Either Tesla:
(1) Call it a 'driver assist system' and carry that definition beyond all reasonable bounds. I've read the regulation, I don't think that defense would stand up in court.
(2) Does physical testing somewhere other than California. The testing regulation is fairly onerous, and I could see them saying 'nah' we'll do this in Arizona, Nevada, etc.
You're right they don't report disengagements, but they still maintain a autonomous test vehicle permit in the state, according to the DMV website. Very strange indeed. I think (2) is probably right.
For Reporting Year 2018, Tesla did not test any vehicles on public roads in California in autonomous mode or operate any autonomous vehicles, as defined by California law. As such, the Company did not experience any autonomous mode disengagements as part of the Autonomous Vehicle Tester Program in California.
You're right they don't report disengagements, but they still maintain a autonomous test vehicle permit in the state, according to the DMV website. Very strange indeed. I think (2) is probably right.