Otsus

From: Ivan Komusanac <[email protected]>
Date: Monday, 9 February 2026 at 14:44
To: Jürgo Vahtra <[email protected]>
Cc: Mart Linna <[email protected]>, Jaak Valter Lõhmuspuu <[email protected]>, Raul Rom <[email protected]>, Mihhail Kotov <[email protected]>, Sofia Bennerstål Andersson <[email protected]>, Stefano Mottarelli <[email protected]>, Sarunas Kondratas <[email protected]>
Subject: Re: Tesla - ADAS testing, Estonia

Kind regards,

Ivan Komusanac

EU Policy and Business Development Manager

Rue du Commerce 72,1040 Bruxelles
E. [email protected]    T. (+32) 492-72 80 42

Hei Ashley,

Thank you for the additional information.

For the registration of vehicles the both ways are acceptable for us.

If it is registered in other EU country, you should have a registration certificate and a document ( invoice/agreement/confirmation) that confirms the vehicle belongs to you.

If it is new vehicle, you should submit for registration the Certificate of Conformity and a document ( invoice/agreement/confirmation) that confirms the vehicle belongs to you.

Best regards

Jürgo Vahtra
Head of Technical Department of Vehicles

Transport Administration
+372 53268406 | [email protected]
Teelise 4 | 10196 Tallinn |Estonia

Hi Jurgo,

I wanted to follow-up on my earlier email.

We are keen to understand whether the below proposal to test our vehicles is acceptable and what the next steps are.

Look forward to connecting on this.

Ashley

Hi Jurgo,

Thank you for the information that testing will be possible. The general information about the system can be found here: https://www.youtube.com/watch?v=tJc-ZtO5b_E - I would like to note that in the US the FSD (supervised) system drives over the speed limit as it's common to speed, but in Estonia we would cap the system at 120 kmph. Please find attached also a slide deck that we are showing to policymakers and we can jump on a call next week if needed to clarify.

We would like to test the following situations on public roads (I would like to emphasize that Tesla's drivers will be extremely cautious to take over control immediately to avoid any incident.):

1. 1. Urban Traffic Navigation: Evaluate the FSD (supervised) system's ability to navigate complex urban environments, including roundabouts, signalized intersections, and pedestrian-heavy areas, focusing on smooth lane selection, stopping for traffic signals, yielding to pedestrians, and managing tight spaces. 
2. 2. Highway Autonomy: Test highway capabilities, including adaptive cruise control, automated lane changes (system initiated, driver initiated, driver confirmations), and highway merging, with a focus on handling maximum allowed speeds, maintaining lane centering, and responding to merging traffic.
3. 3. Dynamic Lane Management: Assess the system’s ability to interpret and adapt to dynamic lane markings, such as construction zones or temporary diversions, with a focus on recognizing temporary signage, cones, and changes to lane structure.
4. 4. Weather and Environmental Conditions: Measure the system's performance in varying weather, including rain, fog, and snow, focusing on reliable object detection, sensor functionality, and safe decision-making in low-visibility conditions.
5. 5. Pedestrian and Cyclist Interaction: Test responsiveness to vulnerable road users, such as pedestrians and cyclists, with a focus on predicting movement, and yielding appropriately.
6. 6. Local Traffic Law Compliance: Ensure FSD (supervised) adheres to specific traffic regulations, focusing on speed limits, priority rules at intersections, and respecting local signage and road markings.
7. 7. Navigation on Regional and Rural Roads: Validate FSD (supervised)'s ability to handle narrower, less-structured roads and regional traffic patterns, focusing on recognizing unmarked lanes, dealing with farm vehicles, and responding to unexpected obstacles like animals.
8. 8. Parking Automation: Test automated parking capabilities in a variety of environments, including parallel, perpendicular, and angled parking spaces, focusing on navigating tight urban parking lots, detecting free spaces, and executing precise maneuvers.
9. 9. Traffic Congestion and Stop-and-Go Scenarios: Examine performance in heavy traffic and stop-and-go conditions, focusing on smooth acceleration and deceleration, maintaining safe distances, and avoiding erratic behavior.
10. 10. Unexpected Scenarios: Assess the system's ability to handle unexpected scenarios, such as emergency vehicles, sudden road closures, or debris, with a focus on safe stopping, rerouting, and communicating the need for manual driver intervention if required.

Regarding registration and documentation of vehicles, we are proposing to test on EU type-approved vehicles (Tesla Model S, X, 3, Y), on which we can download FSD (supervised) through an over-the-air-update. We are flexible to bring cars that are already registered with a foreign EU licence plate or to bring a new vehicle to Estonia which we then register with Estonian licence plates. Do let us know what would you prefer.

Best wishes,

Ashley

Hi Ashley,

Thank you for a letter.

It is possible to test Level 2 automated driving systems in Estonia.

The testing description mentioned by you satisfies the most of our conditions. Additionally we like to get beforehand the description of the automated driving systems what is planned to test.

And what concern the registration of vehicle, there is also needed documentation of vehicles. Are these vehicles type-approved according European Regulations?

Best regards

Jürgo Vahtra
Head of Technical Department of Vehicles

Transport Administration
+372 53268406 | [email protected]
Teelise 4 | 10196 Tallinn |Estonia

Hi Jurgo,

I’d like to follow-up on the below request as we are keen to be speaking to the relevant parties in Estonia.

Look forward to hearing from you.

Best wishes,

Ashley

Hi Jurgo,

I hope you’re well. We are currently testing our Level 2 automated driving system in several EU countries, and we would like to do the same in Estonia if possible.

In other countries we rely on national rules, which can be either a formal permit application or a notification to the police that we want to test our vehicles. What we would like to do in Estonia is the following:

• * Test several Tesla vehicles on public roads in Estonia (on all roads, including city roads and highways). We are open to obtaining Estonia licence plates or some sort of prototype plates.
• * The vehicles would be owned by us as from a hardware perspective be representative to the type-approved vehicles that are already on Estonia roads.
• * The vehicles would be driven only by Tesla employees or people who are in a contractual agreement with us (so that we are liable for our vehicles). We wouldn't provide any sort of ride-hailing service to anyone. We can also offer to demonstration rides to policymakers and officials.
• * Drivers of these vehicles would be trained professionals with at least 5 years of driving experience and will receive an extensive training of the Level 2 system, and we can set up a reporting scheme between the drivers and the Estonia government/relevant agencies (which can include reporting on traffic incidents where we participated).
• * Drivers would in most of the time have full control of the vehicles and occasionally test the hands-off capabilities of the vehicles. This would include driver-initiated, driver-confirmed and system-initiated manoeuvres.

Could you please let me know if this would be possible in Estonia and under which conditions?

Best wishes,

Ashley

Ashley Feldman
Public Policy & Business Development Manager – UK&I
E. [email protected]    T. +44 740 881 4458  

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