eCall in-vehicle system – Ford of Europe comments (in line with ACEA)
Key priorities: date of application, technology neutrality, open platform, Galileo. Comments and suggestions: Date of application (Recital 16, Articles 7 and 12): Once the delegated/implementing acts specifying the technical requirements and precise test procedures will be published, the industry will need sufficient lead-time for development and testing purposes. The standard lead-time requested by the industry to develop and test safety systems is 36 months that allows i.e. timely defining of component-/system-/vehicle-level requirements, sourcing uppliers, designing/building prototypes, verifying/certifying/homologating vehicles, resolving design issues, pre-production building, testing (including crash-tests) and manufacturing. Moreover, for eCall to function, the infrastructure to receive and handle the calls must be in place at least 6 months before the deployment of eCall in-vehicle system. A staggered approach with infrastructure being updated at different dates in Member States is not a feasible scenario for the auto industry: 112-based eCall in-vehicle systems should become mandatory to type-approve new types of vehicles after all EU Member States have the necessary PSAP infrastructure operational. In order to guaranty the functionality over the lifetime of the vehicles in the field, the infrastructure, including mobile networks, PSAPs, GNSS systems, must be available for at least this period of time. Suggested language taking into account the needs of industry and the realistic timeframe resulting from the delay of the legislative process: Art. 7: With effect from 1 October 2015 [36 months after the entry into force], national authorities hall only grant EC type-approval in respect of the 112-based eCall in-vehicle system to new types of vehicles and to new types of 112-based eCall systems, components and separate technical units designed and constructed for such vehicles, which comply with this Regulation and the delegated acts adopted pursuant to this Regulation. Art. 12: It shall apply from 1 October 2015 [36 months after the date of entry into force]. Technology neutrality (Art. 3.2.d; Art. 4; Art. 5.4): Technology neutrality should be an overarching principle of any automotive legislation as recommended in the CARS 21 Final Report. The legislation should enable the OEMs to innovate and develop new cost effective solutions as long as they are compliant with all the performance and technical specifications, which will be specified in delegated/implementing acts. Favouring one olution (such as an embedded system) might distort competition by ruling out other viable solutions from the market, limit innovation and lead to usage of outdated technologies. Suggested language respecting the principle of technology neutrality: Art. 3.2d: (EP’s paragraph 2d is unnecessary as it is covered by Council’s paragraph 2a): ‘in-vehicle equipment’ means equipment within the vehicle that provides or has access to the in-vehicle data required to perform the eCall transaction via a public mobile wireless communications network; Art. 4: Manufacturers shall demonstrate that all new types of vehicles referred to in Article 2 are equipped with an 112-based eCall in-vehicle system, in accordance with this Regulation and the delegated acts adopted pursuant to this Regulation. Art. 5.4: Only those 112-based eCall in-vehicle systems which can be tested shall be accepted for the purposes of EC type-approval. Open platform (Rec. 9; Art. 10a.3): eCall is a safety system only, which does not require an open platform to function. Therefore, the industry cannot accept that the 112-based eCall in-vehicle system should be based on open platform. In particular, the concept of an open platform also raises a number of issues, such as liability, vehicle integrity, data protection etc. which should be clarified in advance. The standards and technical requirements of possible future open platform legislation would change the 112-based eCall system technically and could require the complete revision of the eCall
Regulation. 112-based eCall should remain focused on safety and separated from a possible future open telematics platform. Therefore, a possible open telematics platform should be discussed eparately, as foreseen in the EC ITS Action Plan. Suggested language on open platform: Rec. 9: In order to ensure open choice for customers and fair competition, as well as encourage innovation and boost the competitiveness of the Union’s information technology industry on the global market, the eCall in-vehicle system should be accessible free of charge and without discrimination to all independent operators and based on an interoperable and open-access platform for possible future in-vehicle applications or services. Art. 10a.3: delete paragraph. Galileo (Rec. 6; Art. 5.3) Any satellite constellation must be certified before it can be used for all terrestrial applications. It is a ine qua non condition. The certification of a constellation implies checking the diffusion of a valid ignal (date validity and signal health status) as indicated in ‘European GNSS (Galileo) Open Service - Signal in Space Interface Control Document’ (p.53)1. If the constellation is not certified (it is not today) and therefore the validity of the signal is not verified, Galileo cannot be used to calculate the position of the vehicle sending an eCall as it could induce an erroneous positioning of the crashed vehicle! Demanding compatibility with Galileo/EGNOS systems does not take into account the need to validate the behaviour of the system (including receivers) in all situations (requiring a complex validating plan in an industrial context). The fact that Galileo partly functions does not mean it can be declared available and reliable for commercial applications, and the fact that specifications are available does not mean the real system will behave as foreseen by the specification. Suggested wording taking into account that compatibility should only be required for operational and validated systems: Rec. 6: The provision of accurate and reliable positioning information in emergencies is an essential element of the effective operation of the 112-based eCall in-vehicle system. Therefore, it is appropriate to require its compatibility with the services provided by satellite navigation programmes, in particular the operational and validated systems established under the Galileo and EGNOS programmes as set out in Regulation (EC) No 683/2008 of the European Parliament and of the Council8. ________________
Regulation (EC) No 683/2008 of the European Parliament and of the Council of 9 July 2008 on
the further implementation of the European satellite navigation programmes (EGNOS and Galileo) (OJ L 196, 24.7.2008, p.1.) Art. 5.3: Manufacturers shall ensure that the receivers in the 112-based eCall in-vehicle systems are compatible with the operational and validated positioning services in particular provided by satellite navigation systems including the Galileo and the EGNOS systems. Manufacturers may also choose, in addition, compatibility with other satellite navigation systems.