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Autonomous driving is finally here! Although an upcoming assistance feature for conventional vehicles does not support fully driverless functioning, it is set to relieve the driver of driving tasks in slow-moving traffic on motorways/highways.

Lawmakers at the UN have now formulated a regulation that permits a vehicle equipped with Level 3 (conditional automation) features to operate in certain traffic environments. Upon activation, the feature enables the vehicle to autonomously drive itself, while allowing the driver to take his eyes off the road and focus on other activities like reading emails, choosing music, and accessing the internet on the on-board infotainment system. When prompted by the system, however, the driver has to resume control of all driving tasks.

From the outset, the industry has been challenged by questions over the handover of driving tasks between the driver and the system and the liability associated with it. This has also caused delays to the formulation of regulation and the introduction of Level 3 systems into the market. To address this challenge, lawmakers have chosen to pass regulation on a slow speed system that supports the safe introduction and deployment of Level 3 system in vehicles.

The New Level 3 Regulation

UNECE’s World Forum for Harmonization of Vehicle Regulations (WP.29) recently announced the first international SAE Level 3 regulation, “Automated Lane Keeping System” (ALKS), which will come into effect in January 2021.

5 Level
Source: UNECE (https://www.unece.org/fileadmin/DAM/Corrected_5_Levels_of_Driving_Automation.pdf)

Some of the key highlights of the regulation are:

      • ALKS can be activated on roads
        • with a physical separator that divides traffic moving in opposite directions
        • where pedestrians and cyclists are prohibited
      • The maximum operational speed limit of ALKS is 60km/h
      • Safe handover of driving task from the ALKS to the driver
      • ALKS system should be capable of
        • emergency maneuvers (in case of an imminent collision)
        • issuing a transition demand where the system asks the driver to assume all driving tasks and take back control
      • Minimum risk maneuvers
        • where there is a lack of response from the driver for the driving task transition demand
        • in all situations, wherein the system shall minimize risks to the safety of the vehicle occupants and other road users
      • Automated suspension of vehicle displays used for activities other than driving, when ALKS issues transition demand of the driving task
      • OEMs are obligated to introduce
        • Driver Availability Recognition Systems (Driver Monitoring System) to confirm the driver’s presence in the driver’s seat and their availability to take control of the driving task
        • Data Storage System for Automated Driving (Black Box) to record all events between activation and deactivation of ALKS, transition demand, emergency maneuver, collision and failures
      • Compliance with updated cybersecurity and software regulations

    Along with the EU, countries like Japan and Canada will also apply the ALKS regulation once it comes into effect in January 2021. While the UK is expected to follow the EU’s lead, the US and China are yet to declare their stance on regulating Level 3 autonomy.

    Audi’s Traffic Jam Pilot

    The ALKS regulation follows the lead and echoes Audi’s Traffic Jam Pilot (TJP), the first and only SAE Level 3 (conditional automation) feature offered in its flagship A8 model series in 2018. TJP was designed to handle the task of driving in a traffic jam or slow-moving traffic up to the speed of 60km/h on divided highways and multi-lane motorways separated by a physical barrier allowing the driver to take his eyes off the road.

    Audi initially offered TJP in Germany and announced the incremental introduction in other regions based on their specific legal and compliance requirements. However, in 2020, Audi delisted the TJP feature from its current generation of A8s, hinting at the lack of a supportive regulatory framework and legal challenges.

    The Level 3 Revolution

    With the ALKS regulation coming into force in the near future, Audi will most likely bring the TJP feature back to the A8, and possibly in its top-of-the-line models like A7, A6, Q8 and. Q7. Along with Audi, premium OEMs like Mercedes-Benz (DRIVE PILOT) and BMW (Personal CoPilot Systems) are likely to introduce Level 3 features in Europe, while Lexus is poised to launch its Level 3 feature – Highway Teammate – first in Japan, followed by other regions based on regulatory compliance requirements. Popular and mass-market OEMs like Nissan, Ford, Volkswagen, Hyundai, Kia, Honda, and Toyota are expected to introduce Level 3 features by 2022-2023.

    Most OEMs have announced their plans to launch Level 3 systems. Needless to say, such systems come with their own set of challenges such as risk and complexity during the handover of the driving task and liability in case of an accident. Limited speed application is another issue since the speed limit on motorways in Europe ranges from 100 km/h to 130 km/h, whereas the speed limit of ALKS is set at 60 km/h.

    Analyst’s Perspective

    While the ALKS regulations will encourage the adoption of Level 3 systems, limitations on the type of road (no pedestrian/cyclist access) and the speed limit will restrain the application of the system to certain motorways with dedicated slow lanes. Like other ADAS features, Level 3 systems will be offered initially as an option, adding to the total cost of the vehicle and making it an expensive affair.

    So is it worth investing in a Level 3 system? With limited applicability, Level 3 systems will offer value to only a small cohort of consumers for whom motorways constitute over half their daily commute. For the rest, it will remain a premium or a good-to-have feature. To address the majority of consumers, the industry is offering incremental additions to Level 2, with a system called L2+.

    Filling the gap with L2+

    The L2+ system enhances the safety and capability of Level 2 (Tesla) hands-free driving, with 3600 environment perception supported by HD mapping data. Simultaneously, it continuously tracks the driver’s status with a Driver Monitoring System, thereby ensuring that the driver doesn’t take his eyes off the road. While the L2+ system is again close to Level 3 autonomy and offers less stressful hands-free highway driving, nevertheless, ultimately it is the driver, and not the system, that is liable for any event.

    The autonomous driving ecosystem is actively promoting Level 2+ owing to its safety and efficiency with incremental additions to the Level 2 features. While technology developers like Nvidia and Mobileye are pushing L2+ systems into the market with their robust chipsets, Tier-1 suppliers like Continental and ZF are offering advanced driver assistance systems (ADAS) products and solutions based on L2+.

    The sensor suite strategy for a Level 3 system of most OEMs involves the addition of redundant sensors like LiDAR and multiple cameras. While this ensures the inclusion of systems with higher processing power, it also adds to the cost of the vehicle. The absence of regulatory compliance requirements for Level 2+ systems, reduced complexity, and risks related to handover, lower associated liability, and the mandatory fitment of Driver Monitoring Systems (in Europe), will impel OEMs to offer them at reduced additional cost in comparison to Level 3. OEMs like Nissan with Pro Pilot 2.0 and Cadillac with Super Cruise are offering Level 2+ in their production vehicles, while others like Volvo are keen to offer L2+ features in their less expensive B, C & D segment cars, making it a popular choice over Level 3 systems.

    Should you have any queries on the impact of COVID-19 across industries, need more information on this or any related topic, or would like to schedule an interview/interaction with our spokespersons, please email Priya George at priyag@frost.com.

About Varun Krishna Murthy

Varun Krishna MurthyVarun has a decade of experience in Research, Consulting, Innovation, and Project Management comprising of expertise in Passive, Active Safety, Driver Assistance, and Autonomous Driving systems. He has expertise in a wide range of Chassis, Road and Automotive safety topics, leveraging long-standing working relationships with industry leading experts, leaders, policy makers and  influencers in vehicle feature regulation and policy making, verification and validation of autonomous driving systems, and development of  national  level collision data management system.

Varun Krishna MurthyVarun Krishna Murthy

Varun has a decade of experience in Research, Consulting, Innovation, and Project Management comprising of expertise in Passive, Active Safety, Driver Assistance, and Autonomous Driving systems. He has expertise in a wide range of Chassis, Road and Automotive safety topics, leveraging long-standing working relationships with industry leading experts, leaders, policy makers and  influencers in vehicle feature regulation and policy making, verification and validation of autonomous driving systems, and development of  national  level collision data management system.

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