Showing posts from September, 2021

Autonomous Vehicle Testing Guidance for State & City DOTs

Once in a while I'm contacted by a city or state Department of Transportation (DOT) to provide advice on safety for "self-driving" car testing. (Generally that means public road testing of SAE Level 3-5 vehicles that are intended for eventual deployment as automated or autonomous capable vehicles,) The good news is that industry standards are maturing. Rather than having to create their own guidelines and requirements as they have in the past, DOTs now have the option of primarily relying upon having AV testers conform to industry-created guidelines and consensus standards. And ... in September 2021 NYC DOT blazed a trail by requiring the self-driving car industry to conform to their own industry consensus testing safety standard (J3018). Kudos to NYC DOT!  (check it out here ( link ); more on that in the details below. The #1 important thing to keep in mind is that testing safety is not about the automation technology -- it is about the ability of the human safety driver

Is Tesla Full Self Driving Level 2, or Level 4?

Since this blog was written, I teamed up with William Widen and did an deeper analysis of what Tesla told CA DMV and the relevant CA regulations. Conclusion: Our analysis indicates that Tesla FSD beta is SAE Level 4.  This builds upon the previous blog post below, but the article in the JURIST and associated SSRN article supersede the below, which is preserved only for historical context. (update: Oct 1, 2021) Original article is below. ---------------------------------------------------------------------------- The technical crux of the Tesla "Full Self Driving" naming and marketing dilemma is SAE J3016 Section 8.2  (J3016 is the standard that defines the Levels.) If the design intent for the Tesla FSD feature is to eventually operate without a human driver being required for safety, per SAE J3016 that makes it SAE Level 4 ("L4") -- even if today a human driver is required t