Not really. Take the Minimal Risk Condition, for instance:
The characteristics of automated achievement of a minimal risk condition at Levels 4 and 5 will vary according to the type and extent of the system failure, the ODD (if any) for the ADS feature in question, and the particular operating conditions when the system failure or ODD exit occurs. It may entail automatically bringing the vehicle to a stop within its current travel path, or it may entail a more extensive maneuver designed to remove the vehicle from an active lane of traffic and/or to automatically return the vehicle to a dispatching facility.
Thatâs a few âmay entail,â not âmust entail,â and nothing about when one kind of MRC would be preferable to another. There are plenty of examples, but those arenât requirements.
Contrast that with the FMVSS. Youâre absolutely correct that it doesnât specify the âhowâ something is acheived, only what the performance requirements for that something are. Which is why, for instance, weâre not going to get a regulation that requires LiDAR. But, FMVSS gets very specific on performance requirements, for instance on braking there are specific speeds, vehicle weights, distances, pedal forces, etc. But, nothing on brake pad material or shape of the pads, etc.
Youâre losing the forest for the tree details. Tesla doesnât need complete redundancy, it needs just enough to be able to perform a DDT Fallback. Iâve not seen a regulation that defines specific DDT Fallbacks for certain conditions, and the lazy incorporation of J3016, as I showed above, doesnât fill in those gaps.
Ah, so you want to eat your cake and have it, too:
How much of steering is part of the ADS, if nothing in the suspension is part of the ADS? A failed suspension arm may mean the car canât move at all due to either no propulsion to the wheel, the wheel completely disconnected from the drivetrain, or the wheel just jammed in the wheel well. In any of these cases, the car wonât be able to perform some DDT Fallbacks, âlike pulling off to the side of the road.â
As you said, âThere nothing about being completely fault tolerant.â Picking and choosing what is or isnât in the ADS isnât part of any regulation.
EDIT: I should add that I agree that HW3 vehicles are unlikely to become L4 capable, as Tesla probably wonât even try. Maybe Tesla will take the time to apply for L3 certification for these vehicles, but thatâs probably a lot of time and cost with little financial benefit for the company, so I think itâs unlikely to happen.
And yes, I do agree that Musk has and will continue to make promises that wonât ever be fulfilled.
As Tesla is likely focusing on CyberCab production (supposedly the line is close to completion for first vehicles now), it does seem likely that Tesla will apply for robotaxis using CyberCab first. And I wonât disagree that perhaps Tesla will not apply for L4/robotaxis for existing vehicles, even those being built today. Seeing that Tesla already has some CyberCab prototypes with manual controls is only surprising from the POV of Elonâs statements in Issacsonâs biography of Elon, where Musk hammered down on any suggestion of having CyberCab versions with manual controls. My guess there is that once it was subsequently pointed out to him that to get Robotaxi approval meant first having trials with human drivers to take over forces Teslaâs hand.
But, I donât believe that lack of redundancy is what will prevent todayâs HW4 vehicles from being used for driveless robotaxis.