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I actually don’t see the problem with the current restrictions only the way Tesla tries to follow them. All the other systems with an automated lane change seem to cope absolutely fine so why can’t Tesla? BMW even use eye movement to confirm the action
 
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With FSD v12 rolling out to all North America by end of February potentially and Elon believing this time it may be ready for licensing to third parties by end of year, that might just wake up European regulators to the need to get on with it and properly enable self-driving capability á la Level 3.
 
Given all the nags that we keep getting when our hands are already on the wheel, with the botched torque controls in lieu of a capacitive wheel, at what point does it become LESS of a hassle to actually do the driving yourself rather than being nagged to wiggle the wheel every X secs while on AP?
Is wiggling the wheel what people actually do?

I permanently hold the wheel in my right hand, exerting gentle pressure and have been doing this for so long it's second nature. No need to change the pressure & no warnings either (unless I'm not concentrating) and I haven't noticed any changes to the torque required over the past four years.
 
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It’s hard to get excited about this when the UNECE DCAS specification requires every autonomous action to be approved by the supervising driver.

Yes, the plan is to take the autonomy out autonomous driving
That is not what the proposed UNECE DCAS regulations stipulate.

In general, this is how the system should perform actions (that are not just lane keeping):

A manoeuvre shall only be initiated if the driver is not detected to be disengaged, and
(a) has commanded the system to perform the manoeuvre for a driverinitiated manoeuvre; or
(b) has acknowledged the system’s intention as needed for a driverconfirmed manoeuvre; or

(c) is given sufficient notice to react for a system-initiated manoeuvre.

See article 5.3.7.2.1.1. of the proposed regulations (interesting read!).

Given that the article states "or", either one of the options a, b or c is fine. FSDbeta v12 is in compliance I believe, as long as it (1) does not detect a disengaged driver and (2) gives sufficient notice to the driver to react before performing a system-initiated manoeuvre.

Notice the term "sufficient" notice, not measured in an absolute value. This gives some leeway to the manufacturers to defend their systems.

The notice FSD v12 provides is in the visualization.


The type of language used applies to most aspects of autonomous driving. The regulations often state that the autonomous system should be "designed to" or "aim to" do this or that (eg. smooth turns in one continuous motion), but rarely are there hard cut-offs.

They explain this in the introduction (page 3-4 of the linked document):

7. This impact of system boundaries on the system’s ability to fulfil certain requirements,and the nature of how requirements can be assessed, is reflected by the language used in thisUN Regulation.
(a) Some requirements are expected to be always met, including in all relevant tests. Theseprovisions are phrased as “the system shall…”;
(b) Some requirements are such that whilst the system is generally expected to fulfil them,this might not always be appropriate or achievable under the specific circumstances, or external disturbances may still lead to a varying output. These provisions are phrasedas “the system shall be aim to…”; and

(c) Some requirements are difficult to verify by assessing system performance directly andare more readily verified by assessing the design of the system, for example byanalysing its control strategies. These provisions are phrased as “the system shall bedesigned to…”.


Most of the regulations seem achievable with v12.

Some I cannot assess not being an engineer, such as a maximum allowed lateral acceleration when turning/following a lane (so in all conditions)
which shall not exceed3 m/s² for M1 and N1 category vehicles and 2.5 m/s² for M2, M3, N2 and N3category vehicles. (article 5.3.7.1.2.)

When this is exceeded, the system has to nag the driver or hand control to him, but it has to keep assisting in steering:

5.3.7.1.4. When the system reaches its boundary conditions set out in paragraph 9.1.3.,and both in the absence of any driver input to the steering control and whenany the front tyre of the vehicle starts to unintentionally cross a lane marking,the system shall avoid sudden loss of steering support by providing continuedassistance to the extent possible as outlined in the safety concept of the vehiclemanufacturer. The system shall clearly inform the driver about this systemstatus by means of an optical warning signal and additionally by an acoustic orhaptic warning signal.

For vehicles of categories M2 M3 N2 and N3, the warning requirement aboveis deemed to be fulfilled if the vehicle is equipped with a Lane DepartureWarning System (LDWS) fulfilling the technical requirements of UNRegulation No. 130.



I imagine the lateral acceleration limits in the above articles provides some margin and Tesla FSD v12 falls within these boundaries.

If not, it'll be hard to rewrite the software to take into account these new constraints.

That is my main concern with these regulations. But again, I imagine these restraints provide leeway.

Even most articles that state the system SHALL do so and so, provide an exemption in certain situations, for example when safety requires it (for example stopping abruptly for a spotted pedestrian). I guess Tesla will have to cooperate with the local governments to show their software is in line with the regulations.

(UNECE regulations are adopted at a European level and the European member states then have to convert this into national laws, if I understand correctly. This will add to the timeline. So if in March the current regulations are accepted and they are valid starting September 1st 2024, the national laws still have to implement these regulations).

If we see FSD in Europe in 2025 I'll be happy. Before that I'm not expecting it. 2026 or later is very possible if Tesla cannot prove to regulators its software ticks all the UNECE DCAS boxes.
 
thanks for the link, and I like your optimism!
Even most articles that state the system SHALL do so and so, provide an exemption in certain situations, for example when safety requires it (for example stopping abruptly for a spotted pedestrian). I guess Tesla will have to cooperate with the local governments to show their software is in line with the regulations.

I think it goes further than that, if the system is available and not in full compliance with UNECE rules then the whole vehicle cannot be sold in a UNECE territory. We had this a few years ago, where the FSD/NOA slip road/motorway exit functionality was deemed retrospectively to not be in compliance with UNECE rules (as it did not need confirmation at the time). IIRC Tesla had to stop sales of all vehicles for a few days in Europe, whilst a compliant software release was issued making the vehicles again compliant.

With 7 months before possible implementation, fingers crossed Tesla have time to get FSD updated for a quick release over here - and that we don't have to wait long after rules permit it.
 
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thanks for the link, and I like your optimism!


I think it goes further than that, if the system is available and not in full compliance with UNECE rules then the whole vehicle cannot be sold in a UNECE territory. We had this a few years ago, where the FSD/NOA slip road/motorway exit functionality was deemed retrospectively to not be in compliance with UNECE rules (as it did not need confirmation at the time). IIRC Tesla had to stop sales of all vehicles for a few days in Europe, whilst a compliant software release was issued making the vehicles again compliant.

With 7 months before possible implementation, fingers crossed Tesla have time to get FSD updated for a quick release over here - and that we don't have to wait long after rules permit it.
You're lucky based in the UK. If I had to wager, I'd say UK gets FSD way before EU. (which is frustrating since I'm only located +/- 200 kilometers away (Belgium)) :)
 
I think it was the automated taking off ramps/junctions that caused Tesla to cease deliveries for a while until the fix took it away

The regulations can be quite wide ranging but there will be detail that still needs to be met and there’s no guarantee Tesla will meet them in the short term. Take lane change, it needed to be completed in a given time, for some reason Teslas seem to fail to do so at times whereas other makes of car don’t, no idea why not. Summon - the communication to the car operates on a dead man’s handle approach requiring constant comms which Bluetooth wasn’t great at.

FSD beta 12 looks promising, the opening up of our regulations is a step forward, I’m just a little cautious to assume those two things will automatically come together quickly
 
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