New car registrations in Europe’s largest car market achieved the highest volume since 2009 amounting to 3,441,262, up 2.7% from the year before.
Data from German KBA showed that growth in Mercedes-Benz (+15,000 units) and volume brands, led by Peugeot (+14,000) and Dacia, compensated for the losses in premium brands, especially VW Group’s Audi, Porsche and Volkswagen.
Drivers will be able to experience Conditional automation (SAE Level 3) for the first time in 2018. But validation requirements and safety regulation will restrict customer availability- at least for the first half of 2018.
SAE Level 3 systems combine enhanced levels of sensor redundancy and robustness to be able to control steering, braking and accelerating under their operational domain, thus allowing drivers to turn their attention away from the road, i.e. “eyes-off the road”. However, a handover of control is required between the driver and the system so the driver must be available to takeover.
At the same time, more carmakers are launching Level 2 driving and parking features. More importantly, these features will not be the exclusive privilege of premium cars anymore as more and more Volume OEMs launch assistance systems to meet consumer demand and safety ratings.
Let’s look at some of the most important automated technology coming in new cars in 2018. We concentrate on driving features used in traffic jam situations and parking.
1. AI Traffic Jam Pilot (SAE Level 3-Driving) & AI Remote Parking (Level 2-Parking) in the 2018 Audi A8
Functionality: Audi states that “On highways and multi-lane motorways with a physical barrier separating the two directions of traffic, the Audi AI traffic jam pilot takes over the driving task in slow-moving traffic up to 60 km/h (37.3 mph). The system handles starting from a stop, accelerating, steering and braking in its lane. If the driver has activated the traffic jam pilot at the AI button on the center console, they can take their foot off the accelerator and their hands off the steering wheel for longer periods.
Unlike at level 2, they no longer need to monitor the car permanently and, depending on current national regulations, can turn to other activities supported by the on-board infotainment system. The driver must remain alert and capable of taking over the task of driving when the system prompts them to do so.”
Why it is important: It is the first-ever Level 3 in series production. To achieve the levels of redundancy and robustness the vehicle is also equipped with a laser scanner as an additional forward-looking sensor to the long-range radar and camera.
We expect other major carmakers introducing L3 to utilise an additional forward-looking sensor for redundancy, apart from Tesla, but not everybody believes that it should be a lidar- with ther carmakers might use a high-resolution radar. So far the high cost of lidar has been an obstacle to deployment but Audi’s strategy to enter series production and achieve economies of scale shows positive signs for higher sensor penetration.
The new A8 also has a redesigned central driver assistance controller called zFAS, which generates an image of the surroundings while driving by fusing sensor data. At the same time, a second data fusion takes place in the radar control unit.
Availability: Incrementally from early 2018 depending on the legal situation in the respective country. Even though deliveries of the first-ever Level 3-equipped car have just started, drivers won’t be able to experience “eyes-of-the-road” just yet because the AI Traffic Jam Pilot in Audi’s flagship A8 will be activated when it collects enough data for validation purposes. We expect that activation will occur by mid-2018.
Audi says that “Introduction of the Audi AI traffic jam pilot requires both clarity regarding the legal parameters for each country and specific adaptation and testing of the system”.
Introduction of the Audi AI traffic jam pilot requires both clarity regarding the legal parameters for each country and specific adaptation and testing of the system. Moreover, varying worldwide homologation procedures and their deadlines must be observed. Audi
Automated Driving System (ADS) name & level of automation: AI Remote Parking, SAE Level 2-Parking
Functionality: The Audi AI remote parking pilot and the Audi AI remote garage pilot autonomously steer the A8 into and out of a parking space or a garage, while the maneuver is monitored by the driver. The driver need not be sitting in the car. They start the appropriate system from their smartphone using the new myAudi app. To monitor the parking maneuver, they hold the Audi AI button pressed to watch a live display from the car’s 360 degree cameras on their device.
Why it is important: Audi’s first self-parking feature brings the brand in parity with Tesla, BMW and Mercedes-Benz in terms of Level 2 self-parking features.
2. Active Distance Assist DISTRONIC & Active Steering Assist (Level 2-Driving) in the Mercedes-Benz S-Class
The updated S-Class, with the redesigned multi-function steering wheel providing direct access to the driver assistance systems, launched in autumn 2017 but we include it here because we expect an upgrade to Level 3 within 2018.
Functionality: The Active Distance Assist DISTRONIC and Active Steering Assist now provide even more comfortable support for the driver to keep a safe distance and steer. The speed is now adjusted automatically ahead of bends or junctions.
Why it is important: Mercedes-Benz describes the updated S-Class as a “Level 2 Plus” car, to showcase the improvements made in the L2 Drive Pilot firstly-introduced in the E-Class.
Mercedes-Benz’s decision to “restrict” the S-Class to Level 2 was primarily driven to the uncertainty of the regulatory framework. Once the amendment of international regulation progresses, allowing the approval of Level 3, we expect that Mercedes-Benz will “unlock” the full potential of its flagship.
Read more about how the regulatory framework for Autonomous Driving evolves here.
3. Super Cruise (Level 2-Driving) in 2018 CT6 prestige
Functionality: It’s a highway driving automation technology that will enable hands-free driving even in stop-and-go traffic in lidar-mapped highways.
Cadillac’s system is a more conservative approach than Autopilot and other L2-Driving features in that hands-free is confined to pre-lidar USA and Canada mapped motorways, so no city driving.
What it is important: It’s GM’s first-ever Level 2 system for highways. To keep drivers in the loop, Cadillac will feature a driver attention system which uses a small camera located on the top of the steering column and works with infrared lights to determine where the driver is looking whenever Super Cruise™ is in operation.
Availability: Firstly in the USA and Canada in 2018 and later in China.
4. Connected Pilot (Level 2-Driving) in DS7 Crossback
Functionality: The Connected Pilot will be capable of maintaining lane and positioning itself to the left or right of the lane to allow cycles or motorcycles to pass.
What it is important: PSA’s first model to offer Level 2-Driving & Level 2-Parking. The L2 systems present on the DS 7 Crossback will spread across the PSA Group onto Peugeot and Citroen models not long after it hits UK showrooms in 2018.
5. ProPilot Assist (Level 2-Driving) and ProPark (Level 2-Parking) in new Nissan Leaf
What it is important: Nissan launched the feature first in Japan in 2016. The 2nd gen Leaf will be the 1st Nissan in Europe to feature a Level 2-Driving system following its release in Japan in 2016.
Nissan will gradually roll-out more advanced autonomous drive technologies until 2020. By 2018, an updated version of the ProPilot (2.0) will be introduced with multiple-lane capabilities, followed by intersection capabilities for urban scenarios by 2020 (ProPilot 3.0).
Deployment of higher levels of autonomy, SAE Level 3-5, is subject to national regulatory approval with inherent differences in the way regulation works in the USA versus Europe and China;
USA’s approach to Autonomous Driving is key for harmonisation of safe and secure ADS testing and deployment but USA seems to follow a standalone policy to give domestic stakeholders an advantage;
Although USA’s non-binding guidelines do not impede deployment of L3-4, which promises to reduce road deaths and road stress, they raise concerns over enforcement of safety standards and harmonisation across states;
New Trump administration has delayed progress in key cybersecurity and V2V bills while creating further uncertainty on their final implementation.
Status of AV law in the U.S, Q3-2017 / Source: ncsl.org
NHTSA’s updated guidance does not impede deployment by choosing non-binding guidelines instead of a mandate
12th September, saw the USDOT updating its voluntary guidelines for Autonomous Driving Systems, defined as SAE Level 3-5 systems, by releasing the “AUTOMATED DRIVING SYSTEMS- A Vision for Safety version 2”. The new guidance is an update of the voluntary guidelines for HAVS based on comments received on the Federal Autonomous Vehicle Policy’s (Sep’2016).
The first section of the guidance, titled “Voluntary Guidance” contains 12 priority safety design elements which entities are encouraged to consider when designing ADSs. These elements comprise:
Operational Design Domain
Object and event detection response
Fall back (minimal risk condition)
Consumer education and training
Federal, State and Local laws
Additionally, the agency recommends that entities have a self-documented process for assessment, testing, and validation of the various elements.
A key point is that NHTSA still encourages manufacturers to submit “Voluntary Safety Self-Assessments” (12-point list) demonstrating approaches for safe ADS testing and deployment, but it does not require them.
The purpose of this Voluntary Guidance is to help designers of ADSs analyse, identify, and resolve safety considerations prior to deployment using their own, industry, and other best practices
USDOT, ADSv2 (Sep’17)
The second section of the guidance, the “Technical Assistance to States” clarifies the role of the Federal government and also includes best practices for Legislatures and State Highway Safety Officials.
USA’s updated guidance removes certain obstacles for carmakers
Here are the most significant changes between the new guidance (ADSv2) and the old one (FAVP)
Most of the Auto Alliance’s recommendations/comments on the FAVP made it to the ADSv2. In detail, 3 items were removed from the FAVP’s 15-point Vehicle Performance Guidance: Privacy and data sharing, Registration & Certification and Ethical Considerations;
Another key point removed is the FAVP’s willingness to shift from its current regulatory regime of “self-certification post-fitment” to a ‘’Pre-market approval of HAVs” which has caused significant concern;
The new guidance’s second section incorporates common safety-related components and significant elements regarding ADSs that States should consider incorporating in legislation. NHTSA’s authority remains on design, construction and performance of ADSs;
Finally, “NHTSA strongly encourages States not to codify this Voluntary Guidance as a legal requirement for any phases of development, testing, or deployment of ADSs. Allowing NHTSA alone to regulate the safety design and performance aspects of ADS technology will help avoid conflicting Federal and State laws and regulations that could impede deployment”.
But it fails to address the key concerns
Guidelines have immediate effect against what might be a lengthy rulemaking process but NHTSA’s guidance raises concerns over enforcement of safety and security standards. Enforcement of voluntary guidelines for safe testing and deployment is weaker than a rulemaking procedure and without the latter’s objectivity, such as notice and comment, due process or judicial review.
It lacks clear legal guidance for ADS manufacturers on performance metrics, potential mandate and updatability. NHTSA’s own FAPV noted that “the absence of established metrics could make it more difficult for OEMs to anticipate the Agency’s evaluation and conclusions regarding the safety of their vehicles’ performance. Another key issue is whether the ODD’s data truly represent real-world conditions.
Harmonisation across states is a key challenge for the USA. It requires state collaboration which has been proven difficult. The SELF DRIVE Act and the LEAD’R Act are positive steps in this direction but both are in early stages.
The Trump’s administration creates uncertainty. This has been demonstrated by the slow progress with Cyber security regulation, i.e. SPY Act as well as FMVSS 150: V2V communication.
Cadillac’s SuperCruise is a SAE Level 2 feature enabling hands-off-the-steering wheel in highways but requires constant monitoring / Source: Cadillac
Still significant opportunities exist in the USA from its regulatory approach
While European carmakers, mostly German, lead the SAE level 2 in terms of deployment and sales volume, L3 deployment in Europe is currently restricted by the regulatory and legal framework.
The USA presents a favourable environment for testing whereas deployment is subject to both federal and state rules, which are less restrictive than in Europe, Japan and China. USA’s progressive regulatory stance on deployment of higher levels of technology, coupled with significant investment from tech giants which focus on AD platforms, software and AI can give them an edge provided that the key issues of harmonisation and cybersecurity are adequately addressed.
July 11’s launch of the first-ever Level 3 capable car marks a new era in Autonomous Driving. However, L3 deployment is still subject to regulatory approval. What’s more, the regulatory and legal framework differs across leading car markets.
Here are some insights on which geographies present the most favorable environment for L3 deployment.
Highly-automated driving will be legal in Germany from Sep’17 giving a head start to German brands who are closer to delivering L3. This demonstrates the country’s ambition to be in the forefront of Autonomous driving -not only testing but crucially deployment- ahead of the U.S.A.
Germany will lead L3 deployment in Europe but standardization across Europe is threatened by delays in the amendment process of Regulation No.79.
U.S.A offers a favorable environment for L3 deployment since approval of testing and deployment is at state level while NHTSA’s Federal Autonomous Vehicle Policy is non-binding. But standardization across states is an issue as inconsistencies between state AV regulations exist.
What’s more, there is a concern that the U.S. is pursuing a go-it-alone strategy in an effort to give the domestic industry an advantage. On the contrary, Japan’s government wants to develop international standards for AD through the U.N. World Forum for Harmonization of Vehicle Regulations and Europe is focused on safe and secure deployment with the amendment of Reg.79.
Finally, technology deployment in the world’s largest car market is at risk as delays in Europe’s regulatory amendment have initiated discussion to adopt an earlier version of automated steering regulation which does not include provisions for L3-4.
For an in-depth analysis of the Autonomous Driving regulation in major car markets and how it will affect the AD roadmap of leading carmakers read our report Roadmap to Self-Driving cars.
ADAS & Automated Driving features increasingly become key product differentiators
With Audi teasing its upcoming A8 with emphasis on automated driving capabilities, we present some findings from our latest report on key ADAS feature penetration and their growth potential over the next five years.
Audi’s new flagship will be the first vehicle to feature a Traffic Jam Pilot which will bring Audi to Level 3 in terms of driving features. At the same time it will also offer L2 Remote Parking, bringing Audi to parity with Mercedes-Benz, BMW and Tesla in terms of L2 parking capabilities -all of them offer either Self-Park, Remote Park or both.
While today, Level 3 deployment is constrained geographically by regulatory approval, key car markets are giving the green light. Our report provides in-depth analysis of how the regulatory framework affects OEM strategy as well as Level 3 deployment.
We expect that in 2021, 17% of new car sales in Europe will offer Highly-Automated Driving (Level 3) features as optional or standard, the majority of which will come from premium car manufacturers.
By then, feature functionality will have expanded from the low-speed, single-lane Traffic Jam Pilot to more advanced Highway Pilots.
Read our report to understand carmakers’ strategies to reach higher levels of vehicle autonomy and the opportunities they create for ADAS sensors, AD platforms as well as collaborations.
Level 2 penetration in Europe reached 6.5% in 2016 with German OEMs holding the lion’s share
While the introduction of Level 3 is big news, especially since the debate over its risk-reward as an intermediate level between Supervised (Level 0-2) vs Unsupervised driving (L4-5) continues, it’s Level 2 that makes its way into new car sales, especially in Europe.
In 2016, 22 models from 8 car manufacturers offered (SAE) L2 driving capabilities globally. BMW led the market both in terms of market share in Level 2 offerings but also in terms of share in total L2 sales in Europe.
As a result, sales of cars fitted with Level 2 Traffic Jam Assist as standard or optional equipment reached almost 1 million in Europe in 2016, accounting for 6.5% of the 15.13 million car sales in Western Europe.
Nissan is among the carmakers introducing Level 2 functionality in Europe this year with the ProPilot Assist in the new Leaf, Qashqai and the X-Trail. Nissan’s technology, which will later expand to unlock multi-lane cruising support, was launched last year in Japan in the new Serena.
We expect that in 2019, at least 50 models will be equipped with Traffic Jam Assist or Cruise Assist in Europe, with premium OEMs’ share accounting for 74%.
Here’s a table with the marketing names used by carmakers for their Level 2 Driving features.
To learn more insights on ADAS and Automated Driving, including strategy and roadmap of leading carmakers read our latest report Roadmap to Self-Driving Cars.
For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, email@example.com.
Extensive data recording of “critical events” while in L3 to assist in accident reconstruction and liability
Today, in Level 0-2, the driver’s inattention at any given point in time triggers his liability
Level 3- Conditional “eyes-off”, hitting the road by the end of 2017, has implications for the determination of liability because the driver will be conditionally allowed to be “distracted” but he is still required to be “available”
Impact on traditional vehicle insurance as well as carmakers, given the significant engineering challenges to implement extensive data recording amid an immature regulatory framework
Carmakers to accept liability while in L3 automated mode but drivers must not sleep or move away from the seat- emergency vehicle stop if the driver fails to respond to takeover request
Why we need Event Data Recorders (EDR) for automated driving
Existing EDR capability is focused on the seconds around a crash (e.g. 30 seconds before and 15s after the crash) while data capturing needs for Automated Driving may cover a much broader period and require longer storage.
In Level 3, when the system is active and when it becomes legal for drivers to be partially distracted by ADAS, drivers will be able to relax, read, text, call, watch TV, but not sleep or move from their seat because they must always be available to takeover vehicle control when the system signals a transition demand or in case of a system malfunction. But the driver will still be responsible for the overall vehicle control even when the system is active and will have the ability to override it.
In case a “critical event” occurs while the ADS is active, which might expand from an accident to include traffic law violations, data recording capabilities will be required to contribute to accident reconstruction and potentially assist in supporting claims against the manufacturer.
Data recording would be useful to understand if the system failed or transferred control to the driver who failed to ‘’react’’
Therefore, we assess that AD event data recording requirements will be both an engineering prerequisite and a regulatory/legal requirement for deployment and legality to accommodate ‘’critical events’’ and ‘’automated driving mode’’. In the words, to make sure that effective driver monitoring is in place and, when needed, control can be handed back to a driver who is fit and able to drive the vehicle.
What is more, it will be necessary to be able to access the vehicle data in order to determine the circumstances surrounding a given incident, any possible defect or fault in the system, or whether the vehicle was operating under a partially/fully automated mode.
Immature regulatory guidance on data recording and storage for Automated Driving challenges deployment
There is a consensus that EDR-AD will be a regulatory prerequisite for the deployment of L3 as demonstrated by the requirements for EDRs-AD in the amendment of the German Road Traffic Act and the amendment of Reg.79 which already mentions DSSA capabilities -although at a draft status. The problem is that regulatory action is at an early stage therefore guidance on engineering requirements is still immature. We expect though that this will not restrict car manufacturers and suppliers to put EDR-AD in place for L3.
Germany has already passed a law that will allow L3 as long as data recording and sharing are in place and systems are compliant with relevant international regulation. Furthermore, Germany and the UK are among the key car markets which have already started procedures to adjust their road traffic laws/acts to accommodate L3.
On the contrary, the U.S follows a standalone policy based on the star-by-state control of AD regulation and the voluntary federal guidelines which might cause lack of standardisation.
Amid the immature regulatory framework, carmakers face the challenge to design and implement data recording capabilities that will cover the minimum (expected) regulatory requirements but also cover them above and beyond in terms of product liability.
Learn about leading OEMs’ ADAS & Autonomous Driving roadmap and strategies
Auto2x’s latest report examines the current status of autonomous vehicle deployment including the ADAS&AD portfolio of 24 leading OEMs, the engineering and regulatory challenges for high levels of autonomy and the business models to overcome and monetise them. Finally, we provide a technological roadmap for the introduction of L2-5 by leading OEM and a penetration forecast of cars equipped with different levels of autonomy over the next decade.
Read about our key findings:
2017 will see the introduction of technology that allows “eyes-off” the road
2017 is the year of transition from Partially-automated cars (SAE L2), where drivers are in complete control with ADAS providing assistance for safety and convenience, to Conditionally-automated ones (L3) which can take over the driving and monitoring task under specific scenarios allowing the driver to be ‘’distracted’’. However, in L3 the driver will still be the ultimate back-up and must remain ‘’available’’ to regain control within a few seconds of the
Level 3 deployment is still subject to regional regulatory approval. What’s more, the regulatory and legal framework differs across leading car markets. This could result in lack of harmonisation and restrict standardisation, adversely impacting the adoption of higher levels of vehicle autonomy.
Germany legalises Level 3 automated driving giving a head-start to German carmakers
Germany wants to be in the forefront of Autonomous driving (testing and deployment) ahead of the U.S. therefore it has amended the German Road Traffic Act (Straßenverkehrsgesetz, StVG) to allow domestic car manufacturers, which already are closer to L3, to deploy their systems in the market. Deployment of L3 in Germany would be possible under the new framework, but also provided that systems are compliant with UNECE regulations and data recording for accident reconstruction and claims.
The transition from driver-centric regulation to Automated Driving Systems is necessary for the deployment of higher levels of vehicle autonomy. Amendment in international regulations and national traffic laws will soon give the green light for deployment but will there be regional inconsistences between what’s legal?
Another OEM skips L3 as the debate for Conditionally-Unsupervised driving continues
Volvo is now added to the list of carmakers pulling away from deployment of Level 3 with the CEO characterizing the handover of vehicle control as unsafe. The company claims they will only offer (completely) unsupervised autonomous mode when it’s safe, for which it will assume full responsibility. This comes a few months away from the first-ever L3-equipped car from Audi.
Different OEM strategies over Supervised vs Conditionally and Completely-Unsupervised driving
This development is another demonstration of the different approaches leading car manufacturers are following to commercialize automated driving amid the engineering, regulatory and consumer adoption hurdles.
The industry is currently facing a debate over supervised (L0-2) vs (optionally) unsupervised driving (L4-5) and whether an intermediate” level (L3), where the system can monitor but drivers have to takeover in case of an emergency is safe and adds value to owners. Thus, the commercialisation of L3 is uncertain given the high cost/benefit ratio, i.e. the marginal impact on safety and driver convenience from L2 comparing to the massive engineering challenge.
Partially-automated (L2) model offerings expand to the compact segment
At the same time, more carmakers are introducing L2 parking and driving capabilities and expand L2 feature availability across their model range. What’s more important though is that L2 expands from premium large cars to the compact car segment. This breakthrough is another indicator that ADAS are no longer the privilege of flagships, premium large cars and luxurious SUVs since regulations, consumer requirements and competition drive fitment of ADAS.
Aggressive marketing contributes to customer confusion and leads to misuse and/or abuse of L2
L2’s purpose is to assist the driver but not substitute him by offering longitudinal and lateral assistance. L2 Traffic Jam Assists and Cruise Assists may allow a few seconds of hands-free driving
but do not have the system capability and redundancy to monitor the road-hence your hands-on-the steering- wheel are mandatory (from both technological and legal perspective) despite what you here from some aggressive marketing campaigns.
Engineering challenges to drive demand for sensors, SW and collaborations
A Mobileye executive has recently described the challenge and complexity of launching SAE L4, i.e. chauffer driving and valet parking features among others, with putting a man on the moon. Higher level of vehicle automation will require augmented sensor set, new architecture and innovative validation methods among others.
This will drive demand for sensors, supercomputers, high precision
maps etc. It will also drive further collaboration between OEMs and Tier 1s-2s for the development of AD platforms-be it L4 for car sharing or not.
New business models arise in the new era of smart mobility
Carmakers, Tier-1s and new-entrants, such as tech giants Apple and Google (Waymo) and MNOs compete in the autonomous vehicle race to establish a winning portfolio or just remain competitive.
L4/fully-automated vehicles will revolutionise transportation and mobility leading to what we call Intelligent Mobility. This includes the rising car-sharing and ride-sharing businesses as well as new
vehicle ownership models in the Passenger Car market. We analyse opportunities across the supply chain.
Current ADAS Level 2 systems assist but do not substitute the driver, i.e. provide longitudinal and lateral assistance enabling some limited hands-off driving but drivers must always be in control -due to regulation and system capabilities
Level 3 systems, enabling the car to take control of the driving and monitoring task, will hit the road this year but are subject to regulatory approval
Amendment of the German Road Traffic Act opens up the road for L3 in Germany but compliance with EU law is also required
Germany wants to be in the forefront of Autonomous driving (testing and deployment) ahead of the U.S. therefore it has amended the German Road Traffic Act (Straßenverkehrsgesetz, StVG) to allow domestic car manufacturers, which already are closer to L3, to deploy their systems in the market.
In April, the Bundestag, the lower house of the German parliament,approved the version therefore the only part missing for the amendment of the StVG to come into force was approval from the upper chamber of the German parliament, the Bundesrat. This came in May 12th, earlier than initially expected, removing the regulatory barrier for Audi who plans to deliver the first-ever L3 Traffic Jam Pilot in its updated version of the flagship A8.
Level 3 (SAE) vehicle automation represents a milestone in Autonomous Driving because when these features are active they can take over the monitoring task, together with the driving task, enabling drivers to take their “eyes-off” the road. But the driver must always be available to takeover, since he/she are the ultimate back-up. In case the driver is incapacitated and unable to take back control, adequate robustness must be in place to bring the vehicle into a safe stop, initially in lane.
To learn how Level 3 changes the driving task and how carmakers plan to get there read our post: Volvo to skip Level 3.
Today, even the most innovative ADAS systems for driving and parking, such as Mercedes’s Drive Pilot, Tesla’s Autopilot and BMW’s Remote Control Parking are classified under SAE’s definition as Level 2-Assistive. This means, that they can assist but cannot substitute the driver who must always be in control.
L3-Conditional automation to be legal in Germany from Sep’17 requiring EDRs-AD and compliance with UN-EU regs
Initially, this legislation was expected to pass Parliament before federal elections in September 2017, a timeline that aligns with the introduction of the L3-Traffic Jam Pilot from Audi in the 2018MY A8. However, the approval occurred earlier than expected demonstrating the German government’s willingness to promote the domestic market as the leader in Automated Driving which promises a zero-road death future and to unlock time for drivers to focus on other tasks beside driving while commuting.
The amendment of national traffic laws, together with the amendment of international Reg.79 which is expected to come into force by Oct’18, will open up the road for “hands-off and eyes-off” L3 (but not L4 yet). However, many issues remain open with the most important being what exactly will drivers be allowed to do in L3 and the specifications of data recording and sharing capabilities for Event Data Recorders (EDR) which will assist in determining liability when an accident occurs while the L3 system was driving.
Deployment of L3 in Germany would be possible under the new framework, but also provided that systems are compliant with UNECE regulations (e.g. Reg.79 or an exemption is granted) and EDRs (for L3) are fitted for accident reconstruction and claims.
EDR requirements for L3 are immature yet, with more information is expected to come before the finalisation of the law. Minimum requirements from the German draft law include recording of lateral control, system active status, and handover requests for accident reconstruction and insurance claims. Data must be available to relevant road traffic authorities upon request, as well as to any third party. From conversations with Tier 1s, we understand that EDRs for TJP are probably developed in-house by other OEMs rather than in collaboration with suppliers.
Audi to get a head start, other leading premium German OEMs and Tesla to follow
This gives an advantage to Audi since the brand’s launch date for L3-TJP with the new 2018MY A8 is in line with the law coming into force in Sep’17. Audi’s system will probably be categorised as ACSF B2 but we expect the brand to use EU’s Article 20 to get an exemption for the new technology.
Figure: Audi L3 Piloted Driving (Source: Audi)
We expect that other German-based OEMs which are technologically closer to L3 will also benefit, with BMW and Mercedes-Benz being the obvious candidates. Tesla will also benefit since it claims that it is close to L3 (Self-driving functionality). However, the company has been asked by the German government to change its Autopilot naming to avoid customer confusion and misuse/abuse.
The transition from driver-centric regulation to Automated Driving Systems is necessary for the deployment of higher levels of vehicle autonomy
The problem arises from the fact that vehicle regulation and national traffic laws have been developed with the driver in mind, i.e. driver in control. From a technological perspective, we have now reached the point where in certain markets the amendment of regulation is needed to allow Automated Driving Systems to take conditional and eventually full control of the driving task and monitoring of the road.
At the same time, national traffic laws might need to change to accommodate the new driving conditions, e.g. allow the complete absence of driving controls for L4/L5 or driver for L5. Amendments are in progress, to allow the driver to be ‘’out of the loop’’.
But will there be regional inconsistences between what’s legal given that the regulatory landscape in the U.S is different than the rest of the world’s major car markets?
To read more about Autonomous Driving regulation check our report Roadmap to Self-Driving Cars. For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, firstname.lastname@example.org.
Partially-automated model availability more than doubled in 2016
The number of models offering Partially-automated driving capabilities (L2-D) as standard or optional equipment rose by 144.4% in 2016 to 22 models, from just 9 in 2015. Growth was primarily driven by European automakers’ strategy to expand Traffic Jam Assist (TJA) offerings across their model range.
German car manufactures hold the lion’s share in Level 2-Driving feature offerings
What is more, the number of models offering Self-Parking (SP) capabilities tripled in 2016 amounting to 6 models, whereas those equipped with Remote Parking (RP) doubled to 4. Still though, capability of both L2 driving and parking (L2-D+P) is concentrated in a handful of premium brands’ models. In detail, only 3 car manufacturers, BMW, Mercedes-Benz and Tesla, offered 6 models equipped with TJA and SP as standard or optional equipment in 2016, of which only 4 also offered RP.
Some of our key findings for the availability of L2 in Europe in 2016:
Partially-automated model availability more than doubled in 2016
Audi, BMW and Mercedes are expanding their offerings of Level 2 Automated Driving across carlines but more importantly, TJA (L2) has now reached the compact car segment and volume OEMs including VW and Nissan.
2017 will see the introduction of technology that allows conditional “eyes-off” the road
Regulatory, engineering and other challenges for L3-5 deployment
Autonomous Driving regulation shifts from testing to deployment but standardisation will be a challenge 2016 saw a shift in the focus of regulation from approval of L3/4 testing to discussion for reforms to enable deployment of L3 in public roads. We expect regulatory action to continue stronger in 2017 as key car markets boost their efforts to lead the AV global scene but also guarantee safe and secure deployment.
The transition from driver-centric regulation to Automated Driving Systems is necessary for the deployment of higher levels of vehicle autonomy. Amendment of international regulations as well as national traffic laws will soon give the green light for deployment but will there be regional inconsistencies?
Volvo is now added to the list of carmakers pulling-away from deployment of Level 3 automated driving (at least for now) with the CEO characterizing the handover of vehicle control as unsafe.
This comes a few months away from the first-ever L3-equipped car from Audi which will conditionally allow drivers to take their eyes-off the road at low speeds and perform some side tasks but requires them to always be available to takeover within a few seconds. Volvo argues that this handover of control is unsafe and will only offer (completely) unsupervised autonomous mode when it’s safe, for which it will assume full responsibility.
Debate over supervised vs unsupervised driving modes-is an intermediate one a good idea?
Earlier, Ford and Google have also expressed a similar philosophy, with the latter basing its approach on the fact that intermediate levels were subject to abuse and/or misuse. More recently, Mercedes has expressed a similar approach, at least as long as it can guarantee the “best or nothing” moto. Thus, it’s expected the updated version of its (Level 2) Drive Pilot in the upcoming flagship S-Class will also be marketed as an Assistive Level 2 system, even though its capabilities could probably support Level 3.
Another key issue is that the deployment of an immature technology for the sake of remaining competitive could have continuous disengagements thus spoiling the driving experience and ruining customer attractiveness.
This development is another demonstration of the different approaches leading car manufacturers are following to commercialize automated driving amid the engineering, regulatory and consumer adoption hurdles. The industry is currently facing a debate over supervised (L0-2) vs (optionally) unsupervised driving (L4-5) and whether an “intermediate” level (L3), where the system can monitor but drivers have to takeover in case of an emergency is safe and adds value to owners.
2017 is the year of transition from Partially-automated cars (SAE L2), where drivers are in complete control with ADAS being purely assistive for safety and convenience, to Conditionally-automated ones (L3) which can take over the driving and monitoring task under specific scenarios allowing the driver to be ‘’distracted’’
What’s coming up from leading carmakers
Volvo will start testing its geo-fenced L4 Intellisafe technology using real families this year in Sweden with the Drive Me project, collecting data on system performance as well as feedback of driver acceptance of what will now be an “unsupervised” driving experience.
Mercedes-Benz is also collecting data for it’s automated driving technology in a project in Australia.
Tesla’s Enhanced Autopilot, which is equipped with an augmented sensor set and Tesla Vision – the proprietary image processing after the split with Mobileye- has almost reached feature parity with the original Autopilot (L0-2) with Musk promising Self-driving capabilities within the year.
Audi is expected to launch the new A8 in Germany, where the legal framework is currently being amended to allow L3, together with certain states in the Americas where the regulatory framework allows it. The feature is expected to initially run in the background until validation and verification is completed.
It’s up to the Germans now to prove that handover of vehicle control can be done safely, intuitively, without disrupting user experience, and that drivers will exploit the conditional eyes-off the road Traffic Jam Assist offers. If the outcome is successful, this head start will be crucial and determine the approach other carmakers follow to commercialise autonomous driving. It will also provide evidence to other key car markets to amend their legal and regulatory framework to allow conditional automation.
To read more about the strategies leading carmakers follow to unlock higher levels of automated driving check our report Roadmap to Self-Driving Cars. For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, email@example.com.