Will Mercedes jump to level 3 before Tesla? Looks like it.

[Daniel in SD]

Their lawyers will figure that out

Haha. Just admit that you have no evidence of any rule.

According to @stopcrazypp and @Knightshade such a capability is not within the SAE level 3 standard, since a Level 3 a system shall only give the driver "within seconds" to take over manual driving and then disengage whatever the driver does. A safe stop capability (like Mercedes have) is the difference defining a Level 4 system.

What does it mean? Can Mercedes call a Level 4 a Level 3? Do they follow a different standard? Can they deviate from the standard at their own will?

An L3 system could do that but no L3 system will ever do that. Just stopping the vehicle is far safer so that is what every conceivable L3 system will do. Stopping the vehicle is relatively safe but it is not achieving the "minimal risk condition" which in the case of the Mercedes system would probably be pulling over to the shoulder. Achieving a minimal risk condition is required for a vehicle to be L4.

 

[EVNow]

Haha. Just admit that you have no evidence of any rule.

Lets see
- Merc wants to do unsupervised
- Merc wants to sell in CA

So,
- Where is merc testing their unsupervised car ?
- What is the disengagement rate ?
- Where is the annual report ?

 

[S4WRXTTCS]

According to Mercedes, Drive Pilot is a Level 3 system. But at the same time they are publishing text showing a complete safe stop strategi if the driver does not respond to a "take over request".

All it means to me is MB is choosing to do more than the minimum requirement spelled out by L3.

I don't see it as being a deviation from standard. In fact there might be a stricter regulatory requirements for L3 in some jurisdictions.

There is also what owners would feel safe in. I would not feel safe in an L3 vehicle that went "Oh, he's not responding so I guess its crash time".

 

[Knightshade]

According to Mercedes, Drive Pilot is a Level 3 system. But at the same time they are publishing text showing a complete safe stop strategi if the driver does not respond to a "take over request".

You claim is not factually true though.

It says it will make a controlled stop.

Not necessarily a safe one.

In fact Mercedes calls this out in your source doc- pointing out it's still the human who must take action to achieve a minimal risk condition like actually pulling off the road.

So literally all the Mercedes system will do driving-wise if it gets no response is stop in its current lane and turn on the hazards. Teslas system has already done that for years if it doesn't get a response to TAKE OVER nags on autopilot.

So no, it's not L4.



I suggest you read up on what the minimal risk condition descriptions are in SAEJ3016 and what a car would have to be able to to do meet them.[/B]

 

[Daniel in SD]

Lets see
- Merc wants to do unsupervised
- Merc wants to sell in CA

So,
- Where is merc testing their unsupervised car ?
- What is the disengagement rate ?
- Where is the annual report ?

What does that have to do with NHTSA rules?

Here are the 2021 disengagement reports for CA:

https://www.dmv.ca.gov/portal/file/2021-autonomous-vehicle-disengagement-reports-csv/

Apparently they only did 58k miles of testing in CA in 2021 and it's not clear if they did any testing of Drive Pilot. Of course like Tesla they are probably doing testing in other states and countries too.

 

[stopcrazypp]

According to Mercedes, Drive Pilot is a Level 3 system. But at the same time they are publishing text showing a complete safe stop strategi if the driver does not respond to a "take over request".

According to @stopcrazypp and @Knightshade such a capability is not within the SAE level 3 standard, since a Level 3 a system shall only give the driver "within seconds" to take over manual driving and then disengage whatever the driver does. A safe stop capability (like Mercedes have) is the difference defining a Level 4 system.

What does it mean? Can Mercedes call a Level 4 a Level 3? Do they follow a different standard? Can they deviate from the standard at their own will?

The screen shot says the car can come to a stop if the driver does not respond (which as pointed out, Tesla's L2 system does too if you ignore all the nags), but that does not necessarily mean it is "safe" by that point, just that it is safer than the alternative of continuing to operate. By the time the "several seconds" countdown timer runs out, the car isn't considered "driving" anymore, so anything that happens afterwards is the driver's fault (for example if the car slams into something or gets slammed into while coming to a stop).

An L4 car instead will be able to ensure the driver is safe without ever needing to request assistance from the driver, whether that is stopping in the current lane if there was no other choice, or moving over to the shoulder if that is an option. So even while it is performing the stop maneuver as it exits its ODD, the manufacturer is still responsible for it.

But as noted in the screen shot, Mercedes already said the system is a SAE L3 system from their own mouth, hopefully there is no dispute from you on this point any further.

I also linked another post made by Mercedes that clarified:
"However, the driver must always be able to take over control of the vehicle. Meaning that the driver, for example, is not allowed to sleep, continuously face backwards, or leave the driver’s seat."
Conditionally automated driving with the DRIVE PILOT | Mercedes-Benz Group

Hopefully there is also is no further dispute from you suggesting that Mercedes says it is safe to sleep in the car while the L3 function is active.

 

[t3sl4drvr]

L4 does need to have a human in the car at all.

 

[EVNow]

What does that have to do with NHTSA rules?

Because ..... this thread is titled "Will Mercedes jump to level 3 before Tesla? Looks like it.".

So, lets talk about how why Merc is not testing in CA.

 

[Daniel in SD]

Because ..... this thread is titled "Will Mercedes jump to level 3 before Tesla? Looks like it.".

So, lets talk about how why Merc is not testing in CA.

That does not explain what NHTSA rule Mercedes is going to need an exemption from. They need approval from the CA DMV, there is no approval needed from any federal agency.
I presume they’re not testing much in California (at least not in 2021) because they’re developing it in Germany but I have no idea. I hope their application is made public (and not completely redacted) when they do apply for approval. I’ve said all along though that I have my doubts that they will release it anywhere.

 

[S4WRXTTCS]

That does not explain what NHTSA rule Mercedes is going to need an exemption from. They need approval from the CA DMV, there is no approval needed from any federal agency.
I presume they’re not testing much in California (at least not in 2021) because they’re developing it in Germany but I have no idea. I hope their application is made public (and not completely redacted) when they do apply for approval. I’ve said all along though that I have my doubts that they will release it anywhere.

To me its idiotic not to test it in California for numerous reasons:

• As I understand it California has actual L3 regulations. In fact Volvo plans on releasing an L3 system in California first before any other US state.
• California also allows motorcycles to lane split so an L3 car is always going to have deal with them.
• California has crazy traffic, and bizarre things happen all the time
• California has more EV sales than any other state so if you don't have autonomy there then it doesn't make much business sense to have it available in other states.

As a potential customer the lack of autonomous testing in California signals to me that its nowhere near close to release in the US.

I do feel MB will have L3 in Germany before Tesla has it in the US, but it will be so limited in terms of capability that it won't be a significant sales advantage by itself.

I don't feel as if Tesla skipping L3 is a mistake. It's something that does benefit some customers such as myself, but it's not an Elon/Tesla kind of thing.

 

[daktari]

You claim is not factually true though.

It says it will make a controlled stop.

Not necessarily a safe one.

In fact Mercedes calls this out in your source doc- pointing out it's still the human who must take action to achieve a minimal risk condition like actually pulling off the road.

So literally all the Mercedes system will do driving-wise if it gets no response is stop in its current lane and turn on the hazards. Teslas system has already done that for years if it doesn't get a response to TAKE OVER nags on autopilot.

So no, it's not L4.



I suggest you read up on what the minimal risk condition descriptions are in SAEJ3016 and what a car would have to be able to to do meet them.[/B]

Parking in the shoulder of a highway is certainly not a safe spot. But I agree it is safer than stopping in the lane most of the time, depending on traffic conditions. Both are safer than driving along with eyes closed and hands not on the wheel.

We all know a Level 2 system can disengage without warning, the red hands take over symbol. And that is the big thing with a decent level 3 implemetation, it should never do that, like Drive Pilot. Always stop safely.

Why does anyone need to blur the difference between these two levels?

 

[daktari]

The screen shot says the car can come to a stop if the driver does not respond (which as pointed out, Tesla's L2 system does too if you ignore all the nags), but that does not necessarily mean it is "safe" by that point, just that it is safer than the alternative of continuing to operate. By the time the "several seconds" countdown timer runs out, the car isn't considered "driving" anymore, so anything that happens afterwards is the driver's fault (for example if the car slams into something or gets slammed into while coming to a stop).

An L4 car instead will be able to ensure the driver is safe without ever needing to request assistance from the driver, whether that is stopping in the current lane if there was no other choice, or moving over to the shoulder if that is an option. So even while it is performing the stop maneuver as it exits its ODD, the manufacturer is still responsible for it.

But as noted in the screen shot, Mercedes already said the system is a SAE L3 system from their own mouth, hopefully there is no dispute from you on this point any further.

I also linked another post made by Mercedes that clarified:
"However, the driver must always be able to take over control of the vehicle. Meaning that the driver, for example, is not allowed to sleep, continuously face backwards, or leave the driver’s seat."
Conditionally automated driving with the DRIVE PILOT | Mercedes-Benz Group

Hopefully there is also is no further dispute from you suggesting that Mercedes says it is safe to sleep in the car while the L3 function is active.

I have always thought of the MB System as level 3, that will come to a safe stop if the driver is passed out. The screenshots says that also. Automated driving isn't over until the car has stopped.

Even if Teslas can come to a safe stop, as some other brands level 2 also, it can randomly also not do it, but rather disengage at will. That is the difference. You don't know when you are safe.

I was expecting that sleeping was ok with level 3. MB says no. But as I read the screenshot, one could do it still and be safe. Safer than in a Tesla with an orange squeezed in the steering wheel.

My point is that level 3 is a much bigger deal than level 2. Your argumentation have, as I interpret it, both been discreditng level 3 as useless and at the same time claiming that the feature MB have (safe stop) is a Level 4 thing that means the MB lv 3 system still is poor.

And I disagree, to me MB has hit the nail for lv 3. And I think Tesla should focus on that also instead of city streets.

 

[Knightshade]

Parking in the shoulder of a highway is certainly not a safe spot. But I agree it is safer than stopping in the lane most of the time, depending on traffic conditions. Both are safer than driving along with eyes closed and hands not on the wheel.

We all know a Level 2 system can disengage without warning, the red hands take over symbol. And that is the big thing with a decent level 3 implemetation, it should never do that, like Drive Pilot. Always stop safely.

But Drive Pilot does not always stop safely.

It just always stops.

So does Autopilot if you don't take over.

In fact both stop the same way- by just braking to a stop in their current lane and sitting there.


There's no blur at all.

Neither is designed or intended to be able to stop safety-- or more accurately bring the car to a minimal risk condition, which is the actual thing L4 requires and which neither system from Tesla nor Mercedes can or even claims to do.

 

[stopcrazypp]

I have always thought of the MB System as level 3, that will come to a safe stop if the driver is passed out. The screenshots says that also. Automated driving isn't over until the car has stopped.

Even if Teslas can come to a safe stop, as some other brands level 2 also, it can randomly also not do it, but rather disengage at will. That is the difference. You don't know when you are safe.

I was expecting that sleeping was ok with level 3. MB says no. But as I read the screenshot, one could do it still and be safe. Safer than in a Tesla with an orange squeezed in the steering wheel.

My point is that level 3 is a much bigger deal than level 2. Your argumentation have, as I interpret it, both been discreditng level 3 as useless

I never claimed that. That is merely you projecting your own prejudices onto my statements and putting words into my mouth (you are not the only one that have done that, so I've come to expect it in these forums).
This is the exchange that prompted you to get on my back and using a factually incorrect statement to do so:

Even L3 does not allow you to sleep, because you have to be ready to take over within seconds of the car requesting.

This is wrong. The L3 car will stay in lane, then try to wake you, then safely stop and put hazard lights on and auto call emergency services if you fail to respond to a take over request.

One is not supposed to sleep in it anyway.

Entire early comment for context:

We don't trust our lives to AP on those new roads. We just ask it to keep the car in the lane and we are ready to catch it if it fails. That's very different from "Car, drive me through this complex city while I sleep even though you've never driven on these roads before."

Door-to-door L2 doesn't allow you to sleep, you still have to monitor the car just like AP. Even L3 does not allow you to sleep, because you have to be ready to take over within seconds of the car requesting. Door-to-door L2 is pretty much the current end game for FSD Beta, at least according to Tesla's CA DMV filings. There are no plans yet for anything beyond that at the moment.

My point was the driver is not allowed to sleep in a L2 or L3 car. It's that simple.

and at the same time claiming that the feature MB have (safe stop) is a Level 4 thing that means the MB lv 3 system still is poor.

I never claimed the stop in lane feature MB has is a level 4 thing. Again others pointed out Tesla AP has the same thing. A car being able to stop in its own lane after the driver does not respond to the car is not a L4 feature. I will note it's not necessarily a "safe stop" either, as it can be quite dangerous to come to a complete stop in a travel lane (part of why it can't be considered L4). Others already pointed out, a L4 car never has to ask the driver to take over in the first place. It'll do whatever maneuver necessary (including pulling to shoulder or even pulling to a parking lot, if necessary).

And I disagree, to me MB has hit the nail for lv 3. And I think Tesla should focus on that also instead of city streets.

 

[bradtem]

My point was the driver is not allowed to sleep in a L2 or L3 car. It's that simple.

While you keep talking about L2 and L3 as though they are real things rather than ideas dreamed up by junior developers and non-developers, you could certainly make a car with a standby driver who falls asleep. In fact, research shows people will fall asleep even when you tell them not to, so it is a bad design that can't handle that happening. Same for ADAS, frankly.

But with a standby driver (similar to fake level 3) I could see a car that handles only highways and setting it on the highway for a 2 hour drive before its exit. You could easily let the driver sleep and wake them up 10-20 minutes before the end of the drive, doing so in a way that there is a known "escape route" in case the driver won't wake. Though between hard brake jabs, seatbealt squeezing and alarms, if the driver won't wake in a few minutes of that you have a bigger problem and maybe should call 911, or an ultra-deep sleeper should not use it.

Of course such a system needs to handle surprises, including surprise construction -- or have no chance of surprise construction because it's part of a fleet that has a car going by every minute to detect such construction. Here in California, I don't think you can go 30 seconds on the highway without a Tesla going by, except in super light traffic where it's not a problem to just stop.

 

[EVNow]

to me MB has hit the nail for lv 3.

MB says they have done vigorous testing according to the UN regulation. That regulation calls for 5 minutes of testing.

You might be looking at a different kind of "hit"

 

[stopcrazypp]

While you keep talking about L2 and L3 as though they are real things rather than ideas dreamed up by junior developers and non-developers, you could certainly make a car with a standby driver who falls asleep. In fact, research shows people will fall asleep even when you tell them not to, so it is a bad design that can't handle that happening. Same for ADAS, frankly.

But with a standby driver (similar to fake level 3) I could see a car that handles only highways and setting it on the highway for a 2 hour drive before its exit. You could easily let the driver sleep and wake them up 10-20 minutes before the end of the drive, doing so in a way that there is a known "escape route" in case the driver won't wake. Though between hard brake jabs, seatbealt squeezing and alarms, if the driver won't wake in a few minutes of that you have a bigger problem and maybe should call 911, or an ultra-deep sleeper should not use it.

Of course such a system needs to handle surprises, including surprise construction -- or have no chance of surprise construction because it's part of a fleet that has a car going by every minute to detect such construction. Here in California, I don't think you can go 30 seconds on the highway without a Tesla going by, except in super light traffic where it's not a problem to just stop.

What you describe above that can always safely end a car's ODD without any driver response is a L4 car. If the car can't do that, by definition it is not L4 (it'll be a level below that). The definition does not allow you to "sometimes" be safe or gamble on being able to wake up the driver in time.

Your scenario also fails to consider shorter trips, what if the highway portion is only 5 minutes?

 

[bradtem]

What you describe above that can always safely end a car's ODD is a L4 car. If the car can't do that, by definition it is not L4 (it'll be a level below that). The definition does not allow you to "sometimes" be safe.

Your scenario also fails to consider shorter trips, what if the highway portion is only 5 minutes?

Sleeping is not desired on 5 minute trips.
To me, a standby driver car is one that legally must leave its ODD while moving. Stopping in the middle of the highway is not legal except in an emergency situation, which is how I would class a non-responsive driver.

The key difference is this. Most plans for fake level 3 involve being able to give the driver 10 seconds warning, as they can almost always respond in 10 seconds unless asleep. I am saying you can let them sleep if you make the warning a few minutes in advance, particularly when there is an emergency escape plan, like an off-ramp.

If your design requires getting them back on board in 10 seconds for a surprise event like surprise construction, you would not want to let them sleep. Other surprises like debris on road, stalled cars etc. the car is expected to handle on its own. The main plan for fake level 3 is a car which can do only freeway, or can do entry to off-ramps but needs takeover once in the off-ramp as it can't handle things like lights at the base of the ramp. It can probably handle red lights at the end of the ramp, it's green which it would have a problem with.

People are also working on tolerable handling of freeway construction zones. Tesla certainly plans to do this. Then you can avoid issues with surprise zones. Though again, for a Tesla, it should be almost impossible to be surprised by a construction zone in the places that are thick with Teslas. Long before the zone becomes real there will be cones and construction equipment that weren't there before, easy to notice if Teslas had maps. Which they will, after Elon takes the stick out of his butt about maps.

 

[sedluk]

It is clear that bradtem is not in the software writing business.

At this stage it looks like maps, and for that matter lidar and radar could be useful. Tesla is doing very well with the perception problem and figuring out the roads. Yes, it is not currently perfect but will be solved. It has to be solved and using maps is a crutch. The harder problems are things like eye contact and interactions with other drivers, people directing traffic and a whole bunch of other difficult problems. Maps, Lidar and radar do not help you with the difficult problems, they only help you with the easy problems.

 

[bradtem]

It is clear that bradtem is not in the software writing business.

At this stage it looks like maps, and for that matter lidar and radar could be useful. Tesla is doing very well with the perception problem and figuring out the roads. Yes, it is not currently perfect but will be solved. It has to be solved and using maps is a crutch. The harder problems are things like eye contact and interactions with other drivers, people directing traffic and a whole bunch of other difficult problems. Maps, Lidar and radar do not help you with the difficult problems, they only help you with the easy problems.

Plonk.