The article is correct. The SAE explains this in more detail and makes the distinction between being constantly ready to immediately take over and being asked to resume driving.

https://www.sae.org/blog/sae-j3016-update

Is this supposed distinction actually meaningful? I don't know...color me unconvinced.

When I interpret "being constantly ready to immediately take over" language, it's unambiguous that I need to maintain full situational awareness as if I were driving the vehicle.

Physically and mentally transitioning from partial to full situational awareness obviously takes some time, and yet from the graphic in the SAE link, the chart remains entirely ambiguous about the permitted time between "when the feature requests" and when "you must drive".

Furthermore, a quick review of SAE J3016 Rev 2021-04 reflects equally ambiguous language in § 5.4 NOTE 4 (my emphasis):

> NOTE 4: In the event of a DDT performance-relevant system failure in a Level 3 ADS, or in the event that the ADS exits its ODD, the ADS will issue a request to intervene within sufficient time for the fallback-ready user (whether in-vehicle or remote) to respond appropriately.

I'm curious what the normative minimum of "sufficient time" will be in practice.

There’s a big difference between “constantly vigilant” and “you can chill out and watch YouTube, and just, like, don’t be drunk or super stoned

The way I’m reading the SAE, it’s closer to the second. Like, it’s actual real self driving, but might need the user to take back control with a modicum of warning if it sees, say, a construction zone ahead or if it detects too much standing water on the road.

Chilling out and watching youtube is still a huge issue though. You lose situational awareness and, drunk or not, you cannot react to sudden urgent issues that confuse the system.

There are studies on this, but most of them are paywalled.[1] The key value issue is "takeover time", where a level 3 system asks the driver to take over. Values studied are in the 5 to 7 second range.

This is marginal. Volvo was trying for a level 3 system where, if the driver did nothing, the vehicle ended up safely stopped, preferably out of traffic. That's the gold standard for level 3.

"Under German law, to be allowed to operate at Level 3 above 37 mph, vehicles will have to be able to autonomously reach a 'safe haven' such as a breakdown lane in case of an emergency."[2] Mercedes is not there yet. They claim 10-second handoff, but they really want the human back on line in 3 seconds.[3] Look away from the road for 5 seconds, and the system starts complaining.

[1] https://www.sciencedirect.com/science/article/abs/pii/S00014...

[2] https://www.motortrend.com/reviews/mercedes-benz-drive-pilot...

[3] https://mercedes-world.com/news/mercedes-benz-level-3-drive-...

Human back online in three seconds is really not much different from instantaneous. Certainly not reasonable to read a book with both hands on the book and not on the steering wheel.

I can’t find anything supporting “they really want the human back on line in 3 seconds” in your 3rd link. Quite the contrary:

> You’re allowed to take your hands off the steering wheel, to take your eyes off the road, and even to turn your head to the side. But you can’t take a nap. > > As I discovered in my short closed-course test-drive, some flexibility is built into the system. For instance, as long as you’re belted, it’s OK to look back to a child in the back seat for three to five seconds. > > You can push it too far, though. After consulting with the engineer in the passenger seat, I closed my eyes completely, and just eight or nine seconds later a prompt popped up asking me to confirm I was still alert. I ignored it, which soon started the 10-second countdown toward disengagement.

The graphic in that link is very helpful in describing the feature set by driving automation level. However, the green/blue color coding is misleading IMO. That tiny blue box in Level 3 means that while you are technically not driving and can take your eyes off the road, you must be ready to start driving at any time. 10 seconds warning really is not a lot of time at highway speeds when you must unexpectedly context switch between whatever you were doing and driving. It seems to me that the real leap in ability occurs when going from Level 3 to Level 4, not Level 2 to Level 3. I also have a hunch that if/when we get to Level 4 we will end up with a bunch of sublevels (Level 4.1, 4.2, 4.n) that progressively expand the conditions under which the system will operate over a period of decades as we asymptotically approach Level 5.

Big difference between needing to keep attention on the road because the car is liable to hit parked cars obstructing the travel lane, and merely having to be ready to shift your attention and start driving when the operational design domain of a L3 system is no longer met. Like for this Drive Pilot, when traffic speeds up to 40 MPH.

The only thing is whether or not Mercedes will take liability for their system if it causes an incident while operating within their defined driving limitation (eg. 35mph). If they still say "it's up to you", it's tough to trust it enough to read a book or watch a movie.

In Germany, they take the liability. Probably the same in the US.

It certainly sounds like a contradiction, but I suppose it comes down to how much time the driver has to take control "when prompted to intervene". If they are expected to take control in (for example) less than one second's notice, then yes driver must keep their attention on the road at all times.

If the car is able to recognize far enough in advance that it doesn't know what to do in a situation and reduce speed, pull over, etc., then that could be enough time for a person to put down their phone and take control of the vehicle.

L3 driving is only available at low speeds, approx 35mph which means only useful for stop-and-go traffic. Many cars with adaptive cruise control can already do this.

Source: https://www.rambus.com/blogs/driving-automation-levels/#leve...

The public page makes no such distinction[0].

I created a mySAE account to download the full spec. What I found is that the manufacturer generally has fairly free reign to define their "operational design domain (ODD)" for level 3 systems, aka what conditions the car's "level 3" operation is designed for and can operate under. The only real requirement for level 3 is that OEDR is required (monitoring the driving environment (detecting, recognizing, and classifying objects and events and preparing to respond as needed) and executing an appropriate response to such objects and events (i.e., as needed to complete the DDT and/or DDT fallback [fallback to driver]).

0: https://www.sae.org/blog/sae-j3016-update

Those are SAE’s criteria but I wonder what Federal and state DoT’s have to say about the matter.

Props to SAE for making their spec free do download, modulo a gratuitous account.

> L3 driving is only available at low speeds, approx 35mph

In that case, this paragraph from the article doesn't make much sense (in fairness, it was on pretty shaky ground to begin with):

> Mercedes’ Level 3 conditionally automated driving assistant can, on suitable highway sections [emphasis added] and where traffic density is high, offer to take over the driving, leaving the driver free to do something else, like watch a movie or participate in a meeting.

It's for people stuck in traffic on a congested highway.

Highways during rush hour in many cities have traffic that moves very slowly for many miles/hours. This L3 is perfect for those situations where people are reading books during the stop and go.

Then why does the article claim Mercedes is the first automaker to offer L3 driving?

The difference is the confidence level. The required level of supervision. Other cars, like Teslas, can “do” this task, but not with enough certainty that they are safe to do it while not being actively monitored by a driver.

Teslas did this years ago. The standard autopilot could do this, at speeds up to 100miles/hour.

Later, they add the nag. 2018 I think.

Yes, at SAE J3016 level 2.

The big difference is MB is taking liability in the event of a collision and he car won’t simply hand control back to the driver. This is much more advanced than any L2 system and the fact MB is taking liability is a whole different ballpark.

In Germany (where this system is already available) Mercedes takes liability and the system gives the driver a 10 second advanced warning before they have to take over.

It's also only available on certain stretches of the Autobahn. If the system allows you to enable it, you can use it. The German law allows autonomous driving up to 130 km/h although Mercedes currently only allows their system to work up to 60 km/h.

> Mercedes takes liability

This has to be the standard for all but the most egregious examples of other-driver-at-fault crashes. That, together with marketing standards, e.g. you can say FSD but you have to also say Level 2, should help clean things up while incentivizing good development.

Certainly.

But companies will offer this only if the downside risk is bearable. Which, (IANAL) is quite certainly much bigger in the US than in Germany.

> companies will offer this only if the downside risk is bearable

Is the liability in Germany uncapped?

Didn't find anything, but I imagine it's similar to normal car insurance. In Germany most insurances are capped at 100m (legal minimum is 7.7m). Most expensive accident in history was 32m.

It's important to note that healthcare is much cheaper in Germany than in the US. In addition to that, compensation for injuries also tends to be much lower. That massively affects the costs of accidents.

In Germany if you are liable for an accident the health insurance of the affected people will bill you for all incurring costs. At market rate, not at "health insurance discount" rate. I wouldn't bet that the cost in that case is lower than in the US.

US users are apparently confused. Germany does not have universal healthcare, everything is priced differently if you pay out of pocket.

>The German law allows autonomous driving up to 130 km/h although Mercedes currently only allows their system to work up to 60 km/h.

That's weird; usually laws are behind the tech, not ahead of it.

Sometimes it pays off to have a cool head with tech too: have you ever seen a broken down Mercedes on the side of the road? Well, I just thought about it too, and no, never.

So it is only usable in congested Autobahn traffic to begin with - it's the minimum speed you're allowed to drive on a clear road.

Mean speed is somewhere at ~110km/h (and you're on the slower end in my experience if you go 110 km/h).

> The first part of the article mentions the driver being able to take a meeting or watch a movie.

I think the idea here is that typical executive meetings ( which of course Mercedes owners would be) are monotonous and boring and it would not take more than 20% of your attention in any case.

Roughly same for movies as it has to be Hollywood franchise movies which even if one is watching first time, it still feels like seeing same thing thousand times before. And now concentrating on road looks more interesting than movie.

All Mercedes has to do is put `*` on Movies/Meetings and define them appropriately to be on firm legal grounds.

It is 100% attention. The caveat is there is ample time after the car notifies you to take control where you put down your task, look around and gain situational awareness. How often that happens is a question. Seemingly rare enough you could reliably do a meeting, that latter part is just a presumption though.

No '*', Mercedes takes full responsibility and there are many seconds before it shifts control (and liability). The system can reliably predict when it will want to give back control.

Right, these things seem worse than nothing if they're good enough to make you completely distracted, paying no attention to the road, but them dump control over to you the minute something unexpected happens.

That describes Tesla FSD, not this. Tesla does level 2 in more varied of situations, but that warning time before taking control is a very key difference. Enough that you can pay 0 attention to be able to look around and see what's up before taking control (vs, you're expected to swerve the car when it fails)

Why? As far as I can tell, people already watch their smartphones while driving at level zero.

Not legally.