The update on the amendment of UN Reg.79 is a first step towards self-steering systems for automated driving
Automated driving today: what is legal and what’s not
Partially-automated vehicles capable of both Level 2 driving and parking are already on the road today but concentrated in a handful of premium brands’ models. In detail, only 3 car manufacturers, all them premium ones, offer both L2 driving and parking (L2-D+P) features today. That is BMW, with L2-D+P introduced with its flagship 2017MY 7-Series, Mercedes-Benz with the 2017MY E-Class, and finally Tesla with the Model S and Model X respectively.
Audi, with its 2017MY Q7 and 2017MY A4, offers L2-Driving but only L1-Parking similar to Volvo’s 2017MY XC90 and the upcoming 2017MY S90.
Level 2 driving and parking is already here and Level 3 features will hit the market in mid-2017
The 1968 Vienna Convention on Road Traffic and the Regulation No.79-steering equipment are the most relevant regulations regarding autonomous driving. L2 driving (e.g. LKA, TJA, etc.) and parking features (e.g. Tesla’s self-parking) are legal due to exemptions in steering Regulation No.79. The Vienna Convention, whose amendment came into effect on April 23, 2016 is not restrictive for many countries e.g. the UK is not a signatory.
Level 3 is not legal in Europe and going beyond partial automation (that is still permanently monitored by the driver) would require a new approach to legal framework in road traffic: Otherwise drivers would be breaching their legal obligations.
What is Reg.No 79 and what makes it so important for Automated Driving?
UN-ECE Regulation No.79 contains requirements for the steering configuration of M, N and O category vehicles and it is an obstacle to highly and fully automated driving (L3-onwards) because it currently limits automatic steering functions to driving conditions below 12km/h.
However, provisions of Reg.79 allow:
- auto steering control (without the driver being in the steering loop) at low speeds (<12 km/h) which allow today’s park-assist systems or in other words hands-free parking
- steering assistance (with the driver in the loop) only for a limited time, to maintain the basic desired course or to influence the vehicle’s dynamic behaviour. This provision is currently used by car manufacturers to allow approval of LKA, ACC and other L1 ADAS.
The Tesla fatality has changed the direction of the Reg.79 amendment
However, some OEMs have been using these provisions to get approval for L2 systems (equivalent to Traffic Jam Assist). Following the Tesla fatality, the counterparties were even considering prohibiting L2 automated steering at all but it has been decided that using this provision will not be possible once the first stage of the amendment comes into force.
The amendement process is in progress. In detail, 23rd Sep saw technical provisions for automated driving being adopted by experts (GRRF) as a first step towards the introduction of self-steering systems.
The group defined 5 categories of automation corresponding to the functionalities that the vehicle will be able to perform and adopted performance requirements for the first 2 levels of automation defined by SAE International.
The proposed amendment sub-divides ACSF into five
categories between A for functions that operate up to 10 km/h and E which can operate up to a maximum speed of 130 km/h. These relate to systems that, under specific driving circumstances, will take over the control of the vehicle under the permanent supervision of the driver, such as self-parking functions and Lane Keeping Assist Systems (e.g. when the car will take corrective measures if it detects that it is about to cross a lane accidentally).
They also entail removing the current limitation of automatic steering functions to driving conditions below 10km/h contained in UN Regulation No. 79.
Timeline of amendment
The contracting parties are taking a 3 step approach:
- Stage-1 will see CSF and ACSF categories A and B1 coming into force by Jan’18
- Stage 2 (ESF, ACSF C) and 3 (ACSF B2, D, and E) by Oct’18
Once adopted by the World Forum at one of its forthcoming meetings (WP.29), these provisions will be integrated into UN vehicle Regulation No.79 and then in most European countries where Reg.79 is binding.
3 concerns arising from the regulatory amendment
The first problem arises from the fact that given the current timeline getting approval of SAE/BASt-Level 3 in Europe will probably not be possible before Jan’18 or Oct’18.
Second, the Reg.79 amendment will only allow approval of up to L3.
Third, being a Steering regulation, Reg.79 does not cover what the driver is allowed and not allowed to do in L3. Amendment of national traffic laws is required in this direction to allow driver distraction under specific scenarios.
To learn more about automated Driving Regulation, including OEMs’ roadmap to self-driving cars, read our report: Roadmap to Self-Driving cars: status, roadmap and strategy