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Until the car requests intervention and the timer runs out, levels 3 and 4 are supposed to have the same behavior. If that process has not happened, why should the driver's level of responsibility be any different?

(Though a consequence is that levels 3 and 4 are very close together in difficulty. We might not see many level 3 cars.)



Volvo was visionary and dismissed Level 3 in about 2014 for being too dangerous. Basically the car drives until it doesn't and you may suddenly die because the time to get the situation and react is too short. Level 3 way purely for managers to claim it would be a linear progression whereas it is petty much THE gorge of automated driving. If you look at the SAE table it's just a little blue wart in a green column, but it's a lethal one.

https://www.sae.org/binaries/content/gallery/cm/content/news...


> because the time to get the situation and react is too short

The time is up to the manufacturer, isn't it?

Mercedes uses 10 seconds right now and that seems pretty good to me. At that point I know it can't be too dire or the car would have already emergency stopped.


> The time is up to the manufacturer, isn't it?

The time depends on how quickly an event unfolds in traffic. You can't guarantee 10s notice for an event that is imminent in 2s and the system might not be able to handle or can't detect.

The car could become temporarily "blind" for some reason with just 4-5s to brake before a collision. It's enough for a human driver even considering reaction time. But it's impossible to guarantee a minimum time without the ability to predict every issue that will happen on the road.


If there isn't a guaranteed minimum time, then it's not level 3, it's advanced level 2. Level 3 needs to be able to handle very rapid events by itself.

If it becomes "blind" because of an unexpected total system failure, that's an exception to the guarantee just like your transmission suddenly exploding is an exception. It had better be extremely rare. If it happens regularly then it needs a recall.


> If there isn't a guaranteed minimum time

When dealing with unpredictable real life events there are no guarantees, unless we're considering the many carveouts to that definition from a legal perspective. A blind car (fluke weather, blown fuse, SW glitch, trolley problem) can no longer guarantee anything. Giving the driver 10s, or assuming the worst and braking hard could equally cause a crash.

> your transmission suddenly exploding is an exception

As long as the brakes or steering work a driver could still avoid a crash. The driver having a stroke is closer to a blind car.


> When dealing with unpredictable real life events there are no guarantees

The guarantee here is that the human isn't obligated to intervene for a moment.

If you call that guarantee impossible, then what about level 4 cars? They guarantee that the human isn't obligated to intervene ever. Are level 4 cars impossible?

Is this a wording issue? What would you say level 4 cars promise/provide? Level 3 cars need to promise/provide the same thing for a limited time. And that time has to be long enough to do a proper transfer of attention.


> The guarantee here is that the human isn't obligated to intervene for a moment.

Ah, understood. So the guarantee is that the driver is not legally responsible for anything that happens in those 10s. I always took that as a guarantee of safety rather than from legal consequences.


It's more about safety than legality. But with the understanding that nothing is perfect.

The guarantee is that you will be very safe and you can go ahead and look away from the road and pay attention to other things. But at most this is as good as a level 4 or 5 car, not an impossibly perfect car.


> The time is up to the manufacturer, isn't it?

Yes but there is a minimum time (if a bit under-specified)

> "At Level 3, an ADS is capable of continuing to perform the DDT (Dynamic Driving Task) for at least several seconds after providing the fallback-ready user with a request to intervene."

J3016 Section 3.12, Note 3: https://wiki.unece.org/download/attachments/128418539/SAE%20...


I feel like that lack of standardization is part of the problem. Some manufacturers may pick different times to avoid nuisance braking, but that translates to higher risk to the driver. I’d like to see some core parameters like this standardized (whether by an industry body or regulator).


Volvo plans to introduce a level 3 system in the future.


If you're drinking coffee or reading emails your reaction speed can be way too long to react.

Which makes me think: if FSD requires constant hands on steering wheel and concentration what is the point? May as well drive yourself.


I've had several different cars from a few different manufacturers with different levels of ADAS systems and have used them on many long road trips and short trips. I haven't used any Tesla ADAS system for very long though.

The highest level of ADAS system I use regularly has facial attentiveness tracking. If you spend too much time drinking coffee or even looking out the sides of the car it will alert you and eventually turn off. So you're not spending a ton of time drinking coffee or reading emails.

It's really nice having the car just want to stay in the center of the lane and keep the following distance all on its own. It's less fatiguing on your hands and arms having the car feel like it's in a groove following all the curves for you instead of resisting your input all the time for hours and hours. It's incredibly nice not having to switch between the brake and the gas over and over in stop and go traffic. Instead, the only thing I need to focus on are the drivers around me and be ready to brake.

I've driven between Houston, Dallas, and Austin dozens of times with ADAS systems and another dozen or so times with only basic cruise control. It's way nicer when the only time I have to touch the gas and brake are getting on and off the highways. I'm considerably more relaxed and less exhausted getting to my destination.

Let's assume all these options are either the same price or an immaterial difference to the price of your next car. If you had an option for a car with basic cruise control or no cruise control, which one would you take? If the option was basic cruise or adaptive cruise which kept pace with traffic and operated in stop and go conditions, which would you choose?


You're right cruise control or whatever you want to call it is definitely great on long journeys on the highway. Maybe car makers should concentrate on those systems?


They are, other than Tesla. GM's SuperCruise, Ford's BlueCruise, and Mercedes DrivePilot are the few actually hands-free driving systems made by the legacy automotive companies and they're all largely locked to only fully operate on mapped and approved highways.


I actually think its worse than driving yourself. Humans are OK at doing a repetitive task non-stop. They're terrible at sitting still doing nothing waiting to quickly spring into action. They fall asleep or their mind wanders. This is something a computer is good at yet we've got it reversed. The car drives along doing mundane things but then hands it over to groggy human right when things really get hairy.

And then there's the skill atrophy. How do you learn to perform in stressful situations? By building up confidence and experience with constant repetition in more mundane ones, which this robs you of.


You're right but also keep in mind that FSD is level 2.


> levels 3 and 4 are supposed to have the same behavior.

This isn't correct. Level 4 doesn't require driver intervention[0]. Hence, why I'm arguing "Full Self Driving" starts here, level 4.

So now if you're explicitly not required to "be present" then the system should be liable or at least the "driver" isn't to blame directly.

It's actually level 5 is the same as level 4 but add heavy rain, snow, ice, name-your-adverse-condition.

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


And the part of my sentence that you cut off was all about the circumstances of intervention.

Level 2 requires the driver to choose whether to intervene at all times. This is an unreasonable task for humans.

Level 3 puts the car in charge of when intervention is needed, and even once it wants intervention it still has to maintain safe control for several seconds as part of the system spec.

Level 4 puts the car in charge of when intervention is wanted, but you can refuse to intervene and it has to be able to park itself.

So I will double down on my claim. Until the car requests intervention AND the timer runs out, level 3 and 4 are the same. They require the same abilities out of the car. And that section of time, between wanting intervention and getting intervention, is the hardest part of level 3 driving by far. If you can solve that, you're 90% of the way to level 4.

A level 3 car has to be able to handle emergencies several seconds long, and turning it into level 4 is mostly adding the ability to park on the shoulder after you get out of the initial emergency.

The gap between 4 and 5 is a bunch bigger. A level 4 car can refuse to drive based on weather, or location, or type of road, or presence of construction, or basically anything it finds mildly confusing. 5 can't.

I edited a bit for clarity, but also I'll append a thought experiment as an extra edit:

A level 3 car with an hours-long driver intervention timer is basically identical to a level 4 car.

If you have a 0 second intervention timer, you're barely better than a level 2 car.

How long does the timer have to be before developing your level 3 system is almost as difficult as a level 4 system?

I don't think it's very long.


I agree with your thought experiments and also agree that overall it's a valid, technically accurate interpretation. So, this may be where we agree to disagree.

I still stand by level 3 != level 4 in terms of real world liability.

Level 3 allows too much wiggle room and sloppiness to be able to legally shift liability away from the driver. At that point you're playing that "intervention period" length. Manufacturers claiming Level 3 will want to lower it as much as possible, regulators raise it. To me, Level 3 simply shouldn't exist.

Only at Level 4 is the expectation, without a doubt, the machine is in control. A person in the driver seat is optional because the steering wheel and pedals are as well. When people bought "Full Self Driving" they seriously believe "when can I go to sleep?" ability is where it belongs, which always put the expectation at Level 4.


Saying level 3 shouldn't exist makes sense. But I don't think the liability gets very blurry as long as the intervention period is properly documented.

It looked like the Mercedes system is 10 seconds which seems like plenty to me.

And while it would be nice to sleep I'll be pretty happy just looking away from the road.




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