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Project 3 Mobility d.o.o.

P3

Fully funded startup in stealth mode building the future of urban autonomous mobility with the ultimate goal: to provide customers with a premium experience of riding, and to give them the opportunity to get back the time spent in traffic.

Lobbying Activity

Response to Creation of the Common European Mobility Data Space

7 Dec 2022

Project 3 Mobility (P3), a Croatian company dedicated to developing a new urban Mobility-as-a-Service (MaaS) ecosystem based on fully autonomous electric vehicles, welcomes the opportunity to provide feedback on the creation of a common European Mobility Data Space; please find our feedback attached below.
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Response to Technical requirements for unlimited series, small series, special purpose vehicles and fully automated vehicles

13 Apr 2022

Project 3 Mobility would like to provide feedback on the documents of the Delegated Regulation: "Amending Annexes I, II, IV and V to Regulation (EU) 2018/858 of the European Parliament and of the Council as regards the technical requirements for vehicles produced in unlimited series, vehicles produced in small series, fully automated vehicles produced in small series and special purpose vehicles, and as regards software update". Project 3 Mobility fully supports and thanks the Commission for its work on enabling the approval of fully automated vehicles. Project 3 Mobility would like to raise a concern regarding glazing, and in particular the windscreen of a fully automated passenger vehicle. Item B10 of Table 2 of the proposal covers Safety Glazing and offers an "Exemption only for windscreen (no R-point available in relation to the windscreen)". According to the current definitions within UN ECE R43 (Safety Glazing), it is possible to interpret that the forward-facing glazing of a fully automated passenger vehicle is not a windscreen but is defined as "exterior forward-facing glazing". The definition for a windscreen from UN ECE R43 is as follows: "'Windscreen' means the glazing in front of the driver through which the driver views the road ahead." In a fully automated passenger vehicle, there is no glazing that performs this function, therefore the following definition can be applied: "'Exterior forward-facing glazing' means any glazing other than a windscreen installed in the front of the vehicle body, representing a part of the vehicle exterior." The concern that Project 3 Mobility have with this understanding is that exterior forward-facing glazing does not need to be laminated, it can just consist of a piece of toughened glazing. Traditionally, the only place where exterior forward-facing glazing has existed is on the upper deck of a double-deck bus. In this location, there is less chance of a debris strike or damage caused by a collision with another vehicle that could lead to a breakage of the glazing, therefore toughened glass has deemed to have been sufficient. Project 3 Mobility do not believe that toughened glazing offers a suitable level of safety in a fully automated passenger car through which the occupants view the road ahead. Project 3 Mobility would therefore like the Commission to specify under B10 of Table 2 of the proposal that any exterior forward-facing glazing to be installed in a fully automated vehicle through which the occupants can view the road ahead shall be laminated. Thank you for your consideration and continued work.
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Meeting with Toma Šutić (Cabinet of Vice-President Dubravka Šuica)

31 Mar 2022 · Meeting to share with us updates on their project and present their plans for expansion within the EU and other countries. Presented by Mr Goran Dautović, Director of Public Policy