Regulatory Issues and Potential Regulatory Strategies
for Highly Automated Vehicles (AVs)
AVS15 ‐ Automated
Vehicles Symposium
Christopher Nowakowski, Steven E. Shladover, and Ching‐Yao Chan
California PATH Program, Institute of Transportation Studies, University of California, Berkeley
July 21‐23, 2015
Ann Arbor, MI
Project Background
California Vehicle Code (VC) 38750
• CA SB 1298 passed in September 2012 created VC §38750
Defined “autonomous” as the capability to drive without active physical control or monitoring by a human operator
Equates to SAE Level 3+ Automated Driving Systems (ADS)
Designated the CA DMV to adopt additional regulations
• ADS testing regulations adopted effective Sept. 16, 2014
CA Code of Regulations: Title 13, Div. 1, Ch. 1, Article 3.7
8 manufacturers, as of 6/30/2015, hold CA ADS testing permits
‐ https://www.dmv.ca.gov/portal/dmv/detail/vr/autonomous/testing
• ADS deployment and operations regulations
Currently under development
Legislative mandates include data collection (privacy) disclosures
Legislative notification followed by a 180‐day waiting period before the approval of an ADS that allows “driverless” operation
Fundamental Regulatory Challenges
• Automation blurs traditional regulatory boundaries
NHTSA is responsible for vehicle safety (e.g. FMVSS, NCAP)
States are responsible for operational safety (driver licensing)
• Need to balance public safety while encouraging innovation
• Lack of technical standards for safety or testing procedures
• Multiple ADS Operational Design Domains (ODD)
ODD dimensions include road type, traffic condition, weather, speed, time of day, and certified geographic location
• Cultural and conceptual differences between regulatory agencies, the automotive industry, and the IT industry
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Certification models: self‐certification vs. 3 party certification
How to Ensure Safety Prior to Deployment?
• Behavioral competency testing
Minimal ability to respond to external hazards, operate in typical traffic conditions, and obey traffic laws with reasonable etiquette
Road & track tests cannot cover all situations an AV must handle
How to scale from several tests to all possible conditions?
• Functional safety
Ability to accommodate internal hazards & failures
Cannot be evaluated through testing alone and must be embedded in the design and development process
ISO 26262 provides general methodology, but assumes driver available as backup
Methodology
Behavioral Competency Requirements
Behavioral Competency
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OPT
Area of Operation
Required competency for SAE L3+ system
Required behaviors differs for SAE L4+ driverless
Safety case uncertain for requirement
Competency may be optionally included in SAE L3/4
Low‐
Rural
City
Valet
Freeway
Speed
Highway Streets Parking
Shuttles
Detect Operating Envelope Based on ODD
Engagement / Disengagement Criteria
Detect System Faults & Failures
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Transition to Minimal Risk State
Detect & Respond to Speed Limit Changes
and Speed Advisories
Perform High Speed Merge (e.g., Freeway)
L4+
L4+
L4+
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Perform Lane Change / Lower Speed Merge
Move Out of the Travel Lane and Park (e.g., on to the Shoulder for Minimal Risk)
Detect & Respond to Encroaching Oncoming Vehicles
Detect Passing and No Passing Zones
& Perform Passing Maneuvers
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Minimum Competency Examples and Discussion
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Perform Car Following (Including Stop & Go)
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Detect & Respond to Stopped Vehicles
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Detect & Respond to Lane Changes
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Detect & Respond to Static Obstacles in the Roadway
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Detect Bikes, Peds, Animals, etc.
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Respond to Bikes, Peds, Animals, etc.
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Detect Traffic Signals & Stop/Yield Signs
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OPT
Respond to Traffic Signals & Stop/Yield Signs
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OPT
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OPT
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Navigate Intersections & Perform Turns
Navigate a Parking Lot & Locate Spaces
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Detect & Respond to Access Restrictions
(One‐Way, No Turn, Ramps, etc.)
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Detect Work Zones and/or Safety Officials
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Navigate Work Zones and/or Safety Officials
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Detect Emergency Vehicles
Respond to Emergency Vehicles
1. Define the areas of operation that have unique sets of
behavioral competency requirements
Freeway driving – Valet parking (No driver in the vehicle)
Rural driving
– Low‐speed shuttle (Restricted environment)
City street driving
2. Define high-level minimum behavioral competencies
Behavioral competency table constructed based on minimum requirements for a SAE Level 3 system (licensed driver required)
If ~5 s of time would be available, the minimum required competency is to simply alert the driver and transfer control
Driverless operation (SAE Level 4+) will require additional behaviors to achieve minimum competency
3. Define test conditions & pass/fail for each competency
Could be defined by DMV, NHTSA, SAE, ISO, manufacturer, or 3rd Party
Example: NHTSA NCAP FCW Confirmation Test (34 Pages)
4. Conduct tests
Could be by DMV, NHTSA, manufacturer, or 3rd Party
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• Speed limits must be detected and automatically followed, but if a licensed driver is present, can the driver override the speed limit?
• Are freeway/highway lane changes required for safety at SAE L3?
• Is moving out of a freeway/highway lane required? (Eliminates SAE L3.)
• Oncoming vehicles, bicycles, and pedestrians on a freeway are very rare, very dangerous, and very difficult to detect and avoid. What’s the avoidance requirement, if any? How can it be tested (safely)?
• On a rural highway, passing slow moving cars or bicycles is not required
since the system could safely follow the slow vehicle.
• Emergency vehicle response could be to transfer control to the driver.
Detailed Example: Navigate Work Zones
ADS Level
ADS Required Response
Fallback
Level 3
Minimum: • Alert Driver (~5 s)
Driver (by definition)
Level 4+
Licensed Driver Required in the Driver’s Seat
Minimum: • Alert Driver (~5 s)
ADS Safe Stop
Level 4+
Driver Not Required
Optional:
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Minimum: •
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Navigate Temporary Lanes
Respond to Temporary TCDs
Lane Changes When Needed
Respond to Safety Officials
Navigate Temporary Lanes
Respond to Temporary TCDs
Lane Changes When Needed
Respond to Safety Officials
ADS Safe Stop &
Alert Remote Operator