From what I can read in the CFR, Tesla is just fine "without a bumper". The purpose is to protect lighting and equipment of the vehicle at slow speeds, it's up to the manufacturer to self certify apparently. I would argue the bumper as proposed will operate just fine with a Los speed collision
https://www.google.com/url?sa=t&sou...FjABegQIBxAB&usg=AOvVaw03LabmKrDSvz-KgYGha6Rr
https://www.google.com/url?sa=t&sou...FjABegQIBxAB&usg=AOvVaw03LabmKrDSvz-KgYGha6Rr