Tesla’s communications with the DMV about full autonomous driving are posted and create some confusion


Tesla’s communications with the DMV about the release of its full autonomous driving beta have been released via a freedom of information request.

Some of the comments made by Tesla to the DMV are causing some confusion among people, as they could be interpreted against what Tesla and Elon Musk are saying publicly.

We look at it below.

The California Department of Motor Vehicles (DMV) has an autonomous vehicle branch that attempts to oversee and regulate the many autonomous vehicle programs that are being developed and tested in California.

For the most part, Tesla has been trying to stay away from the DMV and doesn’t report a lot of autonomous mileage by the organization’s definition.

Instead, the automaker claims to be testing its autonomous system on private highways in California and on public and private highways in other states that don’t have the same disclosure requirements as Tesla’s home state.

This is clear from the DMV’s annual report on driver disconnects during autonomous mileage.

What is disclosed to the public through its Autopilot and Full Autonomous Driving (FSD) packages are considered Level 2 driver assistance features that require driver supervision.

Now Plainsite, a website that focuses on making legal documents public through freedom of information requests, has received and released all communications between the California DMV and Tesla regarding the release of the full autonomous driving Beta. from the last batch.

Some of what Tesla says in its communications to the DMV confuses people, as it seems to contradict what Elon Musk has been saying, which is that Tesla’s FSD package will lead to a true “level 5 system of complete autonomous driving.” for the end. of the year.

At the center of the controversy is a letter that Tesla Associate General Counsel Eric Williams sent to Miguel Acosta, Head of the Autonomous Vehicle Branch of the California Department of Motor Vehicles, about some questions the latter had about the FSD Beta. from Tesla.

In the letter sent in December 2020, Tesla writes:

“While the current pilot version of City Streets is still in a validation and review stage, we expect the functionality to remain largely unchanged in a future full customer fleet release. We are analyzing the data obtained in the pilot and using it to refine the operation of the function and the customer experience. We will continue to improve as needed, and only after we are fully satisfied with the performance, integrity, and safety, will we release the feature to the customer’s fleet. That said, we do not expect significant enhancements to the OEDR or other changes in function that shift responsibility for all DDT to the system. As such, a final version of City Streets will continue to be an advanced SAE Level 2 driver assistance feature. “

Considering that ‘City Street’ is the latest upcoming feature to be listed as part of Tesla’s complete autonomous driving package, Tesla’s naysayers are using the comment to claim that it means it will never pass ‘level 2’:

Tesla’s associate general counsel continues in the same letter:

“Please note that Tesla’s development of true autonomous features (SAE Levels 3+) will follow our iterative process (development, validation, early release, etc.) and those features will not be released to the general public until we have validated them by full. and received all required permits or regulatory approvals. “

Here are the communications from Tesla and the DMV in its entirety:

Electrek taking

While this information is obviously used primarily by Tesla naysayers and naysayers, I wouldn’t blame anyone for being confused by Tesla’s approach when it comes to “total autonomous driving.”

The moment they decided to call the package “Total Autonomous Driving”, they invited that confusion.

But when you look at what is actually being said here, it’s not that confusing.

Tesla has promised that people who buy the FSD package will eventually receive a software update that will make their vehicle fully autonomous level 5, meaning the vehicle can be driven alone with no one in it or if someone is in it, no. they do. I have no responsibility for driving the vehicle.

Where responsibility resides is the main difference between level 2 and level 3 and above.

Everything Tesla has released so far makes it clear that the onus remains with the driver and is therefore a Tier 2 system.

What seems to confuse people is that the “final release of City Streets” will remain a tier 2 system.

I assume the confusion is due to Tesla listing the function as the last “next” in the FSD package:

But Tesla has been changing those features all the time and could easily decide to add a “level 5” feature that transfers responsibility to the system for a new version of the software that has been approved by regulators in your specific market.

What Tesla is really rolling out with “automatic steering on city streets” is what Musk has previously called a “complete full autonomous driving feature,” which again can understandably be a confusing term.

“Full feature” means that with “city streets”, allowing you to drive through intersections and city streets with Tesla’s autopilot system, the FSD package would have all the features it needs to be completely autonomous when operating. Combines with autopilot on the road and “smart summon” in parking situations.

However, it is not completely autonomous until the responsibility is shifted to Tesla and that will not happen until the automaker obtains more data, refines the system and achieves a higher level of reliability that is demonstrable to regulators.

Musk indicated that it would happen with future versions of the software later this year.

We can argue about the chances of that actually happening, but I don’t see anything in those letters that contradicts the plan previously laid out by Tesla.

What I see is a company actively trying to avoid being regulated, which is the same as usual, while having confusing nomenclature.

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