Emails between Tesla and CA DMV on Smart Summon, FSD

[Tam]

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

There is no denial in current Tesla capability which is not L3 except for the very specific L3 Video Demo.

...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)...

As long as the driver is in the car then Summon not autonomous but as soon as the driver is outside of the car, then it's autonomous.

...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...

Yes. It's autonomous testing because the driver has been outside of the car for many years.

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

Even if used in a public parking lot....

It's a matter of enforcement. Maybe it wasn't a big deal when people were crashing their own private garages with Simple Summon before.

But since Smart Summon, it might be another story with the start of reports of near misses and parking lot accidents.

Just because DMV didn't enforce driver-outside-of-car practice for many years, that doesn't mean it can't currently.

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

"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."

I interpret that clause as a system is not autonomous if the system is not good enough to the point that it still needs a driver who:

1) controls it

or

2) monitors it

Since it is not good enough in its sub-L3, it is unreasonable to interpret that the driver could control or monitor it from outside the car when the car is speeding at 80 MPH on the freeway.

I interpret "natural person" here must be inside the car, and not outside the car.

 

[Knightshade]

As long as the driver is in the car then Summon not autonomous but as soon as the driver is outside of the car, then it's autonomous.

This is directly contradicted by your own source- so no.

If it requires constant monitoring by a human inside or outside the car is irrelevant it's not autonomous.

It literally says that in your source doc

You are making up this entire fictional idea that "outside the car means autonomous"

It's not in the definition anywhere.

Yes. It's autonomous testing because the driver has been outside of the car for many years.

No, it's really not. Again read your own doc, it directly contradicts you.

"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."

I interpret that clause as a system is not autonomous if the system is not good enough to the point that it still needs a driver who:

1) controls it

or

2) monitors it

Not driver.

Natural person.

Who can be located in, or out, of the car- it doesn't require either.

Since it is not good enough in its sub-L3, it is unreasonable to interpret that the driver could control or monitor it from outside the car when the car is speeding at 80 MPH on the freeway.

Except, of course, the car doesn't go 80 mph when using summon.

So it's totally reasonable they CAN monitor it from outside the car using summon.

Thus using summon is NOT an autonomous feature, since it requires constant monitoring of a natural person.

I interpret "natural person" here must be inside the car, and not outside the car.

Which is entirely not there in the actual definition.

You're adding it- for no apparent reason.

 

[Tam]

...You're adding it- for no apparent reason.

With good reasons.

The clause needs to be read with context.

"Natural Person" is not specified as a driver or an unlicensed 5-year-old pre-schooler. However, in this context, it's a person must be old enough to be legally licensed for driving, not a pre-schooler.

Same, when controls or monitors are not mentioned as inside or outside of the car. In this context, those are customarily done when a person is in the car just like as if when that person passed a driving licensed test. Got to be inside, not outside.

If I need to pass a driving test and I am outside, that's another whole different level. It's the certification process of Autonomous for the car.

 

[Knightshade]

With good reasons.

The clause needs to be read with context.

"Natural Person" is not specified as a driver or an unlicensed 5-year-old pre-schooler. However, in this context, it's a person must be old enough to be legally licensed for driving, not a pre-schooler.

Which has nothing to do with where they are sitting at the time.

Same, when controls or monitors are not mentioned as inside or outside of the car.

Absolutely wrong.

There' NOTHING in the text that requires the natural person monitoring it to be INSIDE the car.

If you have a feature that requires a natural person to constantly actively monitor the car it's not autonomous. Period full stop.

The physical location of said person isn't an issue either way.

Obviously as you suggest having them be outside the car only works at low speed and short distance.

Which- coincidentally- is EXACTLY the conditions under which summon works.

Which is why using summon does not make the car autonomous under CA definitions.

If I need to pass a driving test and I am outside, that's another whole different level. It's the certification process of Autonomous for the car.

It's not though, because the CA regs explicitly say you are wrong


If the vehicle function requires active monitoring of a natural person (with NO regard to them being inside or outside the car) then it is not an autonomous vehicle.

 

[willow_hiller]

Not to re-litigate the Plainsite issue, but in case anyone still had questions about the incentives of the founder, Aaron Greenspan: https://twitter.com/enn_nafnlaus/status/1280456905907896325

Greenspan is suing Omar Qazi (used to run the "Steve Job's Ghost" pro-Tesla twitter account), and is now using his charity Plainsite to dox people donating to Qazi's legal defense fund...

 

[jelloslug]

I (and many, many other people) have been saying for a while that Tesla has been testing their more advanced self driving for a long time under the guise of the current hardware.

 

[timewasted]

I (and many, many other people) have been saying for a while that Tesla has been testing their more advanced self driving for a long time under the guise of the current hardware.

It never made sense when people started saying it, and it still doesn’t make sense today. Smart Summon is, and continues to be, a dumpster fire of a feature. It ignores all signage, will happily drive onto the curb or down an embankment, and just gives up right in the middle of the lane forcing you to run up to it. This is a feature they released!

So the theory is that they have something amazing that will blow everyone’s mind but they WON’T release it? Why is that? I’m serious, I’d like to know. It’s not because of safety issues, because they have no problem releasing features that aren’t fully vetted already.

The reason they haven’t released this mind blowing improvement update is because such a thing doesn’t actually exist. That’s not to say that it can’t ever exist, just that it doesn’t right now. Ever since AP2.0 was released people have been talking about the super secret level 5 code branch that they have all ready to go. We’re coming up on 4 years since that point. It’s time to accept that they have what we see, with maybe incremental improvements.

Sorry to be the bearer of bad news (aka the realist).

 

[jelloslug]

It never made sense when people started saying it, and it still doesn’t make sense today. Smart Summon is, and continues to be, a dumpster fire of a feature. It ignores all signage, will happily drive onto the curb or down an embankment, and just gives up right in the middle of the lane forcing you to run up to it. This is a feature they released!

So the theory is that they have something amazing that will blow everyone’s mind but they WON’T release it? Why is that? I’m serious, I’d like to know. It’s not because of safety issues, because they have no problem releasing features that aren’t fully vetted already.

The reason they haven’t released this mind blowing improvement update is because such a thing doesn’t actually exist. That’s not to say that it can’t ever exist, just that it doesn’t right now. Ever since AP2.0 was released people have been talking about the super secret level 5 code branch that they have all ready to go. We’re coming up on 4 years since that point. It’s time to accept that they have what we see, with maybe incremental improvements.

Sorry to be the bearer of bad news (aka the realist).

Why are you focusing on smart summon when I never mentioned it? I said "advanced self driving".

 

[timewasted]

Why are you focusing on smart summon when I never mentioned it? I said "advanced self driving".

It’s their latest banner feature, and literally in the title of this post. On top of that, parking lots are incredibly difficult areas to drive in due to the crazy number of different things to keep track of. It’s basically everything needed for city driving packed into a tiny area.

 

[diplomat33]

I (and many, many other people) have been saying for a while that Tesla has been testing their more advanced self driving for a long time under the guise of the current hardware.

What exactly do you mean by "advanced self-driving"?

Tesla does test new software before releasing it to the public. So yes, they do test more advanced software than what we have. That's the nature of software development. And we know that Tesla has a rewrite that is more advanced that what we have. But I don't think Tesla has some super advanced L4 or L5 autonomous driving hiding somewhere. If they did have that, I am sure we would hear about it. But they don't have that. What we saw on Autonomy Day in the FSD demo is probably a good representation of the best Tesla has.

 

[jelloslug]

It’s their latest banner feature, and literally in the title of this post. On top of that, parking lots are incredibly difficult areas to drive in due to the crazy number of different things to keep track of. It’s basically everything needed for city driving packed into a tiny area.

Again, read my post.

 

[diplomat33]

An excerpt from the letter between Tesla and the CA DMV about FSD Beta:

 

[willow_hiller]

An excerpt from the letter between Tesla and the CA DMV about FSD Beta

I'm not sure I really understand why there's so much controversy over this text. I've seen a lot of commentary on Twitter assuming this means FSD as a whole was never intended to be autonomous, but It states very clearly at the bottom that Level 3+ is in continued development. This is just assuring the DMV that Autosteer on City Streets is a Level 2 driver-assistance feature.

 

[diplomat33]

I'm not sure I really understand why there's so much controversy over this text. I've seen a lot of commentary on Twitter assuming this means FSD as a whole was never intended to be autonomous, but It states very clearly at the bottom that Level 3+ is in continued development. This is just assuring the DMV that Autosteer on City Streets is a Level 2 driver-assistance feature.

Part of the controversy might be because some Tesla fans think FSD City Streets is already autonomous, just needing a little supervision. Or they believe that FSD City Streets needs driver supervision now while it is in beta but it is very close to autonomous so when it is released to the public, it will be autonomous. Tesla saying that FSD City will not be autonomous in the final release contradicts that perception.

Also, with Elon talking about L5 happening this year, it might have led people to assume FSD City Streets would be autonomous. I mean it would seem unlikely that FSD City Streets would be released say in a month as L2 but then 8 months later (by December of this year), FSD becomes L5. So hearing that FSD City Streets will be released as L2 might have made some people conclude that Tesla cannot achieve L5 this year.

 

[Bednarz42]

I think it means L5 FSD is a long...long way off still.

 

[willow_hiller]

some Tesla fans think FSD City Streets is already autonomous, just needing a little supervision

Is there anything in that communication that contradicts that belief? This is a regulator asking Tesla "Do you need to collect data on disengagements of autonomous systems and send it to us?" and Tesla replying "We have no immediate plans to allow the public to operate FSD without supervision, therefore no."

It's been known for a while that Tesla has used the technicalities of SAE definitions to skirt these reporting requirements. Just because they continue to do so doesn't change anything about the capabilities of the FSD.

 

[diplomat33]

Is there anything in that communication that contradicts that belief?

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.

 

[ZeApelido]

I think it means L5 FSD is a long...long way off still.

I think it means absolutely nothing.

 

[Mardak]

"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.

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.

 

[willow_hiller]

"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."

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.