ECall Type-Approval - TRL Client Project Report CPR1868

8/21/2019 ECall Type-Approval - TRL Client Project Report CPR1868

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eCall


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European Commission eCall

DisclaimerThis report has been produced by the Transport Research Laboratory under a contractwith the European Commission. Any views expressed in this report are not necessarily

those of the European Commission.

The information contained herein is the property of TRL Limited and does notnecessarily reflect the views or policies of the customer for whom this report wasprepared. Whilst every effort has been made to ensure that the matter presented in

this report is relevant, accurate and up-to-date, TRL Limited cannot accept any liabilityfor any error or omission, or reliance on part or all of the content in another context.


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Executive summary

One of the safety initiatives attempting to reduce the burden from the 1,100,000

injurious accidents occurring on the roads of Europe, each year, is the implementation

of pan-European eCall. The core function of an eCall system is to notify the emergencyservices automatically and rapidly of a potentially injurious accident. The benefit of

eCall arises through the reduction in response times for emergency services attending

to the accident, thus helping to save lives and to treat injuries more rapidly.

The European Commission (EC) has adopted a proposal for a regulation concerning

type-approval requirements for the deployment of the eCall system. However, thedelegated/implementing acts to this regulation, detailing technical requirements andtest procedures for type-approval, do not exist as yet. This report documents,

structures and assesses the available information which may offer support in

developing the vehicle approval requirements and test procedures with respect to

eCall in-vehicle systems.

A comprehensive review was undertaken of all available relevant information which

could be used as a basis for delegated/implementing acts supporting the Commissionsproposal for a Regulation of the European Parliament and of the Council concerning

type-approval requirements for the deployment of the eCall in-vehicle system. This

review forms the basis of the study and included sources from

l f EU UN d R i l i l ti


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sources. In other areas, differing views on the necessity of regulatory requirementsand the approach to be taken make a decision necessary before progress can be made

in specifying requirements. Finally, several aspects which should be included in a

regulation remain underdeveloped, i.e. no test methods are currently available thatcould reasonably be considered for immediate use in a type-approval regulation.

These areas will require substantial work to define appropriate requirements and test

procedures and represent priorities for future development, if they are to be included.

Areas where substantial further work was identified as being necessary were: The practicalities associated with demonstrating post-crash operations of the

eCall IVS within the environment of full-scale crash test facilities.

A mechanism to test and discourage superfluous eCall triggering in very low

severity collisions.

The appropriate testing regime for assessing wireless link performance of the

vehicle regarding positional accuracy and mobile phone networkcommunication robustness.

The extent of self-test features of the IVS (and perhaps also periodic technicalinspections) to identify faults and hence reduce the need to regulate lifetime

performance at the type-approval stage.

Defining guidelines for the HMI design of eCall systems.

These areas should be considered as a priority.


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Table of Contents

Executive summary ........................................................................................... 3

1 Introduction ...................................................................................... 8

2

Supporting documents, standards and research ....................................10

2.1

Legislators, standardisation and research groups ........................10

2.2

Overview of relevant sources ....................................................12

3

Future requirements and test methods for eCall in-vehicle system (IVS) ..13

3.1

Scope of the regulation ............................................................14

3.1.1

Options ........................................................................14

3.1.2 Commentary .................................................................17

3.1.3 Recommendation ...........................................................18

3.2 Privacy and liability aspects ......................................................19

3.2.1 Expectations .................................................................19

3.2.2 Liability ........................................................................22

3.2.3 Privacy and data protection .............................................25

3.3

Conformance to relevant technical standards ..............................29

3.3.1

Reasons for requirements ...............................................29


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3.7

Climate resistance ...................................................................70

3.7.1 Reasons for requirements ...............................................70

3.7.2 Options ........................................................................70

3.7.3 Commentary .................................................................71

3.7.4 Recommendations .........................................................72

3.8 Autonomous power supply .......................................................73

3.8.1

Reasons for requirements ...............................................73

3.8.2

Options ........................................................................73

3.8.3

Commentary .................................................................74

3.8.4

Recommendations .........................................................75

3.9

Electromagnetic compatibility (EMC)..........................................77


3.9.2

Options ........................................................................77

3.9.3 Commentary .................................................................79

3.9.4 Recommendations .........................................................79

3.10 Resistance to electric impacts ...................................................80


3.10.2

Options ........................................................................80

3 10 3

C t 81


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3.14.2

Options ........................................................................97

3.14.3 Commentary and recommendations .................................98

3.15 Human-machine interface (HMI) ............................................. 100

3.15.1 Reasons for requirements ............................................. 100

3.15.2 Options ...................................................................... 101

3.15.3 Commentary ............................................................... 101

3.15.4

Recommendations ....................................................... 103

3.16

Test equipment ..................................................................... 104

3.16.1

Standards conformance testing ..................................... 104

3.16.2

Wireless link performance testing .................................. 105

3.16.3

Resistance testing ........................................................ 105

3.16.4 Electromagnetic compatibility (EMC) testing .................... 107

3.16.5

Audio equipment testing ............................................... 107

3.17 Definitions of terms ............................................................... 108

3.18 Co-existence of third party and mandatory eCall systems .......... 109

3.18.1 Reasons for requirements ............................................. 109

3.18.2 Expectations ............................................................... 109

3.18.3

Commentary ............................................................... 111

3 18 4

R d ti 112


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1 Introduction

During 2012, in the European Union, over 28,000 people were killed on roads 1. The

number of people injured was around 1,400,000; resulting from just under 1,100,000

accidents2. One of the initiatives attempting to reduce the burden from these accidentsis the implementation of eCall.

The concept of an automatic crash notification system or eCall is not new. In the caseof a crash, an eCall-equipped car will automatically call the nearest emergency centrevia the emergency number 112. Even if no passenger is able to speak, e.g. due to

their injuries, a 'Minimum Set of Data' is transmitted, including the exact location ofthe crash. Shortly after the accident, emergency services therefore know that therehas been an accident, and where exactly it occurred. The benefit of eCall arises

through the reduction in response times for emergency services attending to the

accident, thus helping to save lives and to treat injuries more rapidly. EC documents

suggest that eCall could speed up emergency response times by 40% in urban areasand 50% in the countryside, and save up to 2500 lives a year 3.

In addition to the road safety benefits, eCall may also help to reduce the congestioncaused by traffic accidents and the potential for secondary accidents to occur as a

result of unsecured accident sites.

Conventionally, eCall is activated automatically as soon as in-vehicle sensors detect a

i h O t ff th t di l th E b 112


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available information which may offer support in developing the vehicle approvalrequirements and test procedures with respect to i eCall in-vehicle systems.

Following this information gathering, it is expected that the available information willthen be compared with the requirements and expectations for eCall in-vehicle systems

before final proposals (draft regulatory texts) for system validation testing will be

made at a later stage.


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2 Supporting documents, standards and research

Many previous studies have reviewed the technology and investigated and discussed

the potential benefits associated with eCall systems. The target for this review of the

supporting documents, standards and research was to provide the EC with anobjective review of the existing documents supporting the implementation of eCall. It

is anticipated that the information collated forms the basis of, and enables, the

detailed technical requirements and tests for the type-approval of eCall IVS to bespecified. Therefore it included, wherever possible, the identification of proposals for

methods and assessment procedures which could be used to assess eCall systems in a

vehicle type-approval setting.

2.1 Legislators, standardisation and research groups

The United Nations Informal Working Group AECS

4

(Accident Emergency Call Systems)is in the process of drafting a new UN Regulation on the type-approval of accidentemergency call systems (in the following referred to as Draft UN Regulation No. XX on

AECD/AECS). The Informal Working Group (IWG) is under chairmanship of the RussianFederation and forms a sub-group of the Working Party on General Safety Provisions

(GRSG) within WP.29 (1958 Agreement). The 1stmeeting took place in October 2013

with the initial aim to complete the work by October 2014. At the 4thmeeting in April2014 it was decided to postpone the date for finalising an agreed draft to October

2015 Th di i b d i i i l d f id d b h R i


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technical aspects like operating requirements, data to be transmitted in case of anaccident and end-to-end conformance testing.

The Russian Federation is in the process of legislating on ERA-GLONASS which is theRussian equivalent to eCall. ERA-GLONASS will be required for M1, M2, M3, N1, N2

and N3 vehicles (with varying levels of functionality) from the beginning of January

2015 for new types of vehicles. The Russian legislative process was supported by a setof nine GOST standards, published in two batches in 2011 and 2013 respectively.

These cover numerous aspects of technical requirements and test methods and weredesigned with the aim in mind to ensure technological compatibility with the main

functional properties of EUs eCall, e.g. using a modem tone as the main mechanism

for transferring data, structure and format of the standardized mandatory data

transmitted as part of the MSD, and two-way voice connection with vehicle occupants.

The Japanese eCall equivalent, HELPNET, was established in 2000 and has since beenvoluntarily adopted by major vehicle manufacturers such as Toyota, Lexus and Honda.

The system is not legally mandated or regulated but based on voluntary agreementsand managed privately.

The HeERO project5 is a pre-deployment trial for pan-European eCall based on thecommon European emergency number 112. The project started with a first phase in

January 2011 and continued with a second phase, running partly in parallel, in

January 2013, extending to December 2014. The aim of the project is to prepare thedeployment of the necessary infrastructure for a harmonised in-vehicle emergency call

h bl d d b d d


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The ITS Advisory Group8is a group of experts on Intelligent Transport Systems (ITS)set up by the EC to advise on business and technical aspects of deployment and use of

ITS, including eCall. The group was formed in 2012 and consists of 25 members,

including service providers, manufacturing industry, transport operators.

2.2 Overview of relevant sources

The supporting documents identified and reviewed throughout this study are listed in

Table A-1 (see Appendix A,page 127). The table provides a concise overview of thedocuments considered relevant for type-approval legislation on eCall IVSs. The

relevant content of each document is listed with regard to potential type-approval

requirements and potential test procedures. Furthermore, comments on the status ofthe documents and their relevance are given. The table is intended to give a brief

summary of all documents referenced in the main body of the report and to inform the

reader on the wider context of documents if needed while reading the report.


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3 Future requirements and test methods for eCall in-

vehicle system (IVS)

Based on a technical assessment of the material available and discussions with

technical experts in the area of eCall and stakeholders from various groups, manydistinct aspects of eCall were identified that needed to be considered for type-approvalregulation:

1.

Scope

2. Privacy and liability aspects

3. Conformance to relevant technical standards

4. eCall triggering and test calls

5.

Resistance to mechanical impact during normal use

6.

Resistance to mechanical impact during accident (crash)

7.

Climate resistance (temperature, temperature change, foreign body ingress,water-tightness, condensed water)

8.

Autonomous power supply

9. Electromagnetic compatibility (EMC)


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3.1 Scope of the regulation

The scope defines which vehicle categories the type-approval regulation applies to and

whether separate eCall systems intended to be fitted in such vehicles are also

covered. The scope of a regulation is a fundamental requirement of itsimplementation. The requirements within the regulation are not necessarily uniform

for all vehicles in scope.

3.1.1 Options

Different options have been proposed as ways of defining the scope for a regulation

concerning type-approval requirements for the deployment of eCall IVS within the EU.

During the course of the legislative process, the European Commission (EC), the

European Parliament and the Council of the European Union (i.e. the member states)have adopted and published their positions. The Commissions initial proposal included

all M1 and N1 vehicles in scope; the Parliaments resolution added an exemption forsmall series vehicles; the Councils general approach included separate technical unitsand components within the scope, but added exemptions for individual approval

vehicles and vehicles which for technical reasons cannot be equipped with an

appropriate eCall triggering mechanism:

Commission proposal for a regulation of the European Parliament and of the

Council concerning type-approval requirements for the deployment of the eCall


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be excluded from the obligation to comply with the eCall requirements.Moreover, some M1 and N1 vehicles cannot be equipped with an

appropriate eCall triggering mechanism.

o Article 2: This Regulation shall apply to vehicles of categories M1 and

N1 as defined in points 1.1.1. and 1.2.1. of Annex II to Directive

2007/46/EC.

European Parliament legislative resolution of 26 February 2014 on the proposalfor a regulation of the European Parliament and of the Council concerning type-

approval requirements for the deployment of the eCall in-vehicle system and

amending Directive 2007/46/EC, P7_TA(2014)0154, dated 26/02/2014:

o Recital 7: The mandatory equipping of vehicles with the 112-based

eCall in-vehicle system should initially apply only to new types of

passenger cars and light commercial vehicles (categories M1 and N1) for

which an appropriate triggering mechanism already exists. The

possibility of extending the application of the 112-based eCall in-vehicle

system requirement in the near future to include other vehicle

categories, such as heavy goods vehicles (HGVs), buses and coaches,

powered two-wheelers (PTW) and agricultural tractors, should be further

assessed by the Commission with a view to presenting, if appropriate, a

legislative proposal.

o It should be noted that to date, few HGVs, buses, coaches, and powered


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General Approach of the Council with regard to the Proposal for a Regulation ofthe European Parliament and of the Council concerning type-approval

requirements for the deployment of the eCall in-vehicle system and amending

Directive 2007/46/EC, 9879/14 ENT 123 MI 428 CODEC 1299, dated19/05/2014:

o Recital 7: The mandatory equipping of vehicles with the eCall in-vehicle

system should initially apply only to new types of passenger cars and

light commercial vehicles (categories M1 and N1) for which anappropriate triggering mechanism already exists.

o Recital 11: Small series vehicles and vehicles approved pursuant to

Article 24 of Directive 2007/46/EC are excluded under Directive

2007/46/EC from the requirements on the protection of occupants in the

case of frontal impact and side impact. Therefore, those vehicles should

be excluded from the obligation to comply with the eCall requirements.

Moreover, some M1 and N1 vehicles cannot be equipped with anappropriate eCall triggering mechanism.

o Article 2: 1. This Regulation shall apply to vehicles of categories M1and N1 as defined in points 1.1.1. and 1.2.1. of Part A of Annex II to

Directive 2007/46/EC and to eCall in-vehicle systems, components and

separate technical units designed and constructed for such vehicles.

It shall not apply to the following vehicles:


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Part II: the installation on vehicles of categories M1 and N1 ofAECDs which have been approved to Part I of this regulation.

Part III: vehicles of categories M1 not exceeding 2,5 tons, and

N1 where the "R" point of the lowest seat is not more than 700

mm from ground level, with regard to AECS or equipped with an

AECD which has not been separately approved according to Part

I of this Regulation. Other vehicles may be approved at the

request of the vehicle manufacturer. Discussions at the 4thAECS meeting in April 2014 indicated that the scope is

still disputed: it might either be defined as a wide scope, i.e. all M1 and N1vehicles (possibly except small series); or M1 and N1 vehicles which are fitted

with accident detection systems; or M1 and N1 vehicles which undergo UN R94

and/or UN R95 full-scale crash testing. Separate technical units will also becovered in the Regulation.

The following vehicles would be covered, if the scope was linked to full-scalecrash testing:

o Define scope as M1/N1 undergoing both UN R94 and UN R95 crash

tests:Would capture only M1 vehicles 2,500 kg

o Define scope as M1 undergoing one or both of UN R94 and UN R95

crash tests: Would capture M1 vehicles 2,500 kg, and all M1 and N1

hi l ith R i t h i ht f l t t 700


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UN regulations would mean that it will no longer apply to all M1 and N1 vehicles. Thiswould severely limit the potential safety benefits of eCall.

3.1.3 Recommendation

Based on the General Approach of the Council, currently all large series M1 and N1vehicles (and eCall systems and components intended to be fitted in such vehicles)

should be included in the scope of the regulation as long as they can be equipped with

an appropriate triggering mechanism. The vehicles which cannot be equipped will needto be clearly identified in the future, which is already covered in the General Approach

by empowering the EC to carry out analyses and adopt delegated acts in this regard.

General Approach of the Council, 9879/14 ENT 123 MI 428 CODEC 1299, dated

19/05/2014, Article 2:

1. This Regulation shall apply to vehicles of categories M1 and N1 as defined

in points 1.1.1. and 1.2.1. of Part A of Annex II to Directive 2007/46/EC and to

eCall in-vehicle systems, components and separate technical units designed

and constructed for such vehicles.

It shall not apply to the following vehicles:

(a) vehicles produced in small series approved pursuant to Articles 22 and 23

of Directive 2007/46/EC;

(b) vehicles approved pursuant to Article 24 of Directive 2007/46/EC;


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3.2 Privacy and liability aspects

Basic expectations regarding privacy and liability aspects associated with eCall have

been described by several authors (including CEN, eSafety Driving Group eCall,

European Data Protection Supervisor and Article 29 Working Party). In additionspecific liability questions have been considered in previous research and data privacy

aspects have also recently been reconsidered by the European Data protection

Supervisor. These sources of information on privacy and liability aspects have beenreviewed and are summarised and, in some cases, reproduced below.

3.2.1 Expectations

Some core texts are provided to set the context for the privacy and liability aspects of

eCall.

EN 16072

o eCall shall be considered as a public service operating as part of thepublic emergency call service, where the first part of service provision is

a Public Safety Answering Point (which may be a public or private

organisation under public delegation as determined within nationstates).

o All stakeholders involved shall comply with all EU and national


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with all directives related to the protection of data and the privacy of thecitizens in relation to 112. The different Directives related to the single

European emergency number 112 and data protection can be found in

the Directive on data protection 95/46/EC.

o The DG eCall recommends that the MSD includes only the minimum

required information needed by the emergency services to ensure anadequate response.

o

The DG eCall recommends that the citizen will be informed about theexistence of the eCall service at the moment of buying/hiring a vehicle.

This must include information about the data that would be transferredto the PSAP in the event of a call, and explain that the contract will

include the explicit acceptance of the citizen of the eCall service. The

citizen should have the possibility to ask for a disconnection of theservice at the moment of purchase and in this scenario, it must be

possible for the vehicle owner to ask for a re-connection of the serviceat a later stage.

o DG eCall recommends that when implementing eCall it is ensured that itwill not be possible to track the vehicle at all times. It is recommended

to make eCall a sleeping application on the eCall generator that only

comes to life when the eCall generator detect an incident seriousenough for triggering an automatic eCall or the vehicle occupants


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mandatory, rules have to be embodied in a dedicated law, taking intoaccount data protection principles.

o In case the mandatory option is implemented, a system of proper data

protection safeguards has to be introduced.

o While using eCall, a Minimum Set of Data (MSD) to handle theemergency will be circulated. The Article 29 Working Party considers

that MSD including the complete VIN number as currently indicatedcould be excessive in relation to the clearly defined purpose.

o From a data protection point of view, an emergency call released

automatically by a device or triggered manually and transmitted viamobile networks resulting in geo-localization of the emergency event isin principle admissible, provided that there exists a respective specific

legal basis and sufficient data protection safeguards are provided.However, the purposes of the emergency call system and the relevanceof the data to be processed must always be taken into account, inparticular if the processing involves the so-called Full Set of Data.

European Parliament legislative resolution of 26 February 2014 on the proposalfor a regulation of the European Parliament and of the Council concerning type-approval requirements for the deployment of the eCall in-vehicle system and


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comply with the applicable safety, security and data protectionlegislation and should always remain optional for consumers.

o Recital 13: Directive 95/46/EC of the European Parliament and of the

Council1, Directive 2002/58/EC of the European Parliament and of theCouncil2 and Articles 7 and 8 of the Charter of Fundamental Rights ofthe European Union3govern the processing of personal data carried out

in the context of this Regulation. Any processing of data through the112-based eCall in-vehicle system should therefore be carried out inaccordance with these Directives and under the supervision of theMember States' competent authorities, in particular the independentpublic authorities designated by the Member States pursuant to thoseDirectives, in particular to guarantee that vehicles equipped with112-based eCall in-vehicle systems, in their normal operational status

related to 112 eCall, are not traceable and are not subject to any

constant tracking and that the minimum set of data sent by thein-vehicle eCall system includes only the minimum information requiredfor the handling of emergency calls by PSAPs, and that no personal datais stored after that . Given the consent of the data subject or a contract

between both parties, other conditions may apply in case anotheremergency call system is installed in the vehicle in addition to the112-based eCall in-vehicle system, but it should nevertheless complywith those Directives.


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1.

incidental flaws in hardware and software components in the in-vehicleequipment

2. the threshold for triggering the automatic eCall was not met

3. the in-vehicle equipment is damaged in a crash before an automatic eCall wastriggered

4. in-vehicle equipment was not adequately installed or maintained

5.

service provider or PSAP eCall equipment not adequately installed ormaintained

6. lack of telecom service (due to lack of network coverage or othercircumstances)

7.

human errors somewhere in the service delivery chain

Depending on the reason(s) for the unsuccessfulness of the automatic eCall, liability

claims may be directed towards one or more of the actors in the production andservice delivery chain, including:

1.

dealer/system supplier

2.

car/system manufacturer

3.

private service provider

4. mobile network operator


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1.

The presentation of the product;2. The use the product could reasonably be put to;

3.

The time when the product was put into circulation.

From the wording of Article 6 it can be concluded that the EC Directive defines "defect"

in terms of consumer expectations. Furthermore, the definition of a defective product

makes clear that courts are allowed to take a broad range of circumstances into

account when deciding product liability questions and therefore there are no clear andunambiguous answers when it comes to assessing product liability implications of eCall

equipment.

A key question in relation to eCall is whether an unsuccessful or corrupted eCall canrender the system defective in terms of the Directive. To answer this question it is

useful to distinguish between manufacturing defects and defects that can beconsidered to be inherent system limitations. It seems reasonable that expectations of

the consumer regarding the inherent system limitations could be managed to someextent via the provision of information regarding the service.

Manufacturing Defects

A manufacturing defect exists when a product (an eCall system or component) does

not meet the manufacturersown product specifications. In other words, the product

deviates from the product-line-standard. For example, it could happen that some


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An unsuccessful (or corrupted) eCall may also be the result of inherent limitations ofthe eCall system. The eCall may be unsuccessful as a result of specific accident

situations (e.g. threshold for triggering the automatic eCall not met, vehicle under

water), inadequate coverage of mobile phone network, eCall equipment damaged inthe crash, etc.

It will be clear that manufacturers in principle cannot be held liable for servicesindependently delivered through the in-vehicle equipment. It is only for defects in the

in-vehicle equipment for which the manufacturer is responsible under the Directive.

Liability for false alarms

The situation of false alarms differs from unsuccessful or corrupted eCall in terms of

consequences (unnecessary dispatch of emergency services) and potential claimants

(government entities responsible for emergency services).It should be noted that

normal PSAP operation already includes a high number of false alarms.

An end user may be held liable in tort for intentionally misusing an emergency numberand as such an eCall system. However, in other cases recovery of costs will be

problematic because providing emergency services is a typical public task and seekingrecovery of costs through a civil law claim may be regarded inadmissible. This is

because it conflicts with public law and because of the potential hurdle it would create

for people to call the emergency services.


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is related to a directly or indirectly identifiable individual and therefore qualifies aspersonal data. Therefore, the PSAP is presented with personal information which

requires data protection.

This means that in the technical and organisational set up of eCall services the

principles laid down in the relevant European Directives and national data protection

laws have to be applied. Processing of personal data is one of the core obligationscreated by the Proposal which is therefore subject to the application of and compliance

with data protection legislation and safeguards. In this regard, the European DataProtection Supervisor (EDPS) provided a reminder that it is essential to explicitlymention the applicable EU data protection law in a substantive provision of the

Proposal: a mere indirect reference in a recital cannot be considered as sufficient. The

reference should explicitly provide, as a general rule, that Directive 95/46/EC and its

national implementing rules apply to the processing of personal data within theframework of the Proposal.

Other comments provided by the EDPS were:Article 6 would require vehicle manufacturers

i. to ensure that vehicles equipped with the system are not traceable and are

not subject to any constant tracking in their normal operational status

related to the eCall,

ii.

to make use of privacy enhancing technologies (hereinafter 'PETs') as well


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The EDPS recommends the introduction of an additional paragraph to Article 6 of theProposal which contains these additional essential safeguards, and in particular:

i. Designates the data controller and the entity responsible for handling access

requests.

Specifies the list of data referred to as a minimum set of data and as a full

set of data (possibly to be elaborated in a delegated or implementing act).

Includes the possibility for data subjects to deactivate private eCall and

added value services.

Specifies retention periods for the data processed.

Specifies the modalities of the exercise of data subjects rights,

The EDPS highly welcomes that Article 6(3) requires manufacturers to provideindividuals purchasing new vehicles with information about the embedded 112

eCall in-vehicle system and the resulting processing of data, and specifies in

the Regulation itself the details of what such information should cover, i.e. the

fact that the system is activated by default, and the modalities of the data

processing that is performed as required under Articles 10 and 11 of Directive

95/46/EC (such as the purpose of the 112 eCall processing, the reference to

the legal basis for the processing, the types of data collected and processed,


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general terms and conditions, whose acceptance is mandatory, will not fit thisrequirement.

Under Directive 95/46/EC, data exchanged should only be kept for the time necessaryto achieve the purposes for which they were collected and should be automatically

deleted following the expiry of the retention period. The EDPS notes that the retention

period of the data processed for 112 eCall purpose is not specified even though thisinformation is included in the notice that should be given to data subjects by car

manufacturers. In any event, the data shall not be retained longer than necessary foradequate transmission to the appropriate PSAP and the MSD should be deletedafterwards. These storage periods shall be adapted and harmonised depending on the

parties and location of the data (in-car storage, PSAP databases storage). If the data

were to be necessary after the expiration of the required period of storage, in

particular for statistical purposes, they should be anonymised, i.e. there should be noway to identify directly or indirectly a person based on these data. The EDPS advisesspecifying these safeguards with regard to retention.


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3.3 Conformance to relevant technical standards

3.3.1 Reasons for requirements

Different actors are involved in the eCall chain (vehicle/IVS, MNO, PSAP, TPSP) and

pan-European eCall is intended to work across the EU. In order to allow transfer of an

emergency message and the establishment of a voice channel between IVS and PSAP

via a mobile network, common protocols and standards are required. To ensureinteroperability, test procedures are necessary to assess conformance without having

influence over the other actors involved. Also, the content and format of data to betransmitted from the vehicle to the PSAP (the MSD) has to be defined to ensure

interoperability.

3.3.2

Options

As mentioned in Section2,Working Group 15 of the CEN TC274 has written a set ofstandards regarding eCall. Compliance with these standards is required in the GeneralApproach of the Council, dated 19/05/2014, Article 5.7:

EN 16062 - eCall high level application requirements (HLAP)defines the high

level application protocols to facilitate eCalls using mobile networks.Requirements for the IVS include: Procedures following power-up, activation ofeCall, MSD transfer, handling of error cases, and timings (Section 7, Annex 7).


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includes data presentation, encoding and transmission. Brief requirements forconformance testing are set out.

CEN/TS 16454 - eCall end to end conformance testingsets out test proceduresthat allow different actors in the eCall chain (vehicle/IVS, MNO, PSAP, TPSP) to

claim conformance to all above listed EN eCall standards without being able to

control the behaviour of other actors. The standard specifies a set of statetransition points for which conformance requirements are defined and tests are

arranged into. With regard to the IVS, 47 test objectives and related tests aredefined to demonstrate that it is capable of triggering an eCall, sending theMSD, and making a voice channel available (Sections 2, 9.1 to 9.6, Annex A).

Please note that this document is currently has the status of a published

Technical Specification (TS). A Technical Specification is established by a CEN

Technical Body and approved through a vote by the CEN national members. Itmay be adopted as a national standard, but conflicting national standards maycontinue to exist. A Technical Specification may however not conflict with a

European Standard. If a conflicting EN is subsequently published, the TS iswithdrawn.

Various standards from the European Telecommunications Standards Institute (ETSI)

exist for mobile phone equipment to be interoperable. The following ETSI standardshave been referenced in the various eCall related documents:

ETSI TS 102 164 (Version 1.3.1)


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3.3.3

Commentary

The EN eCall standards EN 16062, EN 16072 and EN 16102 provide an agreed

framework of high level and operating requirements specifically for Europeanconditions. The standards are highly developed and were created by experts in therelevant fields. In order to make these standards mandatory, compliance would need

to be required in eCall type-approval legislation. As there is an ongoing review processfor these documents, the latest version available at the time of legislating will need to

be checked and referenced.

CEN/TS 16454 defines an advanced procedure for demonstrating conformance to therequirements defined in the EN eCall standard framework and could be used for type-

approval testing. This conformance testing requires specialised test equipment (see

Section 3.16)and is expected to be carried out by the eCall system manufacturer (or

on their behalf) in order to provide the vehicle manufacturer with a certificate ofcompliance to eCall standards for the system to be integrated into the vehicle.

EN 15722 defines a widely accepted and technically sound format and content of the

MSD transmitted to the PSAP. This format is also used in the Russian standard GOST R

54620 and discussions on UN level indicate that it will be adopted, regionaldiscrepancies notwithstanding, in the future UN Regulation. The MSD as defined in EN

15722 includes, however, certain elements which are politically disputed due to

potential privacy and data protection issues (see also Section3.2):

The VIN, which is intended to enable PSAPs to obtain detailed information from


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The minimum set of data sent by the eCall in-vehicle system shall include onlythe minimum information as referred to in the standard EN 15722:2011

"Intelligent transport systems - eSafety - eCall minimum set of data (MSD)".

The personal data included in the eCall in-vehicle system shall not be retained

longer than necessary for their transmission to the appropriate PSAP. Data

submitted shall only be used for the purpose for which they were submitted.

They shall be deleted as soon as they are no longer necessary for the purpose

for which they were collected.

From a technical point of view, it is recommended that the MSD data format isrequired to comply with EN 15722 to ensure interoperability. Regarding contents,

further discussion appears necessary to decide on the items mentioned above. In their

final report in 2006, the eSafety Driving Group eCall recommended that the MSDshould include only the minimum required information needed by the emergency

services to ensure an adequate response. A stakeholder survey carried out by EeIP

among road operators (published in the Deliverable of Task Force 3 in 2011) indicatedthe following requirements regarding data transmitted:

The system must provide:

o Number of persons involved

o Number of vehicles involved

o Number of automatic signals and manual signals related to one event


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Position info (report site and travel trail, 64 points at 80 m intervals, i.e. ca. 5km), based on GPS, gyro, velocity signals, map-matching, etc.

Road type

Sensor info (DeltaV, airbag sensors, overturn sensor, multiple crash, etc.)

Originator ID (Originator ID is used to acquire member and vehicle information

(make, model, colour, etc.) from a database.

With regard to mobile communication standards, it appears necessary for the MND tobe compliant in order to successfully access PLMNs. The ETSI standards listed in

Section 3.3.2 are not eCall specific and have not been reviewed in-depth during this

project because they are well-established. Conformance with these standards is, inpart, already required by conformance to the EN standards (as these contain

references).

ISO 24978 on data registry procedures for Intelligent transport systems, for example,

requires in a general way:

() wireless communication shall be established in full compliance with local

telecommunication regulations, procedures and protocols for that media using

the appropriate International or Regional Standards ()

UN R116 for vehicle alarm systems, which might also include transmitting equipment,

requires compliance with the relevant ETSI standards and lists examples. The

wording used in UN R116, Section 6.2.3. is:


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3.4 eCall triggering and test calls


It is a basic functional premise of eCall that in the event of a collision the system is

able to detect the collision and initiate the eCall. This is based on the assumption that

the collision is of a severity that is potentially injurious and that the occupants of the

vehicle may not able to initiate the call themselves. Thereby there is some benefitassociated with automatic triggering of a call to the emergency services.

Within the context of vehicle type-approval one expects certain limitations as to what

can be assessed to guarantee safe performance of vehicle systems. It is often not

cost-effective or practical to test every conceivable condition of use. In the case of

expensive full-scale crash testing, these limitations can be even more evident. Toreduce the costs associated with eCall system development and type-approval it is

hoped that existing crash tests can be used for the assessment of the automatictriggering of eCall. Options for this are discussed in the Section3.4.3.

Alongside crash performance of the vehicle, it is anticipated that each manufacturer

will design and implement an algorithm for deciding whether the eCall should betriggered. A level of in-house development is therefore assumed. The type-approvaltesting merely provides some assurance that for an accepted severity the eCall will be

activated. Furthermore the testing also provides experimental validation that the


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3.4.2

Expectations

General Approach of the Council with regard to the Proposal for a Regulation ofthe European Parliament and of the Council concerning type-approval

requirements for the deployment of the eCall in-vehicle system and amendingDirective 2007/46/EC, 9879/14 ENT 123 MI 428 CODEC 1299, dated

19/05/2014:

o

Article 5, Point 2: Manufacturers shall demonstrate that all their newtypes of vehicle are constructed to ensure that in the event of a severe

accident, detected by activation of one or more sensors or processors

within the vehicle, which occurs in the territory of the Union, an eCall to

the single European emergency number 112 is triggered automatically.

o Point 7 of the introductory text: The mandatory equipping of vehicles

with the eCall in-vehicle system should initially apply only to new

passenger cars and light commercial vehicles (categories M1 and N1) for

which an appropriate triggering mechanism already exists.

EN 16072, Section 7.5

o The automotive manufacturer/equipment supplier shall make bestreasonable effort to enable an audio channel to be established so long

as the relevant equipment has not been disabled in the crash.


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Draft UN Regulation No. XX on AECD/ AECS, Part I: Automatic triggering shalloccur at least under the conditions of UN R94 and UN R95 crash tests (perhapsalso other conditions). Calculation of the automatic triggering signal will not

form part of the UN Regulation.

3.4.3 Options

Draft UN Regulation No. XX on AECD/AECS, Part II, Section 15.2

o The specifications apply to vehicles of category M1, covered by

Regulations Nos. 94 and (or) 95, and those of category N1, covered byRegulation No. 95.

o Russian proposal for text:

The e-call system shall enable:

Automatic transmission of information about the accident

at the time of the accident. The fact that transmission hasoccurred and the information about the accident shall berecorded by the technical service:

o When simulating a frontal collision of the vehicle


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o

Performance or simulation of a lateral collision. Inthe case of a simulation, the logic signal can begenerated according to a test report established

during a Regulation No. 95 lateral collision.

Draft UN Regulation No. XX on AECD/AECS, Part III, Section 24.2.2 + Section24.3.2

o

Generation of the triggering logic signal

The triggering logic signal shall be generated by at least one of the

following events:

Occurrence of a frontal collision according to Regulation No. 94

(frontal collision); or

Occurrence of a lateral collision according to Regulation No. 95(lateral collision); or

Activation of the AECS control.

o Testing the generation of a triggering logic signal

The manufacturer shall carry out or simulate the following tests with a


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o

6.2.2 For the AU, established in the configuration of standardequipment, the mechanism of determining the moment of the accidentis determined by the vehicle manufacturer.

o 6.2.3 AC installed in the option configurations, as a criterion ofoperation of the system it is recommended to use the condition in whichthe value of the index is greater than the possible damage

ASI15_TRESHOLD, given in Annex A.

NOTE: This limit was not obvious in Annex A

Index of possible damage ASI 15 is calculated using the following

equations:


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- Components of the acceleration of the point

vehicle in place of the sensor acceleration direction of the main

axes vehicle averaged over the interval = 50 ms;

- The limit values for the components of the

acceleration on the main directions of the axes of TS.

CEN/TS 16454

Tests of the Post-side-crash performance of automatic trigger; Post-frontal-

crash performance of automatic trigger; and Performance of automatic

trigger - different crash types are defined in CEN 16454. These are

available under CTP 1.1.2.3, 1.1.2.4 and 1.1.2.5. The concept for these

tests is to establish that the automatic trigger is activated as intended by

the system manufacturer. For the lateral crash the conditions refer to UNRegulation 95, the frontal crash refers to Regulation 94. In both cases it issuggested that an equivalent pulse can be generated via sled testing. For

the performance in different crash types it is simply suggested that an

invalid trigger, below the threshold for activation, is generated inaccordance with the manufacturers instructions.


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information can be used in PSAPs with a sufficient level ofreliability to evaluate the likeliness of serious injuries; and

The vehicle manufacturers are responsible for determination of

the automatic eCall trigger signal.

Use of crash tests

As mentioned in the reasons for requirements, it is hoped that existing crash tests canbe used for the assessment of the automatic triggering of eCall. The potential crash

tests available for this purpose are listed below.

UN Regulation 12

o This Regulation applies to the behaviour of the steering mechanism ofmotor vehicles of category M1, and vehicles of category N1 with amaximum permissible mass less than 1,500 kg, with regard to the

protection of the occupants in a frontal collision.o The unladen vehicle, in running order, without a manikin, is collision-

tested against a barrier at a speed of 48.3 km/h (30 mph).

o This 30 mph test could provide some helpful information with regard toeCall offering a slightly different scope to Regulation 94.

o However, this test can be omitted if UN Regulation 94 has been passed.Therefore it is typically only used in approving heavier M1 vehicles


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o

PART II concerns the approval of vehicles with regard to the preventionof fire risks in the event of collision

o Part II requires:

a frontal-impact test against a barrier carried out by the

procedure specified in Annex 3 to this Regulation,

This is either the same 30 mph unladen vehicle test as inRegulations 12 and 33 or the test procedure described inannex 3 of Regulation No. 94, 01 series of amendments.

a lateral impact test performed according to the procedure

described in Annex 4 of Regulation No. 95, 01 series ofamendments, and

a rear-end impact test carried out by the procedure specified inAnnex 4 hereto,

For this test an impactor is driven into the rear of thevehicle. The impactor may either be secured to a carriage(moving barrier) or form part of a pendulum. The velocityof collision shall be between 35 and 38 km/h. Theaggregate weight (mass) of carriage and impactor shall


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o

This test is designed to challenge the vehicles structuralcrashworthiness. Only one side of the vehicle interacts fully with thebarrier and is responsible for absorbing (or managing) most of the

energy.

UN Regulation 95

o This is applicable to M1 and N1 categories of vehicles where the R point

of the lowest seat is not more than 700 mm from ground level when thevehicle is in the condition corresponding to the reference mass definedin paragraph 2.10. of this Regulation.

o Such vehicles undergo a test in accordance with Annex 4 of theRegulation.

o For this test, a mobile deformable barrier (MDB) collides with the side of

the vehicle. The barrier consists of a deformable front face of animpactor (designed to represent crush characteristics of a typical car) ona trolley. The total mass of the impacting barrier is 950 kg. The mobiledeformable barrier speed is 50 km/h.

Potential future UN Regulation 13x

o It should be noted that Regulation 94 is being updated with a


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Rollover tests: UN Regulation 66

o This Regulation applies to single-deck rigid or articulated vehiclesbelonging to categories M2 or M3, Classes II or III or class B havingmore than 16 passengers.

o It includes a "Rollover test on a complete vehicle" meaning a test on acomplete, full-scale vehicle to prove the required strength of thesuperstructure.

There are currently no regulatory full-scale tests for assessing M1 andN1 vehicles in rollover conditions.

It is assumed that only a small percentage of the vehicles sold in Europe are currently

equipped with sensors to monitor for rollover or turnover of the vehicle. However,most M1 and N1 vehicles are fitted with acceleration sensors in order to deployairbags; and it is therefore reasonable to believe that they could also be used for eCall

systems. This limits eCall automatic operation to impacts where airbags are deployed,

but there is much real world evidence, including from the accident analysis undertakenfor this study, that front and/or side airbags deploy in many accident types, including

rollovers. Therefore, it is the authors opinion that essential devices to determine

rollover collisions (e.g. gyroscopes), which may be relatively costly, are not essential


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Figure 3-1: Simple representation of automatic triggering conditions based

on severity

The crash tests described in the section above have a severity level set around thepoint at which there is a substantial risk of injury, in which case they could be used to

assess the point above which eCall must trigger. However, it may also be useful tohave a low severity check to make sure that eCall is not activated when there is no

risk of injury. As such, there may be a desire to use tests at a lower severity to try

and identify a consistent severity under which eCall should not be triggered.Therefore, when considering trigger checks of the automatic eCall system it may also

be worth acknowledging the other end of the severity spectrum. This would provide


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developed test procedures to assess how well a vehicles bumpersystem protects the vehicle from damage in low speed impacts. Damagein these tests closely replicates the damage patterns observed in real

world low speed crashes

o The new bumper tests incorporate a rigid bumper-shaped barrier fittedwith an energy-absorbing material and cover. The barrier is 100 mm tall

and is mounted to an immovable surface and impacted by test vehicles.

o For full-width tests, the impact velocity is 10 km/h. For corner tests, thevelocity is 5 km/h.

UN Regulation 42

o Low severity bumper tests are described in Regulation 42. However,they are extremely low severity and the Regulation isnt widely adopted.

UN Regulation 116, Section 6.4.2.13.

o Safety against false alarm in the event of an impact on the vehicle

It shall be verified that an impact of up to 4.5 Joules of a

hemispherical body with 165 mm in diameter and 70 10 ShoreA applied anywhere to the vehicle bodywork or glazing with its


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Cars registered between 2000 and 2009 and involved in an accident occurringbetween 2000 and 2010

Cars towed from the scene

Cars equipped with front and side airbags

Car occupants for whom the injury data is present and their severity of injury is

known

The national data were taken from UK Department for Transport figures9. In totalthere were approximately 126,000 injured car users for each year in Great Britain

(GB).

An important factor is the distribution of different collision types;Figure 3-2 presentsthe collision types for CCIS car occupant casualties by their injury severity. Car impact

typology varies across the EU member states; and therefore the relative importanceand effectiveness of aligning an eCall automatic triggering threshold to a specific

collision type will vary. For example, if there are more frontal impacts in a region,using an automatic triggering threshold that is based on impacts with similar

characteristics, or which exceed those, of the R94 conditions, is likely to result in a

greater proportion of eCalls compared to a region with a greater proportion of rolloveror side impact injury collisions.

Based on the UK data analysed, if airbag deployment is used as a trigger condition,

more automatic emergency calls will be made for all accident types, and all injury


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Figure 3-2: Distribution of collision typology by driver and passenger injury

severity outcome (UK, CCIS data)

Table 3-1: Summary of percentage of annual GB road users potentially

affected by different eCall automatic triggering mechanisms


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the crash test characteristics; and hence there will be a potential benefit for morecasualties. Unfortunately, using airbag deployment as a trigger mechanism alone, is

also likely to lead to a greater number of emergency calls that are superfluous (e.g.

uninjured occupants). Robust estimates of the burden of calls associated with minor ornon-injury collisions are beyond the scope of this study because of the challenges

associated with gathering the pertinent data, often on non-police reported collisions

across Europe.

Test call

Acknowledging the potential link with airbag deployment and the idea to use crashtests to assess a mandatory triggering severity, then consideration must be given toexactly what is tested for type-approval. Hence, once a crash test has been selected

for use in assessing the eCall system, then it will be important to set out the functionalrequirements to be investigated during the test.

Draft UN Regulation No. XX on AECD/AECS, Part II, Section 15.2

o Russian proposal for text:

On completing the tests specified in paragraph 15.2.3.1,

retention of functionality and two-way voice communicationswith the emergency services through mobile telephonecommunications networks. The fact that the communication has


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audio capabilities and MSD transmission during crash testprocedure.

TV Rheinland German point of view Results of the national meeting ofGerman experts AECS-03-08e

o Homologation of the vehicle should ensure, that after a standard

accident (UN-R 94, UN-R95) the vehicle is able under minimum

conditions (to be defined) to determine its position and to establish amobile phone connection in a sufficient quality (to be defined)

EN 16072, Section 7.5

o This defines the Post crash performance of in-vehicle equipment

o The automotive manufacturer/equipment supplier shall make best

reasonable effort to enable an audio channel to be established so long

as the relevant equipment has not been disabled in the crash.o The in-vehicle eCall system shall transmit the MSD message, so long as

there is an ETSI prime medium wireless network available to receive thesignal, in all crash tests which are required by regulation for theEuropean type-approval:

o In cases where it is impracticable or not commercially viable to test

using real crash tests, for example after-market devices, equivalent


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o

TS12 emergency call and additionally using the test indicator in the MSDOption B

In addition to the eCall flags, described earlier, that are used

solely by the mobile network to differentiate eCalls from otheremergency calls, the IVS also includes eCall and test callidentifiers in the MSD sent to the PSAP. When the MSD data file

is opened the eCall may be recognized as a real eCall, manually

or automatically initiated, or as a test eCall.

o Reservation of fixed numbers for test calls Option C

Test eCalls will normally be made to a non-emergency numberthat may be pre-programmed on the USIM e.g. in the case ofeCall only configured devices, or in case of an unrestricted devicemay be stored elsewhere in the IVS, or entered using a keypad.

In the call set up a fixed number (long number) specifies that aconnection to a dedicated test centre shall be established. Thenetwork does not recognize any characteristic of an eCall,

however the MNO will accept this service call from a restrictedIVS. If a dedicated E.164 number (reserved for testing) is used

then the MNO may use this long number, in conjunction with arouting table, to identify the designated test centre to which the


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In this case additional means are necessary in the network toroute the call to a test server. A simple solution would be theoral information of the PSAP about the test call, but this solution

is not recommended.

o Test eCall initiation

In all cases test eCalls are initiated in accordance with the

manufacturers instructions and access to the test call initiationmechanism e.g. menu command or button, may or may not bemade accessible to the vehicle user.

o A test centre might be hosted by:

1.

PSAP

2.

Governmental body on European or Member State level

3. Privately by vehicle manufacturers, national dealership orinspection bodies

4. Locally by the service centre performing the inspection

o eCall test centre hosted by PSAP (Option 1)


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routed. Every member state may decide on their own if there willbe one national or numerous local test centres. In parallel somemember states might still prefer not to operate any test centre

on national level but to use one on European level.

o eCall test centre hosted by vehicle manufacturer or national dealership(Option 3)

This test centre hosting option could be implemented by usingthe call set-up and routing possibilities C and D. This allows avariety of implementation variants. There might be just only one

huge European test centre per manufacturer or one test centreper dealership to which calls will be routed. Every manufacturermay decide on its own if there will be one or numerous test

centres. If routing possibility D to a dedicated device (e.g.

femtocell) is chosen, the call might need to be forwarded by thetelecommunications equipment located at the inspection body to

a dedicated test server of the car manufacturer.

o eCall test server hosted locally by vehicle service centres (Option 4)

This server hosting option could be implemented by using the

call set-up and routing possibilities C and D. The call would be


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Manual triggering

One of the features of eCall often discussed is the ability to make a Good Samaritan

call. That is to initiate an eCall manually when observing another vehicle beinginvolved in a life-threatening crash. This function would potentially increase thebenefit of eCall during the period where not every car on the road is fitted with an

automatic system; in the transitional period to dominating penetration of eCallsystems into the vehicle fleet.

However, alongside the benefit of manual eCall is the negative potential for manualactivation to be abused and hence generating fraudulent calls to the Public ServiceAnswering Points.

General Approach of the Council, 9879/14 ENT 123 MI 428 CODEC 1299, dated

19/05/2014,Article 5, Point 2: Manufacturers shall demonstrate that newtypes of vehicles are constructed as to ensure that an eCall to the single

European emergency number 112 can also be triggered manually.EN 16072

o The objective of implementing the pan-European in-vehicle emergencycall system (eCall) is to automate the notification of a traffic accident,wherever in Europe, with the same technical standards and the same

quality of services objectives by using 'Public Land MobileNetworks'(PLMN) (such as GSM and 3G), which supports the Europeanpre-assigned emergency destination address (see normative references)


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TV Rheinland German point of view Results of the national meeting ofGerman experts AECS-03-08e

o Systems, installed in vehicles within the scope of UN-R 94 and UN-R

95, shall be triggered automatically.

o All other vehicles shall be fitted with a system which may be triggeredmanually

From these sources, the manual triggering of an eCall system is expected to be a coresupplemental function and could be required in type-approval. In which case the

manual triggering shouldbe demonstrated to function in two conditions:

the Good Samaritan mode, and

after a collision, especially but not limited to, incidents where automated

triggering is not expected or mandated.

Manual triggering without an impact to the eCall equipped vehicle, to help anotherroad user, requires good design of the system to prevent inadvertent calls and to also

ensure calls can be easily and rapidly made when required. These factors are

discussed in the Human-Machine Interface (HMI), Section 3.15 of this report.

Manual triggering is also a possible function following a collision when an automated

call has not been made. It is recommended that the functionality of the manual callmode could be tested following the physical testing which is discussed in Section 3.6


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are directly related to vehicle occupant injury risk. The injury risk for any occupant(s)will not only be determined by the severity of crash for the vehicle, but also on

occupant age and frailty and seating position, etc. This together with the limited

existing options for full-scale testing calls for a degree of pragmatism in selecting thetest conditions. Therefore, the automatic triggering decision must be left to the vehicle

manufacturers discretion.

The Regulatory tests R94 and 95 are associated with some risk of severe injury and

hence it is suggested that these could be appropriate for assessing a threshold where

eCall is expected to operate.

The exact practicalities of doing the evaluations around the crash tests still needssome consideration; however, there will need to be some check that the system tried

to initiate an eCall after the impact and that it still passes some rudimentary systems

checks.

It should be noted that inside crash test facilities there may be weak or no mobile

network or Global Navigation Satellite System (GNSS) coverage. Forcing arequirement to set-up a dedicated network (e.g. using a femtocell) is technically and

legally complex across different countries and potentially expensive (as noted earlierin this Section).

The link with the crash tests of Regulations 94 and 95 is to provide:

A check of the automatic triggering system (that it triggers in a potentiallyinjurious crash configuration)


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N1 vehicles and large M1s. However, most passenger cars of current designs wouldstill be included.

As a slight change to considering only vehicles undergoing R94 and R95, would be thepotential to limit scope of a physical triggering check to those vehicles required to

undergo either Reg. 94 or 95. This is a slightly broader remit of crash testing which

would capture some N1 vehicles (those where the R point of the lowest seat is notmore than 700 mm from ground level). The manufacturers response to this, as muted

during the 3rd meeting of the Informal Group on AECS was that there would be

product liability issues if releasing products which havent undergone broad evaluation

testing implying that they would have to do additional development tests to address

such limitations.

If Regulation 12 was added as well, (i.e. Reg. 95 and either Reg. 94 or 12), that would

give a crash-test assessment for M1 and N1 categories of vehicles where the R pointof the lowest seat is not more than 700 mm, and for the N1 category where the

maximum permissible mass is less than 1,500 kg. However, as the requirements of

the Regulation 12 test are related to physical measurements taken within the vehicle,it may be that the Technical Services offering Regulation 12 testing may not be as

prepared for eCall system checks compared with those offering Regulation 94 testing,

which already includes an element of electronic data analysis and processing.Furthermore, it is not expected that there are many M1 vehicles being approved via

Regulation 12 that also have airbags fitted.


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Reg. 95. That is for the M1 category of vehicles where the R point of the lowest seat isnot more than 700 mm from ground level, or where the maximum permissible mass is

less than 2,500 kg.

However, some vehicles with high R points and high mass already use safety systems

very effectively (e.g. Ford Transit). Perhaps a reduced set of requirements for a

triggering assessment could encourage eCall for the vehicles outside of the dynamictesting scope. In this way it might be useful to have a definition of the automatic

triggering expectations such as:

All M1 and N1 vehicles for which an appropriate triggering mechanismalready exists are to offer eCall. All M1 and N1 vehicles being tested in a

full scale crash are expected to demonstrate proof that the automatic

system functions correctly under those conditions.

Ideally, taking into account the accident analysis, this would be supplemented by therequirement that triggering is to be linked with airbag deployment. Evidence of a link

should be shown to the appropriate Technical Service during the approval process.

Therefore the definition above would be extended with the following stipulation:

All M1 and N1 vehicles required to provide eCall but that are not being tested ina full scale crash are expected to demonstrate a link between airbag

deployment and automatic triggering of the eCall functions.

For the test call, two paths will be needed:


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3.5

Resistance to mechanical impact during normal use


The IVS will be subjected to mechanical vibration and repeated shocks during normal

use of the vehicle. This has the potential to prevent the system from working correctly

while under vibration, permanently damage components or loosen connections. Please

note that severe shocks, as they would occur during a crash, are discussed separatelyin Section3.6.

3.5.2 Options

Draft UN Regulation No. XX, Section 6.4.3 and Annex 7 define requirements and a test

procedure for the AECD in which the SUT is fixed to a test stand (vibration platform /shock plant) and subjected to a defined level of vibration and repeated shocks, each

repeated in three perpendicular directions. Separate tests are defined for: Resistance to vibration,

Durability under vibration,

Resistance to repeated shocks,

Durability under repeated shocks, and

Resistance to repeated shocks during transportation (tested in packaging)


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speakers and requests the tester to push the needed button (buttons) in case

the sound is correct;

- users interface unit detailed test. For example, the In-Vehicle Emergency Call

System/Device plays a voice request to push needed buttons in a specified

order. In addition the In-Vehicle Emergency Call System/Device asks the tester

to confirm the correct work of status indicators of the In-Vehicle Emergency

Call System/Device.

- standby battery test, in case if there exists one and there is a possibility to doa standby battery test;

- performance test of automatic road accident identification sensor

(mechanism) (only for vehicles of category M1), that is obligatory for this

category of vehicles;

N o t e If a base vehicle system is used as a road accident data source, then

the use of previous data of performance of automatic road accident

identification sensor (mechanism) is applied; data received during the period

between engaging the ignition (for example, performance data of automatic

road accident identification sensor (mechanism), received during the diagnostic

process of base vehicle systems, started after engaging the ignition).


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Table 3-2: Test conditions as proposed in Draft UN Regulation No. XX, Annex

7

Test parameters ValuePermitteddeviation

Resistance test when exposed tosinusoidal vibration

Range of frequencies, Hz 10-70 1

Acceleration amplitude,m/s2(g)

39,2 (4) 2(0,2)

Action time in each ofthree directions, min

30 -

Durability test when exposed tosinusoidal vibration

Range of frequencies, Hz 50 1

Acceleration amplitude,m/s2(g)

49 (5) 2 (0,2)

Action time in each ofthree directions, min

2 h 40 min -

Stability test when exposed tomechanical shocks of repeated action

Shock acceleration peakvalue, m/s2(g)

98 (10) 20%

Shock duration, ms 10 -

Sweep count in each of

three directions333 -

In-vehicle Emergency Call Shock acceleration peak


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Table 3-3: Vibration and shock conditions for mechanical resistance test as

proposed in Draft UN Regulation No. XX, Section 6.3.1 and 6.3.2

Vibrationconditions:

The AECD components are subdivided into two types:

Type 1: components normally mounted on the vehicle,

Type 2: components intended for attachment to the engine.

The components/AECD shall remain operational under a sinusoidal vibrationmode characterised as follows:

For type 1

The frequency shall be variable from 10 Hz to 500 Hz with a maximum amplitudeof 5 mm and maximum acceleration of 3 g(0-peak).

For type 2

The frequency shall be variable from 20 Hz to 300 Hz with a maximum amplitude

of 12 mm and maximum acceleration of 15 g(0-peak).

For both type 1 and type 2

The frequency variation is 1 octave/min.

The number of cycles is 10, the test shall be performed along each of the 3 axes.

The vibrations are applied at low frequencies at a maximum constant amplitudeand at a maximum constant acceleration at high frequencies.


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Table 3-4: Vibration conditions for safe operation after vibration test as

defined in UN Regulation No. 116, Section 6.4.2.8.

Vibrationconditions:

For this test, the components are subdivided into two types:

Type 1: components normally mounted on the vehicle,

Type 2: components intended for attachment to the engine.

The components/VAS shall be submitted to a sinusoidal vibration mode whosecharacteristics are as follows:

For type 1

The frequency shall be variable from 10 Hz to 500 Hz with a maximum amplitudeof 5 mm and maximum acceleration of 3 g(0-peak).

For type 2

The frequency shall be variable from 20 Hz to 300 Hz with a maximum amplitude

of 2 mm and maximum acceleration of 15 g(0-peak).

For both type 1 and type 2

The frequency variation is 1 octave/min.

The number of cycles is 10, the test shall be performed along each of the 3 axes.

The vibrations are applied at low frequencies at a maximum constant amplitudeand at a maximum constant acceleration at high frequencies.


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on braking; ABS sensors are an example of electronic components). Other vehiclesafety systems such as airbags are not regulated at all in type-approval legislation,

but, if fitted, are implicitly assumed to work reliably (as they did in the mandatory full-

scale crash tests in the Type Approved sample vehicle) after being exposed tomechanical impacts during normal use.

It should therefore be carefully considered whether mechanical resistancerequirements and tests are necessary for eCall IVS. A failure of the eCall system would

not create an immediate hazard, as opposed to, for example, a failure of a vehicle

immobilizer might be switching off the engine during driving at high speeds. Requiringa thorough self-test of the IVS (see Section 3.14) could ensure that a driver gets

warned in case of a malfunction and can seek assistance at a garage.

If mechanical resistance is to be covered in type-approval legislation, it appears not

feasible to take over entire sections of the current Draft UN Regulation No. XX,because:

The current draft version of the document contains several unresolvedinconsistencies (e.g. different test conditions in main body and annex); and

The operability tests to be performed are not defined in sufficient depth (e.g.

the standby battery tests) and require programming or procuring additional

dedicated test software (which cannot be used for compliance testing to ENstandards).

Furthermore, TRL considers requirements and tests of the packaged product for


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3.5.4 Recommendations

If mechanical resistance is to be covered in type-approval legislation, vibration

conditions as defined in UN R116 (see Table 3-4)prescribing 10 test cycles, could beset out. This equates to about 60 minutes of testing, which is less than the testingprescribed in the Russian UN proposal (160 minutes). UN R116 is an established

regulation accepted for EU type-approval of an electronic system to be installed on avehicle (alarm systems) and also used in Draft UN Regulation No. XX as proposed by

OICA.Shock conditions may be defined based on the later proposal of the Draft UNRegulation No. XX (see Table 3-3). These are in agreement with Russian proposals

and standards.

An operability test procedure is required in order to provide objective pass or failcriteria. A full set of compliance tests in accordance with CEN/TS 16454 after exposing

the system to mechanical impacts would provide a high level of assurance that the

system is fully operable. However, in practical terms these compliance tests requirespecialised test equipment and will likely be performed by different companies from

the mechanical resistance tests (at a different stage of system development; theconformance testing is expected to be carried out by the eCall system manufacturer

(or on their behalf) in order to provide the vehicle manufacturer with a certificate of

compliance to eCall standards for the system to be integrated into the vehicle). Areduced set of functionality tests would therefore need to be defined that allows the


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3.6

Resistance to mechanical impact during accident (crash)


During a road accident, the IVS will experience very severe mechanical shocks. In

order to perform its intended safety function it has to be able to withstand these

impacts.

The mechanical resistance tests discussed below are intended to supplement potentialfull-scale crash testing, rather than replace it. This section therefore assumes that thefull-scale tests of UN Regulation 94 and 95 will be used to assess eCall systems fitted

into vehicles. The tests described below offer an additional means of assessing the

eCall device independently of the vehicle into which it is to be fitted. For this to be of

benefit, it should be anticipated that the component level tests will require mechanicalresistance at higher accelerations, which represent more severe accidents than UN

R94/R95 crash tests.In accidents matching the conditions of the UN Regulation full-scale crash tests,occupants of modern vehicles may stand a relatively low risk of serious injury

(assuming similar anthropometry to the crash dummy, that they were not out-of-position, etc.). To perform its main purpose of facilitating quicker care for severelyinjured casualties, it is necessary to ensure that the IVS is capable of withstanding

more severe accidents, where there is a greater anticipated risk of serious or fatal


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Component tests (performed on test sled or drop rig)

In current UN legislation, two different test pulse corridors representing frontal

impacts are available and used for testing safety belt anchorages, seats, etc.:

The first deceleration corridor is initially defined in UN R17, Annex 9 and used for a

"Test procedure for devices intended to protect the occupants against displacement of

luggage". The pulse corridor describes a maximum deceleration of 20g-28g, aminimum duration of 15 ms and v = 50 +0/-2 km/h (see Figure 3-3). An identical

pulse corridor is used in UN R44, UN R100 and UN R129.

I

ECall Type-Approval - TRL Client Project Report CPR1868

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