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Associazione Italiana Società Concessionarie Autostrade e Trafori

AISCAT

L’AISCAT, costituita nel 1966, è l’Associazione Italiana delle Società Concessionarie di Autostrade e Trafori, alla quale aderiscono, come associate effettive, le società, enti o consorzi titolari di una concessione per la costruzione e/o l’esercizio di autostrade o trafori autostradali a pedaggio in Italia; attualmente, le Associate effettive sono 17 e la loro competenza si estende per circa 5.800 km di rete a pedaggio.

Lobbying Activity

Response to Specifications for the provision of cooperative intelligent transport systems (C-ITS)

8 Feb 2019

AISCAT is the Italian Association of Tolled Highways' Concessionaires and it is duly registered at the EU transparency register. AISCAT members have always been fully involved in ITS deployment and in technological innovation aimed at increasing levels of service and safety to motorway users; in the same way, we strongly believe in the future evolution of these systems, with particular attention to deploy cooperative ITS (C-ITS). In this respect based on the European ITS-G5 standard to improve road safety and traffic efficiency. Although acknowledging the work carried out by the Commission, that accelerates the process for the development of C-ITS, however AISCAT wishes to highlight some aspects that – in our opinion – are not taken into due consideration within this Delegated Act. First of all, it is important to remember the role and responsibilities of motorway operators in the daily management of mobility and in guaranteeing the safest conditions to road users. Role and responsibilities that will have to be appropriately extended and shared - each for its part - with all those subjects that enter the chain of cooperative systems and connected mobility (e.g. telecom and automotive manufacturers and operators, software and hardware producers, service providers, etc.). This is not clear in the Delegated Act (as well as the privacy obligations). Moreover, it seems that the supposed neutral approach has not been respected as far as concerns the technology for V2V and V2I communication. There is a clear bias for G5, which is currently the most mature technology for sure, postponing the introduction of other technologies to a 3-years next review of the document. We see this choice as a significant risk that could affect full developments of services or their duplication or overlap, already starting from the equipment of vehicles. In this respect, interoperability and coverage of all systems seem to be left to the road operators, with all the obvious consequences in terms of investments and responsibilities that are not certain, but which will be continuously variable according to every next scenario. In our opinion, considering the speed of technological developments and the constantly changing situation, it would have been more appropriate to provide already a hybrid approach and a clear address to all the subjects that will enter the market with their products, regarding investments and duties. Finally, while appreciating the reference to the lack of interference with the toll systems, we would like to recall with greater force the principle of safeguarding frequencies (which is already clearly expressed in other directives – e.g. the new EETS Directive). In this respect we think that the statement requiring the lack of interferences with tolling (Chapter II, art 5, comma 5) should be strengthen with mandatory requiring for LTE (or any other future technology). For instance, they should be obliged to follow the same steps already done by G5 (e.g. analyses on interferences with CEN and ETSI tolling standards, development of mitigation techniques and eventual standardization, etc.). These analyses shall also be carried in order to assess the risk of interferences between G5 and LTE.
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