Stepping Up to Level 3 without Mis-selling

Tesla has become a cautionary tale on what promises carmakers should not make about autonomous technology.

Not only is its CEO Elon Musk being sued by the family of an Apple engineer who was killed in a 2018 car crash while driving a Tesla Model X but he is also being investigated by  the US Securities and Exchange Commission (SEC) and the California attorney general regarding the marketing claims he made and the company made about its Autopilot assisted driving system.

Musk has also repeatedly declared that full autonomous driving was just around the corner. At a recent AI conference in China, he said: “In terms of where Tesla is at this stage, I think we are very close to achieving full self-driving without human supervision. This is only speculation but I think we’ll achieve full self-driving, maybe what you would call four or five, I think later this year.”

The truth is that fully autonomous vehicles for consumers are probably decades away. The technology is currently taking its first tentative steps at Level 3, with the launch, in Germany and parts of the US states of California and Nevada, of the 2024 Mercedes S Class and EQS Sedan, which are equipped with the carmaker’s Drive Pilot L3 system. In its marketing material, Mercedes defines that system as “conditionally automated driving”, which it describes in a footnote as “the automated driving function takes over certain driving tasks”.

Perhaps Musk believes that the value for consumers of self-driving technology lies primarily in full autonomy and that the only way to sell the cars is by promising its imminent arrival. If so, he is wrong.

“The benefits of autonomous driving are usually expressed in three ways: safety, convenience and, in the long term, with full automation, new mobility approaches,” said James Hodgson, research director at ABI. He went on to say that the safety benefits have already been achieved by ADAS. “If the limit of your ambition is to make transportation safe, just proliferate active safety and you will cut down the number of accidents caused by human error very considerably. You don’t need Level 3, etc., to achieve the safety goals.”

The selling point of Level 3 autonomy is convenience, Hodgson said, which he described as “handing back time to drivers”. Brands can differentiate themselves by how much time they give to drivers by automating driving tasks. “Level 3 is the most tangible way to achieve that at the moment because the technology implication in going from Level 2+ to Level 3 is not insignificant,” he noted. “At level 2+ you have to supervise all the time, there’s no possibility to disengage, as there is with Level 3.”

As Mercedes puts it, Drive Pilot “allows the driver to take their mind off the traffic and focus on certain secondary activities”. In another footnote, the carmaker explains that the secondary activities a driver is legally permitted to carry out “depends on the respective national road traffic regulations”. In Germany, this means that drivers at the wheel of Mercedes EQS Sedan with L3 capability are legally allowed to eat, draft emails or watch videos while driving.

Drivers can partially disengage or visually disengage, Hodgson said, but they must be ready at any moment to retake control of the car within 10 seconds if prompted by the system. “This is why we are seeing Level 3 targeted primarily at highway driving,” he explained. “That is where driving is most repetitive, most boring, most arduous in long journeys or long spells in heavy traffic. And that is where there can be the most consumer value unlocked, by taking some of the load off the driver. So, highway automation is probably the best way to sell Level 3 to consumers.”

However, under the current conditions for Level 3 deployment, the vehicles cannot travel faster than 40mph in the US and 60kph, in Germany, which is hardly highway speed. However, in Germany one of the conditions for the technology is that the L3 system must be deployed only on the Autobahn. (Another is that street and weather conditions must be good, with good lines of sight and no rain or snow.)

Hodgson said that the speed limit could be raised with simple over-the-air updates “once the OEM has confidence in the system. Eventually you could get to the point that you’re so confident that the system exceeds human performance in all ways that you bump the speed limit up”. That speed limit can now be bumped up to 130kph (80 mph), according to an amendment passed by the United Nations Economic Commission for Europe (UNECE) to its Regulation 157. Yet “the ability to build a safety case is much easier at lower speeds and that is why we are seeing these speed limitations first,” Hodgson said.

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