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Tuesday, September 26, 2023 7:22:05 AM
U.S. DOT March 21, 2023
Motor Vehicle Defect Petition to recall all Tesla cars produced from 20l3 to the present, due to a missing critical interlock feature and specific Autopilot features that contribute to increased likelihood of driver errors in the form of Pedal Misapplication
If pedal misapplications are not brand- or model-specific and they happen randomly across
all brands of cars, then why do we not hear of everyday SUA crashes of other brands, not
equipped with the protective Autopilot software, in quantities and frequencies statistically
compatible with the estimation of 40 mistakes per day among drivers of only one brand of
cars?
If these mistakes are indeed brand-specific, then why are there 40 Tesla drivers every day
that make a serious mistake that does not happen to drivers of other brands of electric or ICE
cars? Is there a specific demographic or other reason that makes Tesla drivers different than
the drivers of other brands, or is there some design factor of the car behind this obvious
statistical anomaly?[
It is our opinion that we cannot implement fully autonomous driving in public roads unless we have a 100% reliable and double redundant system that can be absolutely trusted in every situation, like the autopilot on a modern commercial aircraft that can be trusted to guide and automatically land the plane on a properly equipped airport. Currently (in early 2023) the self-driving packages of commercial cars are not ready to operate in a safety level comparable to aviation standards and we should always keep in mind that a car should be safe to be operated by virtually anyone with the only qualification needed is just valid driver's license. Asking the driver to "keep his hands on the wheel, just in case" is ambiguous enough to cause similar issues like the ones leading to pedal misapplication accidents. Let's not forget that there have been a lot of aviation accidents due to errors and misunderstandings in the proper handover from autopilot to manual flying, noting that this involves highly trained professional pilots and absolutely reliable autopilot equipment, none of which is present in everyday commuting in a private car.
https://static.nhtsa.gov/complaints/11515119/11515119-0003.pdf
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