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Development of California Regulations for the Testing and Operation of Automated Vehicles on Public Roads. Steven E. Shladover, Sc.D. Ching-Yao Chan, Ph.D. Christopher Nowakowski Wei-Bin Zhang Roberto Horowitz, Ph.D. Tom West California PATH Program Institute of Transportation Studies
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Development of California Regulations for the Testing and Operation of Automated Vehicles on Public Roads Steven E. Shladover, Sc.D. Ching-Yao Chan, Ph.D. Christopher Nowakowski Wei-Bin Zhang Roberto Horowitz, Ph.D. Tom West California PATH Program Institute of Transportation Studies University of California, Berkeley
California Automated Vehicle (AV) Legislation • Senate Bill 1298 • Approved by the Governor on Sept. 25, 2012 • Adds Division 16.6, Section 38750 to Vehicle Code • Authorizes the establishment of safety requirements for testing and operation of automated vehicles by the DMV • Defines “Autonomous Technology” as having the capability to drive the vehicle without physical control or monitoring by human operator • Defines what is NOT included in “Autonomous Technology” as: BLIS, Automated Emergency Braking, Park Assist, ACC, Lane Keeping Assist, LDW, Traffic Jam Assist, or similar systems individually or in combination • Defines manufacturer as either the OEM or the person modifying the vehicle by retrofitting automation
SAE Definitions of Levels of Automation(J3016 Surface Vehicle Information Report) 0. Non-Automated 1. Assisted (Lane Assist or ACC) 2. Partial Automation • Driver always in-the-loop and responsible for monitoring • System may require immediate driver take-over - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 3. Conditional Automation • Automation under clearly-delimited conditions • System may require driver take-over with some lead time 4. High Automation • System capable of transitioning to minimal risk state if driver fails to take over • Driverless operation under limited conditions 5. Full Automation • System capable of functioning without a driver
Establishing Automated Vehicle Regulations • CA Vehicle Code Section 38750 provides regulation authority to the California DMV • DMV must adopt regulations by Jan 1, 2015 • For testing of automated vehicles by manufacturers on public roadways (although testing is currently still allowed until regulations are adopted) • For operation of automated vehicles by the public on public roadways • Additional regulations may be imposed for automated vehicles capable of operating without a driver in the vehicle • Vehicle Code Section 38750 states that Federal regulations shall supersede if a conflict arises
Mfg’s Testing Requirements in VC 38750 • AV test driver shall possess the proper class of license for the vehicle being driven • AV test driver shall be seated in the driver’s seat and capable of taking over immediate manual control • Only employees, contractors, or other persons designated by the manufacturer may operate an AV on public roads • Manufacturer shall complete an application/certification for a testing permit and provide evidence of insurance, surety bond, or proof of self-insurance for $5 M
Automated Vehicle Regulations in VC 38750 • Mechanism to engage/disengage easily accessible to the operator • Visual indication that automation is engaged • Alert the operator of failures while automation is engaged • Require the operator to take over • Or bring the vehicle safely to a stop • Operator shall be able to take control with throttle, brakes, steering, and/or other means • Meets FMVSS for vehicle’s model year • AV technology does not disable any FMVSS feature • AV includes a data recording system to capture at least 30 seconds of data before any collision
Potential Regulation Topics Stated in VC 38750 The regulations shall include, but not be limited to: • Any Testing, Equipment, and Performance Standards necessary to ensure the safe operation of automated vehicles on public roads • Aggregate number of AVs deployed • Application process for AV testing permit • Special rules for AV registration • New license requirements for AV operators • Rules for revocation, suspension, or denial of AV permits or licenses
Topics Under Current Research • How to assess system safety? • Testing and certification requirements for manufacturer testing on public roads • Testing and certification requirements for sale and operation by general public • System-level safety requirements • Additional requirements for driverless operation
How to assess system safety? • Certification documentation of design, development and testing process by manufacturer • Third-party safety concept certification • Testing • To satisfy standards (that don’t exist yet)? • Driving competency (like current driver licensing test)? • Specific hazard scenarios?
Manufacturer Testing on Public Roads • Application for approval (documentation) • Level of safety to demonstrate before public road tests? • Contents of documentation when vehicle is modified? • Level of prior closed-site testing? • Evidence that safety requirements have been met? • Review and approval criteria? • Self certification vs. third-party? • Testing, data recording and reporting • Minimum DVI requirements? • Test driver training? • Number of test drivers per vehicle? • Data recording and archiving? • External indicators of special vehicle status? • Restrictions on vehicle class or operations? • Criteria for discontinuation of testing approval?
Requirements for use by general public • Application for general public use/sale • How much prior on-road testing? • Other minimum requirements for approval? • Protection of privacy of vehicle movement data? • Review and approval criteria • What data should DMV retain about each AV? • Operational requirements • Minimum performance? • Minimum DVI to re-engage driver? • Any external markings? • Minimum maintenance requirements? • Licensing of maintenance/repair shops? • Restrictions on vehicle size or usage? • Minimum driver requirements • Training, licensing, special knowledge?
System-level safety requirements • Minimum reliability requirements? • Minimum safety level? • Cyber-security requirements? • Minimal-risk condition capability as a minimum requirement?
Additional Requirements for Driverless Operations • What minimum level of safety, and how to demonstrate it? • What level of closed-track testing before testing on public roads? • Restrictions on vehicle sizes or uses? • What level of public-road testing before sale to general public? • Any special hazard conditions to require in testing? • Any special external markings? • Any restrictions on passenger activities?
Schedule • DMV to release first draft set of regulations (administrative aspects of on-road testing) for public review and comment this fall, followed by public hearings before adoption in early 2014 • PATH to provide recommendations on second set of regulations (technical issues) by end of this year • DMV to release second draft set of regulations for public review in spring 2014, leading to adoption by end of 2014 to meet legislative deadline • Further DMV updates of regulations likely annually • Useful Links: • http://www.dmv.ca.gov/vr/autonomous/auto.htm • lregulations@dmv.ca.gov