As the NHTSA report also states:
"Since it released Autopilot in October 2015, Tesla has made continuous updates to the system’s firmware that are made available to consumers as OTA updates. These updates have included changes to improve TACC, AEB and Autosteer performance, as well as adding new driver assistance safety features, such as In-Path Stationary Object (IPSO) braking and Pedal Misapplication Mitigation (PMM). In September 2016, Tesla released its 8.0 firmware update which included revisions in the driver monitoring strategy, as well as several enhancements to AEB, DBS, and TACC performance."
This means that the addition of Autosteer is not the only difference between the post-AS and pre-AS samples. The miles covered by the post-AS sample were in cars that not only added AS, but also benefitted from software improvements (not present in the pre-AS sample) to TACC, AEB, IPSO and PMM. So there is no way to know whether the reduction of crashes per million miles from 1.3 (in pre-AS sample) to 0.8 (in post-AS sample) is attributable to the presence of AS or to the improvements to TACC, AEB, IPSO, PMM or some other features. Indeed, is possible (but not provable from the information that has been made public), that AS actually increases crash rates, but this effect was washed out by the decreases in crash rate that can be attributed to the other features improved OTA.
Yes... NHTSA said this, and I do not dispute their observation. The problem is that whatever standard they are using for determining what is an "environment that [is]not appropriate for semi-autonomous driving (e.g., city traffic,
highway entrance/exit ramps, construction zones, in heavy rain, and road
junctions/intersections)" hasn't really been stated clearly by Tesla to Tesla users. If-- aside from some broad language deep in the constantly changing user manual-- Tesla won't give drivers specific instructions about what is an "appropriate environment" how is a driver supposed to accurately fulfill their responsibility "for deciding when the road type and other conditions are appropriate for system activation." Tesla can't both (I) avoid giving clear guidelines for appropriate use and then (ii) seek to avoid responsibility when a driver uses the vehicle in a manner that Tesla/NHTSA deems is "inappropriate" via unpublished, difficult to locate, or vague standards.
NHTSA found that Tesla's instructions on how to use AP were "perhaps not as specific as it could be." It s hard to understand, given this finding, why Tesla has chosen not to release more specific (and visible) instructions on proper AP use. Why not develop the best possible user instructions, given that misuse can lead to death and injuries for the driver, passengers, and others on the road?
Furthermore, in NTSB's report on the Florida crash (
https://www.ntsb.gov/investigations/AccidentReports/Reports/HAR1702.pdf), NTSB found:
"Today’s vehicle automation systems can assess the vehicle’s route and determine whether it is appropriate to the system’s ODD.61 But Tesla’s Autopilot remains available to the driver, even under some conditions that do not meet its ODD. This situation allows the driver to activate automated systems in locations and circumstances for which their use is not appropriate or safe. The NTSB concludes that if automated vehicle control systems do not automatically restrict their own operation to those conditions for which they were designed and are appropriate, the risk of driver misuse remains. Therefore, the NTSB recommends that manufacturers of vehicles equipped with Level 2 vehicle automation systems incorporate system safeguards that limit the use of automated vehicle control systems to those conditions for which they were designed. The NTSB further recommends that NHTSA develop a method to verify that manufacturers of vehicles equipped with Level 2 vehicle automation systems incorporate system safeguards that limit the use of automated vehicle control systems to those conditions for which they were designed. Finally, to ensure that vehicle manufacturers that do not currently produce vehicles equipped with Level 2 automation but may do so in the future are aware of the significance of this issue, the NTSB recommends that the Alliance of Automobile Manufacturers and the Association of Global Automakers notify their members of the importance of incorporating system safeguards that limit the use of automated vehicle control systems to those conditions for which they were designed."