Autonomous Vehicle Engineering - July 2022 - 2

Editorial
Structure counts
Automated-vehicle interests from
around the globe had to sit up and pay
attention in the first half of this year,
as a couple of significant new actions
kicked off what may be a new era for AV
development. Not everyone's going to
be happy - particularly those who've
advocated for a " hands-off " approach
to AV regulation and engineering.
In April, the European Union issued
draft legislation for vehicles operating
on public roads with some type of
advanced driver-assistance system
(ADAS) or automated driving system
(ADS). Wisely, the proposed legislation
(found here: https://ec.europa.eu/info/
law/better-regulation/have-your-say/
initiatives/12152-Automated-cars-technical-specifications_en)
divides the
AV regulation into two distinct areas:
performance requirements, which
describe how an AV has to function
under five defined traffic situations
to receive so-called " type approval "
to operate on public roads in Europe,
and a " compliance assessment, " which
defines how AVs will be evaluated,
tested and audited in order to win
approval for on-road operation.
There will be plenty of argument
about the details, but several sources
have indicated to me that they can't find
much fault with the proposed legislation's
general direction. The lengthy
document includes instructions for
third-party validation of testing results
and explanation of what's expected
from an ADAS system under the stipulated
testing scenarios. This helps
potentially " standardize " the various
claims made by OEMs of receiving
some amorphously-defined ADAS/ADS
regulatory approval.
The performance-related aspects
of the proposed legislation are
important. But the compliance-related
portion of the regulations - with five
categories that address, for example,
details of system modeling and simulation
and on-road safety testing - is
more exhaustive. In effect, the EU recognized
that defining performance under
certain operating design domain (ODD)
situations is vital, while describing what
constitutes " compliance " in testing and
evaluation is even more crucial.
And the NHTSA in mid-June
released the first cache of data collected
over the previous year of reported crashes
while vehicles were operating with ADAS
engaged. There are numerous caveats
regarding the report's scope and, more
crucially, the reporting methodology.
On the facing page, you'll see
columnist Sam Abuelsamid's thoughts
about the NHTSA report. Sam has found
a lot more to unwrap. Tesla (273) and
Honda (90) accounted for 363 of the 392
crashes! The lion's share (125) of these
were in California, negating potential
time-of-the-year and regional causes
such as bad weather. The most interesting
takeaway for me was that nearly
two-thirds (258) of the crash reports
came via telematics, which certainly
says something about the potential of
over-the-air (OTA) technology.
The NHTSA report provides a
genesis for the data-acquisition and
-assessment structure that responsible
AV development should embrace
- even if reporting of after-the-fact
incidents seems a pale comparison to
the EU's front-loaded performance and
testing commitment. But if the generally
positive and cooperative public
responses to the EU's proposed AV
regulations are any indicator (those, too,
can be read at the above link), it might
not be long before a similar framework
is considered in North America.
Bill Visnic, Editorial Director
EDITORIAL
Bill Visnic
Editorial Director
Bill.Visnic@sae.org
Lindsay Brooke
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2 July 2022
AUTONOMOUS VEHICLE ENGINEERING
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12152-Automated-cars-technical-specification_en
Autonomous Vehicle Engineering - July 2022

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