Tesla’s communications with DMV about the launch of its Full Self-Driving Beta were released through a request for freedom of information.
Some of Tesla’s comments to the DMV are causing some confusion for people, as they can be interpreted as contradicting what Tesla and Elon Musk are saying publicly.
We look at this below.
The California Department of Motor Vehicles (DMV) has an autonomous vehicle subsidiary 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 tried to stay away from the DMV and does not report many autonomous miles according to the organization’s definition.
Instead, the automaker claims to be testing its autonomous system on private roads in California and on public and private roads in other states that do not have the same disclosure requirements as Tesla’s home state.
This is clear from the DMV’s annual report on driver disconnections during autonomous mileage.
What is being released to the public through its autopilot and Full Self-Driving (FSD) pacakges are considered level 2 driver assistance features that require driver supervision.
Now Plainsite, a site that focuses on making legal documents public through requests for freedom of information, has received and released all communications between the California DMV and Tesla regarding the launch of the latter’s fully autonomous driving Beta.
Some of the things Tesla is saying in its DMV communications are confusing people, as it seems to contradict what Elon Musk has said, which is that Tesla’s FSD package will lead to a “fully autonomous level 5 system” at the end of year.
At the heart of the controversy is a letter that Eric Williams, Tesla’s Associate General Counsel, sent to Miguel Acosta, Head of the Autonomous Vehicles Section of the California Motor Vehicles Department, about some questions the latter had about Tesla’s FSD Beta.
In the letter sent in December 2020, Tesla writes:
“Although the current pilot version of City Streets is still in a validation and revision stage, we expect the functionality to remain largely unchanged in a future full launch for the customer’s fleet. We are analyzing the data obtained from the pilot and using it to refine the operation of the resource and the customer experience. We will continue to make adjustments as needed and, only after we are fully satisfied with performance, integrity and security, will we launch the feature to the customer’s fleet. That said, we do not expect significant improvements in the EMCDDA or other changes to the resource that transfer the responsibility of the entire DDT to the system. As such, a final version of City Streets will continue to be an SAE Level 2, an advanced driver assistance feature. “
Considering that ‘City Street’ is the last feature listed as part of Tesla’s Full Self-Driving package, Tesla opponents are using the comment to state that this means it will never pass ‘level 2’:
Tesla’s Associate General Counsel continues in the same letter:
“Note that the development of Tesla’s truly autonomous features (SAE Levels 3+) will follow our iterative process (development, validation, early release, etc.) and any features will not be released to the general public until we have fully validated them and received any regulatory authorizations or approvals ”.
Here are the communications from Tesla and the DMV in full:
Electrek’s Take
While it is obvious that this information is being used mainly by Tesla’s pessimists and shorts, I would not blame anyone for being confused by Tesla’s approach when it comes to “Total Self-Direction”.
The moment they decided to call the package “Full Self-Driving”, they caused this confusion.
But when you look at what is really being said here, it is not so confusing.
Tesla has promised that people who buy the FSD package will receive a software update that will make their vehicle fully autonomous at level 5 – which means that the vehicle can drive alone without anyone in it or if someone is in it, they don’t. I have no responsibility for driving the vehicle.
Where responsibility resides is the main difference between level 2 and level 3 and above.
Everything that Tesla has released so far makes it clear that the responsibility still lies with the driver and is therefore a level 2 system.
What seems to confuse people is that the “final release of City Streets” will remain a level 2 system.
I suppose the confusion stems from the resource’s Tesla list as the last “future” in the FSD package:
But Tesla has been changing these features all the time and could easily decide to add a “level 5” feature that shifts responsibility to the system for a new version of the software that has been approved by regulators in its specific market.
What Tesla is really launching with “autosteer on city streets” is what Musk previously called a “fully autonomous full driving feature”, which, again, can understandably be a confusing term.
“Full feature” means that with “city streets”, which allows you to drive through intersections and city streets with Tesla’s autopilot system, the FSD package would have all the features you need to be fully autonomous when combined with the driver automatic on the highway and “smart call” in parking situations.
However, it is not fully autonomous until the responsibility shifts to Tesla and this 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 this would happen with future versions of the software later this year.
We can argue about the chances of this actually happening, but I see nothing in these letters that contradicts Tesla’s previously stated plan.
What I see is a company actively trying to avoid being regulated, which is business as usual, although it has a confusing nomenclature.
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