Robotaxis Won’t Be a Real Business for at Least Five Years

Investment Analysis Clubs Macro Economic Trends and Risks
41

Hmmmm…so do you think the 8/8 announcement isn’t a new vehicle, but software? I read it to refer to a new car - presumably one purpose-built to be a taxi. But perhaps it’s not a new vehicle at all, but just claiming that an off-the-rack Tesla can now be used without a human in the driver’s seat?

42

Then why has the Origin already been built? Maybe you mean full production?

That may or may not be true but at the Federal level marijuana is still illegal. Do you deny that?

Andy

43

The ones they drafted in 2021? Then why is the Origin seeking a waiver, which still hadn’t been granted a few months ago? Why are they even bothering with that, and fighting the Teamsters union, if those types of vehicles are already permitted under the FMVSS? I don’t think those rules were ever put into place. Perhaps you have a link that shows that they’re in effect?

44

It’s almost surely both.

Existing Tesla’s (other than CT) will never be able to drive on their own. They literally can’t see directly in front of the car!!!

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45

You’re allow to build concept cars that aren’t street legal. You just can’t, you know, sell them or operate them on public roads.

I don’t deny that. Heck, it’s the reason why marijuana companies have so many problems. They suffer adverse tax consequences, and are shut off from vast swatches of the banking and financial systems. Since the federal government isn’t engaged in criminal enforcement against possession of marijuana, that allows marijuana companies to do business despite the federal illegality.

The same will not be true of a national automaker violating the FMVSS.

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46

I think you would have to ask them that. Have you written to them? I am sure there are many ways to do this and Tesla may take a different tack since they have production sites in Texas and California, which both allow driverless(without steering wheel) cars.

The rules are there, until a Driverless car without a steering wheel is put on the road, you won’t see the effect.

Andy

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47

Texas and California have no jurisdiction over whether a car has a steering wheel or not. The federal government has sole jurisdiction over regulating the physical characteristics of a car. They have completely pre-empted the states in that area. Texas and California can regulate how the car is operated - whether there’s a driver behind the wheel - but not whether a carmaker is allowed to manufacture a vehicle for use on the public roads that doesn’t meet the federal motor vehicle safety standards.

It’s weird, then, that GM has filed a formal petition requesting an exception from the rules that you say have been changed to allow a car without a steering wheel. You’d think they wouldn’t do that - much less get into a legal fight with the Teamsters union - if it was irrelevant.

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48

I think the same argument was put forth on Marijuana companies but here we are. It’s not unusual for states to allow things to happen that the Federal government is against.

Not really, the old, staid companies are no longer driving this. It is perfectly logical for GM to take that route, they can’t think of any other way around it. As far as the Teamsters are concerned, they are a union entity and the unions are embedded into GM and so they have to console them. Something Tesla doesn’t have to worry about, at least yet. As you have shown with UBER, who found ways around one of the most regulated industries, there are always ways to move forward. Tesla will find them and might be one of the reasons Tesla is in Texas and California.

Andy

49

But only if the federal government declines to enforce the federal prohibition.

Is that what you think is going to happen? That the NHTSA - which is currently all over Tesla in their Autopilot investigations - is just going to ignore Tesla manufacturing vehicles that violate the FMVSS?

Are there? Uber was able to do this because they just had all their drivers ignore the rules requiring a taxi medallion in order to provide taxi services. They just went out and did it, ignored the agencies that tried to enforce the rules, and held them off in court long enough that the agencies buckled under and cut a deal with them.

That’s a scenario that could play out with the San Francisco Municipal Transportation Agency trying to enforce regs against (by then) thousands and thousands of arguably independent drivers (and a software company that can plausibly claim to just be intermediating their violation of the regs, not violating them itself).

Do you really think that’s going to happen with a federal agency like the NHTSA, where all they have to do is go after a single company and (presumably) a single factory that’s building these things?

50

I have already shown you that the NHTSA has already set up rules for driverless(wheelless) cars and is very much in front of it. So whatever Federal agency other than the NHTSA is going to be ignored. Tesla will follow the NHTSA rules. Will there be bumps along the way? Yes, Will they work through it? Yes.

Andy

51

Again, I’ve asked you whether the NHTSA rules you cited were actually adopted - not merely “set up.” Because it sure doesn’t look like wheel-less cars are were ever permitted by NHTSA, since Origin is requesting an exception from the prohibitions on wheel-less cars that you’re suggesting the NHTSA has already removed.

Here’s a copy of Origin’s petition, and a link to the current FMVSS requirements set out in 49 CFR Part 571. Running through a few of the specific provisions that Origin requested relief from, they seem to all still be in the regs - including a the ones that pre-suppose the existence of manual controls like a steering wheel or manually operated gear shift.

https://www.ecfr.gov/current/title-49/subtitle-B/chapter-V/part-571

Sure seems like there’s still regulatory barriers to a bespoke robotaxi.

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52

It seems you want to argue what is is. The best I can do for you is give you the final ruling. I am not sure why that isn’t good enough for you. Do you think they are lying? Do you think that stops anyone from producing a fully driverless car?

Microsoft Word - Occupant-Protection-for-Vehicles-with-ADS-final rule-3-10-2022-web.docx (nhtsa.gov)

Andy

53

Of course they’re not lying - it’s just that the rule doesn’t do what you think it does.

They went through revised all the passenger safety specs for the car so that they were defined without assuming a driver. Thus, for example, they revised the requirements for the front left seat - previously described as the drivers seat - so there would be safety regulations in place even if that person wasn’t driving.

But what they didn’t do was scrub the regs to remove all the references to physical controls. So again for example, while the safety requirements for the front left seat no longer assume that seat will have a steering wheel, the requirements for turn signals still do.

That’s why I provided you with a copy of Origin’s waiver request and a link to the current regulations, showing that all that stuff is still in there. It looks like they didn’t remove any of the stuff that requires physical controls - they just amended the safety requirements that were defined in reference to those physical controls in case one day they were no longer provided.

So, yeah - I think there are still regulations that prevent a car that is physically designed without driver controls from being street legal under the federal regulations. I assume Tesla is of a similar mind, since Musk discussed regulatory barriers as something that would be removed upon a showing of better safety, not something that had already been eliminated. I just don’t understand the timing of the robotaxi reveal or the suggestion that production might start within the year, given that situation.

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54

Why would they scrub the regs? There are still cars on the highways, probably forever, that need to still have the old rules apply to them. So they did an addendum to the rules, making it that any “new” vehicles will also have to abide to the new rules.

What Musk was referring to is that they are not up to the new rules yet. Which seems reasonable since they are still working on it. But the old rules will still have to remain and the new rules will be an added addendum just like was pointed out in the link I gave you.

SUMMARY: This final rule amends the occupant protection Federal motor vehicle safety standards (FMVSSs) to account for future vehicles that do not have the traditional manual controls associated with a human driver because they are equipped with Automated Driving
Systems (ADS). This final rule makes clear that, despite their innovative designs, vehicles with ADS technology must continue to provide the same high levels of occupant protection that current passenger vehicles provide. The occupant protection standards are currently written for traditionally designed vehicles and use terms such as “driver’s seat” and “steering wheel,” that are not meaningful to vehicle designs that, for example, lack a steering wheel or other driver controls. This final rule updates the standards in a manner that clarifies existing terminology while avoiding unnecessary terminology, and, in doing so, resolves ambiguities in applying the standards to ADS-equipped vehicles without traditional manual controls. In addition, this final rule amends the standards in a manner that maintains the existing regulatory text whenever

As you see they are trying to resolve ambiguities instead of adding more.

Andy

55

Scrub, not scrap. If you want cars to be allowed to be either driverless or with a driver, you have to go through the regulations and modify all of the current requirements so that they can be satisfied with either manual controls or an automated driver system (ADS). That’s the exercise you have to go through to permit people to remove the manual controls in their cars.

Yeah, again I think you’re misinterpreting what the summary actually says. They went through and modified some of the safety standards to account for future vehicles that might not have manual controls - but they didn’t go through them to permit vehicles without manual controls, or to remove all the things that would preclude a bespoke driverless car.

So, again, they went through and modified the rules that say how the front left seat has to be designed for safety - and they modified those rules to eliminate the reference to that seat as the “drivers’ seat”, because in the future that person might not be driving. But they didn’t got through and eliminate the rules that require, for example, that turn signals have to be designed to automatically turn off upon steering wheel rotation. Because this rule wasn’t drafted in order to permit people to remove steering wheels and brake pedals and front windshields, but just to make sure that the occupant protection part of the standards are ready in case that ever happens.

Which is why, again, Cruise Origin had to actually apply for an exemption from all those rules, rather than just start making their cars without steering wheels or physical gear shift controls. Because the regulations still require them…without exception for driverless cars.

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56

That was the NHTSA, I disagree with how you are reading it. The only way we will know is if you are willing to take it to court. But for me I am fine with how the rules have been laid out.

Andy

57

Then why is Origin seeking an exemption to allow their car? They filed a petition with the NHTSA requesting relief from these regulations. The only reason they would do that is because these regulations are still in effect - and indeed, if you pull up the CFR, they’re all still in there. The changes made by the NHTSA in 2022 changes the passenger safety requirements, but not any of the other regs that have to be amended for a driverless car (no manual controls) to be allowed.

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58

GM is NOT seeking an exemption to not having a steering wheel or brake pedal. Those are apparently ok with the Feds.

The exemptions requested are for stuff like having to have a gear shift, windshield wipers, lamps, etc.

GM has petitioned NHTSA for a temporary exemption from certain requirements in six FMVSS for its ADS-equipped vehicle, the Origin. Specifically, GM seeks exemption from portions of:

I think Andy is correct, ADS-equipped cars are not required to have a steering wheel or brake pedal. That’s why the list of requested exemptions does not include anything about the absence of a steering wheel or brake pedal. It wasn’t necessary.

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59

Right - the existing regulations don’t state that the car must have a steering wheel or a gear shift, they simply assume that the car has a steering wheel or a gear shift. The effect is the same. You can’t meet the regulations without a steering wheel. Which is why several of Origin’s requested exemptions are necessitated by not having a steering wheel.

Below is the petition again. For example, one of the exemptions is from the requirement that turn signals deactivate upon steering wheel rotation. They can’t meet that requirement unless they have a steering wheel. So in order to not have a steering wheel, they need an exemption. That specific requirement is listed under the “lamps, reflective devices, and associated equipment” section of the FMVSS - so if you only read the summary and not the actual petition, it’s hard to tell that it’s the absence of the steering wheel that causes the violation of the rule.

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60

I would point out the obvious design and manufacturing strategy for Tesla:

  1. Design for Manufacturing car model(s) that do not need any manual controls.
  2. design protect those models with a modular “human machine interface”
  3. make it very obvious when the modular HMI has been tampered with or removed to safe liability
  4. scenario plan for how to utilize the space, labor and materials which will no longer be needed when the HMI goes away

It would appear that notifying the public for item number 1 to juice the stock price and engage the public for the sake of .gov influence would be prudent, regardless of when or how it could ACTUALLY be accomplished in an approved NHSTA version.

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