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Your post makes no sense because safety drivers put their hands on the wheel and foot on the brake and there are two engineers monitoring the system at every moment.

All SDC today are physically controlled and monitored by their safety drivers.

If so, I would say that, if that is required for the SW to run, they do not need to report either. However, watching it run is not the same as active interaction with the SW to indicate it is being monitored. A watchdog, if you will.

lol what?
Blowing 6 red lights shows the vehicle was not under (useful) direct physical control nor monitoring. If it was, the driver would have stopped the car.

Base point: EAP is not reported. Replace with FSD code, keep nag, does it require reporting?
 
Blowing 6 red lights shows the vehicle was not under (useful) direct physical control nor monitoring. If it was, the driver would have stopped the car.
This just in, a Ford Taurus vehicle with a driver on the phone blows past several red lights and hits a pole, Ford cars are banned from California road by CA DMV for violation of autonomous driving rules.
 
Occam's Razor. The simplest explanation is:
1) Tesla is working from EAP -> FSD. Their test drivers sit behind the wheel, with hands on 'testing EAP'.
2) The others are all starting at FSD
3) Tesla lawyers interpret the requirement from CA as only applicable to FSD
4) Tesla layers say 'no reporting required' based on a very narrow interpretation of CA regulations.

Leaves us, and their competition, guessing. Nothing technical to be gleaned from this report, but by all means have a discussion whether Tesla lawyers are right to skip the reporting requirements on a technicality.

+100. This is exactly what it is.

If Tesla said they had only 5 disengagements, then shorts will say Tesla is doing no testing because they are behind.

If Tesla said they had 548759 disengagements, then shorts will say Tesla is far behind others due to large number of disengagements
 
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This just in, a Ford Taurus vehicle with a driver on the phone blows past several red lights and hits a pole, Ford cars are banned from California road by CA DMV for violation of autonomous driving rules.

Why the straw man?
CA has defined "autonomous vehicle" and "autonomous mode". AM requires AV. If the SW requires direct physical control or monitoring, it is not an AV.
Link to law.
ca_sd.PNG


A standard vehicle requires direct physical input to supply accelerator and steering inputs, therefore not autonomous.
Cruise control does not steer, therefore requires direct physical input, and is not autonomous.

If the Ford had software that could operate hands/feet free with no nag, and Ford was operating without a permit, they would be in violation of CA law.

Base claim: Tesla is not required to report EAP usage/ disengagements. If EAP is replaced with FSD and the same nag system is retained such that input is required for the SW to continue operating (meeting the criteria of "not capable of driving or operating the vehicle without the active physical control or monitoring of a natural person"), why would Tesla now be required to report anything?
 
If the Ford had software that could operate hands/feet free with no nag, and Ford was operating without a permit, they would be in violation of CA law.
Whoosh.

Ever tried to not hold the steering wheel in a regular car? Esp. with cruise control activated? Does it still go somewhere? Autonomously? ;)

Anyway, relevant quote:
Uber affairs said:
“We respectfully disagree with the California Department of Motor Vehicles’ legal interpretations of existing regulations,” Anthony Levandowski, Uber’s Vice President of Advanced Technologies Group, said on the conference call. Levandowski added that Uber’s current technology was more akin to the Advanced Driver Assist System (ADAS) technology that’s found on Teslas in the form of autopilot software. Tesla's autopilot is not subject to the same scrutiny that more advanced autonomous vehicle software is.

The dispute between Uber and the DMV began on Wednesday, when Uber announced that it had added a handful of self-driving cars to its fleet. As a redundancy, each self-driving car is sent out with an engineer in the driver’s seat, ready to take over if the vehicle struggles to drive on its own. Riders get a notification if they’re selected for a ride in one of Uber’s test cars, which they can accept or decline. But the California DMV stated that Uber hadn’t submitted the proper permitting to put self-driving cars on the road. By Wednesday night, the department told the ride-hailing company to stop (PDF) driving its self-driving cars on state roads until it got proper permission.

So Uber defense was "we are no different than Tesla, we are just ADAS" and they were shot down. So the rule really seems to be "if we say it's autonomous, it's autonomous". And if "we are the same as Tesla" did not fly, how do you think "we are the Tesla" would fly?
 
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Whoosh.

Ever tried to not hold the steering wheel in a regular car? Esp. with cruise control activated? Does it still go somewhere? Autonomously? ;)
You can woosh all you want, I'm still not following how steering tracking has anything to do with SW that is designed to guide a car.

Anyway, relevant quote:


So Uber defense was "we are no different than Tesla, we are just ADAS" and they were shot down. So the rule really seems to be "if we say it's autonomous, it's autonomous". And if "we are the same as Tesla" did not fly, how do you think "we are the Tesla" would fly?

From what you quoted (admittedly not an Uber direct quote, relying on good journalism here)
As a redundancy, each self-driving car is sent out with an engineer in the driver’s seat, ready to take over if the vehicle struggles to drive on its own.

The Uber software is meant to keep going on it's own. The driver input is not required (hence redundancy). There is no active monitoring required. They are not the same as Tesla which will stop the car if the driver does not interact with the vehicle. I would almost say the large jump in nag rate was to clearly link driver input requirements to the SW operation.

Is Tesla in violation for not reporting EAP data?
If not, why would switching the back end to FSD SW with the same nag requirements cause Tesla to be required to report disengagement data?
 
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I just wonder why they would not report FSD testing. I would guess any decent disengagment/miles-ratio would be fantastic marketing. Tesla is the only one selling a product, but no new marketing since 1.5 years ago!?
 
Occam's Razor. The simplest explanation is:
1) Tesla is working from EAP -> FSD. Their test drivers sit behind the wheel, with hands on 'testing EAP'.
2) The others are all starting at FSD
3) Tesla lawyers interpret the requirement from CA as only applicable to FSD
4) Tesla layers say 'no reporting required' based on a very narrow interpretation of CA regulations.

Leaves us, and their competition, guessing. Nothing technical to be gleaned from this report, but by all means have a discussion whether Tesla lawyers are right to skip the reporting requirements on a technicality.

1. Debunked. Uber tried and failed at this argument. ADAS operation in that manner is operation that applies to CA regs regarding self-driving.

2. Ok...except for Uber which tried #1, 3, and 4 and still failed. Clearly Tesla has not done this in California during the 2017 reporting period o public roads.

3. Debunked.

4. Debunked.

Unless you want to argue against @verygreen or his observations as being the only one to actually penetrate and root the AP2 computer (that we know of).

Anyone that does that better bring actual evidence.

So that leaves us with only testing vehicles using software training (which could be useful), on private roads (also useful but if that's all that is going on clearly the software sucks because it cannot handle actual driving so its only a gimmick), or somehow testing in another state (perhaps Nevada).

That's it. Nevada seems most likely but also disheartening because its basically the gimmick factor because its probably not the most challenging or representative training ground. Maybe coupled with software sim. @lunitiks could weigh in best.
 
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I just wonder why they would not report FSD testing. I would guess any decent disengagment/miles-ratio would be fantastic marketing. Tesla is the only one selling a product, but no new marketing since 1.5 years ago!?

No real upside to them. At this point, testing reports are unlikely to induce people pay up front for FSD. Sales are production limited. Wouldn't do much to stock price.

Possibly, they are taking the opposite approach from the 3 launch. Say nothing till it's all groovy.
 
1. Debunked. Uber tried and failed at this argument. ADAS operation in that manner is operation that applies to CA regs regarding self-driving.

2. Ok...except for Uber which tried #1, 3, and 4 and still failed. Clearly Tesla has not done this in California during the 2017 reporting period o public roads.

3. Debunked.

4. Debunked.

Unless you want to argue against @verygreen or his observations as being the only one to actually penetrate and root the AP2 computer (that we know of).

Anyone that does that better bring actual evidence.

So that leaves us with only testing vehicles using software training (which could be useful), on private roads (also useful but if that's all that is going on clearly the software sucks because it cannot handle actual driving so its only a gimmick), or somehow testing in another state (perhaps Nevada).

That's it. Nevada seems most likely but also disheartening because its basically the gimmick factor because its probably not the most challenging or representative training ground. Maybe coupled with software sim. @lunitiks could weigh in best.

Can you point me to a link show regarding 1,3,4 where Uber's software required hands on wheel? (not being argumentative, I would really like to see base data)

EAP is not currently required to be reported, so why would FSD with the same nag system require reporting? (and I am arguing against @verygreen)
 
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Please click some links in that article, CA DMV found them in violation long before the red light accident.

Uber insisted that according to the letter of the law they are just an ADAS and not self driving so they don't need to report. Same argument you seem to be making on behalf of Tesla (speculatively).
Yeah, Uber made a similar argument but failed. I guess the difference is that a EAP and FSD equipped car has no hardware difference, while it's plain to everyone that the Volvos Uber were using are equipped for way more than just ADAS.

The legal intricacies are interesting. California took issue with Uber not having a license at all (Tesla already had a license), but who knows how strict they are about reporting miles. Technically there is almost no way for third parties to tell if Tesla is doing testing, so it won't be easy to catch.
 
Look. Tesla did the 2016 "demonstration" videos in California. They have their HQs in California. They have their Design Studio, factory and engineers in California. According to @verygreen, they're making hd-maps in California. Elon Musk drives around in California. Tesla has applied for and been granted an autonomous test permit in California.

What kind of shred of evidence do we have that Tesla has actually been doing field testing elsewhere than California?

Secret labs. Indoor test facilities. GTA5. Area 51.

LOL !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
Technically though unlike the other companies, there is no way to tell from the hardware if a car is doing FSD testing or other testing. You can tell the car is a test vehicle if it has a MFG plate or a big red stop button.

Just some examples I found with a quick search.
For example some sightings from in Minnesota, in Texas with MFG plates:
Random Model S sightings
Test Tesla with additional sensors and red button spotted in Oregon:
Autopilot testing hardware spotted at Grants Pass SC
Test Tesla with additional sensors and red button returning after doing cross country trip:
Test Mule S - returning to Fremont from 6 week x-country trip
Test Tesla with additional sensors and red button spotted in Texas:
Two more Model S's with more hardware spotted.
Test Model 3 spotted in Florida (humidity testing was mentioned):
Model 3 Spotted at West Palm Beach
More on East coast (from months ago):
Saw a black Model 3 in MA!

Not possible to tell what they are testing other than trusting what the engineer says (assuming they even answer questions). For the other self driving cars you can tell from very far away because of the big sensor housing on the top.
 
Yeah, no. You conveniently left out the part of the discussion where Uber tried to make this argument and got a smackdown from the DMV.

I invested a boatload of money into Tesla. As an investor sometimes you need to take off the rose tinted glasses and be realistic. Too often in this thread people blindly try to rationalize Tesla's problems. And I don't mean you personally, I have seen everybody's reply to this story here.

If anybody else wants to follow this discussion and read about the whole picture feel free to drop by this thread, I will not challenge this here anymore.

Thanks for the redirect to this thread.

I didn't leave it out, I addressed a portion.
However, there is no reason to take as a given that Uber's argument and the ruling against it has any bearing on Tesla.

If someone claims they are doing the same thing as someone else, there are two possibilities:
They are doing the same thing, or
They are not doing the same thing.
If they are not doing the same thing, then any argument they make is irrelevant in regards to the second party.

But since people like talking Uber instead of Tesla...

Looking at the link you posted:
According to NYT, Kohler clarified on Friday: “Our self-driving technology required human intervention. The vehicle operator had time to intervene, but failed to take over before crossing the stop line and manually proceeded through the protected crosswalk.”
Look at that quote, they said it "required human intervention" due to an error. That is in clear opposition to the CA law which gives an exemption for a system that that requires "active physical control or monitoring". In the Tesla ESP nag system, the driver in continuously required to provide input, not just when the system has trouble. If the driver is only intervening, the car is driving itself before intervention.

Second level links from article you posted:
California DMV orders Uber to stop self-driving car tests on SF roads [Updated]
Uber’s cars require a human operator to make any kind of significant trip, with Bloomberg reporting that in a Tuesday test drive, the engineer behind the wheel “took control of the vehicle more than a dozen times in less than 30 minutes.” Still, the cars are meant to largely drive autonomously on city streets.

Again stating that insignificant trips do NOT require a driver. Operating without direct physical input, and no requirement for continuous monitoring is the definition of AV. The idea that it has not perfected all situations does not make it non-autonomous.

Uber, defiant, says it won’t apply for an autonomous car permit in California [Updated]
As a redundancy, each self-driving car is sent out with an engineer in the driver’s seat, ready to take over if the vehicle struggles to drive on its own.
"As a redundancy" is, again, the opposite of a driver as a requirement. The car can drive without anyone in it.

Show me where it states that Uber's system requires continuous physical control or monitoring to operate, and I will agree that that system is similar to Tesla's.

Is EAP reported? No.
Has CA required Telsa report on EAP or warned them about non-reporting of EAP? No
Can we then reasonably conclude that based on the law and real world data that EAP is not considered Autonomous by CA? Yes

Therefore, if the current requirement for hands on wheel are maintained so that the SW will not function without direct physical control and monitoring, how does changing the SW to the FSD code set impact reporting requirements, if at all?
 
Is Tesla in violation for not reporting EAP data?
If not, why would switching the back end to FSD SW with the same nag requirements cause Tesla to be required to report disengagement data?
I am not CA DMV, I guess you are not either.

As such - we can only speculate. Tesla might be one whistleblower away from being busted for illegally testing selfdriving cars in CA. Or they might not be doing any testing. Or they think they are in the clear (Uber-style) and CA thinks they are not (after some discovery or whatever).

The ball is at the CA DMV side, so we'll see what they do. It's just in my opinion the "oh, it's only EAP so no need to report" is debatable, but I have no standing to actually pursue it and I don't really know if Tesla did anything that CA DMV would consider reportable (though I suspect they did, but if a car is not owned by Tesla - would that still be reportable by Tesla? I.e. imagine Elon or some employee has FSD code and activates it in their private car, let's assume it was not done by direction from Tesla).

Edit: I also think theory that they deliberately did not do any testing until December should not be totally written off.
 
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I am not CA DMV, I guess you are not either.

Nope, live in Michigan, and read a lot of specs in my job.

As such - we can only speculate. Tesla might be one whistleblower away from being busted for illegally testing selfdriving cars in CA. Or they might not be doing any testing. Or they think they are in the clear (Uber-style) and CA thinks they are not (after some discovery or whatever).
Or they actually are in the clear. Again, for all I've read, an Uber would drive itself until it runs into a problem or obstacle. A Tesla will only go for some period of time before it requires driver input, and it will not start on it's own. As long as the nag feature stays, the law doesn't appear to address the level of underling functionality.

The ball is at the CA DMV side, so we'll see what they do. It's just in my opinion the "oh, it's only EAP so no need to report" is debatable, but I have no standing to actually pursue it and I don't really know if Tesla did anything that CA DMV would consider reportable (though I suspect they did, but if a car is not owned by Tesla - would that still be reportable by Tesla? I.e. imagine Elon or some employee has FSD code and activates it in their private car, let's assume it was not done by direction from Tesla).

2015 had a 0 report from Tesla, 2016 had a few cars. 2017 was back to 0/ If CA was going after EAP, we'd see it by now.

The law I read was for manufacturers. Depending on base law, private citizens either can or cannot test on their own (Guessing motor vehicle law would be that they can't). However, manufacturers (227.34) are prevented from letting people test their cars outside the stated requirements. So Tesla could not grant access to autonomous function to others.

Edit: I also think theory that they deliberately did not do any testing until December should not be totally written off.

Not writing anything off either, just looking at all the possibilities.
 
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I haven't seen anyone mention it yet, but Nevada isn't that far from California...and they do allow self-driving cars there. Last I heard, Tesla has a big factory there as well. ;)

....

So that leaves us with only testing vehicles using software training (which could be useful), on private roads (also useful but if that's all that is going on clearly the software sucks because it cannot handle actual driving so its only a gimmick), or somehow testing in another state (perhaps Nevada).

That's it. Nevada seems most likely but also disheartening because its basically the gimmick factor because its probably not the most challenging or representative training ground. Maybe coupled with software sim. @lunitiks could weigh in best.

I think its like 5 posts above yours.
 
The AP2 Teslae are equipped for way more than just ADAS also, according to my contract.
I'm talking about outside appearances. If you don't know where to look, a common layperson would not be able to spot the difference between a Model S with the extra cameras vs the ones without.

The obvious non-integrated sensors was how Uber got easily caught (you can spot from blocks away that it's not a regular car). Over the last weekend I walked by a Cruise vehicle and heard an elderly person mention to his friend asking if that's a self driving car. I have never heard anyone comment that for Model S because it's hard to tell without looking up close.
 
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