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Volvo Cars and Uber join forces to develop autonomous driving cars

What does the fatality caused by a self-driving Uber mean for the Automated Driving scene?

  • Uber under criticism for technology failure that marked the first fatality caused by a vehicle in Automated Driving mode;
  • The suspension of testing operations in Arizona is a significant step back for Uber which puts its proprietary autonomy system at risk;
  • Arizona government’s relaxed AV testing laws raise concerns but DOT confirmed there will be no changes to regulations;
  • USA’s AV regulatory approach is characterised by lack of harmonisation among states and lack of capability to enforce robust safety standards;

Regardless of the root cause for the failure of Uber’s self-driving technology testing on public roads, another life has been lost which makes the step towards an accident-free future seem farther away.

The fatality is a massive blow for Uber, which had to shut down its autonomous ride-hailing trials in Arizona amid safety concerns, settle a lawsuit filed by the victim’s family and deal with the criticism over its self-driving technology failure.

The tragic failure of system to either detect, classify the object as a pedestrian or react to the pedestrian has raised questions over the capabilities of Uber’s ADS given that less advanced systems already fitted in modern cars, such as Automated Emergency Braking with Pedestrian or Cyclist detection, could have helped mitigate or prevent the collision.

While the investigation to determine the root cause is still ongoing by the NTSB, the problem could potential be on the software side, which in essence decides if a response is necessary to detected and classified object.

The first death related to a pilot self-driving technology could also have adverse consequences to consumer acceptance since the main argument for the switch to higher autonomy is the capability of Automated Driving Systems to deliver enhanced safety within the Operational Design Domain comparing to humans.

Uber’s Autonomy programme is at risk which could impact its profitability

In 2015, former CEO Travis Kalanick expected Uber’s fleet to be driverless by 2030. “The service will then be so inexpensive and ubiquitous that car ownership will be obsolete”

Developing a driverless system to substitute drivers and increase vehicle utilisation is critical to Uber’s profitability

Uber had an estimated net revenue of $5.5 billion but recorded loses of $2.8bn in 2016.

Driverless autonomy is critical for Uber’s business model since the cost of driver accounts for around 70-80% of net revenue. Substituting drivers with a driverless system could decrease operational cost and help the company become profitable. It can also help Uber beat the competition by allowing to lower its cost service, which can even free in some cases e.g. if subsidized from partners such as Deliveroo.

That is why the company’s Advanced Technologies Group has been focused on developing its own autonomous sensing platform and control software over the last 2 years while its Otto division is also working on self-driving trucks. In Jan’17, Uber announced it will open an autonomous vehicle research center in Wixom, Michigan which we will be focused on integrating Uber’s technology into automakers’ vehicles.

…but testing self-driving Ubers, even with safety operators, has faced lots of setbacks

Uber started its autonomous ride-hailing trials back in Sep’16 in Pittsburgh using a fleet of Ford Fusions fitted with its own ADS. However, it has faced a series of regulatory and legal issues.

Uber's hardles

Uber’s viability is threatened

Halting testing operations is a significant backstep for Uber, threatening to delay its roadmap to substitute drivers with a driverless system. Given how critical Full Automation is to the profitability of Uber’s business model, we expect further developments in the near term to strengthen its open AV platform and diversify in order to secure its viability.

The company’s valuation has already decreased dramatically over the last 2 years amid a series of cultural controversies and legal battles which have been draining resources and put its autonomy programme under risk. According to reports in Jan’18, SoftBank successfully purchased hundreds of millions of shares of the company at a $48 billion valuation, a 30% discount from the $69 billion that private investors valued the company at in 2016.

USA regs

Despite calls for more regulatory scrutiny, AV regulatory approach is unlikely to change 

In the U.S, there is no Federal regulation restricting SAE L3-5 deployment, only non-binding guidelines. The Federal responsibilities are: safety standards, compliance, recalls and public education while the States are responsible for testing permits, law, enforcement and licensing.

This makes the U.S. a favourable environment for AV deployment. However, the U.S. follows a stand-alone strategy and shows lack of cooperation at international level – Europe, Japan and China are counterparties of the UNECE-Regulation No79 which sets the technical requirements for Type Approval of automated steering required for higher levels of autonomy.

The 2 fundamental problems arising from the current U.S. AD regulatory landscape

First, inconsistencies between state policies are restricting standardisation across the country. ‘’As a result carmakers cannot conduct credible tests to develop cars that meet the different guidelines of 50 US states’’, according to Volvo’s CEO. Second, lack of standardisation or conflicting state laws inhibit innovation and slow down road safety benefits. For instance, California has established its own certification process, Arizona does not require specific permits and data recording, while Michigan allows

Arizona government’s relaxed AV testing laws raise concerns but DOT confirmed there will be no changes to regulations

Arizona’s regulatory framework for testing AVs is one of the most favourables which has led to many companies establishing operations there. Specific permits aren’t required as long as the vehicle meets all applicable motor vehicle laws and there is a licensed driver either in the car or monitoring it remotely. Operators do not need to file detailed public reports on incidents, as they do in California, but companies are expected to submit information to help authorities develop a protocol on how to interact with the vehicles.

However, testing and deployment has been made possible by the Governor’s Executive Order, which means that testing and deployment are subject to the Governor’s interpretation.

Arizona DOT confirmed that there will be no changes to regulations for autonomous cars despite the accident. Possible ban of AV testing and sales in Arizona would threaten deployment the deployment of robo-taxis as well as L3 in private cars in the most favourable state to AVs.

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Consumer faith on AVs is still fragile over safety, security and ethical issues 

The first death related to a pilot self-driving technology could also have adverse consequences to consumer acceptance since the main argument for the switch to higher autonomy is the capability of Automated Driving Systems to deliver enhanced safety within the Operational Design Domain comparing to humans.

But other companies testing Highly and Fully-Automated Driving technology use different platforms and/or software and hardware. Regardless, it is very difficult for consumers to understand the technical differences of the different ADSs. Consumer education is needed to guide consumers with regards to their responsibilities and the limitations of the ADSs for private use.

Also, deployment for private cars will follow a different technological roadmap, coming much later than Automated Mobility on Demand (AMoD).

Amid public scepticism for Level 3-5, OEMs need to prove it improves road safety and tackle customer confusion

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Managing vehicle-related Cyber threats is paramount for physical safety 

While carmakers strive to roll out more and more Connected Cars and models equipped with Automated Driving functions in an attempt to gain competitive advantage and enhance costumer-loyalty, they face an important challenge. To ensure that these new types of modern vehicles guarantee not only safety but also security and data privacy. This is because Connected Cars, which are essentially collectors and distributors of information, need robust design architecture that guarantees network security in addition to multiple layers of operational and peripheral security to protect against cyber-attacks.

Some security solutions are already deployed in the field but so far no regulation exists to mandate Automotive Cyber Security detection, prevention and counter-measures.

Cars with different levels of autonomy will coexist which makes the liability framework more complex

Waymo is expected to launch its driveless mobility service later this year. However, driverless capabilities for private cars will lag behind AMoD timeline due to the component cost for use in series production and other differences in the business models.

AD Penetration in USA 2017 vs 2021

What is more, there will be a long transition time until all cars become autonomous. When manually-operated cars and driverless cars co-exist, further coordination is needed to guarantee an accident-free world, such as V2X. This means that accidents occuring when the vehicle is in Automated-Driving model might continue to exist -but risks can be mitigated- which makes the determination of liability even more complex. Also ethical issues might arise.

Data recording will help determine liability when an accident occurs at self-driving mode

For private cars, we expect that many, if not all carmakers, will opt to equip their vehicles with Automated Driving-Event Data Recorders, which will record data while the ADS is active, regardless of it not being mandated in the US until 2020-21. This data recording will be mandatory in the UN-ECE and will help identify liability when a crash occurs while the vehicle is in Automated Driving mode.

Read more insights

For an in-depth analysis of the Autonomous Driving regulation in major car markets and how it will affect the AD roadmap of leading carmakers read our report Regulatory guide to Autonomous Driving, Automotive Cyber Security & V2X.

For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, info@auto2xtech.com.

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California to allow driverless car tests without human behind the wheel

Today, the state’s Office of Administrative Law approved the regulations that would permit fully driverless testing. A public notice will go up on the DMV’s website on March 2nd, which starts a 30-day clock before the first permits can be issued on April 2nd. Companies can apply for three types of permits: testing with a safety driver, driverless testing, and deployment.

Key points:

  • Waymo and GM’s Cruise race for the introduction of the first L4 mobility service. Google’s Waymo approved to begin self-driving ride-share across Arizona
  • GM petitioned NHTSA regarding a Cruise L4 design without steering controls.

GM Cruise AV

Read more insights

For an in-depth analysis of the Autonomous Driving regulation in major car markets and how it will affect the AD roadmap of leading carmakers read our report Regulatory guide to Autonomous Driving, Automotive Cyber Security & V2X.

For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, info@auto2xtech.com.

A row of 2014 Ford Motor Co. Focus vehicles sit on display at Uftring Ford in East Peoria, Illinois, U.S., on Saturday, Nov. 30, 2013. Automakers entered their year-end sales push in November with the most cars and trucks on U.S. dealer lots in eight years, a buildup that’s poised to test the industry’s newfound pricing discipline. Photographer: Daniel Acker/Bloomberg ** Usable by CT and LA Only **

New car sales in Germany grew by 2.7% in 2017 for the 4th year in a row

New car registrations in Europe’s largest car market achieved the highest volume since 2009 amounting to 3,441,262, up 2.7% from the year before.

Data from German KBA showed that growth in Mercedes-Benz (+15,000 units) and volume brands, led by Peugeot (+14,000) and Dacia, compensated for the losses in premium brands, especially VW Group’s Audi, Porsche and Volkswagen.

 

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The UK aims to align with international regulations which allow automated steering for parking and cruising

The UK wants people and businesses who buy type approved cars fitted with Remote Control Parking (RCP) and Motorway Assist (MA) technologies to use them in a safe, legally compliant manner.

Therefore, it launched a public consultation to amend the Highway Code and Construction & Use Regulations to align with international regulations which allow automated steering for parking and cruising- namely Regulation No.79’s Series 2 of amendments for Automatically Commanded Steering Functions (ACSF) Category A and B1.

More and more carmakers are introducing Remote Parking and Self-Parking capabilities while SAE Level 2 feature availability expands across their model range. What’s more important though is that Level 2 has reached the compact car segment.


 

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October 2017, saw the 2nd series of amendments of international Regulation No.79 come into force allowing the use of automated steering (ACSF) at speeds above 10 km/h (6.2 m/h). Vehicles type approved after 1 April 2018 will have to comply with these new standards.

Prior to this amendment, automated steering was only allowed for speeds below 10 km/h, i.e. essentially parking and maneuvering which fall under the term Remote Control Parking in modern cars. Under the amendment, type approval of motorway features which automatically control steering, such as Traffic Jam Assist & Cruise Assist will also be allowed.

The next phase of amendments of international regulation, which are scheduled for 2018, are expected to unlock type approval of SAE Level 3-Conditional automation.

Remote Control Parking

Being able to park via remote control can potentially assist in how vehicles are utilised and parked for thousands of UK drivers, providing extra convenience and flexibility.

This technology should also provide great benefit for drivers with mobility impairments, enabling and empowering users to park in confidence where once it may have been challenging to do so.

Source: UK C-CAV

What the UK plans to change:

The current wording within Regulation 110 of the Construction and Use Regulations prohibits the use of a hand-held mobile communications device (such as a phone, tablet) while driving. The use of a hand-held device to park the vehicle therefore lends uncertainty as to whether enforcement authorities or the Court could interpret this as being in contravention of this regulation.

This consultation seeks agreement on our draft statutory instrument, applicable to Great Britain, to facilitate the use of remote parking. Draft amendments to the Highway Code, specifically rules 149, 150, 160 and 2396, have also been included to reflect this regulatory change and provide clarity to drivers within Great Britain; relevant legislation for Northern Ireland is referenced where appropriate.

  • Rule 149: You MUST exercise proper control of your vehicle at all times. You MUST NOT use a handheld mobile phone, or similar device, when driving
  • Rule 150: Driver distraction caused by driver assistance systems
  • Rule 160: Drive with both hands on the wheel where possible; keel to the left, unless road signs or markings indicate
  • Highway Code Rule 239: Use off-street parking areas, or bays marked out with white lines on the road as parking places, wherever possible

 

Steering assistance of SAE Level 2 systems is limited so don’t take your hands off the steering wheel

The most prevalent ADAS Level 2 driving system is Traffic Jam Assist (TJA) which combines the functions of two Level 1 systems, Adaptive Cruise Control (ACC) and Lane Keep Assist (LKA). The combination of these two systems enables steering assistance which is limited though to a certain speed depending on the capabilities of the system and requires the attention of the driver since TJA does not have the system capability and redundancy (extra sensing, brain, response) to take control of monitoring the road.

Motorway assist, according to C-CAV

Motorway Assist systems builds on existing systems such as ACC, Advanced Emergency Braking System (AEBS) and LKA to take full control of the vehicle’s position and speed while driving along a high-speed road, such as a motorway.

Manufacturers are already producing low-speed variants of this system for use in start-stop traffic situations (sometimes known as Traffic Jam Assist), providing assisted steering to maintain lane position and speed control up to 40mph.

The EU proposals currently being consulted on are for ADAS that can operate at speeds of up to 81mph. The driver must continue to monitor the system and confirm this through regular interaction with it. Without necessary provision and regulatory change, these technologies will not be able to be utilised on British roads effectively.

On the international stage, new standards incorporating this technology, along with increased scope for motorway assistance systems, came into force in October 2017; Great Britain must be ready to adopt these to ensure a smooth transition to increasingly automated vehicles.

Read more

For an in-depth analysis of the Autonomous Driving regulation in major car markets and how it will affect the AD roadmap of leading carmakers read our report Regulatory guide to Autonomous Driving, Automotive Cyber Security & V2X.

Also, for a technological roadmap for the introduction of Level 2-5 features by leading OEM and a penetration forecast of cars equipped with different levels of autonomy over the next decade read our report Roadmap to Self-Driving cars: Status of Autonomous Driving in 2016, roadmap and strategy of leading OEMs to commercialise AD 

For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, info@auto2xtech.com.

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5 key models with Partial & Conditional automation coming in 2018

Drivers will be able to experience Conditional automation (SAE Level 3) for the first time in 2018. But validation requirements and safety regulation will restrict customer availability- at least for the first half of 2018.

SAE Level 3 systems combine enhanced levels of sensor redundancy and robustness to be able to control steering, braking and accelerating under their operational domain, thus allowing drivers to turn their attention away from the road, i.e. “eyes-off the road”. However, a handover of control is required between the driver and the system so the driver must be available to takeover.

At the same time, more carmakers are launching Level 2 driving and parking features. More importantly, these features will not be the exclusive privilege of premium cars anymore as more and more Volume OEMs launch assistance systems to meet consumer demand and safety ratings.

Let’s look at some of the most important automated technology coming in new cars in 2018. We concentrate on driving features used in traffic jam situations and parking.


 

1. AI Traffic Jam Pilot (SAE Level 3-Driving) & AI Remote Parking (Level 2-Parking) in the 2018 Audi A8

Functionality: Audi states that “On highways and multi-lane motorways with a physical barrier separating the two directions of traffic, the Audi AI traffic jam pilot takes over the driving task in slow-moving traffic up to 60 km/h (37.3 mph). The system handles starting from a stop, accelerating, steering and braking in its lane. If the driver has activated the traffic jam pilot at the AI button on the center console, they can take their foot off the accelerator and their hands off the steering wheel for longer periods.

Unlike at level 2, they no longer need to monitor the car permanently and, depending on current national regulations, can turn to other activities supported by the on-board infotainment system. The driver must remain alert and capable of taking over the task of driving when the system prompts them to do so.”

Why it is important: It is the first-ever Level 3 in series production. To achieve the levels of redundancy and robustness the vehicle is also equipped with a laser scanner as an additional forward-looking sensor to the long-range radar and camera.

We expect other major carmakers introducing L3 to utilise an additional forward-looking sensor for redundancy, apart from Tesla, but not everybody believes that it should be a lidar- with ther carmakers might use a high-resolution radar. So far the high cost of lidar has been an obstacle to deployment but Audi’s strategy to enter series production and achieve economies of scale shows positive signs for higher sensor penetration. 

The new A8 also has a redesigned central driver assistance controller called zFAS, which generates an image of the surroundings while driving by fusing sensor data. At the same time, a second data fusion takes place in the radar control unit.

Laser scanner

Availability: Incrementally from early 2018 depending on the legal situation in the respective country. Even though deliveries of the first-ever Level 3-equipped car have just started, drivers won’t be able to experience “eyes-of-the-road” just yet because the AI Traffic Jam Pilot in Audi’s flagship A8 will be activated when it collects enough data for validation purposes. We expect that activation will occur by mid-2018.

Audi says that “Introduction of the Audi AI traffic jam pilot requires both clarity regarding the legal parameters for each country and specific adaptation and testing of the system”.

Introduction of the Audi AI traffic jam pilot requires both clarity regarding the legal parameters for each country and specific adaptation and testing of the system. Moreover, varying worldwide homologation procedures and their deadlines must be observed. Audi

Automated Driving System (ADS) name & level of automation: AI Remote Parking, SAE Level 2-Parking

Functionality: The Audi AI remote parking pilot and the Audi AI remote garage pilot autonomously steer the A8 into and out of a parking space or a garage, while the maneuver is monitored by the driver. The driver need not be sitting in the car. They start the appropriate system from their smartphone using the new myAudi app. To monitor the parking maneuver, they hold the Audi AI button pressed to watch a live display from the car’s 360 degree cameras on their device.

Why it is important: Audi’s first self-parking feature brings the brand in parity with Tesla, BMW and Mercedes-Benz in terms of Level 2 self-parking features.


 

2. Active Distance Assist DISTRONIC & Active Steering Assist (Level 2-Driving) in the Mercedes-Benz S-Class

The updated S-Class, with the redesigned multi-function steering wheel providing direct access to the driver assistance systems, launched in autumn 2017 but we include it here because we expect an upgrade to Level 3 within 2018.

Functionality: The Active Distance Assist DISTRONIC and Active Steering Assist now provide even more comfortable support for the driver to keep a safe distance and steer. The speed is now adjusted automatically ahead of bends or junctions.

Why it is important: Mercedes-Benz describes the updated S-Class as a “Level 2 Plus” car, to showcase the improvements made in the L2 Drive Pilot firstly-introduced in the E-Class.

Mercedes-Benz’s decision to “restrict” the S-Class to Level 2 was primarily driven to the uncertainty of the regulatory framework. Once the amendment of international regulation progresses, allowing the approval of Level 3, we expect that Mercedes-Benz will “unlock” the full potential of its flagship.

Read more about how the regulatory framework for Autonomous Driving evolves here.

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3. Super Cruise (Level 2-Driving) in 2018 CT6 prestige

Functionality: It’s a highway driving automation technology that will enable hands-free driving even in stop-and-go traffic in lidar-mapped highways.

Cadillac’s system is a more conservative approach than Autopilot  and other L2-Driving features in that hands-free is confined to pre-lidar USA and Canada mapped motorways, so no city driving.

What it is important: It’s GM’s first-ever Level 2 system for highways. To keep drivers in the loop, Cadillac will feature a driver attention system which uses a small camera located on the top of the steering column and works with infrared lights to determine where the driver is looking whenever Super Cruise™ is in operation.

Availability: Firstly in the USA and Canada in 2018 and later in China.


 

4. Connected Pilot (Level 2-Driving) in DS7 Crossback

Functionality: The Connected Pilot will be capable of maintaining lane and positioning itself to the left or right of the lane to allow cycles or motorcycles to pass.

What it is important: PSA’s first model to offer Level 2-Driving & Level 2-Parking. The L2 systems present on the DS 7 Crossback will spread across the PSA Group onto Peugeot and Citroen models not long after it hits UK showrooms in 2018.


 

5. ProPilot Assist (Level 2-Driving) and ProPark (Level 2-Parking) in new Nissan Leaf

 

What it is important: Nissan launched the feature first in Japan in 2016. The 2nd gen Leaf will be the 1st Nissan in Europe to feature a Level 2-Driving system following its release in Japan in 2016.

Nissan will gradually roll-out more advanced autonomous drive technologies until 2020. By 2018, an updated version of the ProPilot (2.0) will be introduced with multiple-lane capabilities, followed by intersection capabilities for urban scenarios by 2020 (ProPilot 3.0).

Read more insights

For more information about Autonomous driving contact us on: (+44) (0)20 3286 4562info@auto2xtech.com or visit auto2xtech.com.

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Insights on the V2X regulatory activity with CTO Autotalks

Safety regulation is a major driver for the V2X market given its influence in the technology medium, so that all vehicles speak the “same language”, and the associated infrastructure.

With ITS-G5 (DSRC in the US) deployment and crucial supporting infrastructure being in their infancy, but substantial investment already scheduled for the coming years, today is a critical time for the harmonisation of V2X solutions across carmakers and leading geographies in order to take advantage of their safety benefits.

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Key findings:

  • Regulation, cost and investment to determine which V2X medium will win
    • Not realistic to have both technologies in the car in terms of cost and spectrum efficiency;
    • Voluntary deployment has started but ITS-G5 / DSRC vs Cellular camps could delay standardisation
  • Lack of harmonisation of V2X regulation among major car markets
    • NHTSA’s NPRM for FMVSS 150 provides clear regulatory guidance for DSRC being the recommended technology for V2V communications for Light Vehicles from Sep’20;
    • Apart from NHTSA’s activities for the mandate, we see infrastructure activity in the U.S. which provides an immediate value for drivers. There is no need to wait for the creation of the V2V network;
    • European deployment based on voluntary fitment today whereas substantial investment in ITS-G5 infrastructure is in progress;
    • Europe’s net neutrality principle allows both competing technologies, even as a “hybrid system”, but investment in ITS-G5 infrastructure and VW’s strategy will likely shift the scale towards ITS-G5 (DSRC in the US);
    • China invest in 5G and will set V2V standards circa 2018;
    • Toyota plays major role in Japan;
  • V2X features to mitigate accidents in intersection and left-turn urban scenarios
    • First-day applications with strong potential: “Left-Turn Assist”, “Intersection Movement Assistance”, Incoming Motorcycle Alert” and “Platooning” for Commercial vehicles

Contents

  1. V2X deployment status raises concerns over the lack of harmonization
  2. Learn how regulatory guidance for V2X will evolve in major markets
  3. Weighting in the debate between DSRC / ITS-G5 and C-V2X
  4. Understand which V2X-supported features will come to market first
  5. Winners from the installation of V2X sensors & infrastructure

Download the whitepaper here.

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For a technical overview of 802.11p vs LTE-V2V in terms of performance, cost, services and maturity read a whitepaper that was co-authored by Mr. Haran here.

What our report delivers

For more information on V2X regulation and how it relates to developments for Automated and Secure Connected Cars check our report Regulatory guide to Autonomous Driving, Automotive Cyber Security & V2X.

  • Understand the differences between the way Autonomous Driving regulation works in Europe, the U.S.A and China and how this affects the introduction of SAE Level 3 systems;
  • Learn what deployment strategies carmakers will use to introduce higher autonomy based on the current regulatory and legal framework in major car markets;
  • Benchmark key geographies based on the opportunities regulation presents for testing and deployment of SAE L3-5;
  • Read about the challenges that deployment of Level 3 Traffic Jam Pilot systems faces in Europe and how the amendment of UN Regulation No.79 is progressing;
  • Get an update on the status of regulation, standards and initiatives for Automotive Cyber Security;
  • See how V2V regulatory activity is progressing relative to market deployment.

For sample pages and full Table of Contents, please contact us info@auto2xtech.com.

USA regs

USA’s updated guidance on Autonomous Vehicles fails to address the key issues

  • Deployment of higher levels of autonomy, SAE Level 3-5, is subject to national regulatory approval with inherent differences in the way regulation works in the USA versus Europe and China;
  • USA’s approach to Autonomous Driving is key for harmonisation of safe and secure ADS testing and deployment but USA seems to follow a standalone policy to give domestic stakeholders an advantage;
  • Although USA’s non-binding guidelines do not impede deployment of L3-4, which promises to reduce road deaths and road stress, they raise concerns over enforcement of safety standards and harmonisation across states;
  • New Trump administration has delayed progress in key cybersecurity and V2V bills while creating further uncertainty on their final implementation.

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Status of AV law in the U.S, Q3-2017 / Source: ncsl.org

NHTSA’s updated guidance does not impede deployment by choosing non-binding guidelines instead of a mandate

12th September, saw the USDOT updating its voluntary guidelines for Autonomous Driving Systems, defined as SAE Level 3-5 systems, by releasing the “AUTOMATED DRIVING SYSTEMS- A Vision for Safety version 2”. The new guidance is an update of the voluntary guidelines for HAVS based on comments received on the Federal Autonomous Vehicle Policy’s (Sep’2016).

The first section of the guidance, titled “Voluntary Guidance” contains 12 priority safety design elements which entities are encouraged to consider when designing ADSs. These elements comprise:

  1. System safety
  2. Operational Design Domain
  3. Object and event detection response
  4. Fall back (minimal risk condition)
  5. Validation methods 
  6. HMI
  7. Vehicle cybersecurity
  8. crashworthiness
  9. Post-crash behaviour
  10. Data recording
  11. Consumer education and training
  12. Federal, State and Local laws

Additionally, the agency recommends that entities have a self-documented process for assessment, testing, and validation of the various elements.

A key point is that NHTSA still encourages manufacturers to submit “Voluntary Safety Self-Assessments” (12-point list) demonstrating approaches for safe ADS testing and deployment, but it does not require them.

The purpose of this Voluntary Guidance is to help designers of ADSs analyse, identify, and resolve safety considerations prior to deployment using their own, industry, and other best practices

USDOT, ADSv2 (Sep’17)

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Source: Audi

The second section of the guidance, the “Technical Assistance to States” clarifies the role of the Federal government and also includes best practices for Legislatures and State Highway Safety Officials.

USA’s updated guidance removes certain obstacles for carmakers

Here are the most significant changes between the new guidance (ADSv2) and the old one (FAVP)

  1. Most of the Auto Alliance’s recommendations/comments on the FAVP made it to the ADSv2. In detail, 3 items were removed from the FAVP’s 15-point Vehicle Performance Guidance: Privacy and data sharing, Registration & Certification and Ethical Considerations;
  2. Another key point removed is the FAVP’s willingness to shift from its current regulatory regime of “self-certification post-fitment” to a ‘’Pre-market approval of HAVs” which has caused significant concern;
  3. The new guidance’s second section incorporates common safety-related components and significant elements regarding ADSs that States should consider incorporating in legislation. NHTSA’s authority remains on design, construction and performance of ADSs;
  4. Finally, “NHTSA strongly encourages States not to codify this Voluntary Guidance as a legal requirement for any phases of development, testing, or deployment of ADSs. Allowing NHTSA alone to regulate the safety design and performance aspects of ADS technology will help avoid conflicting Federal and State laws and regulations that could impede deployment”.

But it fails to address the key concerns

  1. Guidelines have immediate effect against what might be a lengthy rulemaking process but NHTSA’s guidance raises concerns over enforcement of safety and security standards. Enforcement of voluntary guidelines for safe testing and deployment is weaker than a rulemaking procedure and without the latter’s objectivity, such as notice and comment, due process or judicial review. 
  2. It lacks clear legal guidance for ADS manufacturers on performance metrics, potential mandate and updatability. NHTSA’s own FAPV noted that “the absence of established metrics could make it more difficult for OEMs to anticipate the Agency’s evaluation and conclusions regarding the safety of their vehicles’ performance. Another key issue is whether the ODD’s data truly represent real-world conditions.
  3. Harmonisation across states is a key challenge for the USA. It requires state collaboration which has been proven difficult. The SELF DRIVE Act and the LEAD’R Act are positive steps in this direction but both are in early stages.
  4. The Trump’s administration creates uncertainty. This has been demonstrated by the slow progress with Cyber security regulation, i.e. SPY Act as well as FMVSS 150: V2V communication.

 

CADILLAC supercruise

Cadillac’s SuperCruise is a SAE Level 2 feature enabling hands-off-the-steering wheel in highways but requires constant monitoring / Source: Cadillac

Still significant opportunities exist in the USA from its regulatory approach

While European carmakers, mostly German, lead the SAE level 2 in terms of deployment and sales volume, L3 deployment in Europe is currently restricted by the regulatory and legal framework.

The USA presents a favourable environment for testing whereas deployment is subject to both federal and state rules, which are less restrictive than in Europe, Japan and China. USA’s progressive regulatory stance on deployment of higher levels of technology, coupled with significant investment from tech giants which focus on AD platforms, software and AI can give them an edge provided that the key issues of harmonisation and cybersecurity are adequately addressed.

Read more

For an in-depth analysis of the Autonomous Driving regulation in major car markets and how it will affect the AD roadmap of leading carmakers read our report Regulatory guide to Autonomous Driving, Automotive Cyber Security & V2X.

For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, info@auto2xtech.com.

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Regulatory impact on deployment of Highly-automated driving

July 11’s launch of the first-ever Level 3 capable car marks a new era in Autonomous Driving. However, L3 deployment is still subject to regulatory approval. What’s more, the regulatory and legal framework differs across leading car markets.

Here are some insights on which geographies present the most favorable environment for L3 deployment.

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Highly-automated driving will be legal in Germany from Sep’17 giving a head start to German brands who are closer to delivering L3. This demonstrates the country’s ambition to be in the forefront of Autonomous driving -not only testing but crucially deployment- ahead of the U.S.A.

Germany will lead L3 deployment in Europe but standardization across Europe is threatened by delays in the amendment process of Regulation No.79.

U.S.A offers a favorable environment for L3 deployment since approval of testing and deployment is at state level while NHTSA’s Federal Autonomous Vehicle Policy is non-binding. But standardization across states is an issue as inconsistencies between state AV regulations exist.

What’s more, there is a concern that the U.S. is pursuing a go-it-alone strategy in an effort to give the domestic industry an advantage. On the contrary, Japan’s government wants to develop international standards for AD through the U.N. World Forum for Harmonization of Vehicle Regulations and Europe is focused on safe and secure deployment with the amendment of Reg.79.

Finally, technology deployment in the world’s largest car market is at risk as delays in Europe’s regulatory amendment have initiated discussion to adopt an earlier version of automated steering regulation which does not include provisions for L3-4.

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For an in-depth analysis of the Autonomous Driving regulation in major car markets and how it will affect the AD roadmap of leading carmakers read our report Roadmap to Self-Driving cars.

Read more insights
Highly-Automated Driving (Level 3) in one out of 6 cars in Europe in 2021
Germany legalises L3 automated driving technology that allows “eyes-off” the road
Who is liable in Level 3 automated mode, the driver or the car?
Volvo to skip Level 3 autonomous mode
Drivers to legally take their “eyes-off” the road from 2017-Autonomous Driving Roadmap report

NASHVILLE, Tenn. (June 22, 2017) ñ The widely anticipated new Nissan LEAF will feature state-of-the-art ProPILOT Assist technology, Nissanís driver-assistance technology that reduces the hassle of stop-and-go highway driving. ProPILOT Assist supports drivers by helping control acceleration, braking and steering during single-lane driving on the highway. In the coming years, Nissanís ProPILOT technology will offer increasing levels of autonomy, with the system eventually able to navigate city intersections. Set to help make driving more secure and more enjoyable, ProPILOT Assist is part of Nissan Intelligent Mobility, the companyís blueprint for transforming how cars are driven, powered and integrated into society.

Highly-Automated Driving (Level 3) in one out of 6 cars in Europe in 2021

ADAS & Automated Driving features increasingly become key product differentiators

With Audi teasing its upcoming A8 with emphasis on automated driving capabilities, we present some findings from our latest report on key ADAS feature penetration and their growth potential over the next five years.

Audi’s new flagship will be the first vehicle to feature a Traffic Jam Pilot which will bring Audi to Level 3 in terms of driving features. At the same time it will also offer L2 Remote Parking, bringing Audi to parity with Mercedes-Benz, BMW and Tesla in terms of L2 parking capabilities -all of them offer either Self-Park, Remote Park or both.

While today, Level 3 deployment is constrained geographically by regulatory approval, key car markets are giving the green light. Our report provides in-depth analysis of how the regulatory framework affects OEM strategy as well as Level 3 deployment.

We expect that in 2021, 17% of new car sales in Europe will offer Highly-Automated Driving (Level 3) features as optional or standard, the majority of which will come from premium car manufacturers.

By then, feature functionality will have expanded from the low-speed, single-lane Traffic Jam Pilot to more advanced Highway Pilots.

Read our report to understand carmakers’ strategies to reach higher levels of vehicle autonomy and the opportunities they create for ADAS sensors, AD platforms as well as collaborations.

Level 2 penetration in Europe reached 6.5% in 2016 with German OEMs holding the lion’s share

While the introduction of Level 3 is big news, especially since the debate over its risk-reward as an intermediate level between Supervised (Level 0-2) vs Unsupervised driving (L4-5) continues, it’s Level 2 that makes its way into new car sales, especially in Europe.

NASHVILLE, Tenn. (June 22, 2017) ñ The widely anticipated new Nissan LEAF will feature state-of-the-art ProPILOT Assist technology, Nissanís driver-assistance technology that reduces the hassle of stop-and-go highway driving. ProPILOT Assist supports drivers by helping control acceleration, braking and steering during single-lane driving on the highway. In the coming years, Nissanís ProPILOT technology will offer increasing levels of autonomy, with the system eventually able to navigate city intersections. Set to help make driving more secure and more enjoyable, ProPILOT Assist is part of Nissan Intelligent Mobility, the companyís blueprint for transforming how cars are driven, powered and integrated into society.

In 2016, 22 models from 8 car manufacturers offered (SAE) L2 driving capabilities globally. BMW led the market both in terms of market share in Level 2 offerings but also in terms of share in total L2 sales in Europe.

As a result, sales of cars fitted with Level 2 Traffic Jam Assist as standard or optional equipment reached almost 1 million in Europe in 2016, accounting for 6.5% of the 15.13 million car sales in Western Europe.

L2 in EuropeNissan is among the carmakers introducing Level 2 functionality in Europe this year with the ProPilot Assist in the new Leaf, Qashqai and the X-Trail. Nissan’s technology, which will later expand to unlock multi-lane cruising support, was launched last year in Japan in the new Serena.

We expect that in 2019, at least 50 models will be equipped with Traffic Jam Assist or Cruise Assist in Europe, with premium OEMs’ share accounting for 74%.

Here’s a table with the marketing names used by carmakers for their Level 2 Driving features.L2 naming

To learn more insights on ADAS and Automated Driving, including strategy and roadmap of leading carmakers read our latest report Roadmap to Self-Driving Cars.

For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, info@auto2xtech.com.

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Who is liable in Level 3 automated mode, the driver or the car?

Extensive data recording of “critical events” while in L3 to assist in accident reconstruction and liability

  • Today, in Level 0-2, the driver’s inattention at any given point in time triggers his liability
  • Level 3- Conditional “eyes-off”, hitting the road by the end of 2017, has implications for the determination of liability because the driver will be conditionally allowed to be “distracted” but he is still required to be “available”
  • Impact on traditional vehicle insurance as well as carmakers, given the significant engineering challenges to implement extensive data recording amid an immature regulatory framework
  • Carmakers to accept liability while in L3 automated mode but drivers must not sleep or move away from the seat- emergency vehicle stop if the driver fails to respond to takeover request

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Why we need Event Data Recorders (EDR) for automated driving

Existing EDR capability is focused on the seconds around a crash (e.g. 30 seconds before and 15s after the crash) while data capturing needs for Automated Driving may cover a much broader period and require longer storage.

In Level 3, when the system is active and when it becomes legal for drivers to be partially distracted by ADAS, drivers will be able to relax, read, text, call, watch TV, but not sleep or move from their seat because they must always be available to takeover vehicle control when the system signals a transition demand or in case of a system malfunction. But the driver will still be responsible for the overall vehicle control even when the system is active and will have the ability to override it.

In case a “critical event” occurs while the ADS is active, which might expand from an accident to include traffic law violations, data recording capabilities will be required to contribute to accident reconstruction and potentially assist in supporting claims against the manufacturer.

Data recording would be useful to understand if the system failed or transferred control to the driver who failed to ‘’react’’

Therefore, we assess that AD event data recording requirements will be both an engineering prerequisite and a regulatory/legal requirement for deployment and legality to accommodate ‘’critical events’’ and ‘’automated driving mode’’. In the words, to make sure that effective driver monitoring is in place and, when needed, control can be handed back to a driver who is fit and able to drive the vehicle.

What is more, it will be necessary to be able to access the vehicle data in order to determine the circumstances surrounding a given incident, any possible defect or fault in the system, or whether the vehicle was operating under a partially/fully automated mode.

Immature regulatory guidance on data recording and storage for Automated Driving challenges deployment

There is a consensus that EDR-AD will be a regulatory prerequisite for the deployment of L3 as demonstrated by the requirements for EDRs-AD in the amendment of the German Road Traffic Act and the amendment of Reg.79 which already mentions DSSA capabilities -although at a draft status. The problem is that regulatory action is at an early stage therefore guidance on engineering requirements is still immature. We expect though that this will not restrict car manufacturers and suppliers to put EDR-AD in place for L3.

Germany has already passed a law that will allow L3 as long as data recording and sharing are in place and systems are compliant with relevant international regulation. Furthermore, Germany and the UK are among the key car markets which have already started procedures to adjust their road traffic laws/acts to accommodate L3.

On the contrary, the U.S follows a standalone policy based on the star-by-state control of AD regulation and the voluntary federal guidelines which might cause lack of standardisation.

Amid the immature regulatory framework, carmakers face the challenge to design and implement data recording capabilities that will cover the minimum (expected) regulatory requirements but also cover them above and beyond in terms of product liability.

To read more about Autonomous Driving regulation check our report Roadmap to Self-Driving Cars.

For more information on this report, including sample pages and full Table of Contents, please contact us on (+44) (0)20 3286 4562, info@auto2xtech.com.