|European policy makers plan to have a type approval framework in place for automation level 4 and level 5 vehicles in a year. The first attempt at legislation has been shared in the Motor Vehicles Working Group chaired by the European Commission.
In this group, experts from industry on the topic are invited. The first draft presented is based on elements from German law. It defines an automated driving system (ADS) comprising a set of hardware and software components. The operational design domain in which the dynamic driving task (DDT) is carried out makes up the ADS. The DDT should be able to manage all normal driving situations by appropriately selecting a trajectory and speed.
There is still much missing from a definition point of view, leaving the implementer with many options. Examples of requirements under normal driving are “driving in a predictable manner,” “cautious with right of way at intersections,” and “leave sufficient time and space for others in lateral maneuvers.” The terms sufficient, predictable, and cautious create subjective loopholes, and they can be interpreted in numerous ways. Such language needs to be clarified.
Further, there is, for example, a requirement on a time to collision (TTC) of 4 s when performing a left turn in an intersection. A TTC of 4 s in low-speed scenarios in an urban environment might cause the vehicle to be standing still for a very long time before being able to turn left. The current proposal leaves too much open for interpretation, which can cause very different behaviors in real-traffic scenarios such as very conservative driving, which annoys other traffic participants.
It is indeed challenging to draft legislation for autonomous vehicles for large-scale deployment in the public domain, and the time plan from policy makers in Europe is ambitious.