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A comment on Ars Technica: "It is important to note that they are using the UNECE Level 3 certification loophole which technically demands that the company tak

A comment on Ars Technica: "It is important to note that they are using the UNECE Level 3 certification loophole which technically demands that the company takes responsibility, but sets the minimum intervention interval for the driver at zero seconds for the under 60km/h case. That means, as long as the car exits its autonomous mode before a crash, the driver is instantly fully responsible. It's level 2 in all but name. There are also practically no certification or safety requirements, hence why several manufacturers have announced their gimped level 2 system as level 3 when under 60km/h, among them Honda in 2021 and BMW in 2022, all of course claiming to be the worlds first." https://arstechnica.com/cars/2023/09/mercedes-benzs-level-3-autonomous-driving-system-takes-over-in-heavy-traffic/?comments=1&comments-page=1 https://arstechnica.com/cars/2023/09/mercedes-benzs-level-3-...

tyrfing 3y ago
Here's what MB says in their press release: > If the driver fails to take back control even after increasingly urgent prompting and expiration of the takeover time (e.g., due to a severe health problem), the system brakes the vehicle to a standstill in a controlled manner while engaging the hazard warning lights. From the CA DMV: > Mercedes-Benz is the fourth company to receive an autonomous vehicle deployment permit in California and the first authorized to sell or lease vehicles with an automated driving system to the public.
rtkwe 3y ago
I can't tell from that if it's stating what MB is actually doing or if that's just a technical loophole in the UNECE definition.
FireBeyond 3y ago
Said Ars comment comes from someone whose history is openly pro Tesla, pro Musk and denigrating of any competitors, offers no sources, and is in contradiction to numerous other sources.
- toomuchtodo 3y ago
  As opposed to Anti Tesla folks who are impressed by MB's (who doesn't make EVs in any meaningful quantity) PR puff piece? Great, they're on track for 150k EV sales this year. Tesla will sell ~2M units, 4x total Mercedes Benz annual volume. We get it, "Tesla Bad." They are the only automaker selling EVs at volume besides Chineses automakers (which are limited to the Chinese auto market), and they are what consumers are preferring (with the Model Y being a best seller in various large markets). You might not agree with consumer preferences, but their dollars and how they vote with them are what matter, while regulators are sufficiently tolerant of Tesla's various Autopilot driver assist flavors (AP1, AP2, AP2.5, Enhanced Autopilot with Auto Lane Change) as well as their Full Self Driving beta to not require they be pulled from the US consumer fleet. One can be "Elon musk is not a decent human being" but also "Tesla makes EVs people will trip over themselves to buy, and we need as many popular EVs as possible to contribute towards solving for the transportation emissions component of climate change." PR pieces do not destroy demand for petroleum or reduce combustion emissions, EVs shipped do.
  - FireBeyond 3y ago
    > regulators are sufficiently tolerant of Tesla's various Autopilot driver assist flavors (AP1, AP2, AP2.5, Enhanced Autopilot with Auto Lane Change) as well as their Full Self Driving beta to not require they be pulled from the US consumer fleet. Regulators are also sufficiently tolerant of MB's efforts (sorry, "puffery"): > currently certified for use in California and Nevada Yes, MB (who I have no love for) is ramping up EV manufacture. Tesla beat everyone to the punch. > Tesla will sell ~2M units, 4x total Mercedes Benz annual volume. Huh, going to disagree there: > 2022 (January to December): Mercedes-Benz Passenger Cars delivered 2,043,900 vehicles
    - toomuchtodo 3y ago
      > 2022 (January to December): Mercedes-Benz Passenger Cars delivered 2,043,900 vehicles I stand corrected, and appreciate the correction as I strive for accuracy. My stat was wrong, pulling from a quarter vs the entire year. Tesla shipped almost as many EVs as Mercedes Benz shipped entirely, vs 4x.
Veserv 3y ago
Can you please fact check that statement? No source or quote was provided and I see no mention in the regulation. Here is the regulation they are talking about: https://unece.org/sites/default/files/2022-05/ECE-TRANS-WP.29-2022-59r1e.pdf https://unece.org/sites/default/files/2022-05/ECE-TRANS-WP.2... On page 17, Section 5.4 they discuss: "Transition demand and system operation during transition phase". In Section 5.4.3: "During the transition phase the system shall continue to operate." In Section 5.4.3.2: "During the transition phase, the transition demand shall be escalated latest after 4 s after the start of the transition demand." In Section 5.4.4: "A transition demand shall only be terminated once the system is deactivated or a minimum risk manoeuvre has started." In Section 5.4.4.1: "In case the driver is not responding to a transition demand by deactivating the system (either as described in paragraph 6.2.4., or 6.2.5.), a minimum risk manoeuvre shall be started, earliest 10 s after the start of the transition demand." In Section 5.5: "Minimum Risk Manoeuvre" In Section 5.5.1: "The minimum risk manoeuvre shall bring the vehicle to a standstill unless the system is deactivated by the driver during the manoeuvre." In Section 5.5.3: "A minimum risk manoeuvre shall only be terminated once the system is deactivated or the system has brought the vehicle to a standstill." In Section 6.2.4: "It shall be possible to manually deactivate..." In Section 6.2.5: "In addition to paragraph 6.2.4, the system shall not be deactivated by any driver input other than those described below..." In Section 6.2.5.1.: "Deactivation by input to driving controls..." In Section 6.2.5.2: "Deactivation during an ongoing transition demand or an ongoing minimum risk manoeuvre. In case a transition demand or minimum risk manoeuvre is on-going, the system shall only be deactivated: (a) As defined in paragraph 6.2.5.1. or (b) Upon detection that the driver has taken hold of the steering control as a response to the transition demand or minimum risk manoeuvre and provided the system confirms the driver is attentive as defined in paragraph 6.3.1.1." So, the car remains in control during hand-off until a driver actively takes back control. The hand-off process must last a minimum of 10 seconds where the car is expected to operate as normal. In the event that the driver does not take control, the car is required to automatically come to a stop without relinquishing control. At no point can the car automatically transfer control to the driver except after fully executing a minimum risk manoeuvre and coming to a halt, or if a emergency manoeuvre is required (at which point the emergency manoeuvre system is in control).

tyrfing 3y ago

Here's what MB says in their press release: > If the driver fails to take back control even after increasingly urgent prompting and expiration of the takeover time (e.g., due to a severe health problem), the system brakes the vehicle to a standstill in a controlled manner while engaging the hazard warning lights. From the CA DMV: > Mercedes-Benz is the fourth company to receive an autonomous vehicle deployment permit in California and the first authorized to sell or lease vehicles with an automated driving system to the public.

rtkwe 3y ago

I can't tell from that if it's stating what MB is actually doing or if that's just a technical loophole in the UNECE definition.

FireBeyond 3y ago

Said Ars comment comes from someone whose history is openly pro Tesla, pro Musk and denigrating of any competitors, offers no sources, and is in contradiction to numerous other sources.

toomuchtodo 3y ago
As opposed to Anti Tesla folks who are impressed by MB's (who doesn't make EVs in any meaningful quantity) PR puff piece? Great, they're on track for 150k EV sales this year. Tesla will sell ~2M units, 4x total Mercedes Benz annual volume. We get it, "Tesla Bad." They are the only automaker selling EVs at volume besides Chineses automakers (which are limited to the Chinese auto market), and they are what consumers are preferring (with the Model Y being a best seller in various large markets). You might not agree with consumer preferences, but their dollars and how they vote with them are what matter, while regulators are sufficiently tolerant of Tesla's various Autopilot driver assist flavors (AP1, AP2, AP2.5, Enhanced Autopilot with Auto Lane Change) as well as their Full Self Driving beta to not require they be pulled from the US consumer fleet. One can be "Elon musk is not a decent human being" but also "Tesla makes EVs people will trip over themselves to buy, and we need as many popular EVs as possible to contribute towards solving for the transportation emissions component of climate change." PR pieces do not destroy demand for petroleum or reduce combustion emissions, EVs shipped do.
- FireBeyond 3y ago
  > regulators are sufficiently tolerant of Tesla's various Autopilot driver assist flavors (AP1, AP2, AP2.5, Enhanced Autopilot with Auto Lane Change) as well as their Full Self Driving beta to not require they be pulled from the US consumer fleet. Regulators are also sufficiently tolerant of MB's efforts (sorry, "puffery"): > currently certified for use in California and Nevada Yes, MB (who I have no love for) is ramping up EV manufacture. Tesla beat everyone to the punch. > Tesla will sell ~2M units, 4x total Mercedes Benz annual volume. Huh, going to disagree there: > 2022 (January to December): Mercedes-Benz Passenger Cars delivered 2,043,900 vehicles
  - toomuchtodo 3y ago
    > 2022 (January to December): Mercedes-Benz Passenger Cars delivered 2,043,900 vehicles I stand corrected, and appreciate the correction as I strive for accuracy. My stat was wrong, pulling from a quarter vs the entire year. Tesla shipped almost as many EVs as Mercedes Benz shipped entirely, vs 4x.

Veserv 3y ago

Can you please fact check that statement? No source or quote was provided and I see no mention in the regulation. Here is the regulation they are talking about: https://unece.org/sites/default/files/2022-05/ECE-TRANS-WP.29-2022-59r1e.pdf https://unece.org/sites/default/files/2022-05/ECE-TRANS-WP.2... On page 17, Section 5.4 they discuss: "Transition demand and system operation during transition phase". In Section 5.4.3: "During the transition phase the system shall continue to operate." In Section 5.4.3.2: "During the transition phase, the transition demand shall be escalated latest after 4 s after the start of the transition demand." In Section 5.4.4: "A transition demand shall only be terminated once the system is deactivated or a minimum risk manoeuvre has started." In Section 5.4.4.1: "In case the driver is not responding to a transition demand by deactivating the system (either as described in paragraph 6.2.4., or 6.2.5.), a minimum risk manoeuvre shall be started, earliest 10 s after the start of the transition demand." In Section 5.5: "Minimum Risk Manoeuvre" In Section 5.5.1: "The minimum risk manoeuvre shall bring the vehicle to a standstill unless the system is deactivated by the driver during the manoeuvre." In Section 5.5.3: "A minimum risk manoeuvre shall only be terminated once the system is deactivated or the system has brought the vehicle to a standstill." In Section 6.2.4: "It shall be possible to manually deactivate..." In Section 6.2.5: "In addition to paragraph 6.2.4, the system shall not be deactivated by any driver input other than those described below..." In Section 6.2.5.1.: "Deactivation by input to driving controls..." In Section 6.2.5.2: "Deactivation during an ongoing transition demand or an ongoing minimum risk manoeuvre. In case a transition demand or minimum risk manoeuvre is on-going, the system shall only be deactivated: (a) As defined in paragraph 6.2.5.1. or (b) Upon detection that the driver has taken hold of the steering control as a response to the transition demand or minimum risk manoeuvre and provided the system confirms the driver is attentive as defined in paragraph 6.3.1.1." So, the car remains in control during hand-off until a driver actively takes back control. The hand-off process must last a minimum of 10 seconds where the car is expected to operate as normal. In the event that the driver does not take control, the car is required to automatically come to a stop without relinquishing control. At no point can the car automatically transfer control to the driver except after fully executing a minimum risk manoeuvre and coming to a halt, or if a emergency manoeuvre is required (at which point the emergency manoeuvre system is in control).