4 Comments

I believe we ought to distinguish between 'driver assistance systemes' and what might be termed 'automated supervised driving'. A driver assistance system is anything which helps an active, in control driver with their task, but still provides a 'safety net' if things seems to start to go wrong, such as coming up against a leading vehicle too quickly, moving into the shoulder of the road at high speed, etc. We could usefully add notifications/warnings when closing in on a traffic light (perhaps with an 'annunciator' panel at the top of the instrument panel showing active colour), warnings when meeting upcoming traffic when the left turn indicator is turned on and the car is slowing for the turn, warnings for pedestrian crossings (from map and GPS, which might not be faultless but as the driver is supposed to be active, no great issue either). Systems such as these are the only ones we rightly ought to call "Level 2".

What I provisionally call 'Automated supervised driving' includes not only what you, Phil, wants to add to "Level 3", but also the kind of automated steering which lets the driver rely on the car to steer, whether with or without hands on the wheel (and after all, in most modern cars on good roads you can release the wheel for a second or two even w/o any automation). As I understand it, the drift towards complacency startas as you no longer needs to perform the activity of continuous small adjustments, not when you take your hands off the wheel - you have probably been 'drifting' long before that if your car steers competently.

And I don't give a lot for so-called 'driver awareness cameras' which starts to complain as soon as you look into the rear view mirror, on the stupid centralized display panel, or just move your gaze around to keep up awareness of the overall traffic situation - which, according to road tests, is what may cars are doing these days.

I also think automated lane change, and automatic speed adjust from roadside speed signs should be firmly placed in the Level 3 category

And what about adaptive cruise control (without sign reading)? I think this is a borderline feature, especially if it is unreliable (influenced by leading car size and color, for instance). But I guess that since it is now so common it will be difficult to reclassify.

Anyway, overall the above reflects my profound negativity to the SAE levels, which in my opinion are nothing but a narrow minded engineers 'feature matrix', with little or no reflection around human cognition, usability or ergonomic research, nor about the real issues encountered in traffic.

I also would like to contrast this approach with the Garmin Autoland feature for civil aviation, which, when necessary (pilot incapacition) can take over the flight, declare an emergency, find a suitable airport, and land on the tarmac and turn off the aircraft - but which strongly illegal if used outside an emergency. I find that kind of 'safety net' a commendable way of thinking about safety, compared to what the car industry seems fixated at doing: providing features to impress your gullible friends while charging a lot of money under the guise of 'safety'.

Expand full comment
author

Thanks for the interesting thoughts. There are (at least) 3 places to put the cut line for regulation:

- Anything that controls steering (which I have previously proposed with Prof. William Widen) for the liability cut line)

- Level 2+ to exempt "dumb" steering cruise control, but include more sophisticated systems which is this proposal to establish an equipment regulation boundary (not quite the same as a liability cut line). There is room to discuss where exactly to put that line to be sure, but it has to be articulated as a simple bright-line test to work even if it leaves out some systems on the border.

- Level 3 -- what we have now, which I think is doing a lot of harm

As you point out there is a lot to dig into beyond creating the cut lines in the best places we can.

Expand full comment

The regulatory process carefully avoids the SAE levels.

The systems you are discussing are called DCAS (driver control assistance systems). The WP.29 regulation for this is Reg171, currently for hands on. The update is in progress for hands off. See https://wiki.unece.org/display/trans/ADAS. NHTSA has stayed out of this.

Reg 157 covers the current level 3 products like Mercedes. Work on the next generation is in the ADS (automated driving systems) informal working group. See https://wiki.unece.org/pages/viewpage.action?pageId=238223362. A NHTSA person is co-chair of this activity

Expand full comment
author

Yes, the EU process avoids the SAE Levels and regulates in a far more substantive way than the US.

However, regulatory capture lobbying by the AV industry have firmly planted the SAE Levels in US DOT policy and US State Laws. For example, California statue bakes SAE J3016 (and the levels) into it with an explicit reference.

Expand full comment