Predictions - "Automatic driving on city streets."

[kbM3]

Very simply put: When the manufacturer declares a production car responsible for the drive (and that declaration is approved by regulators) it will become autonomous within manufacturer’s declared design domain, not a moment before that.

Same for testing: When the manufacturer declares the product in development as autonomous production design intended (and that declaration is approved by regulators), it is considered an autonomous test vehicle within the declared design domain, even if it requires a safety driver.

Otherwise semi-autonomous development, testing and production is not regulated as autonomous (again, as long as approved by regulators — the declarations have to be believable, as Uber learned the hard way, but for Tesla Level 2 production design intents are very believable).


Sure and I guess some of you are arguing they are doing that already, though personally I’m not too sure anything running on HW2/2.5 today bears much if any resemblance to any future autonomous Tesla software.


No, it is not. It is an autonomous driving system once the manufacturer declares it to be. And for testing it is the manufacturer production design intent that makes the distinction.

Then provide exactly when Tesla will be subject to the regulation.

 

[Daniel in SD]

So, GM could sell a Cruise option package on the Bolt that runs their “automatic driving on city streets” software and call it Level 2?
I think you’re completely ignoring the intent of the rules.

 

[electronblue]

So, GM could sell a Cruise option package on the Bolt that runs their “automatic driving on city streets” software and call it Level 2?

Of course they could. If they actually sell and operate it as a driver’s aid.

After all, Tesla is doing exactly the same thing today with their system.

I think you’re completely ignoring the intent of the rules.

These are the current rules, I didn’t make them up, I merely familiarized myself with them.

The important part is not how capable the car is. The important part is: is there a responsible driver or not.

 

[electronblue]

Then provide exactly when Tesla will be subject to the regulation.

1) Tesla is (not will be) subject to autonomous regulation when they are testing prototype systems with autonomous production design intent and

2) will also be subject to autonomous regulation when they are shipping autonomous products they declare autonomous.

3) Tesla could also become subject to autonomous regulation at some other time if the current rules change.

Currently Tesla (or anyone else) is not regulated as autonomous when they are developing, testing or shipping systems (eg software updates in Tesla’s case) that are not autonomous in production.

 

[Daniel in SD]

If they actually sell and operate it as a driver’s aid.

How would that differ from the way they're operating it today? From the point of view of the person sitting in the driver's seat.

These are the current rules, I didn’t make them up, I merely familiarized myself with them.

I think they would declare a sufficiently advanced drivers aid as an autonomous test vehicle because the purpose of the rules is to make the roads safe and testing autonomous vehicles has safety issues.

“In their minds, they really thought they weren’t autonomous,” Jessica Gonzalez, assistant deputy director of public affairs at the DMV, told The Verge. “But we decide what’s autonomous. And under our regulations, it was.”

 

[electronblue]

How would that differ from the way they're operating it today? From the point of view of the person sitting in the driver's seat.

How would it differ from any driver’s aid? It would simply be a driver’s aid. Capable, yes, but the driver would still always be there and always be responsible. I don’t see any reason why they couldn’t sell such a product, any more than I could see any issues with Tesla selling Automatic city driving as a Level 2 feature.

I think they would declare a sufficiently advanced drivers aid as an autonomous test vehicle because the purpose of the rules is to make the roads safe and testing autonomous vehicles has safety issues.

I don’t think they would turn production driver’s aids into autonomous test vehices. In all the instances where an opposing determination has been made, has been internal testing and the argument has been are they testing autonomous prototypes or not. That certainly is a grey area because there is no manufacturer declaration and no production product, there is only the intent (which can be argued). But you can’t sell an autonomous prototype to the members of the public anyway. A production car will not suddenly become an autonomous test vehicle in the hands of the public. In production either it is semi-autonomous (Level 2) or it is autonomous (car responsible driving).

But I agree the purpose of the rules is to make roads safe and this is why I fully acknowledge regulators might start regulating even semi-autonomous things like NoA and Smart Summon — or that Automatic city driving — if given a big enough reason, like a highly publicized accident. But that is what I would call a rule change.

 

[Daniel in SD]

How would it differ from any driver’s aid? It would simply be a driver’s aid. Capable, yes, but the driver would still always be there and always be responsible. I don’t see any reason why they couldn’t sell such a product, any more than I could see any issues with Tesla selling Automatic city driving as a Level 2 feature.

That's exactly the same as what they're doing today, the driver in a Cruise vehicle is always responsible.

 

[Southpasfan]

Well, a trip through the internet revealed that Tesla has a California autonomous driving permit. It was speculated that the reason Uber left California was that it did not want to report collisions and instances where the driver took over, which is a requirement of the California permit.

Through the program, Tesla reports to the DMV, and Tesla does not consider what its cars do as FSD and disengagements.

Which is I suppose what the discussion is about, i.e., what if the DMV changes its mind? Because the DMV cannot have failed to notice hundreds of thousands of Teslas on the road.

I think what Tesla is doing is going to look, in retrospect, like a genius decision. If you say "I am testing my FSD car," notwithstanding the fact that you have to have a driver in it, the other issue is a FSD car should, by definition, NEVER have an instance where a driver takes over.

Tesla, in contrast, is rolling out features incrementally. Frankly, the evolution from cruise control, to lane keeping with cruise control, to lane changing, to exit ramp selection, has moved a system which is merely part of a car (cruise control) to a situation where the car is operating autonomously for significant periods. And does so successfully. And does so not on few hundred test cars, but on hundreds of thousands of cars.

It seems to me the major rule amendment would be that if the DMV viewed an added feature as autonomous, then Tesla would need to seek an amendment to the rules that all drivers of autonomous cars being tested are employees of the manufacturer trained by the manufacturer.

 

[Daniel in SD]

It seems to me the major rule amendment would be that if the DMV viewed an added feature as autonomous, then Tesla would need to seek an amendment to the rules that all drivers of autonomous cars being tested are employees of the manufacturer trained by the manufacturer.

Waymo already got that amendment written into the rules. They have hired contractors as safety drivers in California. They still have the same training and reporting rules.

 

[EVNow]

It is kind of weird that some people here wish for a rule that would rob a lot of our ability to use AP.

Yes, weird.

 

[Daniel in SD]

It is kind of weird that some people here wish for a rule that would rob a lot of our ability to use AP.

Yes, weird.

I'm fine with people testing "automatic driving on city streets" as long as they're properly trained and monitored. I don't think it's weird to think that testing of autonomous vehicles on public roads should be done safely with government oversight.

 

[AlanSubie4Life]

It is kind of weird that some people here wish for a rule that would rob a lot of our ability to use AP.

Yes, weird.

Ummm...where I live, there are a lot of Teslas. I drive a Tesla. I own Tesla stock. I like AP on the highway for long drives. I don't want to lose access to AP. That is why I want Tesla to exercise an abundance of caution when it comes to City AP/NoA. I think it is has much, much greater potential than Highway NoA to lead to inhibitory regulations, due to public safety issues.

I don't wish for any such rule, but I can't deny the argument that a flawed City NoA rollout could lead to just such a rule. And that would not only be a convenience issue for me (loss of highway AP - I won't have City AP), it's also a potential safety issue for me personally due to the local Tesla population. I'm definitely going to want the regulators to do what they need to, to maintain public safety. So not that weird.

 

[Southpasfan]

I'm fine with people testing "automatic driving on city streets" as long as they're properly trained and monitored. I don't think it's weird to think that testing of autonomous vehicles on public roads should be done safely with government oversight.

Not trying to swerve this one into another deep, deep hole, but existing AP and NAP are being tested, and I expect not only safely, but safely enough as demonstrated to regulators.

Any other assumption is that the regulators are not paying any attention, and I don't think its a valid assumption.

The genius is to roll out the incremental features while maintaining the ability of drivers to take control. Smart Summon is actually huge. Its demonstrating that the cars can make both obstacle and cross-traffic decisions. If its only at 5 mph now, it can get faster as the software improves.

The key to city streets is the roll out. As long as the features are rolled out such that the actual drivers, us, can easily monitor and disengage, I would see no reason why the roll out would not go the same was as the NAP roll out has gone.

 

[electronblue]

How would it differ from any driver’s aid? It would simply be a driver’s aid. Capable, yes, but the driver would still always be there and always be responsible. I don’t see any reason why they couldn’t sell such a product, any more than I could see any issues with Tesla selling Automatic city driving as a Level 2 feature.

That's exactly the same as what they're doing today, the driver in a Cruise vehicle is always responsible.

Nope. A big difference, because the production design intent is different. Let SAE explain:

”The level of driving automation system feature corresponds to the feature’s production design intent ... 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.” - SAE J3016

As most regulation especially in the U.S. follows SAE’s cues this is the current reality. In fact, Germany too has a similar system as SAE is based on that. This is what tripped Uber when they tried to claim they were testing a Level 2 vehicle, when it simply was not a believable design intent for them.

Level 4 production design intent being tested with a responsible safety driver is still an autonomous car. But Level 2 production design intent being tested with a responsible safety driver is not an autonomous car... this is why most of Tesla’s testing (not all, mind you... most) has not been regulated as autonomous.

 

[electronblue]

I'm fine with people testing "automatic driving on city streets" as long as they're properly trained and monitored. I don't think it's weird to think that testing of autonomous vehicles on public roads should be done safely with government oversight.

I know you are answering @EVNow’s point, but to be clear what I am laying out is the current regulatory environment, not any kind of opinion on how it should be. I am commenting on how things currently are.

As long as Tesla’s current production design intent is Level 2 for Automatic city driving (for the next release), I don’t see anything that would suddenly make it autonomous in the eyes of regulators. It will be a semi-autonomous driver’s aid just like NoA.

And let’s hope so too, because I’m sure they’d be rather quick to strike down a plan for the non-trained public to be safety drivers in autonomous test vehicles.

 

[EVNow]

I'm fine with people testing "automatic driving on city streets" as long as they're properly trained and monitored. I don't think it's weird to think that testing of autonomous vehicles on public roads should be done safely with government oversight.

It is very weird when you consider people are already doing so.

One would think anyone worried about public safety would be prioritize avoiding climate catastrophe that can kill billions than some margin edge case like city NOA.

 

[Daniel in SD]

And let’s hope so too, because I’m sure they’d be rather quick to strike down a plan for the non-trained public to be safety drivers in autonomous test vehicles.

But you're saying that GM could sell the exact same Cruise Bolts that they're testing as autonomous vehicles and the untrained public could buy them and use them as long as GM markets them as a Level 2 ADAS.

One would think anyone worried about public safety would be prioritize avoiding climate catastrophe that can kill billions than some margin edge case like city NOA.

Really I should get rid of my Model 3 and ride a bike and public transit everywhere. Though city NoA becomes much more important to me while riding a bike or walking! There are a ridiculous number of Teslas around here.

 

[electronblue]

But you're saying that GM could sell the exact same Cruise Bolts that they're testing as autonomous vehicles and the untrained public could buy them and use them as long as GM markets them as a Level 2 ADAS.

Sure, of course, in principle. Because that means the driver is never a safety driver, but the driver. That is a big difference. There might be some other requirements like addition of nags or other suitable driver monitoring, user interface changes, documentation etc to appease regulators in such a case, but the fact that it is a very capable ADAS is not a problem in itself, as long as it really is an ADAS and not an autonomous production car in disguise being operated as an autonomous car... if it is truly produced and sold and used as an ADAS, then it is not autonomous.

In fact I fully expect Tesla to go down this route. At some point (barring company failure or such major event), we will be driving Level 2 ADAS that is quite close to whatever autonomous robotaxi Tesla is cooking in their labs. The big difference being Tesla will not allow it to be operated autonomously.

 

[electronblue]

Let me ask the other way for once:

Those of you who believe Tesla will be regulated as autonomous car maker for Automatic city driving (the kind we expect Tesla to ship end of year by their announcement), what makes you think that?

What is different from NoA or Smart Summon, which are not regulated as autonomous?

Why would Automatic city driving suddenly mean autonomous if these previous two do not?

I have explained my answer but I am genuinely curious to hear your thinking.

 

[AlanSubie4Life]

Why would Automatic city driving suddenly mean autonomous if these previous two do not?

I don’t think it will be “suddenly.”

I think City NoA will turn out to be pretty dangerous, and regulators will decide to change the rules.

It’s different from the others, because the design domain is quite a bit more challenging.