Emails between Tesla and CA DMV on Smart Summon, FSD

[Eno Deb]

Again, this doesn't really describe any of the capabilities of FSD beta. To me that quote translates to "We're not confident enough in the performance of the object detection to hand the entire driving task over to the system, yet. And as such when we release this feature to the public, the driver will still be responsible for monitoring and taking over when necessary."

Is achieving Level 3+ just a matter of improving the accuracy of the object detection? We don't know; this letter doesn't tell us that.

It does mention a few things that the system can't do. This is not an autonomous system that just needs "a little supervision". It simply lacks capabilities required to drive autonomously:

" City Streets’ capabilities with respect to the object and event detection and response (OEDR) sub-task are limited, as there are circumstances and events to which the system is not capable of recognizing or responding. These include static objects and road debris, emergency vehicles, construction zones, large uncontrolled intersections with multiple incoming ways, occlusions, adverse weather, complicated or adversarial vehicles in the driving path, unmapped roads. As a result, the driver maintains responsibility for this part of the dynamic driving task (DDT)."

This is not an autonomous system that just needs "a little supervision". It simply lacks capabilities required to drive autonomously.

Remember that Musk explicitly promised actual L5 for 2020 during the Q&A at the "autonomy day" in 2019, and for the end of this year recently. This will obviously not happen. It's amazing how he keeps getting away with this.

 

[diplomat33]

The term "final release" was originally used by the DMV Chief in the context of "Thank you for… describing Tesla's pilot release of the Full Self Driving City Streets feature. Please describe… intended functionality for the final release of FSD City Streets to the general public." As many people know, Tesla constantly improves on their software, so I would think the Tesla lawyer responded in how the software will behave differently when transitioning from the limited private release to the general public, which others would consider "initial public release." If people want to assume the Tesla lawyer was talking about a "final" never-to-be-updated-again version of the software, then I guess the response could be slightly concerning.

I think most people would assume that "final release" refers to the big release to the public, not some final final release that never gets another update.

Again, this doesn't really describe any of the capabilities of FSD beta. To me that quote translates to "We're not confident enough in the performance of the object detection to hand the entire driving task over to the system, yet. And as such when we release this feature to the public, the driver will still be responsible for monitoring and taking over when necessary."

Is achieving Level 3+ just a matter of improving the accuracy of the object detection? We don't know; this letter doesn't tell us that.

Except that "we do not expect significant enhancements in OEDR or other changes to the features" seems to say that Tesla is not planning to add additional driving tasks to the system, not just that the existing tasks are not reliable enough yet. it is saying that FSD City Streets is lacking some OEDR, not just lacking accuracy. At least, that is how I read that.

And I think most AV experts would say that achieving L3+ requires more than just improving accuracy of object detection. L3+ also requires full OEDR, reliable planning and smart driving policy.

 

[S4WRXTTCS]

Yes.

"we do not expect significant enhancements in OEDR or other changes to the features that should shift the responsibility for the entire DDT to the system."

This line makes it clear that FSD City will not be autonomous since it will not do the entire DDT. It is not just a matter of needing some supervision, FSD City Streets will need a human driver to do the parts of the OEDR that it cannot do. This line is literally saying "we have no plans to make FSD City Streets autonomous."

"As such, a final release of City Streets will continue to be an SAE Level 2, advanced driver-assistance feature".

This line further reiterates that FSD City Streets will be L2 even upon final release. So it will not be autonomous. It will be a driver assist that requires a human driver.

What I like about this is it uses the FSD City Streets language versus the Autosteer on City Streets language that the order page has.

This is important because it solidifies the idea that Tesla is really intending to release FSD beta with its current capabilities to the general release. This is pretty monumental because there is quite a bit of stuff that it does. Things that regulatory agencies might object to being released as an L2 system.

It also solidifies Tesla's approach to scale up a L2 system to L3+ as FSD on City streets is likely the hardest one to get regulatory bodies to be okay with being released as L2.

If they get this released under L2 then I imagine they'll be able to do the entire Smart Summon -> FSD on City Streets -> NoA on the Freeway -> FSD On City Streets -> Reverse Summons all under L2.

Once they have that then they have all the component parts to turn hundreds of thousands FSD owners into safety drivers despite how dangerous lots of experts in the self-driving field feel like that would be.

With all the component pieces in place they are free to expand the OEDR without regulatory interference. OEDR being Object and Event Detection and Response. Which we already know they plan on enhancing object detection localization with FSD Beta V9.

 

[willow_hiller]

Also, I hope everyone in this thread bears context in mind:

1. These emails are from December 2020, and only pertain to FSD Beta as used on public California roads.
2. These emails were FOIA requested by Plainsite. An organization owned and run by a noted TSLAQ figure. (This doesn't mean that the emails are faked, but it does make it likely that these were selected as the most damaging information within everything that was requested.)
3. We're missing any communications between Tesla and the California DMV since December 2020 with any additional potentially positive developments.
4. We know Tesla was hiring autonomous test-drivers in the state of Texas. Tesla would have no reason to communicate any autonomous FSD builds tested in a different state with the California DMV.

 

[grahamcox]

The bit I don’t understand, is how is Tesla going to increase price of fsd as features improve, if L3+ is being done completely behind closed doors now?

it Seems there is a hard fork going on, which doesn’t line up with expectation that users will be able to experience the iterations themselves.

 

[diplomat33]

The bit I don’t understand, is how is Tesla going to increase price of fsd as features improve, if L3+ is being done completely behind closed doors now?

it Seems there is a hard fork going on, which doesn’t line up with expectation that users will be able to experience the iterations themselves.

No. I don't think L3+ is being done behind closed doors. Tesla is working on the software and releasing what they have when it is ready. So Tesla is not hiding anything. It's just that Tesla simply does not have L3+ yet. What Tesla is calling "FSD" is only L2 because it cannot handle all object and event detection and response. But Tesla expects that as the software gets better and better that the L2 will eventually mature into L3+.

 

[Mardak]

Except that "we do not expect significant enhancements in OEDR or other changes to the features" seems to say that Tesla is not planning to add additional driving tasks to the system

"for the [initial] release of FSD City Streets to the general public." S4WRXTTCS's interpretation is indeed somewhat comforting in that Tesla intends to release FSD beta with its current "limitations" (i.e., Level 2) to the public, so we can kinda expect to experience the same thing that the private beta testers have shared so far. There had been some speculation that only some aspects such as "staying in lane" would be initially available to the public or requiring confirmation before turns -- although from earlier in this thread, it seems like CA DMV was able to require additional Smart Summon restrictions before public release.

These include static objects and road debris, emergency vehicles, construction zones, large uncontrolled intersections with multiple incoming ways, occlusions, adverse weather, complicated or adversarial vehicles in the driving path, unmapped roads.

Interesting to see the first item of "static objects," which does indeed match up with FSD beta testers' experience of Autopilot wanting to drive into barriers that do not look like road edges, e.g., fencing for outdoor street dining. Karpathy's presentations seemed to suggest static objects were not part of the initially deployed birds-eye-view network, and Musk's recent tweets regarding "upgrading all NNs to surround video" could indeed mean "FSD Beta 9" will better handle static objects and more. And matching up with Tesla's lawyer's response to keep CA DMV happy in that even with these improvements, the intent is continue not reporting any "autonomous vehicle testing" as these are driver assistance features requiring supervision for private and public release.

 

[powertoold]

Remember that Musk explicitly promised actual L5 for 2020 during the Q&A at the "autonomy day" in 2019, and for the end of this year recently. This will obviously not happen. It's amazing how he keeps getting away with this.

He doesn't get away with it. He acknowledges it during the same Autonomy Day presentation. It's easy to take Elon words out of context:

"Only criticism, and it's a fair one. Sometimes I'm not on time. But, I get it done. And the Tesla team gets it done." timestamp: 3:04:58

We need to stop with this Elon not on time with FSD nonsense. No one has ever been on time with FSD, as it's a constantly moving target, despite anyone's best predictions.

 

[Knightshade]

The bit I don’t understand, is how is Tesla going to increase price of fsd as features improve, if L3+ is being done completely behind closed doors now?

it Seems there is a hard fork going on, which doesn’t line up with expectation that users will be able to experience the iterations themselves.

Sounds like what they're going to eventually release to make FSD "feature complete" will still explicitly be level 2, and still lack a bunch of necessary features for actual FSD (as sold to the pre-march-2019 buyers) to be feature complete.

But it'll satisfy the last item on the list of L2 only features Tesla has sold as FSD since March 2019, so they can recognize revenue from all who bought since at long last.

Then they'll get to work on adding all the still-missing features described in that letter (static objects, emergency vehicles, etc) and eventually if they get all that in there and working, there'll be some other future feature/software update that might go higher than L3.

Personally I continue to see at least 1 item on their "it can not handle this" list that they will never fix in software- Inclement weather. See again how the current NoA system drops back to just dumb AP in moderate rain or worse (or if you get mud/dirt on a single side camera the system has no way to clear and no redundancy to do without)


As to if that's behind closed door? Well, there's a reason another poster noted they're looking for test drivers in Texas

Texas doesn't have the same reporting rules on autonomous testing- so Tesla won't need to publicly report how the system is doing while it's in development, or even how much actual testing they're doing.

 

[grahamcox]

No. I don't think L3+ is being done behind closed doors. Tesla is working on the software and releasing what they have when it is ready. So Tesla is not hiding anything. It's just that Tesla simply does not have L3+ yet. What Tesla is calling "FSD" is only L2 because it cannot handle all object and event detection and response. But Tesla expects that as the software gets better and better that the L2 will eventually mature into L3+.

The letter says any level3 features would not be released until fully tested regulated which presumably involves private testing disengagement reports ie a binary state, no trickling of features to purchasers of fsd.

 

[Bednarz42]

I think it means absolutely nothing.

After spending this much time to Rewrite, QC and roll out City Streets Beta which according to them will max out at L3...if people think that L5 will follow soon after to the masses by the end of this year or even next year....I've got a bridge to sell you.

 

[ZeApelido]

After spending this much time to Rewrite, QC and roll out City Streets Beta which according to them will max out at L3...if people think that L5 will follow soon after to the masses by the end of this year or even next year....I've got a bridge to sell you.

Who said it means L5 is coming soon?

It means nothing.

 

[Mardak]

City Streets Beta which according to them will max out at L3

Where does it say it will max out at Level 3? Tesla's response says the initial public release will be Level 2, so not even Level 3. The lawyer also highlighted what they would do for developing SAE Level 3+ (which starts with conditions where the driver can relax from full attention but not that Tesla necessarily is working on Level 3) because that's the key difference in terms of CA DMV's Autonomous Vehicles program per Testing of Autonomous Vehicles § 227.00. Purpose.

§ 227.02. Definitions.
(b)“Autonomous test vehicle” is a vehicle that has been equipped with technology that is a combination of both hardware and software that, when engaged, performs the dynamic driving task, but requires a human test driver or a remote operator to continuously supervise the vehicle's performance of the dynamic driving task.

(1)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.
(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 Definitions for Terms Related to Driving Automation Systems for On-Road Motor Vehicles, standard J3016 (SEP2016), which is hereby incorporated by reference.

In other words, the lawyer is saying that Tesla knows exactly when CA DMV gets jurisdiction. (And most likely Tesla will stay under to avoid regulations until they need to. I wouldn't be surprised when FSD becomes capable enough for Level 3+ testing, they'll just tell CA DMV that they do indeed have Level 3+ but aren't testing in CA.)

 

[Bednarz42]

Who said it means L5 is coming soon?

It means nothing.

I said it means L5 is not coming soon. Anyone who thinks it is, is delusional.

 

[Microterf]

Not that the emails show anything all of us here don't already know, but it does show how genius they are.

Without having to report disengagements, they can add functionality that people will pay for and still keep their own records and know how good it really is until they decide to take the burden of responsibility in some situations

 

[Mardak]

until they decide to take the burden of responsibility in some situations

It'll be interesting to see how far Tesla can / wants to push the limit of Level 2. As you suggest, Tesla will have a lot of their own data knowing where FSD performs better, and potentially Tesla could relax the nag interval dynamically depending on the situation while officially still requiring driver supervision. This could even be combined with driver monitoring to get pseudo-Level-3 effectively-hands-free still without needing to report to CA DMV.

 

[powertoold]

how far Tesla can / wants to push the limit of Level 2

why wouldn’t tesla want to push level 2 all the way to 2x human performance or whatever they’re targeting? Level 2 is great for fsd development and validation. I can see it backfire if they’re not careful with the rollout, and the regulators decide intersection turns shouldn‘t be considered level 2.

 

[Dan D.]

...I can see it backfire if they’re not careful with the rollout, and the regulators decide intersection turns shouldn‘t be considered level 2.

Have the regulators decided anything like that?
SAE wants us to consider Level 2+: "We believe the market is going to be focused on particularly Level 2-Plus for a long time.”

'Level 2+': Making automated driving profitable, mainstream

'Level 2+': Making automated driving profitable, mainstream

www.sae.org

 

[diplomat33]

I think a driver facing camera monitoring system is going to become more and more of a good idea for Tesla as they roll out FSD Beta. It would help prevent abuse since people could not use anti-nag devices or do silly videos where they climb in the back seat while the Tesla is driving. It would also allow hands-free operation which would be great for Tesla owners who are responsible. FSD Beta could drive us around town and we would just need to keep our eyes on the road. We would no longer need to tug the wheel or hit stalk confirmations all the time.

 

[powertoold]

Have the regulators decided anything like that?
SAE wants us to consider Level 2+: "We believe the market is going to be focused on particularly Level 2-Plus for a long time.”

'Level 2+': Making automated driving profitable, mainstream

'Level 2+': Making automated driving profitable, mainstream

www.sae.org

Not sure if you read that article, but L2+ is basically highway NoA, plus optional driver monitoring features.

These include adaptive merging for when vehicles are entering or exiting the highway, and various types of enhanced automatic emergency braking (AEB) aimed at improving vehicle-to-pedestrian safety and car-to-cyclist (and motorcyclist) safety. Also in the development program for production are interior-monitoring technologies to ensure driver attention.