Earlier this year, before all the fire drama, Tesla wrote to NHTSA in support of a decision on backup cameras saying that cameras were a “vital building block for additional crash avoidance technologies.”

In the response Tesla took the opportunity to highlight not only why rearview cameras should be mandatory, but also why cameras writ large should replace all mirrors.

1 – In reverse cameras allow you to see behind the car

This is pretty straightforward and nothing worth discussing.

2 – Mirrors are to blame for dangerous blind spots

Tesla says that mirrors have physical limits in how much they can show the driver and that when a driver looks into his blind spot it “takes approximately 1.8 seconds which allows a vehicle traveling at 65 miles per hour to travel 171 feet, during which time the driver’s attention is completely misdirected from what is happening in front of him.”


If your first inclination is ‘adjust your mirrors properly’ I agree with you, but even then some modern designs are just prone to blind spots.

The second option, blind spot detection. While a helpful technology, can still be dangerous.

In reading over a briefing given to NHTSA in 2009 by Ford one of the biggest dangers discussed with blind spot detection was a reliance by consumers on the system. People would assume that no indicator meant they were in the clear and merge over without visually confirming in the mirrors let alone turning around.


Tesla’s argument is that you need to take the widest field of view possible and place it into the car so that people can see what is behind/beside them without ever having to look away from the road ahead of them.

3 – Exiting your vehicle is dangerous.

In the letter Tesla explains that because you aren’t looking at your mirrors when you step out of your vehicle that it can be dangerous. They say they would develop a system that would “ensure door exit is only achievable when the road is clear and egress may be done safely.”


Basically if the car thought you were in danger of being hurt, it would lock you inside until all is clear. They did state that such a system would come with an emergency override for cases where your car thinks the meter next to it was a death-dealing cyclist.

4 – Camera lens is more advanced than the human eyeball

Humans can’t see in the dark and are unable to filter blinding glare. For these reasons Tesla say cameras are a better than human eyeballs.


I tend to agree with the automaker here.If I can switch my rear view camera screen to night vision, why isn’t that better than me trying to see through a tinted back window at night with crappy eyes?

5. Mirrors are ears of inefficiency

The easier a car can move through the air the less power (read fuel) it requires. Tesla says being allowed to remove the side view mirrors of a car can reduce drag "between 0.021 to 0.037 CDA" and save fuel.


I emailed Tesla’s regulatory guru, Jim Chen, to see if the automaker had or intended to petition for a waiver from the Federal Motors Vehicle Safety Standard, but this was the same day NHTSA announced they were looking at Tesla's vehicle fires and Tesla announced they asked NHTSA to look at their vehicle fires.

What does all this mean for the future?

Tesla makes valid points in their observations, but I assume any change or consideration to allow cameras to replace mirrors would come with a long rulemaking period and countless studies.


At the very core of the issue is Field of View (FOV).

The standard requires drivers be provided various unobstructed and specified fields of view. If a camera could perform this task better than a mirror then why not let automakers use cameras?

Simple, because the standard says mirrors, not cameras. Even if cameras are better at showing drivers a clear FOV the regulatory system likely wouldn’t a large decision to be made without significant consideration (i.e. long drawn out studies and congressional involvement).


Secondly, you need to consider the human interface factors. How would drivers adapt to a vehicle with no mirrors?

While it still remains unclear if Tesla will formally ask to go sans-mirror should they build the Model X as intended. If they do petition NHTSA and in some twist of fate NHTSA, likely still pissed at the automaker for their 5.4 Star Rating and other media statements, decides to grant their petition, it could mean that we start to rethink not only the mirrors but the rear glass and other components of the vehicle that are impacted by the requirement for a FOV.

Slideshare of PDF for easier viewing: