Regulatory needs and solutions for deployment of Vehicle and Road Automation (Draft1)

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EUROPEAN COMMISSION DG Cmmunicatins Netwrks, Cntent & Technlgy SEVENTH FRAMEWORK PROGRAMME INFORMATION AND COMMUNICATION TECHNOLOGIES Crdinatin and Supprt Actin Grant Agreement Nr 610737 Supprt actin fr Vehicle and Rad Autmatin netwrk Regulatry needs and slutins fr deplyment f Vehicle and Rad Autmatin (Draft1) Deliverable n. Disseminatin level Wrk Package n. Main authr(s) Cntributins Versin Nr (F: final, D: draft) D3.2.1 PU WP3 Maxime Flament AB VOLVO (FR), BMVI (DE), DfT (UK), ICCS (GR), IDIADA (SP), Lindhlmen Science Park (SE), RDW (NL), TRAFI (FI), TransprtStyrelsen (SE), TUDelft (NL), UNI ROMA - CTL (IT) File Name VRA_20140930_WP3_D3.2.1 Regulatry needs (Draft 1) v12.dcx Prject Start Date and Duratin 01 July 2013, 42 mnths

Dcument Cntrl Sheet Main authr(s) r editr(s): Maxime Flament Wrk area: WP3 Dcument title: Regulatry needs and slutins fr deplyment f Vehicle and Rad Autmatin (Draft1) Versin histry: Versin number Date Main authr Summary f changes V0.1 2014-07-02 Maxime Flament First draft adapted t cmmn WP3 structure; Inputs frm past meetings V0.2 2014-07-25 Maxime Flament Inputs frm TRB meeting V0.3 2014-08-29 Maxime Flament Added intrductin V0.4 2014-09-30 Maxime Flament Added inputs frm Detrit ITS WC SIS n liabilities; legal issues WG discussin; recmmendatins Inputs frm MS cntact pints Distributin t VRA partners V0.5 2014-10-10 Maxime Flament Added review inputs frm partners V0.6 2014-10-17 Maxime Flament Added inputs frm Germany and Finland V1.0 2014-10-20 Maxime Flament Finalisatin after WP leader inputs 2014-10-20 Maxime Flament Updates after circulatin t partners Apprval: Name Date Prepared Maxime Flament 2014-10-10 Reviewed Txmin Rdrigues 2014-10-17 Authrised Maxime Flament 2014-10-20 Circulatin: Recipient Date f submissin EC 2014-10-20 VRA cnsrtium 2014-10-20 VRA is an ERTICO Partnership activity 2

Table f Cntents Dcument Cntrl Sheet...2 Table f Cntents...3 List f Figures...5 1 Cntractual infrmatin...6 1.1 Purpse f Dcument 6 1.2 Structure f Dcument 6 1.3 VRA Cntractual References 6 1.4 Prject Objectives 6 1.5 Disclaimer 7 2 Intrductin...8 2.1 Definitins 8 2.2 Objectives and scpe f the VRA task n regulatry needs (WP3.2) 9 2.3 Stakehlders tree 9 2.4 Methdlgy descriptin 11 2.4.1 Tls fr stakehlders engagement in regulatry issues 12 2.4.2 Implementatin plan 12 3 Mapping f the current activities and stakehlders... 14 3.1 Eurpean Cmmissin 14 3.1.1 Study SMART2010/0064 Definitin f necessary vehicle and infrastructure systems fr autmated driving 14 3.1.2 DG MOVE study n actin 5.2 Liability aspects related t ITS applicatins 14 3.1.3 imbility frum Autmatin WG: Sub-WG n regulatry needs 15 3.1.4 Eurpean Cmmissin Platfrm fr the deplyment f C-ITS in the EU 16 3.2 EU Member States 16 3.2.1 Germany 16 3.2.2 The Netherlands 17 3.2.3 United Kingdm 19 3.2.4 France 20 3.2.5 Sweden 21 3.2.6 Finland 22 3.2.7 Greece 23 3.2.8 Other EU member states 23 3.2.9 United States 23 3.2.10 Japan 24 3.2.11 Other parts f the wrld 24 3.3 Internatinal bdies 25 VRA is an ERTICO Partnership activity 3

3.3.1 UNECE 25 3.3.2 Standardisatin 26 4 Regulatry-related studies frm funded research prjects... 28 4.1 FP7 HaveIT (cncluded) 28 4.2 InteractIVe (cncluded) 28 4.3 FP7 SARTRE (cncluded) 28 4.4 FP7 COMPANION (cncluded) 29 4.5 FP7 Citymbil2 WP26 (nging) 29 4.6 FP7 AdaptIVe Respnse4 (nging) 30 4.7 DRIVE Me (SE nging) 30 4.8 HF Aut (NL - nging) 31 4.9 NL DAVI (nging) 31 4.10 FR ABV (cncluded) 32 5 Legal and Regulatry cncerns... 33 5.1 Rles and respnsibilities 33 5.1.1 Rad peratr 33 5.1.2 Vehicle manufacturers 33 5.2 Testing f autmated vehicles 33 5.3 Liability framewrk 33 5.4 Insurance funds 33 5.5 Infrastructure Data 33 5.5.1 Data prvided by cmmercial third parties e.g. service prviders 33 5.5.2 Data prvided by Public services 33 5.6 Vehicle data 33 5.6.1 Eg-Psitining 33 5.6.2 Vehicle tracking 33 5.6.3 Data re-use 33 5.6.4 Data Quality assurance 33 6 Achievements f the WP3.2... 34 6.1 Building a netwrk fr discussin grups 34 6.2 Current status f discussins 34 6.3 Next steps 34 Annex 1: Current recmmendatins frm the Regulatry issues discussin grup... 35 VRA is an ERTICO Partnership activity 4

List f Figures Figure 1: The evlutin f Advanced Driver Assistance Systems twards Highly Autmated Driving applicatins AdaptIVe prject... 8 Figure 2: Evlutin f Autmated Rad Transprt Systems (ARTS) as a supplement t mass transit CityMbil2 9 Figure 3. Illustratin f stakehlder grups and their rle vehicle and rad autmatin...10 Figure 4: early discussins in the SMART64 study n liabilities fr autmated driving SMART64/2010 TNO...14 Figure 5: Autmated Driving - Matrix f categries with examples ( Daimler, J. Schwarz)...15 Figure 6: Japan Crss-Ministerial Strategic Innvatin Prmtin Prgram (SIP) Autmated Driving System Research themes...24 Figure 7: J3016 SAE Taxnmy and Definitins fr Terms Related t On-Rad Mtr Vehicle Autmated Driving Systems...26 VRA is an ERTICO Partnership activity 5

1 Cntractual infrmatin 1.1 Purpse f Dcument The bjective f this deliverable is t reprt the activities f the task WP3.2 f VRA n regulatry needs fr the deplyment f vehicle and rad autmatin. The first perid span frm July 2013 t September 2014. This phase f the task was mstly investigatry with an attempt t identify the relevant persns in Eurpe and beynd fr the regulatry tpic. 1.2 Structure f Dcument This dcument cnsists f the fllwing sectins: Cntractual infrmatin Intrductin Mapping f current activities at EU, MS, and internatinal levels. Related prjects (First versin f Legal and regulatry cncerns planned in Draft2) Reprt n current achievements Annexe: recmmendatins drafted by the discussin grup 1.3 VRA Cntractual References VRA, Vehicle and Rad Autmatin, is a Supprt Actin submitted fr the call FP7-ICT-2013-10. It stands fr Vehicle and Rad Autmatin Netwrk. The Grant Agreement number is 610737 and prject duratin is 42 mnths, effective frm 01 July 2013 until 31 December 2016. It is a cntract with the Eurpean Cmmissin (EC), Directrate General Cmmunicatins Netwrks, Cntent & Technlgy (DG CONNECT). The EC Prject Officer is: Mrs Aude Zimmermann EUROPEAN COMMISSION DG CONNECT - H05 Office: BU31 06/030 B - 1049 Brussels Tel: +32 2 298 7022 E-mail: aude.zimmermann@ec.eurpa.eu 1.4 Prject Objectives In the field f vehicle and rad autmatin, VRA s main bjectives are: T maintain an active netwrk f experts and stakehlders T cntribute t internatinal cllabratin T identify deplyment needs VRA is an ERTICO Partnership activity 6

T prmte research and deplyment initiatives In practice, VRA will: Organise r supprt internatinal meetings tgether with similar initiatives in US and JPN. (WP2.1) Supprt the imbility Frum Autmatin WG and extend its rle as a reference grup fr Eurpean activities n the tpic eventually frmulating cmmn psitins, especially at Eurpean level (WP2.2) Aggregate infrmatin n existing research r deplyment activities in a shared wiki (WP2.3) Describe valid business mdels and deplyment paths & scenaris and investigate the brad sci-ecnmic implicatins f autmatin fr the future scieties (WP3.1) Clarify, reprt and setup a plan f actins n legal, liability, insurance and regulatry issues in different member states (WP3.2) Mnitr and steer standardisatin, cmpliance and certificatin fr vehicle and rad autmatin (WP3.3.) 1.5 Disclaimer The cntent f this deliverable shuld be cnsidered nly as infrmatin and des nt cnstitute in any way any bligatins fr r cmmitments f the referred gvernemental bdies r the industry stakehlders. VRA is an ERTICO Partnership activity 7

2 Intrductin 2.1 Definitins The research arund autmatin in rad transprt has been apprached frm tw distinct expert cmmunities: On ne side, the evlutin f the Advanced Driver Assistance Systems led by the autmtive industry and supprted by a large number f autmtive research centres. Advanced driver assistance systems (ADAS) are systems develped t autmate/adapt/enhance vehicle systems fr safety and better driving. Safety features are designed t avid cllisins and accidents by ffering technlgies that alert the driver t ptential prblems, r t avid cllisins by implementing safeguards and taking ver cntrl f the vehicle. Adaptive features may autmate lighting, prvide adaptive cruise cntrl, autmate braking, incrprate GPS/ traffic warnings, cnnect t smartphnes, alert driver t ther cars r dangers, keep the driver in the crrect lane, r shw what is in blind spts. ADAS technlgy can be based upn visin/camera systems, sensr technlgy, car data netwrks, Vehicle-t- Vehicle (V2V), r Vehicle-t-Infrastructure systems. Next-generatin ADAS will increasingly leverage the prgress n HMI, sensing, V2X and actuatin leading t prgressively mre and mre autmatin f the driving functin, ften referred as Highly Autmated Driving (HAD) systems. Figure 1: The evlutin f Advanced Driver Assistance Systems twards Highly Autmated Driving applicatins AdaptIVe prject One the ther side, the evlutin f the autmated rail transprt systems brught t the rad, first in segregated tracks and gradually in mixed traffic envirnment. Autmated rad transprt systems (ARTS) are transprt systems based n the use f fully autmated rad vehicles cntrlled by a centralized fleet management system, which als cntrls the vehicles interactin with the infrastructure. ARTS allw prviding scheduled, n-demand, r dr-t-dr services n a specific rad VRA is an ERTICO Partnership activity 8

infrastructure that can be segregated, dedicated r shared with ther rad users. ARTS are aimed (at least at the beginning) t supplement mass transit in the last miles and are cmmercially available tday. Figure 2: Evlutin f Autmated Rad Transprt Systems (ARTS) as a supplement t mass transit CityMbil2 The legal and regulatry issues arund these tw appraches are quite different. This dcument reprts n the knwn regulatry activities related t bth kind f systems. 2.2 Objectives and scpe f the VRA task n regulatry needs (WP3.2) The WP3.2 activities cnsist f the fllwing tasks: Cnvene specific meetings, and lead and cntribute t the discussins n: regulatry needs fr deplyment f autmatin and autmated vehicles in Eurpe, legal and liability issues linking with regulatry measures Cntribute t reach cmmn psitins and write a white r psitin paper n the tpic and present it t key stakehlders (such as UNECE WP29), WP3.2 utcme will be cnslidated at the end f each perid f the VRA cntract in the deliverable series D3.2.x n Regulatry needs and slutins fr deplyment f Vehicle and Rad Autmatin. due at M15, M27, M41 (starting frm July 2013). The meeting prtcls, agreements and draft dcumentatin will be dcumented and reprted regularly in Eurpean and Internatinal meetings (WP2.1-WP2.2). 2.3 Stakehlders tree The stakehlders t be taken int accunt in vehicle and rad autmatin can be divided int fur big categries: technlgy prviders (e.g.: OEM s, GNS suppliers, research and cnsulting), service prviders (highway peratrs, assurance cmpanies), decisin makers (e.g.: lcal and natinal authrities, certificatin bdies) and final cnsumers (e.g.: drivers assciatins). Fllwing the distinctin f rles fr VRA, the stakehlder grups are VRA is an ERTICO Partnership activity 9

illustrated in Figure 3. Illustratin f stakehlder grups and their rle vehicle and rad autmatin. The fur sides f the rectangle represent these fur rles. Figure 3. Illustratin f stakehlder grups and their rle vehicle and rad autmatin This general verview is custmized in Table 1, in which the stakehlders are analysed indicating main functin and als key aspects n regulatry needs that are affecting them. This is imprtant t fcus the discussins depending n the grup f stakehlders that VRA is addressing at each mment Table 1. Stakehlder tree identificatin and regulatry key aspects Stakehlder Functin Regulatry issues Plicy makers and legislative bdies Prduce regulatins and ensures cmpliance Rle f gvernments (Eurpean, natinal, lcal) regarding autmated driving (e.g.: guidance, regulatin, versight) Gvernance issues related t autmated rad transprt, Vehicle manufacturers System prviders Research cmpanies Service prviders Manufacture and sell vehicles with a level f autmatin Offer VRA related systems and applicatins fr vehicles and infrastructures Prvide new paradigms and applicatin slutins. Part f the technlgy prviders chain Make business prviding services based n vehicle and rad Data use and wnership Regulatins affecting vehicles manufacturing Ask fr changes in the regulatry framewrk fr new paradigms Need clarificatin f Liability framewrk Regulatins affecting new systems Cyber security and privacy regulatin Ask fr changes in the regulatry framewrk fr new paradigms Accmplish with regulatins VRA is an ERTICO Partnership activity 10

Stakehlder Functin Regulatry issues autmatin Infrastructure Explde rads and highways. Is a Accmplish with regulatins peratrs ptential service prvider Final cnsumers Buyers f technlgy (drivers, fleet wners, lcal authrities, ) Vulnerable rad users prtectin Level f transparency f autmated systems peratin t the users. Understanding f underlying functins, limitatins and Certificatin bdies Insurance cmpanies Standards Develping Organizatins Hmlgatin f vehicles, equipment and drivers fr autmatin Prvide Insurance fr autmated vehicles. Safe mbility and respnsibilities Primary activities in develping, crdinating, prmulgating, revising, amending, reissuing, interpreting, r therwise prducing technical standards that are intended t address the needs f sme relatively wide base f affected adpters 2.4 Methdlgy descriptin cntingencies. Harmnizatin with plicies in autmated driving t enable new certificatin prcedures Liability and risk issues Harmnizatin with plicies in autmated driving t enable new standards. The key aspects and strategy fr discussin grups is based n the fllwing: Creatin and explitatin f a wide range f cntacts related t the tpic f regulatry issues At Eurpean Member State level: experts wrking within the different natinal ministries but that are nt directly invlved in the Eurpean affairs. These persns are ften linked t natinal prjects and/r natinal gvernance bdies such as type apprval authrities r interir ministry. Als, the netwrk f Eurpean ITS natinal rganisatins ffers a gd link t such experts. At EU MS expert level: experts that are appinted by the Eurpean Member States t fllw the Eurpean affairs fr example in the framewrk f the ITS directive r the recent C-ITS platfrm. These persns have large experience n EU affairs and knw well the relevant cntact pints within their rganisatin. At internatinal level: experts in US, Japan r ther cuntries utside Eurpe. Typically, linked t TRB cmmittees and events r t ITS rganisatins similar t ERTICO: ITS America, ITS Japan, ITS Asia Pacific, ITS China, Austrads, ITS Singapre, and many thers At UN level: experts invlved in the WP29, WP1 r ITC activities. Independents pint f views (cnsultants) VRA is an ERTICO Partnership activity 11

Participate t meetings related t the tpic at all gegraphical levels and advcate n the imprtance f a harmnised apprach n regulatins fr autmated vehicles Gather infrmatin n relevant activities as well as psitins frm the different Eurpean Member States and beynd and reprt yearly n the prgress, eventually engage the expert cmmunity t cntribute t imprve the reprt. Organise discussin meetings, breakut sessins r dedicated wrkshps with the supprt f ther grups such as the Legal Issues Wrking Grup f the imbility Frum r the TRB cmmittee AL040 Emerging Technlgy Law Cmmittee. 2.4.1 Tls fr stakehlders engagement in regulatry issues The main tls used fr stakehlders engagement are: Annual TRB meeting: The US transprt experts meet nce a year beginning f January. The Transprt Research Bard (TRB) is rganised in a large number f cmmittees. Many cmmittees are nw engaged in the many aspects f Rad and vehicle autmatin. The cmmittees meet at least nce a year t reprt n their activities. Jint TRB sympsium: This sympsium has been rganised yearly since 2012 and is at its 3 rd editin. The last editin gathered ITS Eurpean and wrld cngresses: The ITS wrld cngresses are rganised jintly by ITS Asia-Pacific, ITS America, and ERTICO - ITS Eurpe. Their lcatins alternate between the three regins. The wrld cngresses are ften rganised in Octber. Whenever the ITS Wrld Cngress is nt in Eurpe, a Eurpean ITS cngress takes place. As the audience is as much representing the industry than the public sectr, the ITS cngresses are gd pprtunities t discuss n the regulatry issues arund autmatin. EU MS experts: Currently there is n dedicated EC initiative arund vehicle autmatin. Hwever, a lt is happening arund C-ITS. The EU MS experts nminated t deal with C-ITS are ften invlved in vehicle autmatin issues in their cuntry. Eurpean presidency: mbility week: the Eurpean presidencies are rtating every six mnths arund the EU MS. The lcal supprt f the presidency n specific tpics gives autmatically a Eurpe wide visibility. In May 2014, the Greek presidency rganised an event with VRA and Citymbil2 n the tpic f certificatin f ARTS. imbility Frum: The imbility Frum WG n Autmatin in Rad Transprt Other EU funded prjects: the currently funded prject AdaptIVe, igame, Cmpanin, Autnet2030, CityMbil2, etc 2.4.2 Implementatin plan The fllwing tasks are freseen ver the 42 mnths duratin f the WP3.2 activities: First perid (July 2015 Sept 2014): Identify the active cntact pints, VRA is an ERTICO Partnership activity 12

Clarify current initiatives f EU Members States, Identify the inputs frm EU and natinal -funded prjects, Netwrk internatinally especially with US and Japan t identify their regulatry initiatives, Prvide first recmmendatins fr EU level crdinatin. Publish findings in a first draft reprt Secnd Perid (Oct 2014 Sept 2015) Initiate cncrete interactin with identified cntact pints, Request feedback n first draft reprt and extend its scpe, List current regulatry cncerns and which actins are needed, Organise at least ne wrkshp n regulatry issues in cllabratin with the legal issues WG f the imbility Frum, Update reprt with status f initiatives and prject results, add any new nes, Publish findings in secnd draft reprt, Third perid (Oct 2015 Dec 2016) Supprt relevant actins identified and prpse slutins, If needed fllw-up with ne wrkshp t validate a plan f actins, Update reprt with status f initiatives and prject results, add any new nes, Publish findings and actins in the final reprt. VRA is an ERTICO Partnership activity 13

3 Mapping f the current activities and stakehlders This sectin maps the different activities at different levels. First, lking at the natinal activities, then Eurpean level as well as cmparing with US activities. Finally, a shrt verview f the UNECE prgress is prvided. 3.1 Eurpean Cmmissin 3.1.1 Study SMART2010/0064 Definitin f necessary vehicle and infrastructure systems fr autmated driving The SMART64 study led by TNO established a list f issues t be addressed in view f autmated driving. Amng the nn-technical issues, Liability and legal issues were discussed briefly. Figure 4: early discussins in the SMART64 study n liabilities fr autmated driving SMART64/2010 TNO The dcument is available n the VRA wiki: http://vra-net.eu/news/smart-20100064- definitin-f-necessary-vehicle-and-infrastructure-systems-fr-autmated-driving/ 3.1.2 DG MOVE study n actin 5.2 Liability aspects related t ITS applicatins In 2012-2013, the Eurpean Cmmissin cnducted a study under the ITS actin plan actin 5.2 n the Liability aspects related t ITS applicatins. The study rganised a wrkshp in June 2012. The results f the study were published in a final reprt in December 2012. As presented by Daimler at the wrkshp, the reprt used the BASt degrees f autmatin and mapped them accrding t the applicatin ranges: Lw speed autmatin, limited duratin autmatin, and permanent driving. See sectin 3.2 fr the German activities. Since 2012, the BASt degrees f autmatin have been further develped eventually making their way in the SAE standard J3016. See sectin 3.3.2. VRA is an ERTICO Partnership activity 14

Figure 5: Autmated Driving - Matrix f categries with examples ( Daimler, J. Schwarz) The reprt listed the main challenges fr legal and liability issues related t Autmated Driving: Paradigm shift: The rle f the driver f a vehicle might develp in directin f a passenger. Regulatry law: Rad traffic which cntains vehicles withut drivers (r drivers that are ut f cntrl) is a blank field in regulatry traffic law. Liability: The burdens f vehicle manufacturers in terms f prduct liability increase massively. The publicatin f the reprt led t a few actins during 2013-2014: Mst imprtantly fr ur purpse, the EC-funded integrated prject AdaptIVe has integrated vehicle autmatin liabilities and legal issues within the sub-prject call RESPONSE4 led by Daimler. Mre recently, the Eurpean Cmmissin rganised a wrkshp in May 2014 but eventually fcussed n the access and availability f multimdal travel and traffic data. As a next step, it is freseen that sme f the plicy discussins abut autmatin will als take place in the newly launched Eurpean Cmmissin C-ITS platfrm. 3.1.3 imbility frum Autmatin WG: Sub-WG n regulatry needs The imbility Frum WG n autmatin f rad transprt was created as an utcme f a wrkshp rganised by the Eurpean Cmmissin in Octber 2011. The kick-ff tk place in 2012. VRA is an ERTICO Partnership activity 15

Its bjective is t act as a frum fr understanding the current state f the art in autmatin in Rad Transprt, explre and prmte the ptential f autmatin and applicatins fr intelligent and sustainable mbility and prviding a clear directin fr the challenges f the future. All activities are reprted n the imbility Frum secretariat website 1. Its first public result Radmaps fr the autmatin f rad transprt was published in June 2013. The VRA supprt actin is directly supprting the WG, rganising meetings, gathering inputs and reprting n the utcme. The Sub-WGs are created n a per need basis t answer aspects that are t specific t be discussed at plenary level. The sub-wg n regulatry issues was created in 2013 as many discussins were n-ging at Natinal level but there was n clear red line frm EU level. The VRA task WP3.2 is directly supprting the sub-wg activities. Fr instance, this dcument cnstitutes a basis fr the wrk f the sub-wg. The first utcme f the sub-wg is reprted in Annex 1. 3.1.4 Eurpean Cmmissin Platfrm fr the deplyment f C-ITS in the EU The platfrm will address the main barriers and enablers identified fr the deplyment f C- ITS in the EU, in relatin t the services likely t be intrduce in the first stage (Day 1 applicatins) in view t prvide plicy recmmendatins t the Eurpean Cmmissin fr the develpment f a Cmmunicatin n the Deplyment f C-ITS in the EU by the end f 2015. A draft wrk prgramme "Gap Analysis: What is t be dne fr C-ITS Deplyment" has been published as a backgrund dcument fr the call fr experts. One f the Wrk Packages in the draft Wrk Plan relates t legal issues. Even if the wrk will be fcussed n C-ITS, autmatin will certainly be cnsidered as an underlying eventuality. Sme aspects related t data re-use and access are essentially the same between C-ITS and Autmatin. 3.2 EU Member States This sectin reviews the activities related t regulatin f autmated vehicles as reprted by the different Member States: Germany, The Netherlands, UK, France, Sweden, Finland, and Greece. 3.2.1 Germany Germany has been studying the legal aspects f vehicle autmatin systems t determine what legal changes may be needed and hw these relate t different levels f vehicle autmatin (which they defined very carefully and precisely). A jint wrk 2 f the Wrking Grup f the German Federal Highway Research Institute (BASt) led by Tm Gasser had 1 http://www.imbilitysupprt.eu/imbility-frum/wrking-grups/autmatin#library 2 Rechtsflgen zunehmender Fahrzeugautmatisierung, BASt-Bericht F 83, T. M. Gasser et al., 2012, Translatin f part 1: Legal cnsequences f an increase in vehicle autmatin. Part1, 2013 VRA is an ERTICO Partnership activity 16

cnsiderable impact n the expert cmmunity. Fr the first time, a study made an extensive legal assessment with respect t regulatry law and liability law, and, ffered a classificatin f the degrees f autmatin frm a plicy perspective. This definitin was at the surce f the NHTSA levels and eventually the SAE standard 3. The study suggested that the current legislatin wuld allw partial autmatin levels n public rads i.e. The system takes ver lngitudinal and lateral cntrl, the driver shall permanently mnitr the system and shall be prepared t take ver cntrl at any time. Further, BASt have prpsed t wrk n ther dimensins namely the speed range and utilisatin time. They have prpsed three speed ranges frm maneuvring level, traffic jam assist / city speed and highways, and, three utilisatin time, shrt, medium and lng. These cncepts are further explred in the RESPONSE4 activity f AdaptIVe, frm which the first deliverables are expected end f 2014. The German Federal Ministry f Transprt and Digital Infrastructure established a Rund Table Autmated Driving in Nvember 2013. This Rund Table can be cnsidered as a natinal platfrm where all relevant stakehlder grups (Federal Ministries invlved, public authrities, industry, insurance cmpanies, user assciatins, technical inspectin, research institutes) are represented. The peratinal wrk is dne by the Wrking Grups Legal Issues, Driver/Vehicle and Research. The bjectives are building a cnsensus with respect t cre issues f autmated driving thereby creating basic precnditin fr the implementatin f highly autmated driving. This natinal platfrm als acts as an advisry bard f the Federal Ministry f Transprt and Digital Infrastructure. Cntact persn: Dr. Christhard Gelau (christhard.gelau@bmvi.bund.de). 3.2.2 The Netherlands On June 16 th 2014, the Dutch Minister f Infrastructure and Envirnment annunced in a letter t the Dutch Parliament its intentin related t the prmtin f autmated driving in the Netherlands. Under current legislatin, sme frms f autmatin like (C)ACC and lw speed autmated parking are allwed. Fr mre far reaching applicatins the present legislatin ffers nly limited pssibilities. T test self-driving cars n the public highway, the existing legislatin under which RDW (the natinal vehicle and driving license registratin authrity) grants exemptins will be amended. It is expect that this prpsal will be sent t the Huse f Representatives in January 2015. Flexibility in legislatin is crucial t these innvative technlgical develpments in rder t respnd alertly t changes. Therefre, the Netherlands will initially lk fr generic functinal standards instead f specific and technical standards. Psitining the Netherlands internatinally as a leader and test cuntry Our high-quality infrastructure cmbined with the psitive cperatin between the autmtive industry, researchers and the gvernment make the Netherlands an extremely suitable cuntry fr the intended innvatin, develpment and use f self-driving cars. Cmpared with neighbring cuntries, we have a high-quality main rad netwrk, with sufficient slip rads and a high-quality separatin f traffic. Mrever, RDW is already a significant glbal party fr the certificatin f new vehicles, as recently ccurred with the 3 SAE defines an additinal level f autmatin, essentially the fully autmated etaxi cncept VRA is an ERTICO Partnership activity 17

Tesla. Many German manufacturers have their new mdels certificated by RDW fr the Eurpean market. The Netherlands is als amng the frntrunners when it cmes t the cmbinatin f autnmus driving and vehicle-t-vehicle cmmunicatin, aimed at creating high (scietal) added value, with the lng histry f cperatin between gvernment and industry and knwledge institutes as a key factr. A prgressive and cllabrative gvernment can reinfrce this gd baseline psitin. This is anther field where we have a lead, because we are accustmed t cperating with knwledge institutins, market parties and authrities, witness the natinal public-private Cnnecting Mbility actin prgramme, the cperative ITS crridr f Rtterdam-Frankfurt- Vienna, and the Dutch Autmated Vehicle Initiative (DAVI). The sectr is already invlved in small-scale trials n the main rad netwrk, such as the Dutch Integrated Test Site n Cperative Mbility (DITCM) in Helmnd. Over the cming fur years, they will carry ut prjects with the market, building upn the existing innvative prjects. The Dutch EU Presidency in 2016 will prvide pssibilities fr shwing the way in cperatin at Eurpean level. Learning by ding The sectr and researchers expect it t take many years yet befre self-driving cars will be usable safely and n a large scale. The autmatic functins will be increased step-by-step and will need t be tried ut in practice. This is imprtant n accunt f the technical availability and n accunt f cnsumer acceptance f these applicatins and their cnfidence in using them. T be ready fr issues that lie ahead, we will adpt a flexible stance and will cperate intensively with stakehlders. The Netherlands will examine questins cncerning data (wnership, management, interchange and security), liability, driving skill requirements and the ptential impact n the (digital) infrastructure. These are questins that will receive extra attentin during the transitin, because fr many years there will still be mixed usage f legacy cars and mdels with (cmpletely) autnmus functins. There are als initiatives taken t research the impact n the insurance branch. It is essential t perfrm tests t mnitr the use f new technlgy and t set dwn the necessary regulatins. Testing will allw ther rad users t becme accustmed t these vehicles n the rads. The first test applicatins have been received. There are fur test applicatins t date (Octber 2014) fr self-driving vehicles n public rads in The Netherlands. These applicatins invlve a variety f use cases. We wish t facilitate these tests and are mindful that safety will bviusly be the mst imprtant precnditin. Fr this purpse the testing will ccur step-by-step with increasing cmplexity (functinality and surrundings) and will be assessed accrding t safety. Fr example, there will first be testing campaigns n clsed private sites befre any tests n the public highways. The apprach t enable large-scale testing in the Netherlands 1. Implement innvatin-prmting legislatin a. T enable self-driving cars (and tests with them) n the public highway frm a legal pint f view, the existing Order in Cuncil (the decree allwing exemptin fr exceptinal transprt mvements) under which RDW grants exemptins will be amended early 2015. Until that time testing is pssible n a small scale. RDW will then grant exemptin and assess safety tgether with the rad managers. In ding s we will bviusly lk at what is happening in the rest f the wrld in this field. VRA is an ERTICO Partnership activity 18

b. The Netherlands will additinally strive fr natinal/internatinal legislatin that enables the market intrductin f self-driving vehicle technlgy. Fr this purpse we will take the initiative in internatinal cnsultative bdies (EU and UN) and we will supprt relevant prpsals. In preparatin fr the Dutch Presidency f the EU in 2016, the Netherlands will take stck f which regulatins/framewrks wuld need t be amended at Eurpean level fr selfdriving cars, r where a jint framewrk is desirable. The Netherlands will naturally cperate with ther cuntries in this respect. 2. Facilitate large-scale practical tests and develp knwledge a. RDW prvides infrmatin n the cnditins and the lcatins fr perfrming the afrementined test in Dutch and English n its website (www.rdw.nl) b. We will use the first tests t develp a basic prcedure and a set f cnditins fr structurally testing autmatic vehicle technlgy in practice. The bjective is t cnduct safe tests and structurally t assure knwledge fr subsequent initiatives and prjects. T this end we are cperating with knwledge institutins, the business cmmunity, RDW and rad managers. c. We will participate actively in internatinal initiatives. Fr example, we participate in the Wrld Ecnmic Frum, where tgether with the autmtive industry and ther relevant parties the barriers and pssible slutins fr selfdriving cars will be identified. This might include issues cncerning data (wnership, management, interchange and security) and liability. At natinal level we will cmmissin studies int these subjects, als factring in privacy and driving skill requirements. 3. Make the Netherlands an internatinal leader and interact with the general public a. Tgether with the autmtive industry and knwledge institutins, the Netherlands will lk fr further ways f making the Netherlands an attractive test cuntry and prmting this rle. The Netherlands will encurage new test applicatins by means f direct cntacts with car and lrry manufacturers and by building up an internatinal netwrk in this field. b. We are starting with an initiative t create a cmmunity f early adpters fr insights int practical experience and a 'challenge' with self-driving cars n the public highway (similar t the Wrld Slar Challenge fr slar-pwered vehicles) as a platfrm fr parties wrking n this develpment. 3.2.3 United Kingdm As part f the 2013 Natinal Infrastructure Plan, the gvernment pledged a review f the legislative and regulatry framewrk t enable the trialling f driverless cars n UK rads. The gvernment als annunced in the 2013 Autumn Statement that it will wrk t encurage the develpment and intrductin f autnmus vehicles.1 The Autmtive Cuncil, chaired by the Business Secretary, sees autnmus vehicles as an imprtant technlgy fr the UK, especially given the strength f UK based autmtive research and develpment, and wishes t prmte UK based expertise.2 On 30 July 2014, the gvernment als launched a driverless cars cmpetitin inviting UK cities t jin tgether with businesses and research rganisatins and hst vehicle trials lcally. VRA is an ERTICO Partnership activity 19

Over the summer 2014, the UK Department fr Transprt (DfT) has been asking fr views n creating a framewrk fr the testing f driverless cars n UK rads as part f a review. The review will establish the bstacles that prevent the testing f self-driving cars n UK rads. We will als cnsider hw these bstacles can be remved whilst maintain existing high levels f rad user safety. The UK DfT has published a backgrund dcument and pened a cnsultatin n the subject: any issues, including regulatry, safety and scial issues, which need t be addressed the best ways t trial cars with qualified drivers and, lking further ahead, fully autnmus vehicles UK DfT has als published a terms f reference fr the cnsultatin. The cnsultatin is nw cmpleted and DfT is analysing the feedback (as f end Sept 2014). Previus t this activity, the same team at DfT had cntracted a preliminary study n the feasibility f rad trains n the UK rads s called platns. The study is nt published but TRL and Ricard published part f the results at the RTIC2014 4. 3.2.4 France Already during the PREDIT 2 perid (1996-2000), the French research centers were studying the issues f the intrductin f autmatin in rad transprt. The fcus was very much n the intrductin f mre and mre ADAS which at this time did nt require changes f legislatin. Als, French activities n Cybercars attracted media attatin but were nt mature enugh t start regulatry actins. In Sept 2013, the French gvernment annunced a strategic review t define France s industrial plicy pririties r Nuvelle France Industrielle framed int 34 industrial renewal (r recnquête industrielle ) initiatives. Their aim is t fcus ecnmic and industrial stakehlders arund cmmn gals, t align gvernment means mre effectively t these gals, and t harness lcal ecsystems t build a new, cmpetitive French industrial ffering that is able t win market share in France and internatinally, thereby creating jbs. Amng the 34 pririties, driverless vehicles r Véhicule à piltage autnme has attracted a lt f media attentin. The aim f this initiative is t make the French autmtive sectr a pineer in vehicle autmatin, ntably by remving regulatry barriers t grwth. The actin plan fr this actin was made public in July 2014. One f the five actins fr the driverless vehicles is t change the regulatry and nrmative framewrk fr experimentatin and the placing n the market f autnmus vehicle, especially the Changes in the regulatry and nrmative framewrk fr experimentatin and the placing n the market and Establishment f an insurance scheme. In December 2014, a text shuld lay dwn the Statutry instrument authrizing experimentatin n pen rad. 4 Semi-autmated heavy vehicle platns n UK mtrways, A. Stevens*, M McCarthy*, P. Gilhead VRA is an ERTICO Partnership activity 20

In 2015, the actin shuld prpse standards and regulatins fr experimentatin and in the lnger term (2017/18), they aim t establish a French Label fr Safe Autnmus Vehicle" r Véhicule Autnme Sûr. Fr 2018, the same actin plans the establishment f an insurance scheme in the frm f an Autnmus vehicle special insurance fund. Finally, in 2019, a series f standards n the prcess and test rules fr autmated vehicles. In parallel, in July 2014, the bill n the Energy Transitin prpsed by Séglène Ryal prcures that the gvernment is authrized t take any actin by rdnnances (within the scpe f the law) t prmte, under secure cnditins, experimentatins n the public rads f innvative vehicles delegating driving tasks, whether it cnsists f cars, gds vehicles r peple carriers. 3.2.5 Sweden Transprtstyrlesen Beginning f September 2014, The Swedish Transprt Authrity (Transprtstyrelsen) unveiled its feasibility study n the need t mdify the Swedish traffic and vehicle regulatins in view f the increased autmatin in the transprtatin system. This pre-study was presented in cnjunctin with the Rad Safety Cnference in Tylösand 5. The study cncludes that there is currently n need fr majr changes as the partially autmated driving systems require that a driver is behind the wheel ready t take ver perating cntrl. This means that the respnsibility remains with the driver. Driving tests d nt need t change because f the new technlgy. The pre-study ntes that the Transprt Agency needs t be mre practive and be active in the develpment f autmated vehicles, and that the law shuld nt stand in the way f technlgical develpments that cntribute t better safety, envirnment and accessibility. The pre-study lists a number f areas that the Authrity intends t wrk with the future including: Participate in r fllw the relevant test activities (eg, Drive-Me prject and KTH s autmated public transprt (bus) prject) Cntinue t investigate pprtunities t experiment with fully self-driving vehicles n public rads in limited areas. Cntinue t mnitr and participate in the wrk n the EU-level legislatin in the field f autmated vehicles, cperative rad systems and intelligent transprt systems. Mnitr develpments at the internatinal level including USA. Increasing knwledge f the safety f cmplex and safety-critical systems may be requested. Investigate the impact f such systems n the cmmunity planning. 5 Transprtstyrelsen, Pressmeddelande. Transprtstyrelsen ser psitivt på självkörande frdn. 2014-09-01 Link VRA is an ERTICO Partnership activity 21

Deepen cperatin with the Ministry f Industry, ther gvernment agencies, industry and academia t cntribute t a natinal cnsensus. Transprt Agency's Directr General, Staffan Widlert has als pinted ut the imprtance f autmated vehicles prvide new pprtunities fr peple wh get their license revked because f illness. The full pre-study in Swedish is available nline n the agency s website. Lindhlmen Science Park Lindhlmen Science Park is leading a natinal prcess ut frm the Autamated Transprt System. The current main activity is t establish a s called Strategic Innvatin Prgram thrugh the Swedish Innvatin Agency Vinnva. Alng this activity Lindhlmen is invlved in ther initiatives, like the Drive Me prject, initiated by Vlv Cars. Drive Me partners are currently the Swedish Transprt Administratin, the Swedish Transprt Agency, the City f Gthenburg and Lindhlmen Science Park. Frm a test & demnstratin perspective it is als valid t mentin the infrastructures nw in place in Sweden; SIM-4 (a full scale driving simulatr run by the Swedish institute VTI) and ASTA (a recently inaugurated prving grund fr active safety and autnmus drive, run by ASTAZer, a cmpany wned by Chalmers and SP). Legal and regulatry issues are clearly a very imprtant dimensin cncerning autmatin f the transprt system. Lindhlmen Science Park, as a partner in the Drive Me prject, and as the hst f the natinal strategic Innvatin Prgram, will engage the Swedish Transprt Agency and ther relevant rganisatins, in rder t secure the necessary develpment needed. 3.2.6 Finland The Ministry f Transprt and Cmmunicatins has been preparing an amendment t the Rad Traffic Act that wuld allw fr driverless rbtic cars t drive within a restricted area n public rads. The amendment in questin wuld cnstitute experimental legislatin that wuld be in frce fr five years starting at the beginning f 2015. Rbtic cars culd be tested, subject t a permit, in areas defined by the Finnish Transprt Safety Agency. The testing f rbtic cars in public rad traffic wuld be pssible within limited time perids and in predetermined areas. In the preparatry wrk fr the amendment, the Ministry, tgether with the Finnish Transprt Safety Agency, has clsely examined all related legislatin and regulatins in Finland. The Ministry has cme t a cnclusin that current Finnish legislatin (including adherence t internatinal cnventins) allws fr the use and testing f self-driving vehicles n public rads given that each vehicle has a specified driver and that the driver is, at all times, capable f cntrlling his vehicle. The Ministry has fund that there is n legislative r regulative requirement fr the driver t be inside the vehicle, which allws, in principle, fr slutins that use remte cntrl (similar t remtely pilted aircraft). The utcme f the amendment preparatin is therefre a finding that current legislatin and regulatins in Finland allw fr the testing f very high-level autmated driving and that n additinal regulatins r amendments are currently needed. The Ministry f Transprt and Cmmunicatins will wrk tgether with ther authrities, cities and cmmercial actrs t enable and supprt testing f autmated vehicles in different test envirnments arund VRA is an ERTICO Partnership activity 22

Finland (e.g. Tampere, Ival). As part f this wrk, the Ministry will cmmissin a radmap fr autmated driving that will be develped in 2015. Frm a regulatry standpint, the Ministry currently sees that the biggest challenges will likely be encuntered n liability issues, namely mving away frm driver liability and twards prduct (i.e. vehicle) liability. At the internatinal level, Finland is actively wrking twards changing the UNECE Cnventins n Rad Traffic s that, in the future, they wuld allw fr all kind f testing related t self-driving vehicles and vehicle fleets. 3.2.7 Greece The Greek Ministry f Infrastructure, Transprt and Netwrks in cperatin with stakehlders in the cuntry (e.g. ICCS, etricala) has begun discussin regarding the pssibility f allwing driverless vehicles within the Greek transprt netwrk frm 2013. The ccasin fr starting this discussin was the pssible CITYMOBIL2 pilt in the Greek city f Trikala, invlving autmated public transprt systems, including driverless vehicles. The discussin led t a cnsultatin which has taken place in between the different ministry divisins and the invlved parties (ICCS, e-trikala). The ministry has encuraged discussin between all relevant actrs in different Eurpean cuntries and fr this cnveyed a meeting n May 2014 in Athens with representatives frm ther ministries t discuss different appraches. As an utcme a legislative act has been prepared and will be prpsed t the Greek Parliament allwing pilt trials f autmated vehicles in public rads, under specific cnditins (which invlve mainly a thrugh analysis f the prpsed rutes, a supervisin by apprpriate research r academic bdies and an active supprt by lcal authrities). The specific act is currently being analysed frm prevalent Gvernmental Offices fr clarifying the last details and will be sn debated in the relevant Parliamentary Cmmittee. It will be put t a vte hpefully later this year. 3.2.8 Other EU member states Other EU Member States are welcme t reprt n their current activities related t regulatry aspects. Any additin will be reprted in draft 2 f this dcument planned t be published in Oct 2015. 3.2.9 United States Frm wiki http://en.wikipedia.rg/wiki/autnmus_car - updated by VRA WP3.2 In the United States, state vehicle cdes generally d nt envisage but d nt necessarily prhibit highly autmated vehicles 6. T clarify the legal status f and therwise regulate such vehicles, several states have enacted r are cnsidering specific laws 7. As f the end f 2013, fur U.S. states, (Nevada, Flrida, Califrnia, and Michigan), alng with the District f Clumbia, have successfully enacted laws addressing autnmus vehicles. 6 Bryant Walker Smith (1 Nvember 2012). "Autmated Vehicles Are Prbably Legal in The United States". The Center fr Internet and Sciety (CIS) at Stanfrd Law Schl. 7 Bryant Walker Smith. "Autmated Driving: Legislative and Regulatry Actin". The Center fr Internet and Sciety (CIS) at Stanfrd Law Schl. VRA is an ERTICO Partnership activity 23

Mre recently, Califrnian DMV delivered their autnmus vehicles testing regulatins which became effective n September 16, 2014. 3.2.10 Japan Japan s Crss-Ministerial Strategic Innvatin Prmtin Prgram (SIP) includes a new research and develpment plan fr an Autmated Driving System as ne f ten pririty plicy issues. The plan was initiated in May 2014 and includes 2.45 billin yen fr fiscal year 2014. Targets include Level 2 systems in 2017, level 3 in the early 2020s, and Level 4 smetime thereafter. There are three wrking grups which include bth public and private members: system implementatin, internatinal cperatin, and next generatin urban transprtatin. The visin fr the next generatin transprtatin system is t integrate multimdal transprtatin int rural and urban envirnments, t serve Japan s aging ppulatin and thse with disabilities. Once develped, the entire system culd be exprted t develping cuntries r ther parts f the wrld. Figure 6: Japan Crss-Ministerial Strategic Innvatin Prmtin Prgram (SIP) Autmated Driving System Research themes While the SIP des nt specifically mentin regulatry aspects as a main actin pint, it is embedded in many f the activities. 3.2.11 Other parts f the wrld In 2014, the Land Transprt Authrity 8 f Singapre will start testing driverless cars. 8 http://www.lta.gv.sg/cntent/ltaweb/en.html VRA is an ERTICO Partnership activity 24

3.3 Internatinal bdies 3.3.1 UNECE In 2011, the UNECE Inland Transprt Cmmittee (ITC) published its Rad Map fr Prmting ITS 20 glbal actins 2012 2020 9. The parties invlved in the elabratin f the Rad Map dcument are the Wrld Frum fr Harmnizatin f Vehicle Regulatins (WP.29), the Wrking Party n the Transprt f Dangerus Gds (WP.15), Wrking Party n Inland Water Transprt (SC.3), Wrking Party n Intermdal Transprt and Lgistics (WP.24), Wrking Party n Rail Transprt (SC.2), the Wrking Party n Rad Traffic Safety (WP.1), the Wrking Party n Rad Transprt (SC.1) and the Wrking Party n Transprt Trends and Ecnmics (WP.5). Wrking Party n Rad Traffic Safety (WP.1) is the nly permanent intergvernmental bdy in the UN dealing with rad safety pen t all cuntries thrughut the wrld. It is respnsible fr administering the internatinal rad safety-related cnventins including the 1968 Cnventins n Rad Traffic and Rad Signs and Signals. It wrks in cnjunctin with WP.29 and ther wrking parties t ffer a platfrm that enables cperatin and the exchange f rad safety infrmatin and best practices amng gvernments. The Wrld Frum fr Harmnizatin f Vehicle Regulatins (WP.29) is a UN bdy that develps and adpts harmnized vehicle regulatins that can be applied wrldwide. The research-based regulatins prmte the design and cnstructin f safer and mre envirnmentally-friendly vehicles. T date, ver 140 regulatins have been develped (annexed t the 1958 and 1998 "Vehicle Regulatins" Agreements). The WP.29 als sets standards fr peridical technical inspectins. The key UNECE internatinal legislatin relating t rad safety are Cnventin n Rad Traffic, Vienna 1968 and the Cnventin n Rad Signs and Signals, Vienna 1968 signed by 73 parties. In Additin, the previus versins f the same cnventins frm Geneva 1949 are als relevant as they were signed by 96 parties including USA, Japan, Australia, etc which are missing fr the 1968 cnventin. In April 2014, the WP.1 adpted prpsal amendments f Article 8 f 1968 Cnventin n Rad Traffic 10. A new paragraph (i.e., paragraph 5bis) is t be inserted int Article 8. The paragraph 5bis shall read as fllws: 5bis. Vehicle systems which influence the way vehicles are driven shall be deemed t be in cnfrmity with paragraph 5 f this Article and with paragraph 1 f Article 13, when they are in cnfrmity with the cnditins f cnstructin, fitting and utilizatin accrding t internatinal legal instruments cncerning wheeled vehicles, equipment and parts which can be fitted and/r be used n wheeled vehicles* Vehicle systems which influence the way vehicles are driven and are nt in cnfrmity with the afrementined cnditins f cnstructin, fitting and utilizatin, shall be 9 Rad Map fr prmting ITS 20 glbal actins 2012 2020 http://www.unece.rg/fileadmin/dam/trans/publicatins/its_fr_sustainable_mbility_rad_map.pdf 10 Reprt f the sixty-eighth sessin f the Wrking Party n Rad Traffic Safety http://www.unece.rg/fileadmin/dam/trans/dc/2014/wp1/ece-trans-wp1-145e.pdf VRA is an ERTICO Partnership activity 25

deemed t be in cnfrmity with paragraph 5 f this Article and with paragraph 1 f Article 13, when such systems can be verridden r switched ff by the driver. The amendment may have slved sme f the current cncerns related t the Vienna cnventin, but sme further issues still need t be clarified such as the peratin f fully autmated vehicles in applicatins such as cybercars r valet parking. In the framewrk f Actin 20 f the Rad Map, the ITC is rganising a jint wrkshp n 17-18 Nv 2014 with the Federal Public Service Mbility and Transprt f Belgium titled Twards the future driving and transprtatin culture: technlgy innvatins fr safe, efficient and sustainable mbility. One f the bjectives f this meeting is t explre hw UNECE can reach a harmnized apprach fr the develpment and evaluatin f cperative systems and autnmus driving. A panel will help t articulate expectatins twards the regulatrs, natinal and internatinal bdies. SAE 3.3.2 Standardisatin SAE has taken the initiative t prpse a standard fr the levels f autmatin based n the previus wrk f BASt and NHTSA. Figure 7: J3016 SAE Taxnmy and Definitins fr Terms Related t On-Rad Mtr Vehicle Autmated Driving Systems 11 11 J3016 SAE Taxnmy and Definitins fr Terms Related t On-Rad Mtr Vehicle Autmated Driving Systems: http://standards.sae.rg/j3016_201401 VRA is an ERTICO Partnership activity 26