FSD email from Tesla (April 5, 2019)

[Chris350]

It will be interesting on how this FSD computer gets rolled out...

Waiting until software is ready seems like a major bottleneck for retrofits...

I mean, if all those who have purchased FSD and then software is issued that uses it, allot of owners are going to be rabid for the upgrade...

 

[run-the-joules]

It will be interesting on how this FSD computer gets rolled out...

Waiting until software is ready seems like a major bottleneck for retrofits...

I mean, if all those who have purchased FSD and then software is issued that uses it, allot of owners are going to be rabid for the upgrade...

It'll be as poorly managed and communicated as every other Tesla rollout, I'm sure.

 

[Daniel in SD]

It will be interesting on how this FSD computer gets rolled out...

Waiting until software is ready seems like a major bottleneck for retrofits...

I mean, if all those who have purchased FSD and then software is issued that uses it, allot of owners are going to be rabid for the upgrade...

Since the laws about FSD vehicles are different in every state it seems like they could just roll it out in the states where they get it approved first. It seems to me that the "automatic driving on city streets" feature would not be allowed in California as testing of FSD is only allowed to be done by employees.

 

[ItsNotAboutTheMoney]

None of it matters, your aren't getting real FSD either way.

We get it, you think the name is misleading.

But this thread is somebody asking about new computer hardware and features, not asking when the car will be Level 3+.

 

[Knightshade]

Since the laws about FSD vehicles are different in every state it seems like they could just roll it out in the states where they get it approved first. It seems to me that the "automatic driving on city streets" feature would not be allowed in California as testing of FSD is only allowed to be done by employees.

Since it'll be Level 2 at launch the regulations are irrelevant and it'll be legal in all 50 US states (Europe might be more complex)

More relevantly- this gives Tesla a bit of time to build up a stock of spare parts (a thing they're notoriously terrible at) so that when they start doing the rollouts via both service centers and rangers, they'll be able to burn through the # of retrofits needed rapidly.

The above is how they should be doing it, but that's usually a WILDLY optimistic expectation as Tesla has historically been utterly terrible at planning anything involving logistics.

 

[Daniel in SD]

Since it'll be Level 2 at launch the regulations are irrelevant and it'll be legal in all 50 US states (Europe might be more complex)

What Elon Musk has described is level 2 in the same way that Waymo and Uber FSD are level 2, it requires a vigilant driver to monitor the system. I had a long argument in another thread and I don’t think it’s going to happen in states that have FSD testing rules. I guess we’ll see!

 

[Watts_Up]

Since the laws about FSD vehicles are different in every state it seems like
they could just roll it out in the states where they get it approved first.
It seems to me that the "automatic driving on city streets" feature would not be
allowed in California as testing of FSD is only allowed to be done by employees.

The installation might depend on the car's state registration, but also the usage should be GPS based,
so FSD should be disabled when passing a state line for out of state vehicles with FSD activated.

 

[banned-66611]

What Elon Musk has described is level 2 in the same way that Waymo and Uber FSD are level 2, it requires a vigilant driver to monitor the system. I had a long argument in another thread and I don’t think it’s going to happen in states that have FSD testing rules. I guess we’ll see!

Waymo cars do not require a driver. They are operating with no-one in the driver's seat.

 

[Watts_Up]

Waymo cars do not require a driver. They are operating with no-one in the driver's seat.

Can they be controlled and manoeuvred remotely, in case the car get stranded and cannot decide what to do,
for example if there is an obstacle, like if a tree felt in middle of the road...?

 

[Knightshade]

What Elon Musk has described is level 2 in the same way that Waymo and Uber FSD are level 2, it requires a vigilant driver to monitor the system. I had a long argument in another thread and I don’t think it’s going to happen in states that have FSD testing rules. I guess we’ll see!

and in that thread I quoted, and linked to, the exact CA regulations that proved you were incorrect about this- might wanna go back and re-read it.

The driver being explicitly responsible for the driving task at all times means it's not in need of any regulatory approval whatsoever in CA.

Uber and Waymos vehicles are testing at higher levels where they driver has to be ready to take over the driving task at any time, but is NOT primarily responsible for the driving task at all times.

 

[Daniel in SD]

and in that thread I quoted, and linked to, the exact CA regulations that proved you were incorrect about this- might wanna go back and re-read it.

The driver being explicitly responsible for the driving task at all times means it's not in need of any regulatory approval whatsoever in CA.

Uber and Waymos vehicles are testing at higher levels where they driver has to be ready to take over the driving task at any time, but is NOT primarily responsible for the driving task at all times.

And I argued that that’s not how regulations work. Regulators are the ones who interpret the rules and I don’t think they’re going to buy that argument. There is no difference between being ready to take over and being explicitly responsible. How would an outside observer determine the difference between someone ready to take over and someone who was being responsible for the driving task?

 

[Daniel in SD]

Waymo cars do not require a driver. They are operating with no-one in the driver's seat.

They have a permit for that, every other company has a permit to test only with a driver. Last I read Waymo is not actually using that permission yet though.

 

[Knightshade]

And I argued that that’s not how regulations work. Regulators are the ones who interpret the rules and I don’t think they’re going to buy that argument.

Yes but your argument is wrong.

You can tell because current EAP (now FSD) is legal in California, and this would be literally under the same terms/laws/regulations/restrictions.

There is no difference between being ready to take over and being explicitly responsible

Of course there is.

it's literally the difference between L2 and L3 (or higher) in the SAE spec.

WHO is primarily responsible for the driving task? If it's the human behind the wheel, that's L1 or L2. If it's the car/computer it's L3 or higher. That's a fundamental difference.

. How would an outside observer determine the difference between someone ready to take over and someone who was being responsible for the driving task?

Why would they need to? They only need determine the designed use and limits of the system to see where it falls regarding regulation- not how "This dude I am observing looks like he is using it"

 

[Knightshade]

Since you apparently don't remember this being explained the last time, here we go again-

https://www.dmv.ca.gov/portal/wcm/c...essAV_Adopted_Regulatory_Text.pdf?MOD=AJPERES

That's California regulations on driverless cars.

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

FSD as it's going to be rolled out later this year is not capable of performing the dynamic driving task on a sustained basis without the constant control or active monitoring of a natural person.

Thus it is not an autonomous test vehicle under CA law.

Further-

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

FSD as Tesla plans to initially deploy it is not capable of L3, L4, or L5 operation- therefore, again it is not an autonomous test vehicle.


When Tesla decides they wish to upgrade the software to L3 or higher then they will need to deal with the various autonomous vehicle laws (or lack thereof) in the various US states. But that's not in their plans for this year.

 

[Daniel in SD]

Of course there is.

it's literally the difference between L2 and L3 (or higher) in the SAE spec.

WHO is primarily responsible for the driving task? If it's the human behind the wheel, that's L1 or L2. If it's the car/computer it's L3 or higher. That's a fundamental difference.

I think you’re misinterpreting the FSD testing rules in California. The test driver has the responsibility to determine when it is necessary to take over. In a level 3 system the car tells the driver when to take over.

You can tell because current EAP (now FSD) is legal in California, and this would be literally under the same terms/laws/regulations/restrictions.

It’s a slippery slope. Regulators aren't going to step in until there's a problem. I think the fact that all deaths and serious injuries have been to the driver of AP equipped vehicles has helped Tesla keep the system in the good graces of regulators.

FSD as Tesla plans to initially deploy it is not capable of L3, L4, or L5 operation- therefore, again it is not an autonomous test vehicle.

I still don't see the difference between "feature complete" FSD as a level 2 system and testing L3-5 FSD.

The activation and use of these features are dependent on achieving reliability far in excess of human drivers as demonstrated by billions of miles of experience, as well as regulatory approval, which may take longer in some jurisdictions.

To me that says that customers will be testing FSD. Tesla clearly knows that they may run into regulatory problems with their plan in some jurisdictions. Or maybe as a cyclist and pedestrian I'm just hoping that the DMV interprets the rules the way I do . Let other states verify the safety with untrained test drivers and bring it here when it's done.

 

[Knightshade]

I think you’re misinterpreting the FSD testing rules in California. The test driver has the responsibility to determine when it is necessary to take over. In a level 3 system the car tells the driver when to take over.

So it sounds like you agree Teslas system is not Level 3. And adding "in city" features won't change that.

So, just like I said, the testing rules in CA don't apply to Teslas FSD system as they plan to roll it out later this year.

It’s a slippery slope.

It's really not. The text I quoted is pretty clear about this.

It's why EAP cars don't need permits, but Waymo does.

I still don't see the difference between "feature complete" FSD as a level 2 system and testing L3-5 FSD.

Uh...one is L3+ and the other isn't?

Again there's a fundamental, specific, difference between L2 and L3 in the SAE spec.

Teslas stated implementation of FSD as it rolls out is L2. Therefore it's explicitly not required to do anything under CAs autonomous car rules since it's explicitly not an autonomous vehicle.

To me that says that customers will be testing FSD.

In the same sense they're "testing" EAP/AP? Sure. Since both will have the exact same rules around them, and neither will require any regulatory approval.

In the sense they need permits in CA? Not at all, by the actual text of CAs rules.

Tesla clearly knows that they may run into regulatory problems with their plan in some jurisdictions.

In non-US countries quite possibly (see also how NoA came out in the US while it was delayed elsewhere... or summon in Canada on the Model 3 vs available in the US much earlier)- but not in the US with the L2 plan.

They expect there'll be problems- in the sense many states don't even have regulations for this stuff yet- once they want to move to an L3 or higher system- hence why they're NOT promising to deliver one until that gets figured out... just an L2 version of FSD, which requires no approvals in the US.

 

[Daniel in SD]

So it sounds like you agree Teslas system is not Level 3. And adding "in city" features won't change that.

So, just like I said, the testing rules in CA don't apply to Teslas FSD system as they plan to roll it out later this year.

I agree that it's not level 3 in exactly the same way the Uber's system is not level 3. By your logic any company could test L3-5 FSD without a permit by simply calling it a level 2 system. They're already required to have an operator responsible for the driving task (The Uber test driver involved in the pedestrian collision is in fact facing criminal charges) so what advantage does getting a testing permit have?

 

[Knightshade]

I agree that it's not level 3 in exactly the same way the Uber's system is not level 3. By your logic any company could test L3-5 FSD without a permit by simply calling it a level 2 system. They're already required to have an operator responsible for the driving task (The Uber test driver involved in the pedestrian collision is in fact facing criminal charges) so what advantage does getting a testing permit have?

Ubers system wasn't L2. Didn't matter what they "called" it- it matters how it actually works.


https://www.techradar.com/news/uber-self-driving-cars

while the vehicle had an automatic emergency braking feature, this was disabled because the car was in "computer mode."


Though the car detected it needed to make an emergency braking maneuver 1.3 seconds before it struck the pedestrian who would later die of her injuries, the system doesn't alert the driver to take control of the vehicle.

That is not a level 2 system. No matter what Uber would "call" it.

 

[Daniel in SD]

That is not a level 2 system. No matter what Uber would "call" it.

Explain?
It sounds like the Uber test driver failed to be responsible for the driving task as they were legally mandated to be. I don't see how the scenario would have played out any differently in a Tesla running "feature complete" FSD.

 

[Knightshade]

Explain?
It sounds like the Uber test driver failed to be responsible for the driving task as they were legally mandated to be. I don't see how the scenario would have played out any differently in a Tesla running "feature complete" FSD.

The car was in a mode that disabled human assist features (since the car not the human was driving)- and in that mode the car also did not alert the driver to something that might need attention.

In other words- the system did not require the driver to be performing the primary driving task, and did not require constant human control/monitoring.

That's at least a Level 3 system (possibly higher depending on the operational domain) based on its actual function...wouldn't matter what Uber "called" it.

Hence it requires certification under CA law.

Teslas system is nothing like that, and so does not require such certification.


Tesla would like FSD to be L3 or higher in the future- but that's not the system they're rolling out later this year- so again there's no regulation required, at all, for the L2 version to roll out.