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Emails between Tesla and CA DMV on Smart Summon, FSD

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Ah yeah I think you're right. I found this diagram showing some limited ODD for Level 1 through 4. I guess NTSB wants Tesla to explicitly say currently released Autopilot's ODD is say limited access highway, and if Tesla continues to allow turning on the feature on city streets, NHTSA should force Tesla to disable it?

View attachment 643918

I suppose Tesla could then say the ODD is "any roads" then NTSB would want NHTSA to force Tesla to disable the feature as it's not actually safe for "any roads?"
That was a very frustrated Robert Sumwalt in that letter from the NTSB to the NHTSA. It was a "please do your job" type appeal. Too bad NHTSA seems to be a wait-and-see system at best, or a politically-driven system at worst. That could change.
 
That was a very frustrated Robert Sumwalt in that letter from the NTSB to the NHTSA. It was a "please do your job" type appeal. Too bad NHTSA seems to be a wait-and-see system at best, or a politically-driven system at worst. That could change.


NHTSA via FMVSS allows red turn signals in the rear, which have been known for a very long time to be less safe than amber.

They also don't allow any of the recent breakthroughs in headlight technology.

They appear to be a "do nothing, ever" system.
 
Ah yeah I think you're right. I found this diagram showing some limited ODD for Level 1 through 4. I guess NTSB wants Tesla to explicitly say currently released Autopilot's ODD is say limited access highway, and if Tesla continues to allow turning on the feature on city streets, NHTSA should force Tesla to disable it?

View attachment 643918

I suppose Tesla could then say the ODD is "any roads" then NTSB would want NHTSA to force Tesla to disable the feature as it's not actually safe for "any roads?"

Yes, that is the diagram.

AFAIK, the owner's manual says that the current AP is not designed for city streets and should only be used on limited access highways. So Tesla says city streets are outside the ODD of the current AP. So I think the NTSB simply wants Tesla to better enforce their own ODD since by definition, it is risky to operate any system outside of it's ODD. The NTSB is concerned with Tesla owners who "stress test" the current AP on city streets when even Tesla says it is not designed for that. So yes, I think the NTSB wants Tesla to restrict the current AP to only limited access highways since that is Tesla's ODD for the system.

FSD Beta is of course different since city streets is part of the ODD. I don't think the NTSB has a problem with FSD Beta being used on city streets since that is inside it's ODD. Of course, they do want a strong driver monitoring system to make sure that the driver is paying attention since FSD Beta is L2.
 
That was a very frustrated Robert Sumwalt in that letter from the NTSB to the NHTSA. It was a "please do your job" type appeal. Too bad NHTSA seems to be a wait-and-see system at best, or a politically-driven system at worst. That could change.

Does the NHTSA actually have an Administrator?

As far as I can tell:
The last acting one resigned in 2019
The last true one was Mark Rosekind who left in 2016, and went onto Zoox
Googling "who is the head of the NHTSA" brings up Jack Danielson, but he seems to be a career staffer, and not exactly someone who will take any serious action against a car company.

I do think its going to change, but not likely not for at least another year.