Will the NHTSA Force a Tesla Recall? Analyzing the FSD Degradation Detection Filing
I’ll get to the headline takeaways from the recent results in due course, but I felt some cyberink should be spilled on a relatively obscure but crucial subject matter. It relates to an engineering analysis underway at the National Highway Traffic Safety Administration (NHTSA) into Tesla. It may not sound like much, but it’s a potentially serious affair, not least as an engineering analysis is the last step before a recall is ordered. Interestingly, Tesla’s management addressed the issue in the very last question on the first-quarter earnings call.
NHTSA Engineering Analysis EA26002
Opened on March 18, the Office of Defects Investigation (ODI) is evaluating “Tesla’s Full Self Driving Beta and Full Self Driving (Supervised) (collectively, FSD) degradation detection system.”
The degradation detection system’s purpose is to warn the driver that Tesla’s full self-driving (FSD) has degraded visibility due to glare from the sun or other limited-visibility conditions. According to NHTSA, the ODI reviewed Tesla crashes in which “the system did not detect common roadway conditions that impaired camera visibility and/or provide alerts when camera performance had deteriorated until immediately before the crash occurred.”
Tesla did make an upgrade to the system after a fatal crash in 2023, but the ODI is concerned that the system, “both as originally deployed and later updated,” fails to appropriately detect degraded visibility conditions.
What Tesla's management said
The subject matter came up on the earnings call with an analyst asking about NHTSA filings on the matter. Tesla’s vice president of vehicle engineering, Lars Moravy, said, “We did change the cameras some months ago,” and “the NHTSA is referring to like older vehicles.”
New measures implemented
Management also claimed it had ‘implemented stricter measures for the visibility of the camera,” meaning that FSD won’t be available for cars that can’t see clearly. Interestingly, the main issue appears to be a residual buildup of volatile organic compounds (VOCs) on the camera’s lens rather than its ability to see in a sun-glare environment without VOC buildup.