Not a chance that one of the largest manufacturers in the country wouldn’t be aware of the NHTSA’s changes that had been in the works for years. But we don’t even need to guess at that, because GM was (unsurprisingly) one of the commenters to the proposed rule - so not only were they clearly aware of it, but they had reviewed it depth - more than a dozen of their comments were referred to in the rule. Or that NHTSA hadn’t even bothered to mention it to any of GM’s representatives and lawyers when they met to discuss these issues prior to filing the petition (which surely happened - you don’t file a 120-page document filled with technical data with a regulatory agency without having at least a few pre-filing meetings.
And once more - these provisions weren’t changed with the amendment. They’re all still in the regulations. The amendments changed other provisions of the FMVSS - not these. If you go to the regulations today, they still say (for example) that the turn signals have to deactivate upon steering wheel rotation.
The only thing that makes sense is that the NHTSA amendments did what they said they did - changed the requirements relating to occupant safety to contemplate cars without manual controls - and didn’t amend any of the other regulations that might have to be changed to eliminate manual controls. Which is why GM needed to get exemptions.
**Let’s see what the link I gave you says about this. ** 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 possible, to make clear that this rule maintains the level of crash protection currently provided occupants in more traditionally designed vehicles. This final rule is limited to the crashworthiness standards to provide a unified set of regulatory text applicable to vehicles with and without ADS functionality.
Also
In the proposal, NHTSA proposed to amend the existing FMVSSs in a way that maintains the occupant protection performance currently required by the 200-Series FMVSSs while amending the wording that has or will become obsolete as applied to new designs, and to clarify for manufacturers developing ADS-equipped vehicles the application of a particular FMVSS to their vehicle**. The NPRM also ensured these revisions accounted for dual-mode ADS-equipped vehicles (ADS-equipped vehicles that also have a conventional driving mode)**, as defined by SAE International (SAE).8 NHTSA also sought to remove requirements for which a safety need does not exist.
Also
The agency acknowledges that uncertainty continues to exist around the development and potential deployment of ADS-equipped vehicles. Nevertheless, NHTSA believes it is appropriate to finalize this action at this time in anticipation of emerging ADS vehicle designs that NHTSA has seen in prototype form.
and
NHTSA believes that children should not occupy the “driver’s” position when the· vehicle is operating in ADS mode and steering controls are present, given that the driver’s seating position has not been designed to protect children in a crash. For example, the required limit on the rearward displacement of the steering column and forcefulness with which the air bag deploys have been optimized for adults and could pose a safety risk to children. The NPRM proposed that ADS vehicles must suppress vehicle motion when: (1) the vehicle contains a driver’s seat (i.e., manually operated driving controls are available, but not necessarily functional during ADS operation)
Finally and if you read none of the rest this one makes it very clear.
Similarly, occupants seated behind driving controls in ADS-vehicles (dual-mode ADS vehicles) will be protected just as drivers are today. Second, NHTSA sought to amend its standards to account for new designs, and to clarify for manufacturers developing ADS-equipped vehicles, particularly those that lack manual controls, that the standards apply to their vehicles. In short, NHTSA sought to clarify that a manufacturer of ADS-equipped vehicles must continue to apply occupant protection standards to its vehicles even if manual steering controls are not installed in the vehicle.
So tell me again how the final regulations they put up, that I gave you a link to . Do not pertain to vehicles without a steering wheel.
You can twist this however you want but I strongly suspect that if the issue really was the absence of a steering wheel and brake pedal, the exemption would specifically request an exemption for the steering wheel and brake pedal.
Looking at the petition, the only requirement for which an exemption is requested that mentions steering wheel (none mention brake pedal by the way) is the one about self-cancelling turn signals (9.1.1).
“…turn signal operating unit…must be self-canceling by steering wheel rotation and capable of cancellation by a manually operated control.”
Interestingly, this issue came up before in a request from Google for clarification about this specific requirement in Googles planned self-driving System (SDS). Here is a link to the NHTSA response to the Google letter in its entirety, and I’ve copied one very relevant statement from this official response. Google -- compiled response to 12 Nov 15 interp request -- 4 Feb 16 final | NHTSA
“For purposes of these provisions of FMVSS No. 108, we interpret the SDS to be the “driver.” We also agree that the “operator” of a turn signal operating unit is the SDS, because NHTSA has typically used “driver” and “operator” interchangeably in its interpretations over time. We further agree that a steering wheel is not expressly required by any FMVSS.…”
To sum up, the NHTSA does not require a steering wheel and the fact that no exemption was asked for the absence of a brake pedal strongly suggests that this is also not required in an autonomous vehicle. The GM-Origin issue is about whether there is a “self-cancellation” mechanism for the turn signal and whether the requirement for a “manually operated control” can be satisfied by the self-driving entity.
The point is there is no specific rule that requires a steering wheel. But there are rules that require things that accompany steering wheels. Hence the request for exemption for things that accompany steering wheels.
Which either become irrelevant in the absence of steering wheels or have to be adequately adapted to a no steering wheel design. That is what the NHTSA has to assess. But what the NHTSA has already decided is that a steering wheel is not a requirement for a self-driving vehicle. Tesla or any other company can produce a vehicle without a steering wheel and it is not automatically disqualified as has been suggested.
Tesla can’t produce a vehicle without a steering wheel and comply with the federal regulations. That’s the point. We know from GM’s petition that there are three FMVSS requirements that can’t be met in a car without a steering wheel. We know from the fact of their petition that NHTSA was not willing to just say “well, those are irrelevant.”
NHTSA went through the regulations in 2022 and changed them to make sure that the occupant safety provisions would be just as effective in the event that cars were made without manual controls. But they didn’t change all the regulations that can’t be satisfied without manual controls. And apparently they’re not willing to tell automakers that those regulations are just “irrelevant” if their car doesn’t have manual controls, and instead will make them come in and ask for an exemption.
Which makes Tesla’s plan to move forward with a robotaxi in the near term very interesting - and confusing, if that vehicle is going to be designed without manual controls.
That is completely incorrect. I think you are purposely being argumentative. It is like arguing that a humanoid robot doesn’t have hands and then when you are asked if a humanoid robot has to have hands you say no.
It’s very simple, the addendum was written specifically for vehicles that do not have a steering wheel. Your argument that a car has to have a steering wheel because it has to have blinkers is both dense and completely fabricated. Blinkers have nothing to do with a steering wheel. Now that the truth has been pulled out of the addendum and boldly outlined it makes it pretty clear that you are only argumentative and are not doing this to make things more clear for everyone to understand. I want to thank you for helping me to understand that.
Again, you completely misunderstand the addendum you keep citing. The addendum does not say that a car doesn’t need to have a steering wheel. What NHTSA did is go through the regs and amend some of them relating to passenger safety so that those regulations no longer defined the safety requirements by reference to manual controls like a steering wheel. They didn’t go through the regulations and take out everything else that might require a steering wheel. Which means that the regulations still can’t be complied with if you don’t have a steering wheel - hence GM having to ask for permission to not have a steering wheel in the car.
I’m not being purposely argumentative. I have a lot of experience with agencies implementing regulations, and unless they are expressly given the power to waive regulatory requirements you have to comply with them. Even if they’re stupid. Even if you think that they intended to get rid of anything that required a steering wheel but just missed something that’s now still on the books. If the regulations say that the turn signals have to be designed so that they deactivate when the steering wheel is rotated, then you’re going to have to have a steering wheel to do that.
That’s not the argument. The NHTSA regulations require that blinkers have to turn off automatically if the steering wheel is rotated. So under the regulations, there is a connection between blinkers and the steering wheel. Because the blinkers have to be able to deactivate with steering wheel rotation, a steering wheel must be present in order to satisfy that regulation.
Is that a “dense” interpretation of the regulation? It doesn’t matter - because that’s clearly the interpretation that NHTSA has landed on. Else GM wouldn’t have filed for the exemption - because NHTSA would have told them they didn’t need a steering wheel under the addendum back when they filed.
Just to clarify, YOU are saying: “Tesla can’t produce a vehicle without a steering wheel and comply with the federal regulations.”
The NHTSA is saying: " We further agree that a steering wheel is not expressly required by any FMVSS."
You are not the NHTSA.
Now you are moving the goal posts. The existing NHTSA requirements include some “manual controls” that need further clarification. Neither steering wheels or break pedals are part of this group. The first is based on a direct statement from the NHTSA, the second is implied by the absence of an exemption request.
I absolutely am not the NHTSA. You’re absolutely right that it’s their interpretation of the situation that matters.
But we have a pretty clear indication of what their interpretation is, because GM filed a request for an exemption from these requirements. NHTSA didn’t tell GM that they didn’t need an exemption to exclude the steering wheel. Even though they’ve said that a steering wheel is not expressly required by a FMVSS, there are at least three FMVSS that implicitly assume the existence of a steering wheel. If NHTSA had interpreted those standards the way you and BAHID are suggesting, they would have told GM that no exemption was necessary and GM wouldn’t have included requests for those exemptions in the petition.
But they did. The requests for the exemptions are in there. Which means that someone from NHTSA told GM that it was necessary to have those exemptions. That simply because you don’t have a steering wheel or gear shifts doesn’t mean you can ignore the standards that refer to those things. That while the regulations don’t explicitly require these things, they implicitly do in a way that a vehicle that lacks a steering wheel does not comply with that specific standard.
It’s entirely possible that they just missed it.^^ That their intent was to revise the safety standards so that steering wheels were no longer necessary. But from a career in dealing with regulatory agencies, I can tell you that if the regulation is still there, you have to comply with it - or comply with the process for requesting relief from the regulation. The agency generally won’t just ignore it or declare it a mistake that it didn’t get amended. Why is why the NHTSA’s decision makes sense - if they nor the many commenters to the 2022 rule change missed a handful of provisions, the required response under the APA is to undertake rule-making again as a glitch process - not for NHTSA to ignore the plain language of the regulations.
^^There are other possibilities, of course, but this is the one that’s most favorable to companies that want to make cars sans steering wheels.
The spirit of this discussion is intense and meaningful. I appreciate the zeal in representing from all parties and their collective “search for truth” uncomfortable as it may be.
Nope, that’s your spin. The NHTSA has explicitly stated that there is no requirement for a steering wheel in a self-driving car. However, there are mechanical safety devices that have been traditionally associated with steering wheels that are still required. An example would be the self-cancelling turn signal.
In other words, the NHTSA is saying that while you don’t need a steering wheel, you still need a turn signal that automatically shuts off after the turn is made. This is about the turn signal, not the steering wheel. This is why GM asked for the exemption specifically about the turn signal. The NHTSA was in the process of determining whether what GM did with the turn signal was an acceptable alternative.
To put it another way. If GM had built the Origin with a steering wheel but still without a self-cancelling turn signal, GM would still have had to apply for the same exemption from the NHTSA. This demonstrates that the presence/absence of the steering wheel is irrelevant. This exemption is solely about the self-cancelling turn signal.
This is all made clear in the interaction between Google and the NHTSA linked above. Google asked and asserted the following:
Google further asks that NHTSA “expressly acknowledg[e]” that a steering wheel is not required by the FMVSS. The supplemental information Google provided on January 11, 2016 stated that the SDV’s turn signal operating unit self-cancels based on the position of the steering rack (which is controlled by the SDS), “which is what happens in a conventional vehicle by virtue of the link between the steering rack, steering column, and steering wheel,” and that Google therefore believes that the SDV complies with S9.1.1.
This is the direct response from the NHTSA:
We further agree that a steering wheel is not expressly required by any FMVSS. We agree with Google that, as described, the SDV appears to be designed to self-cancel the turn signal operating unit as NHTSA would have intended, had vehicles without steering wheels been available when FMVSS No. 108 was developed.
Couldn’t be clearer that the NHTSA isn’t concerned about the absence of the steering wheel. It just wanted a turn signal that self-cancelled after the turn. QED
Steering wheels aside, will you at least admit that you have no evidence that a brake pedal is required by the NHTSA in a self-driving car?
No, they’re not. If they were, GM wouldn’t need to ask for an exemption from the rule. The rule says that the turn signal has to be deactivated by the rotation of the steering wheel, not after the turn was made. NHTSA could have interpreted it the way you are suggesting - but if they did, GM wouldn’t have had to request an exemption from the rule. They would have just satisfied the rule.
Oh, sure. I knew that Origin wasn’t able to build their car without getting an exemption approval from the NHTSA because they had stripped out the manual driver controls, but I misremembered which ones specifically. It wasn’t the steering wheel and brake pedal, it was the steering wheel and gear shift. My mistake.
## Musk Has a Vision for Tesla’s Robotaxi. Others Can’t See It.
Carmaker plans to show off its automated vehicle this summer, but tech and regulatory hurdles remain before it can become reality
[Tesla] Chief Executive [Elon Musk] has made clear that he is making robotaxis a centerpiece of his long-term strategy. The hard part will come next.
This summer Tesla plans to show a future model—which is expected to have [no steering wheel and pedals]—that the automaker can deploy in its own, [Uber]-like ride-hailing service. Musk last week floated the idea of allowing owners to rent out their robotic Teslas, comparing it to Airbnb.
The strategy amounts to a sizable bet on a yet-to-be-built car underpinned by technology that [remains under development]. A combination of regulatory ambiguity and technology hurdles make widespread deployment of driverless taxis any time soon a long shot, analysts say.
“Robotaxis are likely years away from mass-market adoption,” said RBC Capital analyst Tom Narayan
The article is gifted, if I’ve done it correctly.
For Albaby’s argument
Today, a complicated, evolving patchwork of rules govern autonomous vehicles. Musk’s plan to deploy self-driving cars on public roads is expected to set up a face-off with federal regulators, which already are looking into the automaker’s advanced driver-assistance technology and how it has been rolled out to customers.
Congress has yet to pass a law that would create rules for deployment of autonomous vehicles. That void has left developers to shoehorn their plans into existing motor-safety laws and subjected them to a jumble of state and local rules.
Autonomous-vehicle companies have tried to get a federal nod to put driverless cars on the road and faced setbacks. [General Motors] Cruise division for years tried unsuccessfully to get special approval to deploy vehicles without a steering wheel or other manual controls.
The first sentence here says “Few would dispute…” OK, I guess I’m one of the few because I certainly do. By 2030? No way.
Few dispute the growth potential for robotaxis deployed on a broad scale. In 2019, [UBS] pegged the potential revenue opportunity for robotic cars that can be beckoned like an Uber or cab at $2 trillion globally by 2030, far exceeding that of the entire U.S. auto market.
Frankly I’d be surprised if it’s more than a significant fraction of that.