NHTSA Complaint #11558753 — 2020 TESLA MODEL 3

Currently occurring with FSD Beta firmware V.2022.27.12 but the same has occurred with previous firmware versions also. Normal operation of the vehicle with the ADAS engaged puts the windshield wipers into AUTO mode. At times the windshield wipers are activated when the windshield is dry. It isn't raining or misting and there's nothing on the surface of the windshield at the location of the front-facing cameras. "No rain" occurrences seem to correlate with times when visibility ahead has low contrast and there are no highlights and shadows to sharply define the scene, (ie, a little "muddy"). Observed when it is overcast but not raining, around sunrise when the sun is low in the sky and the light levels ahead are relatively low and headlights aren't helping illuminate the road ahead, and at times there are high-contrast light and shadows immediately ahead but farther down the road there is mist or fog, creating the same low contrast lighting conditions some distance away. It is as if the ADAS is aware that the scenery is not sharply defined and is "wiping its eyes" in an attempt to gain a more sharply-defined view. Occasionally, but rarely in my experience, the windshield washer is also engaged. Having the ADAS activate the wipers at these times is not a safety hazard, per se, but it is distracting and concerning as it gives the driver the impression that perhaps the ADAS is malfunctioning. I've read in user forums reports from a fair number of FSD Beta drivers complaining that the wipers go on when the windshield is dry and the ADAS is engaged. I haven't observed the same when the ADAS is not engaged.