Strategy and concepts
Opportunities and challenges
Fewer accidents, greater traffic safety. This is one of the objectives associated with the utilization of automated and autonomous systems in vehicles. However, a potential improvement in traffic safety is not the only advantage of automated driving: the technology can also make for efficient traffic management.
For all the advantages, however, caution is also called for: when pursuing goals, ethical and legal risks in connection with automated systems must not be disregarded and are therefore are therefore already taken into account by the Mercedes-Benz Group in product development at Mercedes-Benz Cars. An important consideration in this regard is the responsible use of Artificial Intelligence (AI), which is important for automated vehicles, especially in the form of Machine Learning (ML): among other things, it helps the system to rapidly and reliably identify objects and situations on and off the road quickly and safely.
The Mercedes-Benz Group is convinced that it can only succeed in entering a new age of mobility in a responsible way through interdisciplinary cooperation.
Leading role in automated driving
The Mercedes-Benz Group seeks to play a leading role in the field of automated systems. To achieve this, the Mercedes-Benz Group takes into account various aspects that go beyond purely technical issues. For example, it implements data protection principles and standards in accordance with the “Privacy by Design” maxim along the entire value chain. In addition, the Group integrates the “Ethics by Design” principle in its concepts for conditionally and highly automated driving and is continuously developing them further. In the reporting year, “Ethics by Design” was developed further for SAE levels 3 and 4.
The introduction of the “DRIVE PILOT”1 for S-Class models and the EQS shows how the Group’s aspirations are already becoming reality today. This system for conditionally automated driving has been on the German market since May 2022. The “DRIVE PILOT” is the world’s first series production system with internationally valid certification which corresponds to the requirements for SAE Level 3. The “DRIVE PILOT” meets the demanding requirements of the internationally valid technical approval regulation UN-R157 Automated Lane Keeping System (ALKS). This paves the way for such a system to be offered internationally. Accordingly, the “DRIVE PILOT” is to be gradually introduced in other countries such as the USA, as soon as the respective national legislation permits driver distraction. However, in addition to the regulatory aspects, technical requirements must also be met – for example, the availability of High Definition Maps for Autonomous Driving in the respective countries. As a next step, the Mercedes-Benz Group aims to obtain system approval for the “DRIVE PILOT” in individual states of the USA.
With “INTELLIGENT PARK PILOT”2, a Mercedes me connect service3, the Mercedes-Benz Group also created the prerequisite for parking according to SAE Level 4 in 2022. With this pre-installation, the first customers of the S-Class and the EQS for whose vehicle variants the corresponding Connect service is available can use the highly automated and driverless parking system “Automated Valet Parking” from Bosch and Mercedes-Benz, the first of its kind worldwide to have been officially approved for day-to-day operation. The function will first become available in car park P6 at the airport in Stuttgart (Germany) following approval by the Federal Motor Transport Authority (KBA) in November 2022.
Standards and legal framework for automated driving systems
New technologies require legal certainty. For this reason, the Mercedes-Benz Group is a member of national and international bodies and associations that promote the establishment of consistent legal standards for automated driving.
In Germany, the following laws and regulatory requirements in particular apply to the use of automated driving systems: amendments to the Road Traffic Act (StVG) from 2017 permit conditionally automated driving (SAE Level 3). Furthermore, since 2021, the law on autonomous driving together with the implementing ordinance has also allowed highly automated driving (SAE Level 4).
The ALKS technical approval regulation adopted in 2021 by the World Forum for Harmonization of Vehicle Regulations of the United Nations Economic Commission for Europe (UNECE) is of international significance. In principle, it allows a conditionally automated driving system (SAE Level 3) to be offered internationally and also serves as the basis for system approvals by the Federal Motor Transport Authority (KBA) in Germany. In 2023, extensions to UN-R157 will come into force that extend the range of applications for conditionally automated driving systems (SAE Level 3).
In the meantime, further countries have created legal regulations for the use of automated systems or initiated corresponding legislative processes.
In the opinion of the Mercedes-Benz Group, it is also necessary to further develop the respective national traffic and behavioural legislation in other countries. This is the only way to ensure the legally compliant use of automated or conditionally/highly automated systems (SAE Level 3 or 4).
In order to enable the cross-border use of automated cars, international harmonisation of the relevant legal regulations will also be necessary. These should be as compatible as possible and include the same technological requirements. This also involves the issue of how the data needed to ensure the proper operation of automated driving systems should be handled.
Responsible product development
The development of automated driving systems presents special challenges. Accordingly, the Mercedes-Benz Group uses the tools of the “technical Compliance Management System” (tCMS) in the automotive divisions. The aim is to identify risks in the product development process at an early stage and to counter them preventively. The tCMS sets out values, principles, structures and processes that are intended to provide security and orientation for the Group’s employees, particularly on challenging questions of interpretation of technical regulations.
Complex issues in the area of automated driving are evaluated and decided within the framework of an interdisciplinary process, in which legal, ethical as well as certification and safety-relevant criteria are taken into account.
If vehicles that are already in customer hands show anomalies in terms of safety, conformity or emissions, established assessment and regulatory processes take effect. In such cases, the Mercedes-Benz Group carries out customer service measures or recalls vehicles if necessary.
In addition to the legal, certification-related and technical requirements, the Mercedes-Benz Group also observes further internal guidelines and ethical principles. These include the Data Governance Guiding Principles and the AI Principles, for example, which apply both to software requirements and to the design of hardware and are based on the corporate principles of the Mercedes-Benz Group and are set out in the Integrity Code of the Group.
In addition to its own guidelines and principles, the Group is guided by planned or already adopted national and international guidelines and standards. Examples include the 20 rules of the Ethics Commission of the German federal government on automated and connected driving and the independent expert report of the EU Commission on “Ethics of Connected and Automated Vehicles: Recommendations on road safety, privacy, fairness, explainability and responsibility”.
The Group uses an integrated approach to answer the technical, legal, ethical and certification and safety-relevant questions relating to automated driving at Mercedes-Benz Cars. An interdisciplinary team evaluates the possible effects of the technical innovations, and develops and implements to deal with the effects. This involves such things as the responsible use of data in programming or considering the needs of all road users who encounter automated vehicles on the road. In this way, the Group wants to increase both the safety and the acceptance of these products.
Among other things, the German Road Traffic Act (StVG) and the German Road Traffic Regulations (StVO) have been translated into a system language. This was necessary, because although the German Road Traffic Act and the German Road Traffic Regulations essentially define the currently valid road regulations in Germany, most of their elements are not designed to be used as a template for programming technical systems. The result of this cross-divisional cooperation is the creation of special driving and system requirements, which help the Group to implement the various legal, ethical, product safety and certification requirements on the system side.
Comprehensive data protection is also important for ensuring public acceptance of automated driving systems. Therefore, data protection experts are involved in the conceptual development at an early stage. The aim is to develop data protection-friendly concepts according to the “Privacy by Design” principle.
The integrated approach played an important role in the market launch of the “DRIVE PILOT”, a system for conditionally automated driving. The task was to support the paradigm shift in mobility in a responsible manner using the example of an SAE Level 3 system. To this end, the Mercedes-Benz Group carried out special training measures for Sales and After-Sales in 2022. Furthermore, it provided various information services for customers and continually implements individual advisory and accompanying measures to support them in using their vehicle with “DRIVE PILOT”.
The Mercedes-Benz Group promotes open dialogue between business and consumer associations, authorities, industry, science and society – because broad-based social discussion is a prerequisite for the acceptance of automated driving. To this end, the Group has been using the annual “Sustainability Dialogue” since 2015 to exchange views on ethical, legal and social issues related to automated driving. The “Sustainability Dialogue” last took place on 27 October 2022. The participants in the “Road Safety” working group were in agreement that the transformation of mobility entails fundamental changes that place new demands on road safety research. The Mercedes-Benz Group, as well as all other automotive manufacturers, authorities and the scientific community, can make a contribution to meeting these demands.
With regard to safety in cities in the future, the participants defined two key focus areas. In 2022, the Mercedes-Benz Group worked on both of these together with politics, society and researchers and will continue the work in 2023.
The needs and requirements relating to future mobility vary across different countries, cultures and population groups. One thing is therefore clear: For the safe cities of the future, different solutions are needed worldwide. The aim is thus to work out possible country-specific features in dialogue with external stakeholders. The Mercedes-Benz Group also wants to continue to include ethical and social aspects in the product development of its vehicles.
The participants in the working group also expressed their desire to see the Mercedes-Benz Group participate more extensively in the public debate on – and the development of solutions for – sustainable mobility and traffic safety in cities. The Mercedes-Benz Group firmly believes that legal certainty is a fundamental prerequisite for the concrete implementation of mobility solutions. Here as well, the Group plans to work more closely and intensely with cities and research institutions in order to bring together various perspectives.
Involvement in committees and associations
The Mercedes-Benz Group is a member of numerous international and national committees and associations. These include the Automotive Industry Association, the European Automobile Manufacturers’ Association and working groups of the United Nations Economic Commission for Europe (UNECE). As part of the association work, the Group contributes to establishing reliable legal frameworks, technical standards and ethical guidelines for use of the new technology. The following are some examples:
- As part of a working group of the German Association of the Automotive Industry (VDA), the Mercedes-Benz Group participated in an interdisciplinary discourse from a legal and certification-related perspective on the drafting of legislation for autonomous driving, which came into force in July 2021.
- Since 2019, the Mercedes-Benz Group has been participating in the Verification and Validation Methods (VVM) research network for SAE Level 4 and 5 automated vehicles. This project, funded by the Federal Ministry of Economics and Climate Protection, aims to develop a system and methods for the safety verification of highly automated and driverless driving functions and vehicles in urban areas. Interim results of the project were presented at a mid-term event with the participation of the Mercedes-Benz Group in April 2022.
- Since 2019, the Mercedes-Benz Group has been involved in the drafting of the ISO TC/241 WG6 standard through the working group of the DIN Standards Committee on Automotive Technology in the VDA. The topic is the “Development of Recommendations on Ethical Considerations for Autonomous Vehicles”. The purpose is to embed an ethical perspective in the development process for automated vehicle systems. The International Organisation for Standardisation (ISO) plans to publish the recommendations in 2023.
Automated driving systems will only be approved for road use if they can meet very stringent safety requirements. The Mercedes-Benz Group is therefore working intensively to establish and further develop the required technical standards. This transparency enables the necessary discussion with relevant stakeholders. The Group will continue to support the projects beyond the reporting year. The aim is to arrive at globally accepted and uniform standards for the safety verification of automated driving functions.
Effectiveness and results
Effectiveness of the management approach
In the area of automated driving, many of the legal rules and regulations necessary for future developments are currently still at the draft stage. The Mercedes-Benz Group would like to contribute to this work, as the effectiveness of its measures depends heavily on the future regulatory framework. The Group has therefore defined the internal requirements for product design in automated driving in interdisciplinary expert and decision-making committees. The focus in this regard was on the safety and compliance of future products, as well as on the already existing legal requirements.
The Group also continuously monitors the developments on the market and accordingly derives further measures for the safety of its automation systems as required – where necessary, also in close coordination with the responsible authorities.
In addition, all employees at the development units can submit technical compliance questions to the responsible tCMS units, which then make their decisions within the framework of an interdisciplinary process. During the reporting year, the established tCMS units used this interdisciplinary process to deal with questions related to automated driving.
Safety through redundant systems and responsible use of AI
With the DRIVE PILOT, the Mercedes-Benz Group is aiming to take a decisive step toward conditionally automated driving (SAE Level 3).4 The DRIVE PILOT was released for sale in Germany in May 2022 after the German Federal Motor Transport Authority issued the new system a licence to operate as an SAE Level 3 system on the basis of the internationally valid UN-R157 regulation. Since that time, customers who drive a Mercedes-Benz S-Class or EQS with corresponding optional equipment can switch to conditional driving automation (SAE Level 3) in congested traffic as well as in traffic jams (up to 60 km/h) on selected stretches of German motorways.
Conditionally automated vehicle operation according to SAE Level 3 requires a system design that enables malfunctions to be safely managed. For this, numerous components must be duplicated.
In the case of safety-related functions – including control of the vehicle during automated driving – the Mercedes-Benz Group also deliberately dispenses with algorithms that change the vehicle’s behaviour while it is in operation, for example through self-learning processes. The focus is instead on “supervised learning” using previously collected data. Before the AI software is used in the “DRIVE PILOT”, extensive release tests are therefore carried out to ensure that the AI used shows the intended behaviour in the real traffic environment.
Driverless parking and unparking
The Mercedes-Benz Group goes one step further when it comes to parking: with pre-installation of the “INTELLIGENT PARK PILOT” in the S-Class and the EQS, for whose model variants the corresponding Connect service is available, the driverless parking system “Automated Valet Parking” from Bosch and Mercedes-Benz can be used. This function will first become available in car park P6 in Stuttgart, Germany after the approval by the Federal Motor Transport Authority (KBA) in November 2022.
1 Availability and use of DRIVE PILOT functions on the highway depend on equipment, countries and applicable laws
3 The system performs all driving tasks in specific circumstances. Even at SAE level 3, the driver must be able to resume all driving tasks at any time when prompted.