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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

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.

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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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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