A Critique of the NHTSA "Levels" for robocars
Last year, the NHTSA released a document defining "levels" from 0 to 4 for self-driving technology. People are eager for taxonomy that lets them talk about the technology, so it's no surprise that use of the levels has caught on.
The problem is that they are misleading and probably won't match the actual progress of technology. That would be tolerable if it weren't for the fact that NHTSA itself made recommendations to states about how the levels should be treated in law, and states and others are already using the vocabulary in discussing regulations. Most disturbingly, NHTSA recommendations suggested states hold off on "level 4" in writing regulations for robocars -- effectively banning them until the long process of un-banning them can be done. There is a great danger the levels will turn into an official roadmap.
Because of this, it's worth understanding how the levels are already incorrect in the light of current and soon-to-be-released technology, and how they're likely to be a bad roadmap for the future.