NHTSA asks Tesla how it plans to release its robotaxi service based on FSD

NHTSA is asking Tesla to do what it has always been able to avoid: release data from its ‘Full Self-Driving (FSD)’ program.

The agency wants to know how closely its planned robotaxi service in Austin will be to its FSD program, which is currently under investigation for safety defects.

NHTSA, the agency in charge of automobile safety regulations in the US, appears to know very little about Tesla’s planned rollout of a “robotaxi service” in Austin, Texas, even though it is reportedly just a few weeks away.

The agency is currently investigating Tesla’s ‘Supervised Full Self-Driving’, FSD, program and when it heard from Tesla recently that the planned robotaxi service in Austin is going to be based on its FSD program, it got worried.

Advertisement – scroll for more content

Tanya Topka, Director of NHTSA’s Office of Defects Investigation, wrote to Tesla in an email sent last week and obtained by Electrek:

As you are aware, NHTSA has an ongoing defect investigation (PE24031) into FSD collisions in reduced roadway visibility conditions.

They are asking Tesla for more information:

The agency would like to gather additional information about Tesla’s development of technologies for use in “robotaxi” vehicles to understand how Tesla plans to evaluate its vehicles and driving automation technologies for use on public roads.

I included the entire list of questions below, but in short, NHTSA wants to know what parts of Tesla’s ‘Supervised FSD’, which is under safety investigation, will be used in the robotaxi service planned for Austin and other expansions later this year, and if it is different, what the differences are.

They want to know what data Tesla has to prove its vehicles are safe enough to be fully autonomous in this paid robotaxi service.

As we have often reported before, Tesla famously has avoided ever releasing any data about its FSD program. We have to rely on crowdsourced data to track progress in the program.

The automaker also avoids releasing critical data to NHTSA in its ADAS crash reporting system.

Tesla has until June 19 to respond or face up to $27,874 in penalties per violation per day.

Here’s the complete list of questions NHTSA is asking Tesla about its planned rollout of a robotaxi service in the US:

1. Based on Tesla’s public statements described above, NHTSA understands that Tesla is developing an automated driving system (ADS) based on its current FSD Supervised system, which Tesla has labeled an advanced driver assistance system. State the name(s) of the system(s) that will be used in robotaxi development and deployment as well as Tesla’s position on the SAE Level classification for the purposes of reporting under NHTSA’s Standing General Order on crash reporting.
2. Describe Tesla’s plans to develop, test, and commercialize a robotaxi or analogous technologies on public roadways, including details regarding:
   • The number of vehicles by make and model anticipated at start of on-road operations and within the subsequent 12 and 24 months.
   • To the extent that Tesla plans to use any new vehicle models in the next 24 months, explain whether any vehicles that do not fully comply with Federal Motor Vehicle Safety Standards (49 C.F.R. Part 571) will be operated on public roadways, and state whether Tesla plans to seek any FMVSS exemptions.
   • The expected timetable for availability of a robotaxi or similar service to the public or other groups.
   • The expected timetable for availability of robotaxi technology for operation on vehicles controlled by people or entities other than Tesla and whether Tesla will require such individuals or entities to meet certain requirements to ensure safe operations.
   • The locations anticipated at start of on-road operations and within the subsequent 12 and 24 months.
   • Whether and how vehicles will be supervised or otherwise monitored by Tesla in real time.
   • Use of any teleoperation technologies such as remote driving and remote assistance and the limits of control authority for remote input to system/vehicle operation.
   • The roles and responsibilities of any in-vehicle or remote staff involved in monitoring, supervising, or intervening in system operation.
3. Describe the driving automation system(s) that will be used for the robotaxi effort and any relationship to Tesla’s existing FSD Supervised product available to consumers today.
   • Descriptions of each perception sensor (including count and location), each compute subsystem, and overall system architecture for perception, planning, actuation, and performance monitoring/logging.
   • The role(s) of any cameras or other sensors within the vehicle cabin for the robotaxi system’s safe operation when supervised and unsupervised.
   • Explanations of differences in system implementation for the robotaxi and FSD Supervised.
   • Describe the maximum control authority for the system when engaged including commanded speed, acceleration, braking, steering angle, permissible gear selection states while engaged, and limits on specialized maneuvers (e.g., reversing, parking, etc.).
   • Description of whether Tesla complies fully or partially with any industry standards, best practices, or guidance for the development and safety assurance of driving automation systems (e.g., SAE J3018, ISO/TS 16949, ISO 26262, SOTIF, UL4600, etc.).
4. Provide a detailed description of the operational design domain (ODD) for the robotaxi driving automation system, including an explanation of:
   • ODD elements3 and associated thresholds for the ODD for each automation feature.
   • The set of ODD elements that are monitored by the automation system.
   • The set of ODD elements that are solely monitored by any in-vehicle or remote staff.
   • The designed response of the automation feature, for each ODD element, if a system limit is exceeded or an ODD exit occurs.
   • Specific operational restrictions Tesla is implementing (e.g., relating to time-of-day, weather, geofencing, maximum speed) and whether each operational restriction is implemented primarily to ensure safe operations within the subject system’s ODD.
5. Describe how Tesla plans to determine whether its robotaxi system has achieved acceptably safe behavioral competency for a given ODD scope including:
   • a. Establishing behavioral competency thresholds for supervised on-road operations.
   • Establishing behavioral competency thresholds for on-road operations without real-time supervision.
   • Determining which behavioral competencies (and associated ODD elements) do not satisfy established thresholds for on-road operations both with and without real-time supervision.
   • How this approach aligns with or differs from Tesla’s processes for FSD Supervised.
6. Explain Tesla’s approach for monitoring in-use interventions for the robotaxi system as it relates to:
   • Defining and tracking the types and frequency of disengagements or other human interventions – including both in-vehicle and remote interventions – and their relationship to safe driving behaviors.
   • Provide the current metrics for disengagements/interventions for the robotaxi system.
   • Planned differences in monitoring disengagements/interventions in comparison to Autopilot and FSD Supervised.
7. Describe Tesla’s design and approach for emergency scenarios including:
   • Crash detection and response, including adequacy of minimal risk conditions depending on crash scenario.
   • The designed/intended maneuvers and/or other responses to achieve a stable stopped condition – i.e., a minimal/mitigated risk condition (MRC) – or takeover following a crash, system failure, ODD exit, or other scenario requiring an appropriate disengagement or other intervention.
   • Planned operational steps following achievement of an MRC.
   • Subject system and subject vehicle interactions with first responders.
   • Tesla’s operational response to incidents occurring with the subject system.
8. Explain the methods and processes (e.g., establishing a safety case) in detail that are employed by Tesla to determine readiness of the robotaxi system for on-road use with and without supervision.
   • Explain whether Tesla employs a safety case or similar methodology. Describe how Tesla gathers and assesses evidence that its robotaxi system is ready for onroad use under supervision and without supervision.
   • List all processes Tesla has established for internal decision making on whether the system is acceptably safe for on-road use (e.g., satisfying whether safety claims in a safety case have been fully satisfied). Identify the accountable decision makers by name, role, and organizational structure.
   • List and describe each process that Tesla uses to establish metrics and associated baselines or thresholds that quantify acceptable performance for on-road use. Include descriptions of how the metrics are established.
   • Describe Tesla’s verification and validation methodology for the robotaxi product for metrics/thresholds including:
     • How Tesla identifies and handles potential performance gaps and regressions during development and while in use.
     • How changes or updates to existing metrics or thresholds are approved.
     • Tesla’s use of simulation, test track, and on-road testing as well as whether Tesla is leveraging data from consumer owned vehicles for verification or validation efforts of the robotaxi product.
   • To the extent that Tesla is using performance thresholds or metrics established based on human drivers, identify the source of the underlying data Tesla is using to establish the thresholds/metrics.
   • Explain how the system is designed to comply with traffic safety laws and how Tesla will monitor for compliance with traffic safety laws including traffic control devices, interactions with construction zones, and interactions with first responders.
   • Describe Tesla’s plan to collect, evaluate, and retain data to continuously monitor the ongoing operational performance metrics/thresholds.
   • Describe Tesla’s approach for determining if an operational performance metric/threshold has been violated.
9. Describe how Tesla intends to ensure the safety of its robotaxi operations in reduced roadway visibility conditions, such as sun glare, fog, airborne dust, rain, or snow. In your response, describe whether Tesla’s approach differs, if at all, for a ride in which the reduced roadway visibility condition exists at the beginning of the ride and a ride in which the reduced roadway visibility condition first appears or is encountered during a ride.