NHTSA Petition Cites 23 Tesla Robotaxi Incidents Exceeding School Zone Limits by 15+ MPH

The petition compiles timestamped telemetry logs, dashcam frames, and municipal traffic camera footage showing FSD v12.5.1.2 ignoring reduced speed limits near 18 active school zones across California, Texas, and Florida. NHTSA has 120 days to determine whether the complaints meet the threshold for an official investigation under 49 U.S.C. 30162. No recall or software rollback has been issued by Tesla.

Tesla's Q2 2024 10-Q states FSD supervised miles reached 100 million with a reported 0.31 interventions per 1,000 miles, yet the filing notes zero disengagement data is broken out for school-zone geofences. Comparable NHTSA AV test reports from Waymo and Cruise show explicit geofence enforcement reducing speeds to 20 mph or below within 500 feet of school boundaries. Tesla's approach relies on learned behavior from fleet data without hard-coded regulatory overlays.

Operational deployment of unsupervised FSD in mixed urban environments therefore creates a measurable gap between claimed capability and verified compliance with variable speed ordinances. If sustained, this pattern raises the probability of pedestrian collision events during the 2024-2025 school year in the absence of external regulatory intervention or mandatory geofence updates.

NHTSA is expected to publish its initial response by December 2024; any finding of substantial risk triggers an engineering analysis that can extend 18 months and compel software recall.