Regulations and Policies Impacting AV/CV Introduction...

Regulations and Policies Impacting AV/CV Introduction in Transit

Thursday, November 16, 2017 2:00-3:30PM ET

TRANSPORTATION RESEARCH BOARD

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As such, it does not include content that may be deemed or construed to be an

approval or endorsement by RCEP.

Purpose Examine how to design roundabout intersections that are right-sized for all modes of travel at the specific location. Learning Objectives

At the end of this webinar, you will be able to: • Describe basic regulatory issues facing AV adoption in transit • Understand applicable safety standards, regulations, and transit

policies • Identify barriers facing introduction of AV technology in transit • Understand the necessary next steps toward smoothing technology

introduction, such as what needs to be studied and what outcomes need resolution

NCHRP Web Only Document 239:Regulations and Policies Impacting AV/CV Introduction in Transit NCHRP Project 20-102(02)

NCHRP is a State-Driven Program

– Suggest research of national interest

– Serve on oversight panels that guide the research.

• Administered by TRB in cooperation with the Federal Highway Administration.

• Sponsored by individual state DOTs who

Practical, ready-to-use results • Applied research aimed at

state DOT practitioners • Often become AASHTO

standards, specifications, guides, syntheses

• Can be applied in planning, design, construction, operations, maintenance, safety, environment

Additional NCHRP Publication Available on this Topic

• Connected and Automated Vehicles: NCHRP Support for Transportation Agency Leaders

• TRB's Transportation Research E-Circular 222: Automated Vehicles Symposium 2016

You can learn more about this publication by visiting www.trb.org

Join us for a TRB Workshop

57th Annual Workshop on Transportation Law

July 15-18, 2018 in Cambridge, MA

Learn more at:

http://www.trb.org/Calendar/Blurbs/176648.aspx

Today’s Speakers • Douglas Gettman - Kimley – Horn -Tree-top summary of key challenges and opportunities • J. Sam Lott – Texas Southern University -Deeper dive in Safety, Workforce, and Regulatory issues • Douglas Gettman - Research, Development, and

Policy roadmap • Moderator - Jerome M. Lutin, NJ TRANSIT

(Retired)

NCHRP 20-102 (02) Laws, regulations, and the future of AV transit Douglas Gettman, Ph.D.

REGULATIONS

TECHNOLOGY READINESS

SAFETY

OPERATING POLICIES

WORKFORCE

LAWS

2030

ACTIVITIES ROADMAP

PROJECT TASKS

11/14/2017 8

HIGH

LOW

LOW HIGH

APM GRT

PRT AV-BRT ATN

AV-TAXI

$

RISK

COST

11/14/2017 9

“unconstrained” by Laws & Regulations

Challenges abound….

“Prediction is hard, especially about the future.”

Transit driver of the future

Safety plans + safety standards

Demos Revenue Service == Safety Assurance Procedures & Mitigations

Section 13c: Collective Bargaining

Major Opportunities: • First-mile, last mile • Environmental Justice

REGULATIONS

TECHNOLOGY READINESS

SAFETY

OPERATING POLICIES

WORKFORCE

LAWS

2030

ACTIVITIES ROADMAP

PROJECT TASKS

Activity Budget Schedule (months) Timeframe

Assessment of restrictions on transit platooning strategies

$150K 9 2018-2020

Research identifying possible changes to transit facilities and stations

$1M 18 2020-2022

Research on transit vehicle sizing, dynamic “entrainment”, and other innovations enabled by automation

$1M 24 2022-2025

Research on design of platform edge protection and automated entry for vehicle berths

$5M+ 24 2020-2022

Technology


Categories of hazards and risks for L3 and L4 AV transit $250K 12 2018-2019

Hazards analysis methodology for L3 and L4 AV transit implementation

$500K 18 2018-2019

New consensus safety standard(s) for AV transit systems

$1.5M 24 2021-2023

Transit operational design domain definitions $150K 9 2018-2020

Hazards assessment and mitigations for L3 operations $350K 15 2020-2023

Safety Management System development Guidance $350K 18 2019-2021

Automation of employee actions in compliance with ADA

$250K 15 2019-2020

Workforce

Safety


Union Contracting Guidelines $500K 18 2021-2023

Employee involvement Guidelines $200K 12 2021-2023

Definition of AV transit employee roles and responsibilities

$350K 18 2020-2022

Long range planning AV transit benefit/cost analysis guidelines

$1M 24 2020-2022

Integration of AV transit scenarios in regional transit master planning

$750K 24 2019

Benefit/cost analysis of conversion from L3 to L4 operations

$250K 12 2021-2022

Scenario analysis of AV transit operations without federal funding

$150K 12 2019-2020

Workforce & Planning


Possible changes to Section 13c of Federal Transit Act $350K 12 2018

Evaluation of Applicability of transit-related laws and regulations to private contractors (e.g. “TNCs”)

$150K 12 2020-2021

Evaluation of OSHA regulations for robotic vehicles in the workplace

$150K 12 2020-2021

Evaluation of Minority population involvement and environmental justice in AV transit

$150K 12 2020-2021

Evaluation of Title VI adjustments and incentives $150K 12 2020-2021

Evaluation of boarding requirements and exceptions to ADA compliance

$500K 18 2019-2020

Evaluation of Buy America requirements $150K 12 2021-2023

Evaluation of Implications of FMVSS for low-speed L4 AV transit vehicles

$150K 12 2019-2021

Risk, liability, and insurance for AV transit operations $150K 12 2018-2019

Policy & Regulations


AV transit service types and operational planning parameters $1M 24 2019-2021

AV Cybersecurity issues affecting transit agencies $750K 18 2019-2020

Management of “big data” in AV transit systems $350K 18 2019-2020

AV Operations Control Center Concept of Operations $350K 18 2020-2021

Operations

Collin Castle, Michigan DOT Adriano Alessandrini, University of Florence

Ken Chambers, Nevada DOT Charles Carr, Flanigan

Mark Johnson, Lane County Transit District Prakash Sah, Caltrans

Barry Einsig, Cisco Jerome Lutin, (ret) New Jersey Transit

Max Azizi, FHWA Brian Sherlock, Amalgamated Transit Union

Tim Witten, Blacksburg Transit

Lauren Cochran, Houston METRO (Proterra) Wil Buller, AC Transit

Dee Pereira, CATS Robert Lohmann, 2getthere

Marla Westervelt, LA METRO Charlie Howard, Puget Sound RCG

Gary Rouseau, Atlanta COG Art Guzetti, APTA

Dave Hudson, CCTA Bill Churchill, CCTA

Joe Calabrese, GRCTA Pete Gould, Shared Mobility Strategies

Usa Darnall, JTA James Garner, Pace

Vince Valdes, FTA Steve Mortensen, FTA

Lou Sanders, APTA Peter Thompson, SANDAG

Jerry Spears, formerly WSTIC Jane Schroter, CapMETRO

Gary Miskell, VTA Rashidi Barnes, CCTA

Casey Emoto, VTA Marlene Connor, MCA

Brad Thoburn, JTA Art Carter, NHTSA

Michel Parent, AutoKAB Stan Young, NREL Andy Mao, TxDOT

Brenda Bustillos, TxDOT Siva Narla, ITE

Steve Gota, LA METRO Terence Fontaine, Houston METRO

Marzia Zafar, CPUC Ed Coven, FDOT

Acknowledgments

TRB Webinar – Nov. 16, 2017

JSafety, Workforce and Regulatory Issues

1

J. Sam Lott, Principal Investigator Texas Southern University Center for Transportation Training and Research

AV Transit Baseline Selected Findings on Automated Driving Systems and Readiness Timeline

2

Source: 2GetThere, www.2getthere.eu

AV Transit Baseline Technology NHTSA (USDOT) Policy Guidelines and SAE (Vehicle Manufacturers) Standards Referenced in Study

Announcements and Updates to Key AV Technology Policy and Standards Documents • Sept. 16, 2016 Federal Automated Vehicles Policy –

USDOT/NHTSA Policy Guidance document released

• Sept. 30, 2016 Update to SAE J3016 – Taxonomy and Definitions for Terms Related to Driving Automation Systems for On-Road Motor Vehicles

May 2017 – NCHRP 20-102(02) Documentation Completed

• September 12, 2017 Automated Driving Sytsems 2.0 – A Vision for Safety – Updated USDOT/NHTSA Guidelines

NHTSA has adopted terminology from SAE J3016 –Automated Driving Systems (ADS) for higher levels of automation

AV Transit Technology Baseline

NHTSA has adopted terminology from SAE J3016 –Automated Driving Systems (ADS) for higher levels of automation L3– (Conditional Automation*) Automated System conducts some parts of driving task and monitors driving environment in some instances, but Human Driver must be ready to take control * New NHTSA Designation


NHTSA has adopted terminology from SAE J3016 –Automated Driving Systems (ADS) for higher levels of automation L3– (Conditional Automation*) Automated System conducts some parts of driving task and monitors driving environment in some instances, but Human Driver must be ready to take control

L4 – (High Automation*) Automated System conducts driving tasks and monitors driving environment, but only in certain environments and under certain conditions * New NHTSA Designation


NHTSA has adopted terminology from SAE J3016 –Automated Driving Systems (ADS) for higher levels of automation L3– (Conditional Automation*) Automated System conducts some parts of driving task and monitors driving environment in some instances, but Human Driver must be ready to take control L4 – (High Automation*) Automated System conducts driving tasks and monitors driving environment, but only in certain environments and under certain conditions

L5 – (Full Automation*) Automated System conducts all driving tasks and monitors all driving environments * New NHTSA Designation



Timelines Expected for AV Technology readiness for general transit applications

Near-Term (5-10 Years) – L3 BRT Transitways and HOV lanes, L4 operations in campus environments

Medium-Term (10-15 Years) – L4 operations in BRT/HOV and low speed in mixed traffic on city streets

Long-Term (15-20+ Years) – L4 and L5 operations in all environments, and with fully automated transit systems

Over the next few decades the Transit Workforce will be redeployed to new roles, gradually reducing the size and cost of the required AV Transit Workforce.

8

AV Transit Technology Baseline Definition of Fully Automated AV Transit

• Automated Driving System(s) per SAE J3016 PLUS ADDITIONAL SUBSYSTEMS • Other vehicle systems, facilities and components:

Operational Safety Systems – e.g., Automated Emergency Braking

Vehicle location and path guidance systems Vehicle/station berth interfaces, safety protection

systems, and precision docking systems Other monitoring, supervisory control and passenger

safety systems and facilities appropriate for public transit

9

Safety Considerations Selected Findings on Methodology and Standards

10

Source: CitiMobil2 Source: Wikimedia

Findings – Safety Standards and Precedents Transit Industry vs. Automotive Industry Approaches

• Safety Analysis methodologies follow different paths, and the initiatives from NHTSA and FTA tend to align with their industry group

• NHTSA/SAE will focus on DRIVING TASK automation safety – Vehicle Focused

• FTA will focus on the whole transit system operational safety – System Focused

11





12

Findings – NHTSA/SAE Vehicle Focused Safety Result of NHTSA/SAE vehicle-focused methodology using international machine-automation safety certification methodology is:

• Product oriented safety analysis per ISO 62626

• Safety is defined in terms of an absence of unreasonable risk

• Safety analysis addresses hazards due to operating conditions of manufactured products (components, assemblies and control systems)

• “Failure” is defined as a control system’s unintended behavior with respect to its “design intent”

13





14

Findings – Transit Industry System-Focused Safety

FTA and Transit Industry have a long history in safety analysis and hazard mitigation processes • MIL Std 882 – System-level approach through a

System Safety Plan has proven very applicable to complex transit systems

• Classification of safety in terms of protection from human fatalities or injuries, with probabilities calculated to prevent such occurrences

• Site-specific deployment conditions of each project is an integral part of the hazard analysis/resolution

15


FTA is advancing its transit system safety program as applicable to any type of transit system, and required for rail/fixed guideway transit built with FTA funding • Public Transportation Safety Program – final

rulemaking 49 CFR Part 670 (effective Sept. 2016) • Safety Management System – formal approach to

managing safety risk and risk mitigation, including organizational decision making, and safety/operational processes, activities and tools

16


17

CONCLUSIONS on the Recommended Approach to AV Transit Safety Program

A Blended Approach is Necessary for AV Transit Safety • Vehicle subsystem must be manufactured and procured with

the safety certification of DDT and ODD that are specified for the specific transit application.

18



the safety certification for DDT and ODD that are specified for the specific transit application.

• Other vehicle functions necessary for completely automated transit service must be included in the manufacturers safety certification process.

19



the safety certification for DDT and ODD that are specified for the specific transit application.

• Other vehicle functions necessary for completely automated transit service must be included in the manufacturers safety certification process.

• Operating agency must initiate, conduct and maintain a Safety Assurance process in accord with FTA SMS criteria, wrapping around the vehicle safety certification and completing the system safety program that encompasses all subsystem elements for each specific application.

20

IEC Automated Urban Guided Transport Safety Requirements – IEC 62267

Development Started 1992

Development Started 2001

Findings – Benefits of Transit Industry Consensus Standards fo AV Transit

ASCE Automated People Mover Standards – ASCE 21

10

Example Benefit: Defining safety beyond “driving” functions

22

UTO – Unmanned Train Operations

Source: IEC 62267, Levels Of Train Automation

Non-Driving Functions

Comprehensive Safety Assurance Program for Fully Automated AV Transit Deployment

Safety Analysis Model Adapted from Automated Fixed Guideway Transit Standards 1. Vehicle ADS safety certification for product liability 2. Vehicle deployment enhanced for ADA provisions 3. Vehicle deployment and safety certification to

include all AV vehicle functions per APM/ATS systems for a complete transit operational design domain (ODD expanded to include transit functions)

4. Vehicle / OCC communications and associated command & control for remote operations

23

Comprehensive Safety Assurance Program for Fully Automated AV Transit Deployment

Safety Analysis Model Adapted from Automated Fixed Guideway Transit Standards 5. Station design and vehicle/berth operation

suitable for safe ADA compliant boarding and platform edge protection

6. Transitway/roadway deployment appropriate for a given project’s mix of roadway vehicle and ped modes

7. Maintenance, storage and operations facility(ies) deployed for a complete transit-grade AV System

24

ADA Safety Regulations Selected Findings on FTA Regulations and Implications for AV Transit Applications

25

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Americans with Disabilities Act Existing Laws and Regulations – General • ADA law and regulatory implications for public transit are

monitored and assessed by the FTA Civil Rights Office. o3” Maximum gap between platform edge and vehicle oMinimum clear 48”x 30” for wheelchair parking in vehicles o Interior vehicle handrails and stanchions required

• Priority Seating – Signs and Designated Seating Locations • Audio Announcements and Instructions for the Hearing and

Visually Impaired. • Wheelchair Securement – at least 1 wheelchair securement

locations for vehicles less than 22 feet in length, and 2 locations for longer vehicles.

26

Americans with Disabilities Act Existing Laws and Regulations (cont.) Subpart D – Light Rail Vehicles (38.83) • Lifts, ramps or bridge plates mounted on the station platform

are allowed • Maximum slope of ramps for height difference of:

o Less than 3 inches total rise is 1:8 slope – 8 inches of “run” for each 1 inch of “rise”; a 3 inch rise needs a ramp with a 2 foot length

oGreater than 9 inches total rise is 1:12 slope – 12 inches of “run” for each 1 inch of “rise”; a 9 inch rise needs a ramp with a 9 foot length

27

Americans with Disabilities Act Existing Laws and Regulations (cont.) Subpart H – Automated Guideway Transit (38.173) • Low speed “people movers” (maximum operating speed no

greater than 20 mph) • Horizontal gap no greater than 1 in. for an ADA accessible

station platform and a maximum height difference of 1/2 in.

Non-FTA Reference Requirements for Fully Automated Transit ASCE-21 Automated People Mover Standard has a more strict requirement for systems with speed greater than 20 mph : • Maximum horizontal gap no greater than 2 in. between vehicle/

station platform and a height difference less than 5/8 in.

28

Critical Safety Design Issue for AV Transit Systems is Passenger Boarding Area

29

2009 Source: Caltrans PATH

Source: 2getthere Source: 2GetThere, www.2getthere.eu

Precision docking and level-platform boarding at vehicle floor height have been demonstrated for AV transit deployments

Practical Safety for Persons with Disabilities Has a Focal Point Where the Passengers Enter and Exit the Vehicle • Americans with Disabilities Act (ADA) requirements

for transit are focused on safe accessibility by sight, hearing and mobility impaired passengers

• Transit boarding area interface with transit vehicles will be critically important for fully automated transit systems

30

• Protection from entrapment in vehicle doors is essential for all passengers

AV Design/Regulatory Research Need – Local Paratransit Service or Service in Rural Areas 1. How will station boarding be safely managed if no

human operators are present?

2. Will Laws allow operations control center (OCC) monitored boarding and alighting of disabled passengers to ensure safe passenger transfers?

3. Should regulations allow “drone-mode” operations by Remote Operators for AV transit vehicles to operate wheelchair lifts, ensure wheelchairs are secure, and supervise passenger boarding process?

31

Operating Agency Impacts Selected Findings on Policy Considerations

32

Source: Navya

AV Transit Policy Considerations Span All Aspects of a Local Agency’s Existance

For a number of years into the future unmanned L4 Transit Vehicles will be operable primarily in mixed traffic at limited speeds on selected roads within limited geographic areas like Urban Districts.

33

Source: EasyMile

Policy Implications of ADS L4 Deployment and Full Automation

• “Geo-fenced” boundaries will constrain L4 AV Transit will have beyond which Vehicle Operators must take control

• Added complexity and risks with AV technology balanced with the benefits of safety and staff redeployment

• Cyber security and big data management will become part of transit operations

34

• Sophisticated operations control center will create new dimensions to the local transit operator’s policy framework

Source: Mercedes

Policy Implications of ADS L4 Deployment and Full Automation

Reverting to a Fallback Minimum Risk Condition will usually require the vehicle to leave the active traffic lane

a. How will fallback stopping locations be provided along the length of the lanes throughout the ODD service area?

b. What will be the impact of no fallback stopping locations are available in some areas and the vehicle stops in the active lane?

c. How will passengers be retrieved from a failed vehicle?

Answers to these questions will drive Workforce Deployment and Safety Policy

35

Impacts on Workforce Deployment Roles and Responsibilities of Primary Driving Actors: • Driving automation system – L1, L2 and ADS L3, L4 and L5 • Human driver/operator Types of Human Drivers/Operators (per SAE J3016) • DDT Fallback Ready User – Person who is alert, monitoring

operations and “receptive” to take control of driving (L3 and L4 when exiting Operational Design Domain)

• Remote Driver – Human Driver/Operator who is remote from the vehicle – and who takes control of the driving

• Dispatcher – Person who is monitoring the vehicle’s operational readiness and engaging/disengaging the ADS

36

Impacts on Workforce Deployment • Operation of AV transit systems must have

continual monitoring by personnel located in an Operations Control Center (OCC) – “Dispatchers” per SAE J3016

• Assistance to passengers provided by operations personnel through video and audio communications devices onboard and on the station platforms

• Transition of some vehicle operators to support maintenance of a larger fleet of smaller electric vehicles is expected in the Medium to Long Term.

37

Impacts on Workforce Deployment • Roving operations personnel will be staged

throughout the operational service area to provide rapid response to vehicle/system failures and passenger incidents.

• Remote operation of AV transit vehicles by dedicated operations personnel will be possible from either an operations or a maintenance base – “Remote Drivers” per SAE J3016

• Gradual transitions to new roles changing mix between operations and maintenance with gradual attrition will allow the workforce to be scaled back

38

Impacts on System Safety Program • Local Transit Operating Agencies must establish rigorous

Safety Assurance Program with dedicated Safety Engineering personnel

• Authorization of personnel to exercise safety responsibilities across departments within the organization

• Commitment of resources to implement/sustain the SMS • Addressing the liabilities as more complex operations begin • Monitoring of governmental regulations as AV technology

and laws evolve over the next few decades

39

Detailed Working Papers Address Impacts from AV Transit Operations See NCHRP 20-102(02) Project Website • WP #1 Automated Vehicle Technology Deployment

Scenarios for Public Transit • WP #2 Safety Assurance Considerations – Blending Transit

and Automotive Safety Analysis Methodologies • WP #3 Workforce Deployment – Changes and Provisions of

Future Policy and Contracts • WP #4 Operating Agency Policy – Potential Issues and

Changes Required • WP #5 Government Laws and Regulations – Issues and

Changes to be Considered • WP #6 Timelines for Industry and Government Preparation

In Advance of AV Transit Implementation 40

Source: Daimler

Today’s Participants

• Jerry Lutin, New Jersey Transit (Retired), [email protected]

• Douglas Gettman, Kimley-Horn, [email protected]

• J. Sam Lott, Texas Southern University, [email protected]

mailto:[email protected]



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Regulations and Policies Impacting AV/CV Introduction...

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