Welcome to the latest installment of “International Update” – a monthly feature of the Washington Insider from John Creamer, MEMA’s advisor on international regulatory affairs. This update highlights outcomes from the UN Working Party on Pollution and Energy (GRPE) January session and previews the upcoming sessions of the Working Party on Automated/Autonomous and Connected Vehicles (GRVA). The two groups have new regulatory requirements on their way towards adoption by the UN World Forum for the Harmonization of Vehicle Regulations (WP.29), including new light-vehicle emissions standards and the first regulatory requirements for Automated Driving Systems (ADS).
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Working Party on Pollution and Energy (GRPE)
New UN Vehicle Emissions Regulation
The UN GRPE gave its approval to proposals for new type-approval requirements for light vehicle emissions. Following agreement on amendments, the proposal for a new UN Regulation concerning “the approval of light duty passenger and commercial vehicles with regards to criteria emissions, emissions of carbon dioxide and fuel consumption and/or the measurement of electric energy consumption and electric range” was approved for submission to WP.29. The World Forum is expected to adopt the new regulation during its June 22-26 session.
This initial version of the regulation allows for two levels of national standards, dubbed 1A and 1B, mainly to allow the European Union and Japan, respectively, time to adapt their systems towards a greater degree of harmonization (known as level 2). The regulation envisions a transition period for the EU (Level 1A) region, phasing in mandatory compliance starting from September 2022 based on power-to-mass classifications. Higher power-to-mass commercial vehicles have an extra year (September 2023) before compliance with the new regulation will be required for new type approvals.
GRPE approved proposals for this next level of harmonization as well. Following adoption of the new regulation, an “01 series of amendments” (based on an original proposal with amendments agreed during the January meeting) will already be in place for implementation once the UN sets the date for its entry into force.
The expert group behind this work provided GRPE with a report on its current and future plans for vehicle emissions regulations.
Given the complexity of the regulation, the International Organization of Vehicle Manufacturers (OICA) agreed to provide GRPE with an “explanatory note” to help with interpretation and implementation of its provisions. (We will provide the note when it is available.)
Upstream Emissions of Electric Vehicles
An expert group under GRPE on “Electric Vehicles and the Environment” (EVE) has been working on energy and emissions-related issues, including EV power determination and battery durability, since 2012. One of the stickier issues to come up involves the overall emissions impact of electric vehicles. Although emissions from electric vehicles themselves are minor, environmentalists have often raised questions regarding the sources of their electricity.
Given that WP.29 focuses on the regulation of motor vehicles, this issue of “upstream emissions” led the EVE group into discussions with the UN Group of Experts on Energy Efficiency (GEEE). During the January GRPE session, the EVE group announced that GEEE has included “energy consumption and emissions of electric vehicles” in its 2020-2021 work plan. EVE and GEEE have agreed to form a joint task force “to develop the procedures for energy consumption and emissions that could be applied by EV manufacturers, either voluntarily or legally binding”. The task force would define a “method for monitoring and information of energy consumption and emissions” from electric vehicle use.
Electric Vehicle Battery Durability
In a status report, the EVE expert group also signaled its intention to pursue battery durability requirements for electric vehicles. The group anticipates developing sets of requirements during a two-phased program covering:
- State of Health monitors (SOH)
- Minimum performance requirements (PR)
- In service conformity checks (ISC)
- Vehicle normal-usage indices (NUI)
EVE expects to present a proposal for a new Global Technical Regulation (GTR) along these lines for WP.29 consideration by November 2021.
Real Driving Emissions Proposal
During the first GRPE review of a proposed new GTR on testing real-driving emissions (RDE), Canada and the Netherlands raised concerns over variations in tailpipe dimensions and the cost impact in fitting vehicles with Portable Emissions Measurement Systems (PEMS) for RDE testing. The vehicle manufacturers (though OICA) opposed the notion of requiring uniform tailpipes but agreed to provide information to support the design of tailpipe adapters for PEMS.
Working Party on Automated/Autonomous and Connected Vehicles (GRVA)
Automated Lane-Keeping Systems
The UN GRVA will meet during 9-14 February and again, in a special session, during 3-4 March. The main purpose of the back-to-back sessions is to finalize the text of a new UN Regulation for the type approval of on-highway automated lane-keeping systems (ALKS) operating at speeds below 60 kph.
This regulatory proposal marks the first effort to set standards, including physical tests and other assessments methods, for an Automated Driving System (ADS) as defined under SAE Recommended Practice J3016 (i.e., Level 3-5 automation). Given the introduction of “traffic jam pilot” systems, WP.29 has made the ALKS regulation a priority. Japan and Korea have already initiated national rulemaking in anticipation of the adoption this year of this new international regulation.
GRVA will also consider the final proposal for a new UN Regulation regarding type approvals for vehicle cybersecurity. The cybersecurity proposal represents a significant departure from traditional type approval requirements because it seeks to address an intangible moving target, not a relatively stable on-vehicle system. The safety risk is not a static concern but rather one that must be continuously addressed through management practices and processes. As such, the new regulation, along with a companion proposal on software update processes, proposes the certification of manufacturer management systems (including supplier management). Given this leap into relatively uncharted waters, the task force behind the proposals has worked with safety authorities, testing services, and manufacturers to prepare “interpretation documents” for implementing the cybersecurity and software update regulations.
Automated Vehicles and Driving Systems
The February GRVA session will also receive updates on work to establish performance requirements and assessment methods for vehicles equipped with ADS. The expert groups on “Functional Requirements for Automated Vehicles” (FRAV) and “Validation Methods for Automated Driving” (VMAD) met in Tokyo during 14-17 January. The two groups are in relatively early stages.
The FRAV group has consolidated an initial list of “safety elements” and candidate performance yardsticks from across some 100 stakeholders (government agencies, industry, and other interested parties).
The VMAD group has developed the outlines of a “new assessment/test method” (NATM) involving a comprehensive process for third-party verification and validation of OEM documentation (“audit”) and specific third-party physical performance tests (including conventional track testing and a new method for testing on public roads). The NATM would be based upon validating performance against a database of “foreseeable” traffic conditions and “preventable” crash scenarios.
Another area of GRVA activity involves the establishment of global requirements for Event Data Recorders (EDR) and Data Storage Systems for Automated Driving (DSSAD). The EDR discussions have been based upon the US 49 CFR Part 563 standard but there has been significant pressure to move beyond those requirements. The DSSAD discussions focus on allocation of responsibility concerns (e.g., human and system interactions and involvement in crash causation). Much of the recent work has focused on delivering DSSAD requirements for the ALKS regulation noted above.