Lobbying by The International Motor Vehicle Inspection Committee

CITA welcomes the draft Implementing Act on ADS. CITA supports the provision that vehicles with ADS perform better than competent and carefully driven manual vehicles (cp. chapter 7 in Annex 2). However, it is not reasonable that the defined acceptance criteria by the manufacturer should be based on merged accident data derived from the overall traffic with buses, coaches, trucks and passenger cars. This leads to a deterioration of road safety. Instead, the safety performance threshold should be based on current accident data of the operational area (e.g. shuttle busses in a defined area). CITA welcomes that monitoring of the vehicles with ADS is included in the present draft. It is consensus that field monitoring, as part of a multi-pillar approach, is essential to ensure that vehicles with ADS do not pose a threat to health, safety, the environment or other public interest concerns (which will be a key factor for their acceptance by European consumers). Hence, it is not sufficient that only manufacturers carry out in-service monitoring themselves. Member States should be given the possibility to perform an independent investigation in the context of market and field surveillance and research. Furthermore, the upcoming regulation must address that manufacturers ensure that the operator is able to provide the type-approval authorities or bodies designated by the Member States with vehicle data that go beyond the few data elements of the ADS recorder (cp. chapter 9.5.1 in Annex 2), to identify safety-relevant incidents if requested by national law. Proposed wording to supplement chapter 5 in Annex 3, Part 2, as well as a more detailed justification, can be found in the publicly available documents submitted and presented by CITA at the 11th "MVWG SG ACV" meeting on January 21, 2022.

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Response to Technical requirements and test procedure for approval of Event Data Recorders (EDR)

5 Nov 2021

Whereas approval requirements focus on the features of new vehicles, they also must consider that the performances shall be kept reasonable for the entire vehicles’ life and thus facilitate both vehicle periodical inspection’ and roadside inspection. As a reminder, periodical and roadside inspection are Member States sovereign activities. Our proposal requests access to the system. It takes advantage of the scan-tool defined in Directive 2014/45/EU (Annex III, Section I, point 14) to use the OBD Connector described in the Regulation (EU) 2018/858 (Annex X, point 2.9) to ensure the checking of EDR during vehicle inspection in an impartial manner. The precise proposal is included in the attached file. To be additionally considered: • Vehicle users might not consider EDR an essential system. Therefore, even if the vehicle triggers any malfunction signal, the willingness to repair is expected to be limited. • This proposal considers an already defined connector and scan tool. Therefore, there is no need for further developments on hardware. • The proposal is consistent with the approach of other systems included in the General Safety Regulation.

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Meeting with Thierry Breton (Commissioner) and

27 Oct 2021 · Data

Response to Revision of the Roadworthiness Package

11 Oct 2021

Please, see the document attached.

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Meeting with Elzbieta Lukaniuk (Cabinet of Commissioner Adina Vălean)

19 Mar 2021 · Meeting to make a presentation of CETA to the Cabinet members.