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AD HOC Meeting ADDW Romain Ladret Piciorus European Commission DG GROW Internal Market, Industry, Entrepreneurship & SMEs 02-08-2022 1 GSR and Advanced Driver Distraction Warning systems (10) [...] advanced driver distraction warning [is a] safety system that have a high potential to reduce casualty numbers considerably. In addition, some of those safety systems form the basis of technologies which will also be used for the deployment of automated vehicles. Any such safety systems should function without the use of any kind of biometric information of drivers or passengers, including facial recognition. Therefore, harmonised rules and test procedures for the type-approval of vehicles as regards those systems and for the type‐approval of those systems as separate technical units should be established at Union level. The technological progress of those systems should be taken into account in every evaluation of the existing legislation, in order to be future‐proof, whilst strictly adhering to the principles of privacy and data protection, and to reduce or eliminate accidents and injuries in road transport. It is also necessary to ensure that those systems can be used safely throughout the life cycle of the vehicle. (14) Any processing of personal data, such as information about the driver processed in […] the driver’s distraction [warning system], should be carried out in accordance with Union data protection law, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council (6). […] In addition, the driver drowsiness and attention warning or advanced driver distraction warning should not continuously record nor retain any data other than what is necessary in relation to the purposes for which they were collected or otherwise processed within the closed-loop system. 2 GSR and Advanced Driver Distraction Warning systems Definition (6) ‘advanced driver distraction warning’ means a system that helps the driver to continue to pay attention to the traffic situation and that warns the driver when he or she is distracted; Article 6 (1.d; 3 ) Advanced vehicle systems for all motor vehicle categories (M1,N1,M2,N2,M3,N3) 1. Motor vehicles shall be equipped with the following advanced vehicle systems: (d) advanced driver distraction warning; 3. Driver drowsiness and attention warning and advanced driver distraction warning systems shall be designed in such a way that those systems do not continuously record nor retain any data other than what is necessary in relation to the purposes for which they were collected or otherwise processed within the closed-loop system. Furthermore, those data shall not be accessible or made available to third parties at any time and shall be immediately deleted after processing. Those systems shall also be designed to avoid overlap and shall not prompt the driver separately and concurrently or in a confusing manner where one action triggers both systems ANNEX 2 E3: “Distraction avoidance by technical means may also be taken into consideration” C: Date for refusal to grant EU type-approval: 7 July 2024 Date for the prohibition of the registration of vehicles, as well as the placing on the market and entry into service of 3 components and separate technical units: 7 July 2026  Today’s meeting objectives Tasks: • Confirm the results of the previous discussions • Identify other needed/missing information (if any) • Identify other converging/diverging expectation from stakeholders (if any) • Discuss timeline for the actions until December and until end of March • In red – input from 02/08 4  AGENDA 1. General expectation a) Situations to cover (driver’s action / driving environment / category of vehicles) b) Maturity of existing systems c) User acceptance 2. Data acquisition and management a) Technology available b) Biometric data 3. Distraction type and time a) Continuous / Intermittent distraction b) Visual attention / Visual distraction 4. Testing a) Audit – test procedure for witness test b) Test by technical services c) Real world/feasibility testing (prior to publication) → Confirmation of Stakeholders interest is needed 5. AOB a) STEP 1 / STEP 2 5 1 - General expectation a)/b)/c) Situations to cover / Systems’ maturity / acceptance Main distraction: visual distraction Secondary distraction: audio distraction (if equipped systems) – technical discussion for known source of audio distraction and define metrics Avoid restrictive requirements to allow creative solution  If it help, use “cognitive distraction” to allow systems based on the overall distraction assessment (but the definition must be clear)  Assessment/audit implementation must reflect this ACEA PRESENTATION (note: driver monitoring in the slides covers both distraction warnings and level 2 hands off systems) Authority: Reminded EURONCAP has a proposal on intermittent distraction and that acceptance is worse because of false positive (discussed further in “Testing”) 6 1 - General expectation a)/b)/c) Situations to cover / Systems’ maturity / acceptance Cabin setting – distracted zone must be based on the category of the vehicle (CLEPA example for M1 in ACEA presentation) Speed requirement Must be ON at [XX kph]: not proposed yet – industry: will be clear when how and what is tested Low speed (parking): known accidents, but acceptance risk. Adapted requirements or recommendation -> Issue with reversing (SME) Preventive systems – no acceptance is needed if avoiding warning + should complement with technology have distraction prevention (ex: mobile phone installation) EC: Systems not part of the vehicle are not in the scope, at best it can bee part of an OEM strategy, but not mandatory Consumer assoc + vehicle manufacturer: If a system is mandatory acceptance issues exists, with or without warnings 2nd stage convertors/adapters: Driver monitoring will have to take account of drivers with a disability. There is a clause in 2018/858 which gives partial or full exemption to SPV WAVs if a system cannot be fitted or used. An issue for second stage convertors/adapters.  Important to make it a legitimate approach if de-activation is needed for adaptation 7 2 - Data acquisition and management a)/b) Technology available / Biometric data Main concerns already formulated in the GSR (privacy, closed looped system) 8 3 - Distraction type and time a)/b) Continuous / Intermittent distraction / Visual attention / Visual distraction Continuous distraction : main to consider.  Lesson from EURONCAP discussions – allow for higher threshold for difficult cases (gaze slowly changing, …)  Beware of other vehicle category (how to adapt the threshold) Supplier: Currently focus on continuous distraction and define in more detailed the use cases to cover EURONCAP work on M1 – Continuous long distraction = 3 sec +1 sec (with compelling evidence for implementation – i.e. can be difficult to establish when the gaze is off-road) - (taking into account the acceptance) Intermittent distraction : possible but not mature  Lesson from EURONCAP discussions – 1 proposal but allows other strategy to be presented.  Time window – Cumulated time of visual distraction – reset condition EURONCAP work on M1 – Intermittent Authorities: Euro NCAP gave an example of requirements for type 2 distraction in 3.5.3.1.3 No common understanding of the value (ex: 30 sec window, with 10 sec cumulated (https://cdn.euroncap.com/media/70315/euro-ncap- distraction, if 2 sec long gaze reset the clock). Distinction if the gaze if driving task assessment-protocol-sa-safe-driving-v101.pdf) related or non driving related 9 4 - Testing a) Audit – test procedure for witness test Proposition: Declaration of the technical limitation, with ties to market surveillance implementation. These declarations must meet requirements on the performance of the system (with thresholds) to be tested in defined situation  Same approach for secondary distraction? Is it enough to validate that the system will perform for more than 95% of the population? Industry: aiming for a given % without a reference/template to use is not possible, and it is not possible to find a way to define people who cannot be accommodated – for instance: no country keep statistic of driver with disability EC: We need to identify which criteria are used allow the best performances for the wider audience on industry side – and consider it as starting point Industry: homework to find out how this aspect is done for the development of the system 10 4 b) - Testing Test by technical services Dedicated PASS/FAIL criteria 1- General case – visual distraction above certain speed ACEA presentation. CLEPA clarified that the red areas are focused on non-driving related tasks (i.e. the instrument cluster is not considered distracted in the proposal -> it may generate may false positive if added, because the information is represented close to the windscreen) Authority: the proposal is feasible – How to approach false positive? Need some flexibility in the timing to adapt the protocol-> ex: timing and to integrate the check on OEM technical limitation (ex: sunglasses) Industry: False positive are already important for OEM for the consumer’s comfort. False negative need to be tested, the “red areas” are mandatory – grey area optional Scenario of driver looking at dashboard for a long time. Authority: real safety issue when looking at screen for a long time EC: adding a additional zone is not impossible – with different threshold time. Industry/supplier: • it would need to be adapted from design to design (case by case). In the proposition the result would be identical as today’s situation for this scenario • the approach here is to cover the most critical aspect. • Additional elements will greatly complexify the process and influence the design choice ACEA – in this case it would be the same as today. CLEPA – have to keep in mind a simple test 2- Slow speed case (parking) – open discussion – not clear if mandatory in step 1 11 3- Audio distraction – need technical discussion – potential effect on threshold used for the general case 4 - Testing c) Real world/feasibility testing (prior to publication) Need the confirmation from interested stakeholders, if they agree that a feasibility test is meaningful. Such approach is costly and requires organisation, it is important to validate with enough parties. For August meeting please give your answer Industry (ACEA) is interested to have this test drive organised Supplier: who will organise it? EC it is important to see which members want to participate to answer this Industry/consumer assoc. (FIA): can we participate? EC: yes Opportunity to explore EURONCAP workshop with IDIADA 24-27th of October, in Spain. The scope is different (M1 vehicle, and possible ADDW other distractions to consider) 12 5 - AOB a) STEP 1 / STEP 2 The Step 1 / Step 2 approach is not stated in the GSR  The group / the Commission can make recommendation for the future steps considering the maturity and acceptance of the technology  Stakeholders support the Step 1 / Step 2 approach (nobody objected) 13 5 – Organisation – next step CirbacBC: all documents are uploaded on CIRCABC and soon will be referenced in a single folder https://circabc.europa.eu/ui/group/4273d650-b8a9-4093-ac03-18854fbba4b5/library/ba3f8b33-83d4- 4014-8ef2-51f38954d12b?p=1&n=10&sort=modified_DESC Next meeting: 7th of October (Friday) – 9h30-12h30 (Brussel time – GMT +2) EC is creating a new MVWG subgroup on Driver’s Behaviour Assessment Systems 14  5 – WebEX chat FIA: Question for clarification: 'if equipped systems' does this mean that requirements would be considered for the case 'if fitted' ? (EC: yes) European Mobility Group: Driver monitoring will have to take account of drivers with a disability. There is a clause in 2018/858 which gives partial or full exemption to SPV WAVs if a system cannot be fitted or used. An issue for second stage convertors/adapters. Authority (FR): Euro NCAP gave an example of requirements for type 2 distraction in 3.5.3.1.3 (https://cdn.euroncap.com/media/70315/euro-ncap-assessment-protocol-sa-safe-driving-v101.pdf) European Mobility Group: For low speed parking, would the systems work when reversing ? Industry/authority : • Is there a technical example for a system recognising audio distraction? meaning a system which can be looked at on the market? • We plan to share our positions with TRL, as already discussed, keeping consideration for audio impact (ex. communication on going) on driver reaction time. We will share collected data on this point. • please send it also to ACEA if possible. In general each distraction results in visual distraction in the end FIA/ACEA: Disagree with example 'Driver resistance to warning i.e.'. In our view consumer acceptance is key for system effectiveness in all cases, with or without warning 15  5 – WebEX chat CLEPA is of the opinion that requirements should be technology neutral. ACEA: with the current discussion about single technical solutions we´re already a step to far in the topic. First we need to set the general requirements and after that the technical solutions. Apart from that phone usage is only one use case. Let´s focus on the current task European Mobility Group: agrees with CLEPA & ACEA. This should be a performance requirement, ragther than a defined technical regulation. European Mobility Group: There is no way you can give a specific figure for the % of population which can be accommodated. FIA: Are Mobility Club experts also welcome for a test drive / demo ? Authority (FR): October 24-27th at IDIADA for the Euro NCAP WS [contact names removed from the public minutes] 16 Participants European Commission - DG GROW ACEA fka/TRL AVERE JAMA MS – Romania CLEPA MS – France European Mobility Group MS – Ireland International Road Transport Union MS – Italy European Cyclists’ Federation MS – Czech Republic FIA Region I SaverOne 17  Thank you • © European Union 2020 • Unless otherwise noted the reuse of this presentation is authorised under the CC BY 4.0 license. For any use or reproduction of elements that are not owned by the EU, permission may need to be sought directly from the respective right holders. • Slide xx: element concerned, source: e.g. Fotolia.com; Slide xx: element concerned, source: e.g. iStock.com 18 Saatja: Raili Lillemets <[email protected]> Saadetud: 03.08.2022 16:58 Adressaat: MKM info <[email protected]> Koopia: <[email protected]> Teema: ADDW ad hoc meeting - follow up Tere Edastan asjaomastele. Parimat Raili Lillemets Raili LillemetsPermanent Representation of Estonia to the EUSecretary&#43;32 2227 4357| Rue Guimard 11/13 1040 Brussels From: &lt;&gt; Sent: Wednesday, August 3, 2022 11:52 AMCc: LADRET PICIORUS Romain &lt;&gt;Subject: ADDW ad hoc meeting - follow up Dear MVWG participants, Thank you for your participation in the ad hoc Meeting on ADDW on 2nd of August 2022. We reviewed the conclusions and progressed on the testing methods. The minutes/notes are now available on CIRCABC : Please check the homework indicated the in testing part (slide 10 and 12). The next meeting will be a subgroup meeting Drivers Behaviour Assessment Systems (DBAS) on 7th of October (Friday) from 9:30-12:30 GMT&#43;2. Please ensure you have indicated your interest to join this group by sending an email to the mailbox, including the name of the association or ministry you will be representing. Invitations will be sent to interested parties via the AGM tool in September. Kind regards Romain Ladret Picioruș, PhDPolicy Officer Automated/Connected vehicles and Safety European Commission DG for Internal Market, Industry, Entrepreneurship and SMEs Unit I.2 Mobility Avenue d'Auderghem 45BREY 10/040 1049 Brussels/Belgium &#43;32 2 298 93 53