope, he sure doesn't.

Nothing in the spec says otherwise.

When it says "dynamic driving task" it is not talking doing that task with a "Remote Operator".

It's not talking about remote operators at all. The term doesn't appear, at all, in that entire paragraph.

You keep wanting to insert it anyway for some reason.

That definition doesn't care WHERE the person physically is.

If a natural person is required to constantly monitor the car- it's not autonomous by definition. Inside the car, outside the car, doesn't distinguish or care at all.

When the monitoring is done outside of the car as it is practiced in Smart Summon and is currently designed, then it is "Remote Operator" who can abort the algorithm and since it is "Remote Operator", it's Autonomous.

Nope.

Autonomous does not include vehicles that require constant monitoring by a natural person. With no distinction given regarding that persons location.

 

[Knightshade]

Another relevant section BTW-

(2) For the purposes of this article, an “autonomous test vehicle” is equipped with technology that makes it capable of operation that meets the definition of Levels 3, 4, or 5 of the SAE International's Taxonomy and Testing of Autonomous Vehicles Page 2 of 40 Definitions for Terms Related to Driving Automation Systems for On-Road Motor Vehicles, standard J3016

Teslas, currently, are not capable of L3 or higher operation (with consumer version SW anyway).

So they are not autonomous test vehicles[/B] period full stop under this clause. (in addition to the other ways they're not one under other clauses)


Also- consider- the ORIGINAL summon, that's been around for MANY years- is also a "remote" person controlling it, and the car moves on its own.

But is also no issue, and doesn't require autonomous testing licensing or reporting.

Even if used in a public parking lot.

Because- again- the car is not an autonomous vehicle under CA definitions.