[HN Gopher] California's AV testing rules apply to Tesla's "FSD"
       ___________________________________________________________________
        
       California's AV testing rules apply to Tesla's "FSD"
        
       Author : camjohnson26
       Score  : 80 points
       Date   : 2021-12-17 18:05 UTC (4 hours ago)
        
 (HTM) web link (cyberlaw.stanford.edu)
 (TXT) w3m dump (cyberlaw.stanford.edu)
        
       | lolc wrote:
       | > Tesla's "FSD" has the "capability to drive a vehicle without
       | the active physical control or monitoring by a human operator,"
       | but it does not yet have the capability to do so _safely_. Hence
       | the human drivers. And the testing. On public roads. In
       | California. For which the state has a specific law. That Tesla is
       | not following.
       | 
       | I couldn't find it spelled out in the article what portions of
       | the law Tesla is not following. But upon reading it[0] it is
       | clear Tesla could not possibly comply. There are requirements
       | such as reporting in advance which roads the cars will be tested
       | on. (I assume saying "all roads" would be a non-starter with the
       | DMV.) And each test-driver needs an individual permit. So if it
       | is found that Tesla's FSD falls under this law, they have to
       | disable or severely limit FSD in California.
       | 
       | I found the argument in the article quite strong that indeed FSD
       | falls under that law. So I'm wondering what will happen next.
       | Will the California DMV dare anger those who sunk money into FSD?
       | Or will the DMV just turn a blind eye until there's a crash with
       | a stroller and that will force them to act?
       | 
       | [0] https://www.dmv.ca.gov/portal/file/autonomous-vehicles-
       | testi...
        
         | [deleted]
        
         | jliptzin wrote:
         | I have to have my hands on the wheel and looking at the road
         | near-constantly otherwise autopilot turns off, even if I look
         | at my phone the car warns me to pay attention to the road. I am
         | 100% a safer driver with autopilot on (on the highways - FSD on
         | side streets isn't there yet) because I can focus my attention
         | on higher level details of my surroundings, such as a semi
         | merging onto the highway 3 lanes over or a driver swerving in
         | and out of traffic several cars away, instead of micromanaging
         | the wheel and pedals to stay in my lane and a safe distance
         | from the car in front of me - the autopilot handles that
         | flawlessly.
        
         | [deleted]
        
         | zaroth wrote:
         | The reason Tesla does not fall under this legislation seems
         | pretty simple to me, but IANAL...
         | 
         | The law applies to vehicles with the "capability to drive a
         | vehicle without the active physical control or monitoring by a
         | human operator".
         | 
         | Tesla FSD does not have this capability. If the driver does not
         | consistently demonstrate that they are actively monitoring the
         | vehicle and in physical control, then the "AutoPilot(TM)"
         | feature deactivates.
         | 
         |  _"An autonomous test vehicle does not include vehicles
         | equipped with one or more systems that provide driver
         | assistance and /or enhance safety benefits but are not capable
         | of, singularly or in combination, performing the dynamic
         | driving task on a sustained basis without the constant control
         | or active monitoring of a natural person."_
        
           | akira2501 wrote:
           | So, in summary Tesla "fully self driving" does not actually
           | have the capability to "fully self drive." It seems like the
           | hazy marketing around this feature hasn't been a great idea.
        
           | FabHK wrote:
           | The article addresses that explicitly.
           | 
           | Basically, the DMV is saying "oi, if you're testing a system
           | that's capable of driving by itself, you have to follow
           | certain rules"!
           | 
           | Then you reply "No, we're still testing it, and it requires
           | human supervision, so it's not capable of driving by itself,
           | so the rules don't apply!"
           | 
           | > "FSD" is aspirationally an automated driving system. The
           | name unequivocally communicates Tesla's goal for development,
           | and the company's "beta" qualifier communicates the stage of
           | that development. Tesla intends for its "full self-driving"
           | to become, well, full self-driving, and its limited beta
           | release is a key step in that process.
           | 
           | > Tesla's "FSD" has the "capability to drive a vehicle
           | without the active physical control or monitoring by a human
           | operator," but it does not yet have the capability to do so
           | safely.
        
             | paxys wrote:
             | I think the "loophole" here is that - despite the marketing
             | claims - Tesla is NOT testing a system which is designed to
             | run without active monitoring by a human. This is unlike
             | Cruise, Waymo etc. who do fall under this law.
        
             | clankyclanker wrote:
             | > Tesla's "FSD" has the "capability to drive a vehicle
             | without the active physical control or monitoring by a
             | human operator," but it does not yet have the capability to
             | do so safely.
             | 
             | It's that bit that seems like it would make Tesla's actions
             | fall even further under the DMV's purview. Is their
             | argument really going to be that they can't be held to
             | safety regulations because it's too unsafe to be
             | regulatable? That's like saying you've stolen too much
             | money to be guilty of robbing the bank.
        
           | jasonhansel wrote:
           | I suppose it depends on what "capable" means.
           | 
           | If you mean that a Tesla with FSD can be used to drive
           | without human control, then that is definitely true since the
           | tests for driver alertness can be bypassed.
           | 
           | If you mean that a Tesla with FSD has the level of
           | technological sophistication needed to drive autonomously,
           | that is also true: if you bypass the checks for driver
           | alertness, the Tesla can continue driving (albeit not
           | _safely_ ). This is well beyond the range of most "driver
           | assistance" technologies.
           | 
           | If you mean that a Tesla can drive autonomously _without_
           | bypassing any checks for driver alertness, then no, it
           | cannot, but only _assuming_ these checks never fail and are
           | always sufficient to prevent it from being used without
           | active monitoring.
           | 
           | Tesla's case seems weak here, in that it relies on an
           | extremely narrow interpretation of the law, according to
           | which a system that _can_ drive autonomously but tries to
           | prevent you from doing so is not considered truly autonomous.
           | 
           | But IANAL, so perhaps Tesla has a better case than I'd
           | assume.
        
           | jdavis703 wrote:
           | CHP has alleged cases of drunk or sleepy drivers who disabled
           | the dead man's switch and were somehow in a full self-driving
           | mode. Because people who presumably aren't mechanics or
           | automative engineers can enable an unsupervised self-driving
           | mode, it seems like it might fall under this law.
        
           | _jal wrote:
           | I guess Tesla feels you can "actively monitor" from the back
           | seat? Or did those people defeat some safety?
        
             | zaroth wrote:
             | Yes they weighted the seats, slipped out from a seatbelt,
             | and weighted the steering wheel.
             | 
             | Newer software released in the last couple months also adds
             | some kind of gaze tracking using the interior camera -
             | because the car now alerts constantly if I am looking at my
             | phone and will disengage auto-pilot and put me in the
             | penalty box if I keep doing it. I don't know how that tech
             | would react if it didn't see a human in the drivers seat at
             | all, but I imagine ultimately that will be another safety
             | measure. Tesla has a lot of incentive to cut down on these
             | types of pranks.
             | 
             | For those that don't know, disengage keeps autopilot
             | running but with an extremely annoying alarm and massive
             | red warning on the display, and as soon as you take over
             | the penalty box means you can't re-engage "AutoPilot(TM)"
             | until the next drive.
        
               | jedberg wrote:
               | There is another way to get it to stop alarming. Don't
               | look at your phone while you're driving.
        
               | tmp_anon_22 wrote:
               | Please don't look at your phone while actively driving.
        
             | tshaddox wrote:
             | One guy had this foot on the wheel from the back seat. Not
             | sure how/if they defeat the face/eye detection.
        
               | maxdo wrote:
               | that was old tech, and it's not part of the BETA topic is
               | about
        
         | sroussey wrote:
         | Tesla requires active monitoring by a human operator despite
         | the misleading name that FSD implies, and despite their boasts.
         | 
         | Don't forget to read the Terms of Service!
        
           | phh wrote:
           | And don't forget to read the comment you're replying to!
        
           | nemothekid wrote:
           | From the linked regulatory text:
           | 
           | > _(a) "Autonomous mode" is the status of vehicle operation
           | where technology that is a combination of hardware and
           | software, remote and /or on-board, performs the dynamic
           | driving task, with or without a natural person actively
           | supervising the autonomous technology's performance of the
           | dynamic driving task. An autonomous vehicle is operating or
           | driving in autonomous mode when it is operated or driven with
           | the autonomous technology engaged_
           | 
           | The "active monitoring" part doesn't seem to exempt them from
           | this law. What I'm not sure is - wouldn't this also apply to
           | high cruise control / following?
        
             | sroussey wrote:
             | Yeah, I don't think they mean to ban cruise control, so it
             | is confusing.
        
             | nickff wrote:
             | This law seems to be vague in critical ways:
             | 
             | > _" performs the dynamic driving task, with or without a
             | natural person actively supervising the autonomous
             | technology's performance of the dynamic driving task"_
             | 
             | The terms _' dynamic driving task'_ and _' supervivising'_
             | are critical here, and don't seem to be clearly defined.
             | Supervising could mean an absence of active physical
             | control, maybe meaning a 'supervisor' without a hand on the
             | steering wheel, but with access to a kill-switch. 'Dynamic
             | driving task' also seems a bit vague; does this mean
             | turning, changing speeds, or something else?
             | 
             | This could be interpreted for or against Tesla; maybe
             | that's what they wanted.
        
               | jcranmer wrote:
               | It specifically defines 'dynamic driving task' in the
               | definitions section:
               | 
               | > (g) "Dynamic driving task" means all of the real-time
               | functions required to operate a vehicle in on-road
               | traffic, excluding selection of final and intermediate
               | destinations, and including without limitation: object
               | and event detection, recognition, and classification;
               | object and event response; maneuver planning; steering,
               | turning, lane keeping, and lane changing, including
               | providing the appropriate signal for the lane change or
               | turn maneuver; and acceleration and deceleration.
        
         | TigeriusKirk wrote:
         | Then Tesla should disable it in California.
        
       | maxdo wrote:
       | Can anyone explain me what is fundamentally wrong with Tesla
       | approach emotions aside. Tesla rolled out FSD Beta(not Autopilot)
       | to a very small group of people. After been in public for almost
       | a year, it has 0 death or injuries. It is not ideal. Tesla
       | clearly understand that and _communicate_ that to every user of
       | FSD Beta. They limit amount of people using it. Also they limit
       | the way you use it introducing lots of points of control so that
       | you pay attention at the road.
       | 
       | EDIT: They will kick you out of the beta for a slight miss-doing
       | such as phone or distraction. You will not get into this beta if
       | your driving skills are not perfect. Even if you press a break
       | too hard all the time, it's a passive sign to them your driving
       | is not perfect.
       | 
       | They invest billions of dollars in infrastructure so that
       | application of this feature can grow. Tesla use testing data to
       | eventually enable it in public. That will occur only once they
       | are confident in their security level. They attract some peoples
       | money who admire their goals to save peoples life.
       | 
       | What's wrong with that? Why people getting mad every time they
       | hear aspirational name Full Self driving. What is the logic
       | behind it?
        
         | k8sToGo wrote:
         | Does it not have 0 death or injuries because they kick you out
         | of the beta for not driving perfectly?
        
           | maxdo wrote:
           | yep, that proves their model actually *WORKS*
        
         | simondotau wrote:
         | You're not likely to get a useful response, because it's
         | ultimately an argument over semantics -- and there is no
         | evidence that anyone who actually has access to this FSD beta
         | has been misled by Tesla.
        
       | kjksf wrote:
       | If I understand his argument correctly, Tesla would be in
       | compliance if they allowed anyone who buys FSD to use it
       | immediately, just like Ford allows anyone to use Blue Cruise on
       | Mach-E.
       | 
       | One of the essential parts of the argument is that Tesla falls
       | under current law because they are selective about who they allow
       | to use FSD.
       | 
       | So Tesla could trivially be in compliance if they ditch the
       | careful rollout. Give the software to anyone who pays for
       | (instead of, as is the case currently, slowly expanding the
       | number of people).
       | 
       | And maybe change the name to Yellow Cruise instead of FSD and
       | stop telling people it's beta software.
       | 
       | And voila, compliant with CA DMV legislation.
       | 
       | I hope that this person understands his own argument in which
       | case it's hard to believe that he is concerned about safety.
        
         | renzo88 wrote:
         | >I hope that this person understands his own argument in which
         | case it's hard to believe that he is concerned about safety.
         | 
         | I think he understands his own argument. I don't think you
         | don't understand the implications of why they haven't rolled it
         | out.
        
         | droopyEyelids wrote:
         | Isn't Blue Cruise only available on select mapped highways, and
         | only described as a SAE J3016 level-2 system? That seems to be
         | a crucial difference.
         | 
         | ```The name ["Full Self Driving"] unequivocally communicates
         | Tesla's goal for development, and the company's "beta"
         | qualifier communicates the stage of that development. Tesla
         | intends for its "full self-driving" to become, well, full self-
         | driving, and its limited beta release is a key step in that
         | process.```
         | 
         | Seems like your analysis skipped that part.
        
           | maxdo wrote:
           | There is a huge difference between goal and actual state. You
           | can't enable FSD Beta without clicking several checkboxes in
           | clear language saying you have to pay attention every second
           | on the road, you're responsible for single action of a car on
           | the road. And it provides more restriction on a driver
           | compares to regular driving, such as distraction camera
           | monitor, phone monitor, hands off the wheel etc..
           | 
           | It's so boring to see how trolls have no numbers, no real
           | issues but just trying attack the marketing name/aspirational
           | goal.
        
             | MBCook wrote:
             | Ooooh. Checkboxes. That will definitely prevent abuse.
             | 
             | Even if the Tesla owner is responsible about it, other
             | people could drive the car and they wouldn't have to agree
             | to anything. They can go nuts.
             | 
             | I've seen plenty of videos online too. I have no interest
             | in driving next to a car being driven by a crazy AI that
             | seems to have the driving skill of a 13-year-old playing
             | GTA and not know the rules.
             | 
             | I don't have a Tesla. I was forcibly opted into this
             | program. There is nothing to prevent other people from
             | doing stupid and ridiculous things with this system and
             | seriously injuring or killing me.
             | 
             | Heck, they can do the right thing. I've seen videos were
             | trying to take over control doesn't seem to work. Where it
             | tries to drive directly in the traffic in the wrong lane.
             | 
             | This is insanely dangerous and I want no part of it but I
             | don't have any mechanism to stop it but to hope regulators
             | do something. Tesla put MY life on the line.
        
               | maxdo wrote:
               | They use eye tracking camera, to prevent you from lookin
               | not on the road, sensors of the wheel, and also checking
               | you're not on the phone. They doing way more compares to
               | any car maker to keep you safe as non owner of the tesla.
               | I guess been so emotional you better stay in your
               | basement until Level 4-5 will become a reality.
        
             | thinkmassive wrote:
             | I assume you refer to the invite-only beta with FSD that
             | works on city streets, but Tesla's naming is
             | (intentionally?) very confusing.
             | 
             | It would go a long way if Tesla simply renamed the invite-
             | only program to FSD Alpha, and continued referring to
             | "enhanced Autopilot" that's available to everyone for an
             | additional fee as FSD Beta.
        
         | paxys wrote:
         | If they could roll it out to everyone they would do so in an
         | instant. They cannot though because the system is not ready and
         | needs a lot of testing, which is the point the author is
         | making.
        
           | tshaddox wrote:
           | Yeah, regardless of this supposed legal incentive, I don't
           | see any reason why Tesla wouldn't roll it out to everyone if
           | they thought it was ready for that.
        
           | sovnade wrote:
           | It's 100% not ready. There's so many videos people are
           | posting about it nearly hitting pedestrians, going the wrong
           | way down a 1 way, nearly going straight into a curb, etc -
           | all of these only stopped by the driver quickly grabbing the
           | wheel and taking control.
           | 
           | It also doesn't seem to help that enabling FSD on Tesla makes
           | it use the visual camera only, which seems counterproductive.
           | The ultrasonic sensors seem to be critically important
           | because visuals can be obstructed easier.
        
             | snek_case wrote:
             | > There's so many videos people are posting about it nearly
             | hitting pedestrians
             | 
             | Can you post a link to a video of FSD nearly hitting a
             | pedestrian? Because searching on YouTube, I couldn't find a
             | single one.
        
       | voz_ wrote:
       | Telsa is one of the most evil, malicious, companies, in that it
       | knows that what it has is well short of self-driving, and yet
       | markets it as such. This leads to deaths. Their marketers have
       | blood on their hands.
        
         | cagr wrote:
         | Have you personally used Tesla's products in California?
        
           | voz_ wrote:
           | What a strange question. It reads like one of those weirdly-
           | specific tshirts.
           | 
           | And yes. I have personally used Tesla's products in
           | California, in May, when it wasn't raining, after a small
           | lunch I made at home.
        
         | dqpb wrote:
         | Electric cars were a joke until Tesla showed up
        
           | athenot wrote:
           | My Nissan LEAFs were no joke. Sure they didn't have a fancy
           | 17" LCD display, but they were good cars in their own right.
           | I leased 2 of them.
        
             | singlow wrote:
             | OK but to be accurate, the Tesla Roadster came out before
             | the Nissan Leaf.
        
             | maxdo wrote:
             | leaf was a joke as a product in hot and cold weather due to
             | their non working cooling/heating battery system. Even
             | though it's perfectly working in some cases.
        
         | misiti3780 wrote:
         | You would have to be delusional to really believe this.
        
       | paxys wrote:
       | The author of the article is incorrect in understanding what FSD
       | is. Despite the name and any marketing claims, the system is NOT
       | intended to run without human monitoring and intervention. This
       | isn't just for the testing phase. There will need to be human
       | hands on the wheel at all times at full release as well.
       | 
       | This alone exempts it from the California law, which is written
       | for driverless testing (the kind Waymo and Cruise do).
        
       | maxdo wrote:
       | I guess what's happening here, is that legacy automakers not able
       | to make EV's with decent profit ( that's real numbers ), hence
       | their production is limited.
       | 
       | Traditional media creating so much buzz to slow down and make
       | tesla look bad. I can see every bad news about tesla re-printed
       | everywhere. 1 car got on fire boom... every car outlet re prints.
       | BMW recalled 1M+ cars because of fire risk and some of them still
       | catching on fire on the road while driving on a highway, no one
       | even heard of it.
       | 
       | Regarding the article. Author probably never tried to drive FSD.
       | If driver doesn't look on a road for few seconds few time it will
       | ban you from this feature. They use camera, sensors of steering
       | wheel etc... It is very aggressively RESTRICTED , locked LEVEL 2
       | system. It's only available for few thousands of people. Regular
       | autopliot works only on highways and very limited.
       | 
       | FSD name is clearly aspirational. Once they will have a
       | confidence they will switch from level 2 to 3 etc.. By
       | removing/easing restrictions. Only AFTER THAT it will become
       | eligible to a different regulations.
       | 
       | The only debate here could be how aggressive you are about this
       | level 2 restrictions while building LEVEL 5 system.
       | 
       | I am part of this Beta program. My personal feeling after using
       | this system: you pay attention more compares to regular driving.
       | It tuned this way it will rather do a false positive distraction
       | decision.
       | 
       | And yeah, current version is so far away from LEVEL 4 or 5. And
       | it's not usable for every day. The only use of it try, test,
       | provide feedback, turn off , and use the car in a traditional
       | way. There is 0 amount of people who is using this feature not
       | for testings purposes.
        
         | clouddrover wrote:
         | > _Traditional media creating so much buzz to slow down and
         | make tesla look bad._
         | 
         | That's a complicated conspiracy theory. The truth is more
         | simple: Tesla is making itself look bad.
         | 
         | 5 years ago Tesla said that all of its cars being produced at
         | that time had "the hardware needed for full self-driving
         | capability at a safety level substantially greater than that of
         | a human driver":
         | 
         | https://www.tesla.com/blog/all-tesla-cars-being-produced-now...
         | 
         | That was a lie.
         | 
         | > _FSD name is clearly aspirational._
         | 
         | Super. So when will Tesla start refunding everyone who paid for
         | "full self driving"? Until the "aspiration" becomes an actual
         | delivered product giving refunds is the only honest thing to
         | do.
        
         | davewritescode wrote:
         | Not everything is a conspiracy against Tesla by the media. A
         | lot of folks have legitimate concerns about the way Tesla
         | markets, tests and operates it's self-driving systems and
         | educates it's customers about the limitations.
         | 
         | This is a video from 5 years ago describing Tesla's self
         | driving features.
         | 
         | https://vimeo.com/188105076
         | 
         | I personally feel like Musk is writing checks his engineers
         | can't cash.
         | 
         | A lot of the criticism of Tesla is invited by a stock price
         | which a lot of folks think are propped up by mistruths and
         | exaggerations about the future of company and the feasibility
         | of it's vision.
         | 
         | Also, quite frankly I find the term "legacy automaker"
         | infuriating. Toyota builds 9 million cars a year or 18x what
         | Tesla does and Toyota has a legendary reputation for quality
         | and reliability.
        
           | maxdo wrote:
           | Tela's current production rate is at ~1m a year atm. And they
           | doubled amount of their factories in 2022. So not 18x but 9x
           | now and 4.5x a year or two after. They are in the same league
           | nowadays. And they are doing that with 3 factories in 2
           | countries now. Compare that with Toyota :)
           | 
           | Also Tesla outsold Toyota/Lexus in almost every country they
           | operate in segments/pricing they compete by absolute volume.
           | 
           | Toyota has also a reputation like any legacy car maker a
           | reputation for selling you some crap like GPS for 10x the
           | price. At least Tesla's overpriced autopilot approach works
           | towards safety( the end goal level 5 system). And if you
           | don't believe in it , not buying it will not make you getting
           | from point a to point B more complicated.
           | 
           | Tesla also sell every car "full package" in legacy car makers
           | terms. Every camera, every seat ( except color), every screen
           | detail, speakers , gps is the same in every model from the
           | cheapest to the most expensive. Compare that to legacy makers
           | trying to get 10x of every simple feature like seats heating.
           | You need an App? Pay for it. You need firmaware upgrade go to
           | service and pay for it..
           | 
           | Speaking of safety tesla's cars has always excellent security
           | tests. Toyota don't. There are many things toyota lags
           | behind. Like multi-media, autonomous driving, connectivity,
           | software over the air, battery tech, electric motor design,
           | manufacturing. So yeah, they are legacy atm. Legacy can have
           | a good reputation, even perfect nothing wrong with it.
           | 
           | They are legacy because as of 2021 they bet on legacy tech,
           | their way to sell cars is legacy, their approach to packaging
           | is legacy, their approach to safety is legacy... their way to
           | produce cars is legacy.
           | 
           | Toyota has quite good roadmap for 2-3 years, maybe they will
           | get into modern world eventually.
        
         | soperj wrote:
         | Don't do beta testing with machines that can kill people in
         | public. End of story.
        
           | maxdo wrote:
           | Any person can get distracted and kill people in public. Most
           | of the cars doesn't have distraction mechanisms like FSD
           | Beta. e.g. if you're on the phone, FSD will not work. Lets
           | ban people from roads according to your logic. FSD Beta
           | killed 0 people since 1 year of program, humanity killed and
           | made millions people injured due to human mistakes. Any Level
           | 4-5 system deployed on a large scale with save millions of
           | people, prevent even more people from been disabled in the
           | future.
        
             | [deleted]
        
             | [deleted]
        
           | gitfan86 wrote:
           | Thousands of people die every year because of human errors.
           | Do you think this should continue forever? If not how do
           | suggest we create software without testing it in real world
           | conditions with a safety driver who can monitor and take over
           | at any time?
           | 
           | Do you know how many people have died because they had a
           | medical emergency while driving? Do you think that should
           | continue forever?
        
             | 0_____0 wrote:
             | If you actually want to save lives, you might start at the
             | top. Driving is hazardous for operators and for bystanders,
             | and kills 40,000 people in the US alone every year. Build
             | cities such that the majority of people don't need or want
             | to drive, and viola, you're saving lives.
             | 
             | And the tens or hundreds of billions of dollars worth of
             | human effort and engineering put towards making cars that
             | drive themselves can go to something else.
        
               | Retric wrote:
               | Most deaths from driving occur outside of cities.
        
               | 0_____0 wrote:
               | could you clarify what you mean by 'outside of cities?'
        
               | simondotau wrote:
               | It would probably be more accurate to say 'outside of
               | city streets.' The threat of death tends to scale with
               | vehicle speed.
        
               | maxdo wrote:
               | a very good joke, what's your estimate to rebuild every
               | city and road in the world lol. Billions of dollars it's
               | a very tiny small fraction of this money.
        
               | 0_____0 wrote:
               | It's a matter of priority. Many people have this concept
               | of Amsterdam and Utrecht as having forever been a cycling
               | paradise, but the reality is that they were choked with
               | cars and smog until the 70s. The political will existed
               | to prioritize non-automotive modalities, and a few
               | decades later you have what we see today.
        
             | davewritescode wrote:
             | I think testing these systems on public roads is 100%
             | reasonable if we all have open access to data. I'm not
             | talking about raw driving data, but aggregate metrics about
             | how well the system is operating and limitations are
             | clearly communicated.
             | 
             | Selling a customer a car with a "full self driving" feature
             | while burying the actual functionality in a legal agreement
             | displayed on screen in the vehicle.
        
               | simondotau wrote:
               | That misrepresents how Tesla sells FSD. The actual
               | current functionality is shown in clear bullet points at
               | the time of sale. It is not buried in a legal agreement.
        
           | viktorcode wrote:
           | This requirement is impossible to fulfil because there are no
           | cars that can't kill people on public roads. Regardless of
           | means of driving.
        
       | superjan wrote:
       | https://www.smbc-comics.com/comic/fsd
        
       | somethoughts wrote:
       | I think a critical point to make is that this is not actually
       | about Tesla/Waymo. Its about creating guidelines that are
       | generally applicable to all companies pursuing self driving car
       | technologies.
       | 
       | So it applies to Tesla but perhaps more importantly companies
       | that are trying to copy-cat style mimic Tesla's move fast
       | approach to SDC for tech advantage reasons/marketing PR/save
       | money and perhaps are cuting even more corners than Tesla.
       | 
       | Some examples I hear about are Nuro and maybe even Cruise,
       | Aurora.
       | 
       | And then imagine a host of other companies as well - Faraday
       | Future, Comma.ai, Pony.ai, Xpeng, etc. Its unclear at this point
       | that these companies shouldn't have some oversight/held to some
       | standard operating procedures.
       | 
       | https://techcrunch.com/2021/12/14/pony-ai-suspension-driverl...
        
       | trothamel wrote:
       | Unless I'm reading this wrong, this is just a person's opinion,
       | not an opinion or ruling from a government agency. Interesting,
       | but without any legal authority.
        
         | falcolas wrote:
         | Yes, these things will only shake out when someone takes Tesla
         | to court.
         | 
         | However the opinion of a professor of law, who is also an
         | engineer, is not something to so easily dismiss. IMO, it means
         | that Tesla is likely to find themselves in court.
        
           | simondotau wrote:
           | It's easy for a legal argument to appear convincing in
           | isolation. If you haven't heard from the other side, it's
           | probably appropriate to maintain some reservations, as I dare
           | say that Tesla's lawyers would see things differently.
        
           | mikeyouse wrote:
           | Right - he helped California develop their standards and was
           | one of the coauthors for the "Level 1/2/3/4/5" SAE
           | classification for self-driving. His opinion obviously isn't
           | backed with the force of law, but this analysis is likely
           | enough to get regulators to send Tesla a letter or two.
        
             | HWR_14 wrote:
             | I'm pretty sure Levels 1-5 classification far predate self-
             | driving classifications.
        
             | toomuchtodo wrote:
             | So Tesla geofences FSD beta to outside California? Like
             | moving their HQ to Austin? California should absolutely act
             | if the law covers FSD, but it's entirely realistic for
             | Tesla to jurisdiction shop (just as credit card interest
             | rates are mostly set by the laws of South Dakota).
        
               | mikeyouse wrote:
               | Yeah I don't know they have a good solution - but based
               | on his analysis, more honest marketing (e.g. stop
               | claiming things like "Drivers are only there to meet a
               | legal requirement, the car will drive itself!") might be
               | enough to stay on the right side of the line.
        
               | JakeTheAndroid wrote:
               | California is one of, if not the largest EV market in the
               | US right now. Consumers by and large don't care where a
               | company has their HQ, but they will be upset if they
               | don't have access to features. And this impacts people
               | that aren't in CA that have FSD but road trip to/through
               | CA. I can't imagine this is an ideal situation for Tesla
               | to be in, and they'd prefer to avoid this as much as
               | possible. There isn't a really good solution here for
               | them.
               | 
               | I don't see how they can jurisdiction shop in any similar
               | way to a credit card company in this instance, these are
               | markedly different scenarios and services provided.
        
               | toomuchtodo wrote:
               | They'll still sell FSD, they just won't offer the beta
               | functionality in (or if you traverse) California due to
               | "regulatory constraints." They'll continue to run FSD
               | beta testing in 49 other states.
               | 
               | In similar fashion, Autopilot has tighter operational
               | constraints in parts of Europe versus the US.
               | 
               | https://www.teslarati.com/tesla-autopilot-europe-
               | restriction...
        
               | JakeTheAndroid wrote:
               | Yeah, they will still sell it but it wont sell to people
               | living in CA which is one of the larger US markets.
               | that's a non-trivial market to close your doors to for
               | something like FSD. The margins on FSD have to be some of
               | the best on the whole car.
               | 
               | The EU regulations and standards are likely just as
               | annoying for them, but they don't sell the same volume
               | across the EU yet, and the regulations are a bit more
               | consistent across the whole region. So getting a Tesla in
               | one EU country will work the same in another. Which is
               | just easier for a consumer.
               | 
               | I am not saying this would end Tesla, but I can't imagine
               | a world where they want it to come to that. I think they
               | would look at either properly complying or some other
               | workaround before just drawing a fence around FSD in CA.
        
               | martythemaniak wrote:
               | I think you're a bit confused about what's going on.
               | Autopilot, FSD and FSD Beta are all different things.
               | 
               | Autopilot is advanced cruise control, built-in and sold
               | everywhere with each car.
               | 
               | FSD is a software package you can add. It can do a few
               | things, change lanes on highways, chime when the green
               | light comes on and you haven't moved for a few seconds,
               | etc. You can buy FSD anywhere, but not all the features
               | are available everywhere. Overall, it doesn't do much
               | right now. FSD Beta is a testing program you apply to and
               | can join if you have a good driving record and are
               | selected. Only in the US. There's at most low-digit
               | thousands of people who have access to this, fewer that
               | actually use it.
               | 
               | Article is about the last bit only. Not being able to
               | test FSD in California only is probably a pain, but won't
               | impact much. Allowing people to test the beta only
               | started a few months ago.
        
               | Animats wrote:
               | The European Union already shut down Tesla's "full self
               | driving" capability
        
               | kjksf wrote:
               | No, they didn't.
               | 
               | Tesla never enabled FSD in Europe. Currently it's only
               | enabled in US. FSD couldn't possibly have been shut down
               | if it was never enabled there.
               | 
               | As far as Autopilot goes, EU limits how much software can
               | steer the car that makes some of the Autopilot
               | functionality not possible (e.g. to take a sharp turn you
               | have, you know, turn the wheels).
               | 
               | For that reason some Autopilot functionality is limited
               | in EU.
               | 
               | This is not anti-Tesla rule but one that affects every
               | car maker and they are in the process of changing that
               | rule.
        
               | HWR_14 wrote:
               | Not only that, but California EV transferable credits are
               | a major part of Tesla's income stream. IIRC, if Tesla
               | stops selling in California, their profits go down by
               | more than 50% (assuming that the other states can absorb
               | the extra Teslas, which at this point is a reasonable
               | assumption.)
        
       | maxdo wrote:
       | >Tesla's "FSD" has the "capability to drive a vehicle without the
       | active physical control or monitoring by a human operator,"
       | 
       | Tesla doesn't not have this capability, after few seconds not
       | having your hands on the steering wheel , or not watching on the
       | road , or not having a driver in a sight of camera it will ban
       | you fron FSD Beta. It also monitors if you're using your Phone
       | and warn you for that and after ban. This feature alone makes FSD
       | safer compares to regular human :)
        
         | simondotau wrote:
         | Precisely this. Whether the authors of the legislation intended
         | it or not, this mandatory requirement for continual human input
         | excludes a system from their oversight.
         | 
         |  _"An autonomous test vehicle does not include vehicles
         | equipped with one or more systems that provide driver
         | assistance and /or enhance safety benefits but are not capable
         | of, singularly or in combination, performing the dynamic
         | driving task on a sustained basis without the constant control
         | or active monitoring of a natural person."_
         | 
         | FSD requires constant control of a natural person.
        
       | viktorcode wrote:
       | >... as Tesla's engineering and marketing have become more
       | aggressive.
       | 
       | I get aggressive marketing. What is aggressive engineering?
        
         | darkerside wrote:
         | Willing to take more risks with what they are deploying?
        
         | maxdo wrote:
         | BS from author , Tesla don't market FSD Beta at all. They
         | market autopilot, it's a totally different system
        
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