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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

A member of the media test drives a Tesla Motors Inc. Model S car equipped with Autopilot in Palo Alto, California, U.S., on Wednesday, Oct. 14, 2015. Tesla Motors Inc. will begin rolling out the first version of its highly anticipated "autopilot" features to owners of its all-electric Model S sedan Thursday. Autopilot is a step toward the vision of autonomous or self-driving cars, and includes features like automatic lane changing and the ability of the Model S to parallel park for you. Photographer: David Paul Morris/Bloomberg via Getty Images

Germany legalises L3 automated driving technology that allows “eyes-off” the road

  • Current ADAS Level 2 systems assist but do not substitute the driver, i.e. provide longitudinal and lateral assistance enabling some limited hands-off driving but drivers must always be in control -due to regulation and system capabilities
  • Level 3 systems, enabling the car to take control of the driving and monitoring task, will hit the road this year but are subject to regulatory approval
  • Amendment of the German Road Traffic Act opens up the road for L3 in Germany but compliance with EU law is also required

Germany wants to be in the forefront of Autonomous driving (testing and deployment) ahead of the U.S. therefore it has amended the German Road Traffic Act (Straßenverkehrsgesetz, StVG) to allow domestic car manufacturers, which already are closer to L3, to deploy their systems in the market.

In April, the Bundestag, the lower house of the German parliament, approved the version therefore the only part missing for the amendment of the StVG to come into force was approval from the upper chamber of the German parliament, the Bundesrat. This came in May 12th, earlier than initially expected, removing the regulatory barrier for Audi who plans to deliver the first-ever L3 Traffic Jam Pilot in its updated version of the flagship A8.

Level 3 (SAE) vehicle automation represents a milestone in Autonomous Driving because when these features are active they can take over the monitoring task, together with the driving task, enabling drivers to take their “eyes-off” the road. But the driver must always be available to takeover, since he/she are the ultimate back-up. In case the driver is incapacitated and unable to take back control, adequate robustness must be in place to bring the vehicle into a safe stop, initially in lane.

To learn how Level 3 changes the driving task and how carmakers plan to get there read our post: Volvo to skip Level 3.

Today, even the most innovative ADAS systems for driving and parking, such as Mercedes’s Drive Pilot, Tesla’s Autopilot and BMW’s Remote Control Parking are classified under SAE’s definition as Level 2-Assistive. This means, that they can assist but cannot substitute the driver who must always be in control.

Figure: Volvo’s L3 Intellisafe Autopilot allows hands-off and eyes-off (Source: Volvo)Volvo_Autonomous_driving

L3-Conditional automation to be legal in Germany from Sep’17 requiring EDRs-AD and compliance with UN-EU regs

Initially, this legislation was expected to pass Parliament before federal elections in September 2017, a timeline that aligns with the introduction of the L3-Traffic Jam Pilot from Audi in the 2018MY A8. However, the approval occurred earlier than expected demonstrating the German government’s willingness to promote the domestic market as the leader in Automated Driving which promises a zero-road death future and to unlock time for drivers to focus on other tasks beside driving while commuting.

The amendment of national traffic laws, together with the amendment of international Reg.79 which is expected to come into force by Oct’18, will open up the road for “hands-off and eyes-off” L3 (but not L4 yet). However, many issues remain open with the most important being what exactly will drivers be allowed to do in L3 and the specifications of data recording and sharing capabilities for Event Data Recorders (EDR) which will assist in determining liability when an accident occurs while the L3 system was driving.

Deployment of L3 in Germany would be possible under the new framework, but also provided that systems are compliant with UNECE regulations (e.g. Reg.79 or an exemption is granted) and EDRs (for L3) are fitted for accident reconstruction and claims.

EDR requirements for L3 are immature yet, with more information is expected to come before the finalisation of the law. Minimum requirements from the German draft law include recording of lateral control, system active status, and handover requests for accident reconstruction and insurance claims. Data must be available to relevant road traffic authorities upon request, as well as to any third party. From conversations with Tier 1s, we understand that EDRs for TJP are probably developed in-house by other OEMs rather than in collaboration with suppliers.

Audi to get a head start, other leading premium German OEMs and Tesla to follow

This gives an advantage to Audi since the brand’s launch date for L3-TJP with the new 2018MY A8 is in line with the law coming into force in Sep’17. Audi’s system will probably be categorised as ACSF B2 but we expect the brand to use EU’s Article 20 to get an exemption for the new technology.

Figure: Audi L3 Piloted Driving (Source: Audi)Audi TJP

We expect that other German-based OEMs which are technologically closer to L3 will also benefit, with BMW and Mercedes-Benz being the obvious candidates. Tesla will also benefit since it claims that it is close to L3 (Self-driving functionality). However, the company has been asked by the German government to change its Autopilot naming to avoid customer confusion and misuse/abuse.

The transition from driver-centric regulation to Automated Driving Systems is necessary for the deployment of higher levels of vehicle autonomy

The problem arises from the fact that vehicle regulation and national traffic laws have been developed with the driver in mind, i.e. driver in control. From a technological perspective, we have now reached the point where in certain markets the amendment of regulation is needed to allow Automated Driving Systems to take conditional and eventually full control of the driving task and monitoring of the road.

At the same time, national traffic laws might need to change to accommodate the new driving conditions, e.g. allow the complete absence of driving controls for L4/L5 or driver for L5. Amendments are in progress, to allow the driver to be ‘’out of the loop’’.

But will there be regional inconsistences between what’s legal given that the regulatory landscape in the U.S is different than the rest of the world’s major car markets?

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.

Aktiver Nothalt-Assistent; Wenn der Fahrer nicht mehr reagiert; Der Aktive Nothalt-Assistent bremst das Fahrzeug in der eigenen Spur bis zum Stillstand ab, wenn er erkennt, dass der Fahrer während der Fahrt mit eingeschaltetem Aktivem Lenk-Assistent dauerhaft nicht mehr in das Fahrgeschehen eingreift.  ;

Active Emergency Stop Assist; If the driver is unable to respond; Active Emergency Stop Assist brakes the vehicle in its lane to stand still if the system detects no driver reaction while driving with Active Steering Assist turned on. When there is no steering wheel movement over a 
predefined period, the system informs the driver by visual and audible prompt to place the hands on the steering wheel.;

BMW, Mercedes-Benz and Tesla were the only brands already capable of Level 2 Driving and Parking in 2016-Free whitepaper

Partially-automated model availability more than doubled in 2016

The number of models offering Partially-automated driving capabilities (L2-D) as standard or optional equipment rose by 144.4% in 2016 to 22 models, from just 9 in 2015. Growth was primarily driven by European automakers’ strategy to expand Traffic Jam Assist (TJA) offerings across their model range.

Models with L2-D+P in 2016-17

German car manufactures hold the lion’s share in Level 2-Driving feature offerings

What is more, the number of models offering Self-Parking (SP) capabilities tripled in 2016 amounting to 6 models, whereas those equipped with Remote Parking (RP) doubled to 4. Still though, capability of both L2 driving and parking (L2-D+P) is concentrated in a handful of premium brands’ models. In detail, only 3 car manufacturers, BMW, Mercedes-Benz and Tesla, offered 6 models equipped with TJA and SP as standard or optional equipment in 2016, of which only 4 also offered RP.

bmw self-driving

Some of our key findings for the availability of L2 in Europe in 2016:

  • Partially-automated model availability more than doubled in 2016
  • Audi, BMW and Mercedes are expanding their offerings of Level 2 Automated Driving across carlines but more importantly, TJA (L2) has now reached the compact car segment and volume OEMs including VW and Nissan.
  • 2017 will see the introduction of technology that allows conditional “eyes-off” the road

Regulatory, engineering and other challenges for L3-5 deployment

Autonomous Driving regulation shifts from testing to deployment but standardisation will be a challenge 2016 saw a shift in the focus of regulation from approval of L3/4 testing to discussion for reforms to enable deployment of L3 in public roads. We expect regulatory action to continue stronger in 2017 as key car markets boost their efforts to lead the AV global scene but also guarantee safe and secure deployment.

The transition from driver-centric regulation to Automated Driving Systems is necessary for the deployment of higher levels of vehicle autonomy. Amendment of international regulations as well as national traffic laws will soon give the green light for deployment but will there be regional inconsistencies?

Download our free whitepaper for more insights on ADAS&AD offerings in Europe here: http://auto2xtech.com/go/adlpfreep1/

For further information about our consulting service please contact us on info@auto2xtech.com, (+44) (0) 203 286 4562 or visit auto2xtech.com.

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Volvo to skip Level 3 autonomous mode

Volvo is now added to the list of carmakers pulling-away from deployment of Level 3 automated driving (at least for now) with the CEO characterizing the handover of vehicle control as unsafe.

This comes a few months away from the first-ever L3-equipped car from Audi which will conditionally allow drivers to take their eyes-off the road at low speeds and perform some side tasks but requires them to always be available to takeover within a few seconds. Volvo argues that this handover of control is unsafe and will only offer (completely) unsupervised autonomous mode when it’s safe, for which it will assume full responsibility.

bmw self-driving

Debate over supervised vs unsupervised driving modes-is an intermediate one a good idea?

Earlier, Ford and Google have also expressed a similar philosophy, with the latter basing its approach on the fact that intermediate levels were subject to abuse and/or misuse. More recently, Mercedes has expressed a similar approach, at least as long as it can guarantee the “best or nothing” moto. Thus, it’s expected the updated version of its (Level 2) Drive Pilot in the upcoming flagship S-Class will also be marketed as an Assistive Level 2 system, even though its capabilities could probably support Level 3.

Another key issue is that the deployment of an immature technology for the sake of remaining competitive could have continuous disengagements thus spoiling the driving experience and ruining customer attractiveness.

This development is another demonstration of the different approaches leading car manufacturers are following to commercialize automated driving amid the engineering, regulatory and consumer adoption hurdles. The industry is currently facing a debate over supervised (L0-2) vs (optionally) unsupervised driving (L4-5) and whether an “intermediate” level (L3), where the system can monitor but drivers have to takeover in case of an emergency is safe and adds value to owners.

2017 is the year of transition from Partially-automated cars (SAE L2), where drivers are in complete control with ADAS being purely assistive for safety and convenience, to Conditionally-automated ones (L3) which can take over the driving and monitoring task under specific scenarios allowing the driver to be ‘’distracted’’

L3 driving, 070417

 

What’s coming up from leading carmakers

Volvo will start testing its geo-fenced L4 Intellisafe technology using real families this year in Sweden with the Drive Me project, collecting data on system performance as well as feedback of driver acceptance of what will now be an “unsupervised” driving experience.

Mercedes-Benz is also collecting data for it’s automated driving technology in a project in Australia.

Tesla’s Enhanced Autopilot, which is equipped with an augmented sensor set and Tesla Vision – the proprietary image processing after the split with Mobileye- has almost reached feature parity with the original Autopilot (L0-2) with Musk promising Self-driving capabilities within the year.

Audi is expected to launch the new A8 in Germany, where the legal framework is currently being amended to allow L3, together with certain states in the Americas where the regulatory framework allows it. The feature is expected to initially run in the background until validation and verification is completed.

It’s up to the Germans now to prove that handover of vehicle control can be done safely, intuitively, without disrupting user experience, and that drivers will exploit the conditional eyes-off the road Traffic Jam Assist offers. If the outcome is successful, this head start will be crucial and determine the approach other carmakers follow to commercialise autonomous driving. It will also provide evidence to other key car markets to amend their legal and regulatory framework to allow conditional automation.

To read more about the strategies leading carmakers follow to unlock higher levels of automated driving 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.

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Regulatory framework for autonomous driving gets one step closer

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.

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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.

Amendment

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.

reg79-proposed-categories

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:

  1. Stage-1 will see CSF and ACSF categories A and B1 coming into force by Jan’18
  2. 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

To request a full Table of Contents contact us: (+44) (0)20 3286 4562, info@auto2xtech.com or visit auto2xtech.com