Investor's Corner
Tesla’s Model 3 safety claims and the NHTSA’s scrutiny: A look at an old (revived) story
Multiple reports have recently emerged about the US National Highway Traffic Administration scrutinizing Tesla and the company’s claims that the Model 3 has the lowest probability of injury among vehicles tested by the agency. It should be noted that the NHTSA’s scrutiny, which involved a cease-and-desist letter to Tesla and a prompt response from the automaker, transpired last October, following the agency’s release of the Model 3’s 5-Star Safety Rating.
The NHTSA’s reaction to Tesla recently came to fore due to documents shared by staunch TSLA critic and transparency group Plainsite, which was able to access both the NHTSA’s cease-and-desist letter to Tesla as well as the electric car maker’s response to the agency thanks to a Freedom of Information Act request. What’s quite peculiar about the new string of reports, including those from Bloomberg and Reuters, is that they highlight the NHTSA’s allegations about the company’s alleged misleading claims about the Model 3, but not Tesla’s response arguing that it used the agency’s own data to arrive at its conclusions.
To get an accurate picture of this story, one must look at the full cease-and-desist letter sent by the NHTSA to Tesla, as well as the entire contents of the electric car maker’s response. A copy of each letter will be embedded in this article, to provide a full account of the two parties’ correspondence.
Following Tesla’s release of its blog post stating that the Model 3 has the lowest probability of injury among the vehicles tested by the NHTSA, the agency sent the Silicon Valley-based company a cease-and-desist letter. Addressed to Elon Musk, the letter claimed that Tesla had “issued a number of misleading statements regarding the recent Government 5-Star Ratings of the Tesla Model 3.” NHTSA Chief Counsel Jonathan Morrison, who sent the letter, further argued that statements such as “lowest probability of injury in all cars” are inaccurate and not in the best interests of consumers.
The NHSTA’s cease-and-desist letter to Tesla could be accessed below.
Tesla Model 3 Safety Claims… by Simon Alvarez on Scribd
Tesla disagreed with the NHTSA’s allegations in its response to the cease-and-desist letter. The electric car maker argued that its statements about the Model 3’s safety were neither untrue nor misleading, especially since the company used the NHTSA’s own data (which could be accessed here) when it stated that the electric sedan, as well as its largest siblings, the Model S and Model X, have the lowest probability of injury among vehicles tested by the agency. Tesla also noted that the Model 3’s achievement is “exactly what NHTSA intended with the NCAP — to encourage manufacturers to continuously immprove safety.” With this in mind, Tesla noted that there was no reason to discontinue its blog post highlighting the Model 3’s safety.
Tesla’s full response to the NHTSA could be read below.
Tesla Model 3 Safety Claims… by Simon Alvarez on Scribd
It should be noted that the NHTSA has not doubled down on its allgetations against Tesla’s statements about the Model 3. The electric car maker’s blog post explaining the Model 3’s stellar safety scores is still active today. Contrary to Plainsite’s statements that Tesla was “referred to the FTC for repeatedly lying about the safety of their vehicles,” it appears that the NHTSA opted to back down from its allegations once the electric car maker explained the rationale behind its statements about the Model 3.
The Model 3 has since gained perfect 5-Star Safety Ratings from the Euro-NCAP and the ANCAP, with both safety agencies lauding the vehicle for being one of the safest cars on the road. Following the vehicle’s crash tests, Matthew Avery, head of research at Thatcham Research, which conducts the crash tests with the Euro NCAP, noted that “Tesla has done a great job of playing the structural benefits of an electric vehicle to its advantage. The Tesla Model 3 achieved one of the highest Safety Assist scores we have seen to date.” These sentiments were echoed by ANCAP Chief Executive Officer James Goodwin, who noted that it was “great to see electric vehicles continuing to prioritize safety. It is encouraging to see Tesla give equal attention to the active safety systems and technologies on board as well as the safety fundamentals through the structure and restraints.”
H/T to Vladimir Grinshpun.
Investor's Corner
SpaceX IPO is coming, CEO Elon Musk confirms
However, it appears Musk is ready for SpaceX to go public, as Ars Technica Senior Space Editor Eric Berger wrote an op-ed that indicated he thought SpaceX would go public soon. Musk replied, basically confirming it.
Elon Musk confirmed through a post on X that a SpaceX initial public offering (IPO) is on the way after hinting at it several times earlier this year.
It also comes one day after Bloomberg reported that SpaceX was aiming for a valuation of $1.5 trillion, adding that it wanted to raise $30 billion.
Musk has been transparent for most of the year that he wanted to try to figure out a way to get Tesla shareholders to invest in SpaceX, giving them access to the stock.
He has also recognized the issues of having a public stock, like litigation exposure, quarterly reporting pressures, and other inconveniences.
However, it appears Musk is ready for SpaceX to go public, as Ars Technica Senior Space Editor Eric Berger wrote an op-ed that indicated he thought SpaceX would go public soon.
Musk replied, basically confirming it:
As usual, Eric is accurate
— Elon Musk (@elonmusk) December 10, 2025
Berger believes the IPO would help support the need for $30 billion or more in capital needed to fund AI integration projects, such as space-based data centers and lunar satellite factories. Musk confirmed recently that SpaceX “will be doing” data centers in orbit.
AI appears to be a “key part” of SpaceX getting to Musk, Berger also wrote. When writing about whether or not Optimus is a viable project and product for the company, he says that none of that matters. Musk thinks it is, and that’s all that matters.
It seems like Musk has certainly mulled something this big for a very long time, and the idea of taking SpaceX public is not just likely; it is necessary for the company to get to Mars.
The details of when SpaceX will finally hit that public status are not known. Many of the reports that came out over the past few days indicate it would happen in 2026, so sooner rather than later.
But there are a lot of things on Musk’s plate early next year, especially with Cybercab production, the potential launch of Unsupervised Full Self-Driving, and the Roadster unveiling, all planned for Q1.
Investor's Corner
Tesla Full Self-Driving statistic impresses Wall Street firm: ‘Very close to unsupervised’
The data shows there was a significant jump in miles traveled between interventions as Tesla transitioned drivers to v14.1 back in October. The FSD Community Tracker saw a jump from 441 miles to over 9,200 miles, the most significant improvement in four years.
Tesla Full Self-Driving performance and statistics continue to impress everyone, from retail investors to Wall Street firms. However, one analyst believes Tesla’s driving suite is “very close” to achieving unsupervised self-driving.
On Tuesday, Piper Sandler analyst Alexander Potter said that Tesla’s recent launch of Full Self-Driving version 14 increased the number of miles traveled between interventions by a drastic margin, based on data compiled by a Full Self-Driving Community Tracker.
🚨 Piper Sandler reiterated its Overweight rating and $500 PT on Tesla $TSLA stock
Analyst Alexander Potter said FSD is near full autonomy and latest versions showed the largest improvement in disengagements, from 440 miles to 9,200 miles between critical interventions pic.twitter.com/u4WCLfZcA9
— TESLARATI (@Teslarati) December 9, 2025
The data shows there was a significant jump in miles traveled between interventions as Tesla transitioned drivers to v14.1 back in October. The FSD Community Tracker saw a jump from 441 miles to over 9,200 miles, the most significant improvement in four years.
Interestingly, there was a slight dip in the miles traveled between interventions with the release of v14.2. Piper Sandler said investor interest in FSD has increased.
Full Self-Driving has displayed several improvements with v14, including the introduction of Arrival Options that allow specific parking situations to be chosen by the driver prior to arriving at the destination. Owners can choose from Street Parking, Parking Garages, Parking Lots, Chargers, and Driveways.
Additionally, the overall improvements in performance from v13 have been evident through smoother operation, fewer mistakes during routine operation, and a more refined decision-making process.
Early versions of v14 exhibited stuttering and brake stabbing, but Tesla did a great job of confronting the issue and eliminating it altogether with the release of v14.2.
Tesla CEO Elon Musk also recently stated that the current v14.2 FSD suite is also less restrictive with drivers looking at their phones, which has caused some controversy within the community.
Although we tested it and found there were fewer nudges by the driver monitoring system to push eyes back to the road, we still would not recommend it due to laws and regulations.
Tesla Full Self-Driving v14.2.1 texting and driving: we tested it
With that being said, FSD is improving significantly with each larger rollout, and Musk believes the final piece of the puzzle will be unveiled with FSD v14.3, which could come later this year or early in 2026.
Piper Sandler reaffirmed its $500 price target on Tesla shares, as well as its ‘Overweight’ rating.
Tesla received a price target boost from Morgan Stanley, according to a new note on Monday morning, but there is some considerable caution also being communicated over the next year or so.
Morgan Stanley analyst Andrew Percoco took over Tesla coverage for the firm from longtime bull Adam Jonas, who appears to be focusing on embodied AI stocks and no longer automotive.
Percoco took over and immediately adjusted the price target for Tesla from $410 to $425, and changed its rating on shares from ‘Overweight’ to ‘Equal Weight.’
Percoco said he believes Tesla is the leading company in terms of electric vehicles, manufacturing, renewable energy, and real-world AI, so it deserves a premium valuation. However, he admits the high expectations for the company could provide for a “choppy trading environment” for the next year.
He wrote:
“However, high expectations on the latter have brought the stock closer to fair valuation. While it is well understood that Tesla is more than an auto manufacturer, we expect a choppy trading environment for the TSLA shares over the next 12 months, as we see downside to estimates, while the catalysts for its non-auto businesses appear priced at current levels.”
Percoco also added that if market cap hurdles are achieved, Morgan Stanley would reduce its price target by 7 percent.
Perhaps the biggest change with Percoco taking over the analysis for Jonas is how he will determine the value of each individual project. For example, he believes Optimus is worth about $60 per share of equity value.
He went on to describe the potential value of Full Self-Driving, highlighting its importance to the Tesla valuation:
“Full Self Driving (FSD) is the crown jewel of Tesla’s auto business; we believe that its leading-edge personal autonomous driving offering is a real game changer, and will remain a significant competitive advantage over its EV and non-EV peers. As Tesla continues to improve its platform with increased levels of autonomy (i.e., hands-off, eyes-off), it will revolutionize the personal driving experience. It remains to be seen if others will be able to keep pace.”
Additionally, Percoco outlined both bear and bull cases for the stock. He believes $860 per share, “which could be in play in the next 12 months if Tesla manages through the EV-downturn,” while also scaling Robotaxi, executing on unsupervised FSD, and scaling Optimus, is in play for the bull case.
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Meanwhile, the bear case is placed at $145 per share, and “assumes greater competition and margin pressure across all business lines, embedding zero value for humanoids, slowing the growth curve for Tesla’s robotaxi fleet to reflect regulatory challenges in scaling a vision-only perception stack, and lowering market share and margin profile for the autos and energy businesses.”
Currently, Tesla shares are trading at around $441.
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