NHTSA complaint #11620561

Owner complaint summary

I see in today's news that the NHTSA is investigating Tesla's FSD due to accidents in poor visibility, but the articles I've read are not discussing another visibility issue that may actually be more widespread. I already reported concerns with Telsa's FSD in incident 11618812, but I forgot to mention another issue I believe is crucial to the success or failure of Tesla's FSD, and I am surprised to find that nobody is talking about this serious flaw. Because Tesla's FSD relies on camera video only, the vehicle is blind in the dark. I live in a rural area, and on some roads without streetlights or other vehicles nearby illuminating the areas around the vehicle, Tesla's FSD falsely assumes that the side and rear facing cameras are obstructed because they cannot see in the dark. This was also an issue when my son and I drove home through the night from South Carolina. When we hit North Carolina on [XXX] in the middle of the night between cities and no streetlights, traffic was sparse so there was nobody behind or to the sides of the vehicle. Every few minutes, FSD falsely warned us that the cameras were obstructed, and alerted us that FSD's capabilities were limited. One point of view is that there was nobody there so my car was clear, and FSD could assume that everything is okay and suppress the warning, but what if the driver of the other vehicle at night failed to have their lights on? And how will FSD ever know that the camera is obstructed, or is in pitch dark? Take an average of the low light across multiple cameras? Is that risky? In my opinion, Tesla's FSD cannot rely on video alone and either needs to use LIDAR, night vision, or 3D radar to see more accurately around the vehicle in poor visibility conditions. The answer to low light, bright low sun, fog, or dust is probably the same solution. But we were all promised FSD, so will Musk upgrade the hardware in our cars at Tesla's expense, or expect all of us to pay for the upgrade to get what we were all promised? INFORMATION REDACTED PURSUANT TO THE FREEDOM OF INFORMATION ACT (FOIA), 5 U.S.C. 552(B)(6)