FSD - Level 2

[mikes_fsd]

I think what bothers some people about the DMV emails is that they don't say anything about FSD Beta eventually becoming L5 after release.

What bothers me (and others like me) about these emails is that a known short-seller and Tesla harasser, posts the emails to his cabal, who use it to create a narrative and then gullible people like you lap it up and perpetuate it without actual context on actual fan forums.

 

[mark95476]

It must have been hard for the anti-Tesla crowd when Tesla didn't go bankrupt like they crowed about for years.
- Multiple capital raises so Tesla can retire any debt. They have something like ~$20B in cash-equivalent available.
- TSLA got added to the S&P.
- Building and selling lots of vehicles. Anticipate 50% increase in vehicle for this year, while competitors had lost money in 2020.
- ~150k Model Ys built and sold in the US in first year of production. Shanghai started building and selling MYs in 2021.
- Two new factories about to come online.

The anti-Tesla crowd's last hope is that Tesla will get goaded into relelasing FSDbeta early and some people will get hurt generating ample bad press. Unfortunately for them, safety is paramount at Tesla and their vehicles are very robust. Also, Tesla is going to make drivers be responsible and pay attention as well (oh no, it's only L2! ).

What bothers me (and others like me) about these emails is that a known short-seller and Tesla harasser, posts the emails to his cabal, who use it to create a narrative and then gullible people like you lap it up and perpetuate it without actual context on actual fan forums.

 

[Dan D.]

I've been reading the SAE document on Levels

This line from page 30 explains to me why I feel Tesla is going against the spirit of the SAE Levels:

The level of a driving automation system feature corresponds to the feature’s production design intent. This applies regardless of whether the vehicle on which it is equipped is a production vehicle already deployed in commerce, or a test vehicle that has yet to be deployed. As such,
it is incorrect to classify a level 4 design-intended ADS feature equipped on a test vehicle as level 2 simply because on-road testing requires a test driver to supervise the feature while engaged, and to intervene if necessary to maintain safe operation.

To me, Tesla has designed and is intending FSD to be Level 4. They say that it is Level 2 only to avoid the responsibilities that are required to follow a Level 4 testing protocol.

 

[mikes_fsd]

To me, Tesla has designed and is intending FSD to be Level 4. They say that it is Level 2 only to avoid the responsibilities that are required to follow a Level 4 testing protocol.

SAE is not a regulatory body!

 

[Dan D.]

SAE is not a regulatory body!

True. That's why I feel Tesla is going against the spirit of the SAE document.
Declaring FSD Beta to be Level 2 in California is where they are skirting the regulations. Legally, I suppose.

 

[diplomat33]

SAE is not a regulatory body!

No but the CA DMV, or the NTSB are regulatory bodies and they use the SAE levels.

 

[shrineofchance]

That excerpt is really interesting, but it prompts the question: what, besides the requirement for driver supervision, distinguishes between SAE Level 2 and SAE Level 4?

Moreover, it wouldn’t be in the interest of safety for Tesla to classify FSD Beta as SAE Level 4 because this would mean Tesla users could sleep in the back seat.

I think the safety testing Tesla is doing is going to be exactly the same whether they are classifying FSD Beta as SAE Level 2 or SAE Level 4.

I think there might be a distinction made between paying customers and paid test drivers.

 

[Dan D.]

Moreover, it wouldn’t be in the interest of safety for Tesla to classify FSD Beta as SAE Level 4 because this would mean Tesla users could sleep in the back seat.

I think the safety testing Tesla is doing is going to be exactly the same whether they are classifying FSD Beta as SAE Level 2 or SAE Level 4.

If you're testing Level 4 then you would have testing rules for the safety driver. That would be in their plan.

 

[Dan D.]

That excerpt is really interesting, but it prompts the question: what, besides the requirement for driver supervision, distinguishes between SAE Level 2 and SAE Level 4?

Many, many things

Have a look, download the PDF

 

[diplomat33]

That excerpt is really interesting, but it prompts the question: what, besides the requirement for driver supervision, distinguishes between SAE Level 2 and SAE Level 4?

The SAE is very clear about this. Put simply, L2 needs a driver because L2 needs a human to do certain driving tasks. L4 does not need a driver because the L4 can handle all the driving tasks. So if L4 has a safety driver, it is not to do any driving tasks, it is merely to monitor as part of testing.

SAE, page 24:

A level 2 driving automation feature is capable of only limited OEDR, meaning that there are some events that the driving automation system is not capable of recognizing or responding to. Therefore, the driver supervises the driving automation system performance by completing the OEDR subtask of the DDT.

For example, maybe the L2 cannot recognize or respond to road debris so it needs a human to watch for road debris and intervene as needed.

The SAE document also has a good table that spells out the role of the driver and the system when the system is on or off Here is what it says for L2 and L4.

You can see the differences between the two:

 

[diplomat33]

I've been reading the SAE document on Levels

This line from page 30 explains to me why I feel Tesla is going against the spirit of the SAE Levels:

The level of a driving automation system feature corresponds to the feature’s production design intent. This applies regardless of whether the vehicle on which it is equipped is a production vehicle already deployed in commerce, or a test vehicle that has yet to be deployed. As such,
it is incorrect to classify a level 4 design-intended ADS feature equipped on a test vehicle as level 2 simply because on-road testing requires a test driver to supervise the feature while engaged, and to intervene if necessary to maintain safe operation.

To me, Tesla has designed and is intending FSD to be Level 4. They say that it is Level 2 only to avoid the responsibilities that are required to follow a Level 4 testing protocol.

In the DMV emails, Tesla says that FSD Beta is L2 because it cannot do the entire OEDR. So I don't think Tesla is using the "driver supervision" excuse to say that FSD Beta is L2. Tesla is following the correct SAE definition of L2. They are saying FSD Beta is L2 because it can't do all the driving tasks.

But Tesla hopes the L2 will become L5 at some point. So they are testing L2 but with the goal of making it L5 at some point. If it works, Tesla can get all the benefits of testing and marketing but without submitting to any regulations that might have slowed them down. So it is a clever loop hole.

 

[Dan D.]

In the DMV emails, Tesla says that FSD Beta is L2 because it cannot do the entire OEDR. So I don't think Tesla is using the "driver supervision" excuse to say that FSD Beta is L2. Tesla is following the correct SAE definition of L2. They are saying FSD Beta is L2 because it can't do all the driving tasks.

But Tesla hopes the L2 will become L5 at some point. So they are testing L2 but with the goal of making it L5 at some point. If it works, Tesla can get all the benefits of testing and marketing but without submitting to any regulations that might have slowed them down. So it is a clever loop hole.

Yes, in a sense. However Tesla is testing features that could be Level 3-5. They may not have enough of them to constitute Level 3-5 when taken as a whole but they could call it Level 3 testing if they wanted. For testing you don't have to have a fully working system. It would get them on the board for autonomous miles driven, but they don't want the associated bother and regulations required to do it safely.

Clever loopholes are the refuge of the scoundrel.

 

[diplomat33]

Yes, in a sense. However Tesla is testing features that could be Level 3-5. They may not have enough of them to constitute Level 3-5 when taken as a whole but they could call it Level 3 testing if they wanted. For testing you don't have to have a fully working system. It would get them on the board for autonomous miles driven, but they don't want the associated bother and regulations required to do it safely.

Clever loopholes are the refuge of the scoundrel.

I am fully in the camp that Tesla should admit that they are testing autonomous driving and they should submit disengagement reports to the CA DMV. I think it would be more honest and more transparent.

 

[AlanSubie4Life]

It must have been hard for the anti-Tesla crowd when Tesla didn't go bankrupt like they crowed about for years.
- Multiple capital raises so Tesla can retire any debt. They have something like ~$20B in cash-equivalent available.
- TSLA got added to the S&P.
- Building and selling lots of vehicles. Anticipate 50% increase in vehicle for this year, while competitors had lost money in 2020.
- ~150k Model Ys built and sold in the US in first year of production. Shanghai started building and selling MYs in 2021.
- Two new factories about to come online.

The anti-Tesla crowd's last hope is that Tesla will get goaded into relelasing FSDbeta early and some people will get hurt generating ample bad press. Unfortunately for them, safety is paramount at Tesla and their vehicles are very robust. Also, Tesla is going to make drivers be responsible and pay attention as well (oh no, it's only L2! ).

I think it's possible to be pro-Tesla and be an owner and shareholder, while still insisting that for shareholders (and owners), it's best that Tesla deliver on their commitments to owners who purchased under the pre-2019 version of FSD.

No one is really goading Tesla into releasing FSD Beta early. Elon was the one who said they were going to do it (and then reneged on that)! I think it's also possible as a shareholder to think that having Elon make responsible statements, which bear out in reality, based on the actual state of current development, are good for shareholders. I understand Elon is an ambitious and enthusiastic guy, but I tend to think having optimism grounded in facts is probably better for stability of the development team, and probably also better for the long term success of their autonomous development. Imagine the power if Elon could make statements on Twitter which were generally regarded as true (notwithstanding current SEC limitations)!

I also think it's fine for Tesla to keep their development entirely under wraps and not have Elon tweeting about it, but that's a different strategy (not one they're pursuing right now), and I'm agnostic about which one is best.

 

[mikes_fsd]

it's best that Tesla deliver on their commitments to owners who purchased under the pre-2019 version of FSD.

Oh, I agree 100%.
I am not in the business of giving money for nothing.
That is why I am surprised to find so many people try to ignore the FSD Capability as defined by Tesla on their website.

 

[mikes_fsd]

I am fully in the camp that Tesla should admit that they are testing autonomous driving and they should submit disengagement reports to the CA DMV. I think it would be more honest and more transparent.

Then you are in the camp that does not want to see FSD widely deployed in the next decade.

A great example from SpaceX side today...
SpaceX scrubbed Starship SN11 flight - because FAA observer/agent could not make it there in time...
Oh, FAA updated their guidelines for SpaceX to operate to "give reasonable advance notice" without ever defining what reasonable meant! That is what you're asking for, especially in a state that is -- now -- filled with politicians that openly display their hate towards Musk!

 

[Dan D.]

Then you are in the camp that does not want to see FSD widely deployed in the next decade.

A great example from SpaceX side today...
SpaceX scrubbed Starship SN11 flight - because FAA observer/agent could not make it there in time...

They might not have needed the FAA observer/agent if they had not violated their FAA test license for SN8 in the first place. This only further proves the point that Tesla is playing fast and loose with the rules, then blames the regulators for delays.

 

[diplomat33]

Then you are in the camp that does not want to see FSD widely deployed in the next decade.

No, I am not in that camp. In fact, companies like Waymo, Cruise, Zoox and many others are already deploying FSD now and they submit disengagement reports every year to the CA DMV. They are deploying FSD before Tesla! They are doing just fine deploying FSD and following regulator rules. It is a false equivalency that you have to break the rules and diss regulators in order to make progress with FSD.

Plus, Elon has said that they will get regulatory approval before deploying L5 wide. So will Tesla get regulatory approval or not? You can't have it both ways. You can't say that regulatory approval just slows Tesla down from deploying wide but Tesla will get regulatory approval before deploying wide!

With respect to SpaceX, it only delayed the launch by 1 day. Hardly, an example of regulators delaying progress by decades as you claim. It's not a big deal to simply give the FAA advance notice so that they can show up to watch the launch, is it?

 

[GZDongles]

They might not have needed the FAA observer/agent if they had not violated their FAA test license for SN8 in the first place. This only further proves the point that Tesla is playing fast and loose with the rules, then blames the regulators for delays.

I completely agree with this. The FAA regulations aren't onerous, and if SpaceX were better organized they could easily meet them. Aviation and space have too much of a risk of serious adverse human, environmental, or other consequences to be taken lightly.

As someone in the aviation industry, I can say the FAA normally does an excellent job of balancing safety and industry growth. Air travel is by far the safest form of transit and the industry is a huge export industry for the U.S.

Anyway, I don't want to get sidetracked, but I think regulations are important for things like autonomous vehicles and space travel where consumer and corporate interests are not completely aligned.

 

[mark95476]

The FAA has sooo much credibility after the Boeing 737 MAX debacle. /SARCASM

It's an unfortunate outcome of regulatory capture.

They might not have needed the FAA observer/agent if they had not violated their FAA test license for SN8 in the first place. This only further proves the point that Tesla is playing fast and loose with the rules, then blames the regulators for delays.

I completely agree with this. The FAA regulations aren't onerous, and if SpaceX were better organized they could easily meet them. Aviation and space have too much of a risk of serious adverse human, environmental, or other consequences to be taken lightly.

As someone in the aviation industry, I can say the FAA normally does an excellent job of balancing safety and industry growth. Air travel is by far the safest form of transit and the industry is a huge export industry for the U.S.

Anyway, I don't want to get sidetracked, but I think regulations are important for things like autonomous vehicles and space travel where consumer and corporate interests are not completely aligned.