“Innovation and Regulation: Time for a Reality Check!”
Session chairman Geoff Draper started off by identifying the major difficulties associated with innovation and regulation:
- Barriers at the level of the UN Regulations, because the appropriate technical requirements have not been established.
- Although the technical requirements in the UN regulations are applied by most countries, with the notable exception of the USA, there are barriers to innovation because of delays in their implementation into national regulations.
This session provided an overview of the activities underway in GTB and SAE to address these fundamental issues.
ADB Regulation in the USA
• Michael Larsen, GM (Sponsor of SAE J3069)
Larsen explained that the FMVSS 108 ADB final rule was scheduled to be published by the end of October 2020 but there is further indefinite delay. Once it is published, the SAE Lighting Systems Group will hold a meeting to review the regulatory text as a group.
He reviewed the major requirements in NHTSA’s proposed rule, highlighting where we have some information on how FMVSS108 will be amended.
The NHTSA Adaptive Driving Beam NPRM requirements are extensive and substantial and it is expected that the requirements for the final rule will be relaxed. However, it is still expected that the final US ADB regulatory requirements will be stringent, requiring updates to ECE ADB calibrations
It is expected that there will be a requirement for a horizontal Vehicle Headlamp Aiming Device (VHAD) if a horizontal adjuster is installed, potentially driving design changes to ECE compliant ADB systems.
• Wolfgang Huhn, GTB WG-S Chair
GTB Working Group Strategy was founded in April 2017 to advise the GTB General Assembly and Technical Steering Committee on GTB process improvements, new topics for study and their priority and to define the pre-conditions for the scientific basis of proposals for new regulations.
It is a special group in GTB because it operates with a Chair and two Vice-Chairs and currently has 26 company members represented by CTO’s, VP’s, and General Managers. All the member companies agree to pay a fee to sponsor independent university studies. There is a good participation (~80%) at each meeting.
Wolfgang reviewed nine research projects that are being funded by GTB, some already completed and presented to GRE. He also presented a list of future items to study as part of the GTB roadmap 2020-2030.
GTB Safety and Visual Performance WG
• Rainer Neumann, GTB SVP Chair
GTB WG SVP (Safety and Visual Performance) is taking the tasks from WG Strategy to execute research studies with neutral, objective institutes and universities on important topics. The target is to use the findings to convince the legislation authorities in GRE to accept the release of new lighting systems and functions with an approval.
Results so far are available from research sponsored at TU-Darmstadt (Germany), Embedded Lighting Systems (ELS) (France), Karlsruhe Institute of Technology (Germany) and Literature Studies by Fudan University (China) and Lighting Research Centre, Rensselaer Polytechnic Institute (USA)
SVP work items include Driver Assistance Projections, Signal road projections, AV Communication to other Road Users, Potential Disability Glare of Super Small Lamps, Potential Photobiological risk with blue lights, and Headlamp Safety Performance Rating (HSPR)
Removing Barriers to Innovation
• Geoff Draper, GTB President
Geoff summarised the current status of global harmonisation:
Technical requirements of UN Regulations are adopted by the majority of the 63 countries signatory to the UN 1958 agreement.
The Chinese GB standards are being updated to follow the UN technical requirements but synchronisation remains a problem.
The Korean KMVSS 108 standards are routinely updated to follow the UN technical requirements even though Korea operates a self-certification system.
The Indian Automotive Industry Standards (AIS) are regularly updated to align with the latest technical provisions of the UN Regulations.
The US Federal standard FMVSS108 is partially harmonised with the UN Regulations but there are major issues because the subjective requirements in the UN regulations are not considered acceptable by NHTSA for its self-certification system. Consequently AFS and ADB are not currently possible in the US, and different approaches to the definition of the apparent surfaces have to be resolved.
Currently there is no political will to develop Global Technical Regulations (GTR’s) under the UN 1998 Agreement. To overcome this ongoing situation, Draper believes that a pragmatic approach to remove barriers to innovation should be considered, based upon the Korean regulatory system. This pragmatic approach would be based upon the following elements:
- Encourage governments (Primarily China, and USA) to actively contribute to the development of the technical requirements in a common forum (the UN Working Party on Lighting and light-signalling, GRE).
- Encourage the USA and China, to follow the example of Korea and India to routinely introduce the updated technical requirements into their national legislation.
- Ideally USA and China would agree to jointly chair the GRE informal group
There are some important questions to be addressed relating to how GTB may wish to start a discussion in GRE and whether the UN World Forum (WP29) would be prepared to support such an approach.