[Veserv]

This is a unsupported analysis. Despite the California DMV mandatory reporting requirements for autonomous driving systems (ADS) with a safety driver [1], FSD under open beta testing with a safety driver has been deliberately underclassified by Tesla to not qualify as a autonomous driving system to suppress disclosure of their raw usage data [2]. As the only entity with the raw information is the manufacturer which has a inherent conflict of interest, no robust untainted safety analysis is possible.

The National Highway Transportation Safety Administration (NHTSA) does have a standing general order (SGO) [3] requiring the disclosure of all ADAS incidents [4]. However, Tesla redacts which system and version was in use in all reports citing proprietary information unlike other manufacturers which only redact in a small fraction of their reports. In addition, a cursory examination (filter to Report Type 10-Day Update) shows 749 Tesla incidents with 711 having unknown injury severity. This is distinct from "No Injuries Reported" where they know that no injury occurred; they only know for certain that nobody died in less than 5% of the cases. This is again in contrast to all other manufacturers combined which only have a total of 203 incidents of which only 63 have unknown severity. That is 5% known for Tesla versus 70% known for all other manufacturers, a 14x difference. The deliberate censoring of the incident information by Tesla makes it even more impossible to do a meaningful analysis.

So, not only is the denominator suppressed, even the numerator is censored. It is straight up impossible for any third party to do any analysis. As the default assumption with safety-critical systems is that they are unsafe, and it is literally impossible for any untainted safety analysis to be done, it is affirmatively unsafe until at a minimum they stop suppressing the incident and usage information that they are legally required to disclose.

[1] https://www.dmv.ca.gov/portal/vehicle-industry-services/auto...

[2] https://thelastdriverlicenseholder.com/2023/02/17/2022-disen...

[3] https://www.nhtsa.gov/laws-regulations/standing-general-orde...

[4] https://static.nhtsa.gov/odi/ffdd/sgo-2021-01/SGO-2021-01_In...