I emailed with Dustin Leitch and Suraj Nagaraj, who is Tesla's compliance specialist. Here's a synopsis the thread:
Suraj:
We have tried all avenues ( videos, design studies, reference to warning labels, owner’s guides etc.) to help alleviate the departments concern over the possibility of an adult using the child seats. The Authorities have not been convinced so far and still maintain that the seat could be used incorrectly. One of the requirements under FMVSS 213 is to keep the seat width less than 330mm so it cannot be classified as a normal adult seat and mitigate incorrect seating. The truth is that an adult (should he/she try ) and will be grossly uncomfortable in the 3[SUP]rd[/SUP] row. Could some adult try and sit there ? Possibly, but that would an abuse/misuse condition. It’s like the OEMs being penalized for less-than-educated individuals driving without seatbelts on and killing themselves. Another use the analogy of a trunk / boot, Just because an adult can fit in there does not mean one would try and ride in the trunk of the car.
The one other avenue would be to seek out to higher authorizes and possibly show them a Model S equipped with the 3[SUP]rd[/SUP] row and hope to convince them that those seats can only seat children and all safety measures have been taken to prevent misuse. Still, some owners will misuse the privileges and If the transport authorities expect us to protect for every misuse condition, I’m afraid we’ve lost the battle right there.
What we need to seek out is more objective definition of their concerns and ways to mitigate that. Simply asking us to not offer those seats is not the way.
Dustin:
I looked into this a bit deeper with the relevant parties and in addition to the spec below, Hong Kong vehicle seating capacity does not make a distinction between adult seats and child seats. The transport departments concern is that if the incorrectly sized individual sits in the seat and not be adequately protected in a collision.
(4) Subject to regulation 26, every seat in a vehicle shall be secured to the body of the vehicle and shall, except in
the case of a bus or light bus, measure at least 380 millimetres from the backrest to the front edge of the seat and
380 millimetres along the back.
The rear seats are just too small to meet this regulation they are about 300mm
http://www.legislation.gov.hk/blis_...E5C3D482575EE00771BD5/$FILE/CAP_374A_e_b5.pdf
I think the poll could do with a middle answer: "Wanted 7 seats, now disappointed, but not seriously inconvenienced…." That's me. The grandparents will have to take a taxi or drive themselves….
Suraj:
We have tried all avenues ( videos, design studies, reference to warning labels, owner’s guides etc.) to help alleviate the departments concern over the possibility of an adult using the child seats. The Authorities have not been convinced so far and still maintain that the seat could be used incorrectly. One of the requirements under FMVSS 213 is to keep the seat width less than 330mm so it cannot be classified as a normal adult seat and mitigate incorrect seating. The truth is that an adult (should he/she try ) and will be grossly uncomfortable in the 3[SUP]rd[/SUP] row. Could some adult try and sit there ? Possibly, but that would an abuse/misuse condition. It’s like the OEMs being penalized for less-than-educated individuals driving without seatbelts on and killing themselves. Another use the analogy of a trunk / boot, Just because an adult can fit in there does not mean one would try and ride in the trunk of the car.
The one other avenue would be to seek out to higher authorizes and possibly show them a Model S equipped with the 3[SUP]rd[/SUP] row and hope to convince them that those seats can only seat children and all safety measures have been taken to prevent misuse. Still, some owners will misuse the privileges and If the transport authorities expect us to protect for every misuse condition, I’m afraid we’ve lost the battle right there.
What we need to seek out is more objective definition of their concerns and ways to mitigate that. Simply asking us to not offer those seats is not the way.
Dustin:
I looked into this a bit deeper with the relevant parties and in addition to the spec below, Hong Kong vehicle seating capacity does not make a distinction between adult seats and child seats. The transport departments concern is that if the incorrectly sized individual sits in the seat and not be adequately protected in a collision.
(4) Subject to regulation 26, every seat in a vehicle shall be secured to the body of the vehicle and shall, except in
the case of a bus or light bus, measure at least 380 millimetres from the backrest to the front edge of the seat and
380 millimetres along the back.
The rear seats are just too small to meet this regulation they are about 300mm
http://www.legislation.gov.hk/blis_...E5C3D482575EE00771BD5/$FILE/CAP_374A_e_b5.pdf
I think the poll could do with a middle answer: "Wanted 7 seats, now disappointed, but not seriously inconvenienced…." That's me. The grandparents will have to take a taxi or drive themselves….
