
Tesla received a cease-and-desist letter from NHTSA over Model 3 safety claims - pseudolus
https://www.cnbc.com/2019/08/07/tesla-scrutinized-by-the-nhsta-over-model-3-safety-claims.html
======
srfilipek
Tesla's page in question is quite clear about their methodology, and I can't
really see the fault in it:

> The Vehicle Safety Score represents the “relative risk of injury with
> respect to a baseline of 15%,” according to NHTSA. Model 3 achieved a
> Vehicle Safety Score of 0.38, which is lower than any other vehicle rated in
> NHTSA’s public documents.

How can the NHTSA create a safety score regarding risk of injury, and then say
that you can't use it to make a statement about the risk of injury?

~~~
SiempreViernes
AS explained by others, the NHTSA ratings are for one type of collision and
valid _within_ a weight class.

The methodology simply doesn't provide the data for making the type of global
claims that Tesla make.

~~~
Hypx
It also ignores the way a car is being used. Sports cars are consistently more
dangerous than say, minivans. This is true even if the minivan is poorly rated
and the sports car is top-of-class in its safety rating.

~~~
windexh8er
Source?

A minivan has a higher center of gravity so in an example where a minivan is
cornering aggressively, say to avoid a collision, the rollover likelihood is
higher than that of a sports car. As I understand it safety ratings are
generally after occupancy protection and aren't concerned with the class of
vehicle which goes against what you've claimed.

From the NHTSA website [0]:

"Can I compare vehicles from different classes?

Side crash rating results can be compared across all classes because all
vehicles are hit with the same force by the same moving barrier or pole.

Rollover ratings can also be compared across all classes. Frontal crash rating
results can only be compared to other vehicles in the same class and whose
weight is plus or minus 250 pounds of the vehicle being rated. This is because
a frontal crash rating into a fixed barrier represents a crash between two
vehicles of the same weight."

And again they are, generally, looking for impact to occupant, for example for
the "Side Pole Crash Test Scenario" under "Test Details" they are looking at
"Evaluation of injury to the head, chest, lower spine, abdomen, pelvis".

Just because a sports car is a different class of vehicle does not make it
inherently less safe. The driver input can change that for any class of
vehicle.

[0] [https://www.nhtsa.gov/ratings](https://www.nhtsa.gov/ratings)

~~~
dragontamer
> Source?

A minivan weighs over 4500 lbs, while a sports car probably weighs 3000 lbs.
In most collision situations, the heavier car is safer.

Frontal collision tests (and frontal overlap tests) are against stationary
objects. So a minivan is tested with 4500+lbs of weight, while a sports car is
only tested with 3000 lbs of weight.

Some tests are weight dependent. Others have a static weight.

\-----------

I know some friends who survived getting hit by a bus. Riding in a 5000lb+
vehicle helps in these situations. There is a huge degree of safety that is
afforded by just having a heavier vehicle.

~~~
windexh8er
While that's a great anecdote it's not a source. We could counter your
argument by saying that the power to weight ratio of large vehicle is less
than that of sports cars. Also because of softer suspensions not tuned for
aggressive handling makes for vehicles that get into more crashes due to
characteristics that make them worse with regard to stopping before a crash,
unable to accelerate out of a compromising situation, or at at odds with a
much higher likelihood of rollover due to aggressive maneuvering.

As an aside I have lots of friends who own fast cars who haven't gotten into
accidents by avoiding them. Thankfully they were driving lighter vehicles.

I won't berate survivorship bias here.

~~~
lm28469
> As an aside I have lots of friends who own fast cars who haven't gotten into
> accidents by avoiding them.

As in driving aggressively and avoiding accidents they were about to create ?
Statistically most accidents are rear ends and side collisions, both of which
you most likely won't see coming with enough time to react let alone move your
car. And getting plowed by an SUV when you're sitting in a sport car means
your head is on the absolute worst position you could think of.

Bikers say the same "I'm small, agile and fast, no accidents for me", yet
they're disproportionally represented in crash stats.

~~~
windexh8er
You're example assumes everyone is the victim. Except that all side collisions
and rear ends could be avoided by the stiking vehicle stopping _faster_. Which
vehicles are statistically more often found as being the striking vehicle?
It's likely that larger vehicles which can't stop quickly are. And in your
example you use an SUV as the plowing vehicle, probably because it's mostly
assumed you'll be hit by that type of vehicle, partially for the reasons I
just stated.

Again, with the biker statement, since you'll never find a data set that would
show accidents avoided on the particular vehicle there's a huge swath of
underrepresentation of the reality. And one can argue proportionally bikers
are in more crashes because there are less of them overall on top of the fact
that most drivers of cars and trucks do not pay considerate attention to
smaller vehicles.

And finally my comment about the "friends with fast cars" was a tongue in
cheek response to the fact that the parent I was replying to made a large jump
by saying SUVs are safer because of size and weight.

~~~
dragontamer
> Except that all side collisions and rear ends could be avoided by the
> stiking vehicle stopping faster

Or you know, not being on distracted autopilot:
[https://www.theguardian.com/technology/2016/jul/01/tesla-
dri...](https://www.theguardian.com/technology/2016/jul/01/tesla-driver-
killed-autopilot-self-driving-car-harry-potter)

People get distracted, and when they're distracted they'll crash into things.

~~~
windexh8er
Are you implying distracted driving is unique to only Tesla vehicles? The link
you posted implies that, and then you immediately generalize your argument.

~~~
dragontamer
I intend to argue in the general sense. People will, in general, be distracted
while driving. One protection is to simply be in a heavier vehicle so that you
can survive more collisions when you're in a distracted state.

An alternative solution is "don't be distracted", but that doesn't seem to
work in practice.

------
shakna
More detail can be found at the article's source [0].

\---

> The documents, obtained through a Freedom of Information Act request, also
> include orders for information that NHTSA sent to Tesla following several
> crashes, including a fatal March 1 crash involving a Model 3 operating on
> Autopilot. Tesla shares fell 0.5% in New York pre-market trading to $229.51.

NHTSA seem rather unkeen for Tesla to say the good without the bad, and are
more than happy to try and prove that the marketing fluff Tesla has forwarded
isn't a complete enough story for the public to make a decision.

\---

[0] [https://www.bloomberg.com/news/articles/2019-08-07/tesla-
dra...](https://www.bloomberg.com/news/articles/2019-08-07/tesla-draws-u-s-
regulatory-blowback-over-model-3-safety-claims)

------
RichardHeart
Tesla's are quite heavy as far as sedans go. I think that enhances their
safety in car v car crashes. The average car weighs 2,871 lb. | The average
sedan weights 3,351 lb.| SUV avg: 4,437lb | Truck: 4,710lb | 18 wheeler:
15,000 "tare weight" (empty) | 18 wheeler loaded: 80,000lb | School bus:
23,500-29,500lb

Notice the teslas avg weigh more than everything but the semi's. 3:
3,552lb-4072lb | 60D 5,072 lb (2,300 kg) | 70D 5,072 lb (2,300 kg) | 75D 5,140
lb (2,330 kg) | 90D 5,271 lb (2,390 kg) | P90D 5,381 lb (2,440 kg) | 100D
5,421 lb (2,459 kg) | P100D 5,531 lb (2,509 kg)

------
FireBeyond
Tesla seems to be able to bring out the conspiracy theorists. So far, here,
there are claims that "Big Auto" "told" the NHTSA to come after Tesla, that
NHTSA doesn't have enough Tesla ex-employees, etc., and several that
studiously ignore the whole concept of a weight class and bemoan the NHTSA for
"bad tests".

------
bambax
> _Model 3 has the lowest probability of injury of all cars the safety agency
> has ever tested._

Sounds like something Trump would say.

~~~
Hypx
It's too bad this is being downvoted. It is exactly something Trump would say
in a similar situation.

~~~
zaroth
Read the actual blog post in question from Tesla, complete with the context,
technical background and discussion, graphics, and supporting data. [1]

Pretty much anyone can be made to sound like anything when you take a sound
bite.

I’ll take this blog post from Tesla over, for example, the Ford commercial
showing their concept electric truck pulling a train, any day.

[1] - [https://www.tesla.com/blog/model-3-lowest-probability-
injury...](https://www.tesla.com/blog/model-3-lowest-probability-injury-any-
vehicle-ever-tested-nhtsa?redirect=no)

~~~
navigatesol
> _I’ll take this blog post from Tesla over, for example, the Ford commercial
> showing their concept electric truck pulling a train, any day._

Sounds like you have some pretty serious bias. Meanwhile, Tesla claims their
non-existent truck concept can pull 300,000lbs. Has Ford ever claimed
something similar?

~~~
jowsie
Ford literally claimed their truck can pull over 1 million lbs.

[https://www.youtube.com/watch?v=Au3U72CX74I](https://www.youtube.com/watch?v=Au3U72CX74I)

~~~
vonmoltke
Which it did: [https://www.roadandtrack.com/new-cars/a28506476/ford-
electri...](https://www.roadandtrack.com/new-cars/a28506476/ford-
electric-f150-train-tow-physics-explained/)

It just isn't as big an accomplishment as it looks, since it was on a railway.

~~~
zaroth
Both Tesla and Ford make a factual claim that has important caveats.

Tesla Model 3 _does_ have the lowest weighted probability of an injury of any
car ever tested by NHTSA. The Ford prototype _did_ pull 1 million pounds of
railway cars.

In the case of Tesla, it’s important to understand the limits and intent of
the test and that it’s the lowest probability of injury _when crashing into
certain types of stationary objects or cars of roughly the same mass_. That’s
an important caveat but the Tesla did score much better than any other car
ever has, and I think it’s fair to brag about that.

In the case of the Ford, it turns out any vehicle that can pull with ~2,000
lbs of force could do the same thing. To me, that makes the demo basically a
gimmick and “misleading” to the general public.

By comparison, the world record holder for pulling a train with his _teeth_
pulled over 575,000 pounds. Ok, now that’s impressive! [1]

[1] - [https://youtu.be/CTeb19ICMD4](https://youtu.be/CTeb19ICMD4)

------
LanceH
My first take on this is that Tesla hasn't placed enough former employees at
NHTSA yet.

------
pankajdoharey
If the car has the highest rating of safety ever isnt it obvious that this is
the safest car they "ever tested"?

~~~
kalleboo
If you read the NHTSA letter they go into detail that their crash testing is
done against fixed barriers, which means that it doesn't say anything about
the safety of a lighter vehicle crashing into a heavier one. In a crash
between a big heavy SUV and a Model 3, you can be better off in the SUV even
if it has a worse crash rating.

NHTSA describes that they have a specific guidelines document (which has a
rule about comparing vehicles 250 lbs apart in weight) which Tesla apparently
hasn't followed, so they're not making up rules selectively against Tesla.

~~~
madamelic
>If you read the NHTSA letter they go into detail that their crash testing is
done against fixed barriers, which means that it doesn't say anything about
the safety of a lighter vehicle crashing into a heavier one. In a crash
between a big heavy SUV and a Model 3, you may be better off in the SUV even
if it has a "worse" crash rating.

All I am reading is that the NHTSA has bad tests?

If they are so mad Tesla is saying "We have the best crash test rating of any
car", why not change the test to include those issues?

If someone was mad that I said "My code passes all of the tests", but there
were still bugs in the code, the issue isn't my statement. The issue is that
there is incomplete coverage.

~~~
kalleboo
They have incomplete tests, since crash testing is really expensive.

But they are upfront in their guidelines about what exactly their tests do and
do not say. Their tests are good for comparing cars in the same weight class.
They are not good for saying what is the world's safest car.

~~~
madamelic
If the NHTSA doesn't want their stats in marketing, why not figure out how to
make them completely worthless.

Stars is way too marketable and deceptive to begin with. Make it Pass / Fail.
4 stars to actually failing is "fail". 5 stars is "pass". Actually failing
being a rejection of approval and such a car wouldn't get a rating.

"Our car passes all necessary safety tests" ... good?

~~~
makomk
The NHTSA stars are adequate for their intended purpose - showing how well a
car holds up in a crash compared to equivalent cars from other manufacturers.
You just can't use them to make any conclusion about the overall risk of
injury (which depends on the likelihood of a crash happening in the first
place), can't compare them between cars of different weight classes, and can't
draw meaningful conclusions about the relative safety of different five-star
rated cars. Tesla did all three.

The last one might need a little elaboration. The NHTSA battery of tests is
relatively small and limited. The lower the risk of injury in those tests is,
the more dependent the actual real-world risk becomes on all the scenarios
they didn't test. This isn't a hypothetical problem. The Model S also got the
best score ever in the NHTSA tests and Tesla did a similar press release about
that, but it didn't get the IIHS's highest rating because it performed badly
in small-overlap collisions which weren't part of the NHTSA tests.

------
neo4sure
Well NHTSA’s trying not to offend Big Auto. Once Administration changes the
safety goals should be set at a higher bar. Only one car company can meet
them.

------
Theodores
There is no such thing as bad publicity and here Tesla are back in the news
again. Funny they don't have an advertising budget and here we are learning
the lesson that Tesla safety is a cut above the rest even if the marketing
claims are slightly off.

I am suspect of the safety of all cars that don't have rally/track style roll
cages and four point harnesses (with fire extinguisher in easy reach). But I
would go in a Tesla.

~~~
Zenbit_UX
You really feel you need that for typical car uses or were you joking? I can't
see why I'd need a roll cage to do groceries - christ, I drive a motorcycle as
my sole vehicle so I think we're on opposite ends of the risk spectrum.

~~~
Theodores
I ride a bicycle. I don't go on motorways with it though.

We have all seen the crash test videos, we have all been driving at twice the
speeds in those crash test videos. We have all stepped it on a little bit more
to be travelling past the speed limit.

We have all 'rubber necked' at some ghastly accident on the other carriageway
and wondered how so much carnage can happen on a perfectly straight road. A
million people get killed on the roads globally every year.

On a motor racing event the medics and fire crew are minutes away, ready.
There is no on-coming traffic. There are no people drunk or partially sighted
on the road. The barriers and run-off areas have been tested. Helmets are
mandatory. The road ahead is the same circuit it was two minutes ago, last
time it was lapped. Features in the circuit are there to restrict top speed -
chicanes etc.

Meanwhile, on the autobahn you can do the same speeds. Or, elsewhere you can
find an overtaking car in your carriageway doing 70+ mph, combine that with
your 'safe' 50 mph and imagine how that head on crash compares to the test
videos that are at a fraction of the speed. Imagine how well your brain copes
smashing into your skull in the impact. Just because everyone is driving along
in all weather conditions tailgating the guy in front every day does not make
it wonderfully safe. So yes I am serious about the need for a roll cage or a
Tesla.

~~~
bb123
Cars have roll cages built into the frame of the vehicle. Thats why they don't
crumple under their own weight if they roll. I don't know what kind of Mad Max
world you're driving in but an external roll cage and a 4 point harness (as
opposed to the 3 point harness already fitted in literally every car) seems
like complete overkill for most use cases. Also motorway driving is generally
the safest kind of driving, so while your story is certainly evocative I don't
think it really justifies your claim that every car should have two roll
cages. We don't put cow plows on most cars either, by your logic we probably
should.

------
lazyjones
So, basically NHTSA is threatening Tesla because NHTSA believe their own crash
tests aren't good enough to base claims about risk of injury on? As in, "5
stars" means "5 stars" and not "low risk of injury"...

~~~
zelon88
No, you just don't understand the star system.

Stars are how well the car contains the passengers during an accident in a
variety of situations. 5 stars does not mean "low risk of injury" at all.
Infact, a 1 star Sterling box truck will probably cut a Tesla with a 5 star
rating in half. Guess who's walking away almost 100% of the time?

The star rating is more a rating of how well the car holds together,
prioritizes it's occupants, and the effectiveness of it's safety features.
They mostly don't consider factors such as the mass of the vehicles involved
or other important factors that become non-arbitrary as soon as you enter the
real world.

~~~
lazyjones
> _Infact, a 1 star Sterling box truck will probably cut a Tesla with a 5 star
> rating in half. Guess who 's walking away almost 100% of the time?_

So what is the average risk of injury in all of the following situations for
each of these vehicles (Sterling box truck, Tesla Model 3)?

\- 50 mph against a thick wall

\- 50 mph against a Sterling box truck

\- 50 mph against a random car

\- 50 mph into a dense forest

\- 50 mph falling off a 50 foot ledge

And what's the average risk of getting into these situations, for weighting?

My point is that a Sterling box truck might crush a Tesla Model 3, but the
vehicle's own mass isn't always helping and with no airbags and crumple zones
the risk of injury is still higher in many common situations. So let's not
overrate one particular situation vs a large truck.

~~~
zelon88
And my point is that, statistically, if you want the lowest risk of injury in
the real world you'll buy the one star box truck because you'll have triple
the mass of 90% of the vehicles that could possibly hit you.

Everybody buys 5 star cars. So there's an abundance of them. When a Chevy
Spark crashes into a Toyota Corolla it's a good representation of what crash
tests simulate. Sure they could make every car crash into a semi truck and
give them a rating but none of the dummies would survive. None of them. Even
the mighty Tesla. But trucker Bob goes home to his family at the end of every
shift.

They would be grading flaming chunks of steel and plastic all day. That's why
I drive an SUV. Because I'm broke and can't afford a new "safe" car, but in
all liklihood I'm bigger than the median vehicle size so that gives me
comfort.

~~~
lazyjones
> _And my point is that, statistically, if you want the lowest risk of injury
> in the real world you 'll buy the one star box truck because you'll have
> triple the mass of 90% of the vehicles that could possibly hit you._

Not all crashes involve other vehicles, you have to take into account the
frequency of crashes vs. the environment.

