内能环境 //www.ludikid.com/category/transportation-policy/ 能源、商品和环境法律和政策开发 Frii2023125538+00 en-US 时钟 一号 https://wordpress.org/?v=6.1.1&lxb_maple_bar_source=lxb_maple_bar_source https://insideenvironmentredesign.covingtonburlingblogs.com/wp-content/uploads/sites/47/2021/06/cropped-cropped-cropped-favicon-3-32x32.png 内能环境 //www.ludikid.com/category/transportation-policy/ 32码 32码 拜顿行政发布综合交通去碳化计划 //www.ludikid.com/2023/02/biden-administration-releases-comprehensive-transportation-decarbonization-plan/ 加里S古兹和约翰米泽拉克 Thu,022023 16:56:32+00 拜顿行政 交通策略 生物燃料 双党基础设施法 脱碳化 电动车辆 氢气 减通货膨胀法 转口 //www.ludikid.com/?p=8434 p对齐表示“中心点”++/p>四大联邦机构-环境保护局、交通局、能源局和住房和城市开发局-发布交通去碳化蓝本-雄心勃勃计划概述联邦政府将继续使用的原则实现2050年前全经济净零排放....Continue Reading… sites/defaility/files/2023-01/the-us-National-blueprint-traction-decolation.pdfThis "whole of government" mobilization will profoundly affect many investment decisions, collaborations, regulatory actions and policy disputes with material impacts across many business sectors.

Fostering improved, clean transportation has the potential to benefit the country enormously, and advances key goals of the Biden Administration.  The transportation sector is the largest source of greenhouse gas emissions in the United States, accounting for one-third of all emissions, and must be addressed for there to be any hope of meeting climate goals.  Transportation also affects every American's day-to-day life, from how they participate in their communities to how they pursue economic opportunity and empowerment, representing a significant opportunity to promote equitable growth.

The Blueprint is the Administration's most fleshed out vision for pursuing these goals.  The Blueprint outlines a comprehensive approach, addressing changes to every mode of transportation, and proposing to do so through virtually every policy lever available—a true "whole of government" approach.  It is consistent with, and further advances, key themes in the President's climate policy enunciated from day one, and further reflected in his signature legislative accomplishments, the Bipartisan Infrastructure Law (BIL) and the Inflation Reduction Act (IRA). 

The Blueprint was a highlight of government speakers at the recent Government/Industry Conference for the auto industry, sponsored by the Society of Automotive Engineers:  In a keynote, Gabe Klein, Executive Director of the newly formed DOE-DOT Joint Office of Energy & Transportation, called it the "most important policy document in a decade."

Below are some of the key features:

  • Multiple technological solutions will be needed, reflecting an evolving decarbonization path for several sectors.  To many, the electric passenger car is the symbol of transportation decarbonization.  But power demands and weight considerations, among other issues, may make it more difficult to use this technology in other sectors, including on-highway freight, maritime, and aviation.  The Blueprint recognizes that additional technology must be deployed, including those not yet fully commercialized.  It focuses on three:  battery electric, hydrogen fuel cell, and sustainable biofuel.
SourceDecarbonization Plan at 50

The continued prominence of liquid fuels in a transportation decarbonization plan is especially notable.  There remains active debate, even within the agencies which authored the Blueprint as to whether the types of "sustainable" fuels being promoted have the full range of climate benefits they claim. 

  • But new technology is not the only tool.  In addition to developing and deploying clean technology, the Blueprint will promote measures to decrease transportation demand and increase transportation efficiency.  The Blueprint seeks to redesign the communities in which we live, so that people are physically closer to where they work, learn, and recreate.  Consistent with the Biden Administration's "whole of government" approach, this will involve policymakers outside of the four agencies who authored the report, including non-federal entities like towns, cities, and counties with jurisdiction over zoning laws that shape land use.  The Blueprint also stresses policies to encourage the most climate-friendly mode of transportation when movement is necessary:  For movement of people, this will likely result in renewed focus on mass transit and emission-free micromobility options. 
  • A three stage timeline with interim targets.  Broadly speaking, between now and 2030, the Blueprint focuses most on research and investments to support deployment.In the 2030s, the focus is on scaling up clean transportation solutions, and the 2040s will be about completing the transition to a net zero transportation sector.  But there are plenty of interim benchmarks in between, such as a commitment that all new light-duty acquisitions for the federal fleet be zero emission by 2027, and 30% of private sales of medium and heavy duty vehicles be zero emission by 2030.
  • Continued focus on equity.  Ensuring a just transition of the transportation sector is a cornerstone of the Blueprint.  Among other concerns, this will mean a focus on ensuring that zero emissions technology successfully penetrates all communities.  This could mean creating enhanced subsidies for acquiring electric vehicles, ensuring charging stations are meaningfully available in historically overburdened neighborhoods, and ensuring that transit service is fully accessible for the differently abled. 
  • Interaction with advanced driver assistance technology (ADAS).  The Blueprint acknowledges that transportation will "dramatically change" in "ways that are hard to forecast," focusing in particular on another transformational shift occurring in the transportation sector:  the emergence of automation and connectivity, up to full vehicle automation.  Although such technology is often discussed for its appealing safety benefits, it may also reduce congestion and result in significant environmental gains as well.
  • The continued role of agency-promulgated regulatory standards.  The Blueprint is clear that agency-promulgated, technology-forcing regulation has an important role to play in decarbonizing transport, even if the BIL and IRA focused mainly on incentive-based mechanisms.  The Blueprint specifically mentions renewable fuel standards, and emissions standards for heavy duty on-highway, off road, and fuel pipeline transportation.  More are likely in store, although the Biden Administration will have to tread carefully in light of recent Supreme Court precedent narrowly interpreting the agency enabling statutes that will serve as the authority for these rules.

Whether the Blueprint's lofty ambitions will be met remains to be seen, but the document is an important outline of the federal agenda to come, at least for the remainder of Biden's presidency.  The transportation sector is in the process of fundamental change, set to dramatically reduce where feasible uses of the internal combustion engine—the technology that served as its bedrock for over 100 years.  This process will create exciting opportunities and difficult choices, and the Blueprint provides important insight into federal priorities that should be thoroughly understood when engaging policymakers going forward and when making investment decisions.

IRS发布报告要求确定清洁车辆税抵免条件 //www.ludikid.com/2022/12/irs-releases-reporting-requirements-to-determine-eligibility-for-clean-vehicle-tax-credits/ Jamin库博博列文和W安德鲁杰克 mon,2022年12月12日 减通货膨胀法 交通策略 电池组 清洁能源税抵免 临界矿 电动车辆 基础设施 供应链链 //www.ludikid.com/?p=8359 s发布税务程序2022-42解决车辆制造商和卖方报告需求问题。这些报告需求是购买者根据第25E、30D和45W节有资格获得清洁车辆税抵免的先决条件。 第30D(d)(3)节要求制造商签署书面协议成为合格制造商,这需要定期...Continue Reading… s/www.irs.gov/pub/irs-drop/rp22-42.pdf目标s类似地,第30D(1)(H)节要求出售车辆者向购买者提供报表。

spanid='more-8359'#/span>sSpecifically, a manufacturer needs to include in the report:

(a) The make, model, model year, and any other appropriate identifiers of the motor vehicle;

(b) Certification that the motor vehicle is made by a qualified manufacturer, within the meaning of Section 30D(d)(3);

(c) Certification that the motor vehicle is treated as a motor vehicle for purposes of title II of the Clean Air Act;

(d) The gross vehicle weight rating of the motor vehicle;

(e) The battery capacity of the motor vehicle;

(f) The motor vehicle's vehicle identification number!and

(g) Such other information as the Secretary may provide on irs.gov.

With respect to the Section 30D credit, the following additional information needs to be provided:

(a) Certification that the motor vehicle is propelled to a significant extent by an electric motor that draws electricity from a battery that has a capacity of not less than 7 kilowatt hours and the battery is capable of being recharged from an external source of electricity, or the motor vehicle is a new qualified fuel cell motor vehicle;

(b) Certification that the motor vehicle is manufactured primarily for use on public streets, roads and highways (not including a vehicle operated exclusively on a rail or rails) and has at least four wheels;

(c) Certification that the final assembly of the motor vehicle occurred within North America;

(d) Certification of the percentage of the value of the applicable critical minerals contained in the electric vehicle's battery that were (i) extracted or processed in the United States or a FTA partner country, or (ii) recycled in North America;

(e) Certification of the percentage of the value of the EV battery components that were manufactured or assembled in North America;

(f) Whether the motor vehicle is a van, sport utility vehicle, pickup truck, or other vehicle!and

(g) The motor vehicle's manufacturer's suggested retail price.

Similarly, with respect to Section 25E and 45W credits, the manufacturer must provide additional information to show that vehicles satisfy the statutory qualifications for credit eligibility.

A vehicle seller, such as a dealer, must furnish a report to a purchaser not later than the purchase date and an annual report to the IRS, including the following information:

(a) The name and taxpayer identification number of the seller;

(b) The name and taxpayer identification number of the purchaser;

(c) The vehicle identification number, if assigned, of the vehicle;

(d) The battery capacity of the vehicle;

(e) For new clean vehicles, verification that original use of the vehicle commences with the purchaser;

(f) The date of sale, sale price of the vehicle, and maximum credit allowable to the purchaser!and

(g) If a purchaser makes an election to transfer the credit to the selling dealer that satisfies certain requirements for sales after December 31, 2023, any amount paid or allowable as a partial payment or down payment.

This revenue procedure notably does not require qualified manufacturers to certify as to a vehicle's satisfaction of the requirements in Section 30D(d)(7)—that the critical minerals in the battery have not been extracted, processed, or recycled by a "foreign entity of concern" and that the components contained in the battery have not been manufactured or assembled by a foreign entity of concern.  This would seem to impose less of a diligence burden on manufacturers.同理,税收程序没有解决车辆购买者如何确定车辆满足这些需求的问题。我们注意到,IRS可添加这项附加认证要求,作为2024或2025前“秘书可能提供的其他信息”的一部分,而2024或2025前外国受关注实体规则生效。

IT似乎报告需要解决车辆信用分数问题万博体育app手机登录As such, two vehicles of the identical make, model, and year may not always have the same credit eligibility, which will vary depending on the composition of critical minerals and components and the location of final assembly.

Manufacturers and sellers must submit a declaration under penalties of perjury that the facts presented in support of this certification are true, correct, and complete.  A purchaser of a vehicle can rely on the manufacturer's certification for the Section 30D, 45W, and 25E credits.

This revenue procedure does not provide any guidance on how to determine the value of critical minerals and components.  The revenue procedure expressly notes that it does not constitute the guidance the IRS is required to propose regarding Section 30D(e)(1) (Critical Minerals Requirement) and Section 30D(e)(2) (Battery Components).  Such guidance is due to be published separately, by no later than December 31, 2022.

最后,我们注意到税收程序没有表示政府会放松信用计划的法定时限-例如提供过渡期-正如许多制造商所请求的那样。

我们将继续监测和报告这些动态。

Volkswagen请求最高法院澄清国家在规范制造商售后车辆行为方面的作用 //www.ludikid.com/2021/04/volkswagen-asks-the-supreme-court-to-clarify-the-role-of-states-in-regulating-a-manufacturers-post-sale-vehicle-conduct/ 强米泽拉克 2021年4月21日Wed22:30:21+00 交通策略 清洁空气法 车辆排放 大众汽车 //www.ludikid.com/?p=7421 p对齐=scenterHillsborough县环境保护委员会。 受挑战第九电路决策,如果允许站立,会对联邦机动车排放规则管理以及针对汽车制造商的执法行动产生重大影响。后台程序多自大众公司安装增排Continue Reading…

Briefing for certiorari has recently completed in Volkswagen v.Environmental Protection Commission of Hillsborough County.  The challenged Ninth Circuit decision, if permitted to stand, could have significant effects on federal administration of motor vehicle emissions regulations, and enforcement actions against auto manufacturers.

Background

The suit is one of many stemming from Volkswagen's installation of emissions-increasing software in nearly 600,000 passenger cars sold in the United States.  As relevant here, Volkswagen installed new and updated software after the vehicles were sold and in the hands of customers, effectuated through voluntary recalls and servicing provided when the vehicles were brought in for normal maintenance.  This post-sale conduct implicates the "tampering" prohibitions under the federal Clean Air Act and many similar state laws, both of which generally forbid actions to remove or disable emissions control components after a vehicle has been delivered to the ultimate purchaser.  See, e.g., 42 USC 7522(a)(3)(A).

The United States and the State of California brought suit against Volkswagen, which ended in settlement.  These settlements did not cover claims from other state or local governments however.  Two counties subsequently brought suit against the manufacturer alleging that, inter alia, the post-sale software modifications were violations of state tampering laws.  The Ninth Circuit ruled in favor of the counties, permitting the suits to proceed.

The Dispute

Volkswagen claims that the federal government (and California)[1] have the exclusive right to regulate its post-sale conduct, and that the suits by the counties are therefore preempted.  The mobile source provisions of the Clean Air Act prohibit states from enforcing standards "relating to" emissions controls in "new motor vehicles," but preserves their right to "control, regulate, [and] restrict the use, operation, [and] movement" of vehicles already licensed in commerce.  42 USC § 7543(a), (d).  The Ninth Circuit read these provisions in combination to permit states to enforce tampering violations that occur after the vehicle has been manufactured and is in the hands of customers.  It also concluded that allowing states to bring these suits would not undermine the congressional goal of national uniformity in administration of motor vehicle rules by EPA.

Volkswagen's argument to the contrary, and its emphasis in its request that the Supreme Court hear the case, rests on the fact that the post-sale software modifications were instituted on a fleet wide basis:  That is, all vehicles which were eligible for the modification were expected to receive it, and the modification would affect each vehicle in the same way.  The mobile source preemption provisions were drafted in part in order to prevent manufacturers from having to deal with a patchwork of potentially inconsistent state emissions requirements.  Fleet wide post-sale changes instituted for a 50-state market, Volkswagen argues, should thus also be subject only to a uniform, national standard, administered by EPA.

Despite the potential disruption the ruling could have to EPA's primacy over mobile source regulation, however, the federal government has not offered its views in the suit,[2] previously turning down the opportunity before the Ninth Circuit.

Implications

Unless the Supreme Court hears the case, the Ninth Circuit's decision has the potential to affect both regulatory compliance regime for motor vehicles, as well as enforcement cases brought against manufacturers in the future.

With respect to the former, it could open up and introduce uncertainty into a process that has, to date, taken place largely between the manufacturer, EPA, and the California Air Resources Board (CARB).  As Volkswagen and several amici note in their certiorari submissions, manufacturers routinely implement fleet-wide model updates after a vehicle is placed in service to address an issue or improve performance.  Because of the risk that these changes to a vehicle's certified configuration could constitute tampering (even if the intent behind them is to address a legitimate issue), manufacturers sometimes submit these updates, referred to as "running changes" and "field fixes," to EPA and CARB to preview any issues.  If the 49 other states may now enforce their own views on whether the proposed model updates constitute tampering, manufacturers may be forced to change their practices, such as by generating a more defined record to defend any particular change, or seeking assurances from additional regulatory bodies that the proposed changes do not present an issue.  All these have the potential to delay the in-use update process.

The ruling could also expose manufacturers to "copycat" suits going forward.  Given the sophistication of their regulatory programs, EPA and CARB will likely continue to lead enforcement in this area.  But, as occurred in the Volkswagen matter, the resolution of any action is unlikely to include a release that covers other states so long as they are not a party.  States and their subdivisions could bring suit for the same conduct.  Indeed, as Volkswagen points out, one of the county plaintiffs in the Ninth Circuit ruling up for review has filed suit against Daimler in the wake of Daimler's own recent settlement with the U.S.加利福尼亚州关于击败设备控件。

> >#ftnref1name=>#ftn1>>>[1]>/a>承认加利福尼亚州在机动车辆污染控制方面的领先地位,Clean Activity允许加利福尼亚州在EPA放弃优先区时对新机动车实施更严格的标准,EPA只能在有限情况下拒绝实施。§ 7543(b). 加利福尼亚州一旦获准免免责后,任何其他州都可采用相同的标准。 见d.s/em>§7507.s/p
CMA市场研究英国电车收费部门 //www.ludikid.com/2020/12/the-cmas-market-study-into-the-uk-electric-vehicle-charging-sector/ James Marshall和Ben Donovan 弗里, 04 2020 20:54:52+00 交通策略 CMA EV收费 可持续性 //www.ludikid.com/?p=7366 p对齐='Center'###p> 2020年12月2日,竞争市场管理局宣布对英国正在兴起电动车辆充电段进行市场研究博客文章思考研究范围, 并可能令电车市场跨供应链参与者感兴趣CMA通常进行市场研究Continue Reading… p对齐=scenter##p>2020年12月2日竞争和市场局宣布对英国充电区展开市场研究spanids/news/cma-研究将双重焦点理解:(1) 如何创建有竞争力的部门同时吸引私人投资促进部门增长(2) 如何确保消费者使用电动车辆收费点有信心从服务中获取最佳服务。

UK市场研究机制允许CMA调查市场是否运行良好,如果运行良好,原因何在CMA初步市场研究后,如果CMA发现市场中引起竞争关注的特征或特征,它可以展开详细的市场调查,为政策或法律/监管变化提出建议,或启动单项执法行动,如果它在市场研究中识别潜在反竞争行为。

CapeCMA决定对电动车辆充电部分进行深入审查,这是政府气候变化承诺的一部分”。

CMA市场研究范围为插接混合和全电客EV提供充电点,包括汽车和光箱具体地说,CMA将研究各种环境EV收费问题,包括家/地街上工作场所中心点与目的地p>CMA将审查范围内两个核心主题:

    theme一: 开发竞争同时激励投资CMA将探索如何确保有效竞争开发并同时促进对收费网络的投资CMA将考虑如何发展行业竞争,包括考虑数据采集、使用和集中问题正在审议的具体问题包括支持EV收费基础设施的现有奖励办法、成本影响、进入屏障(如乡村或低人口密度、契约规定如排他性、连接费用等)和EV收费使用的一般政策考量。CMA确认EV收费部门的成功在很大程度上取决于消费者对它的理解和互动程度万博体育app手机登录Consequently, the CMA will consider issues such as information and transparency about the sector, tariffs and the ease of comparing charging options / providers and consumers' experience of using charge-points.

The CMA notes that it wants to "ensure the sector works well for people now and in the future, which will help to build trust in the service and address any competition issues."

Invitation to Comment

The CMA invites comments in particular on its proposed scope of study.

Any interested party may comment by 5 January 2021.

Possible Outcomes

Upon the conclusion of a market study, the CMA has a range of options to address any identified concerns, including:

  • making a reference for a full market investigation (at the end of which the CMA has wide-ranging powers to address any competition concerns identified, including breaking-up businesses);
  • guidance to consumers;
  • guidance to the sector (i.e.物价透明性)并
  • 建议政府需要额外支持(即:或需要政策或监管干预的地方 。
Timelines

CARB通过高级清洁卡车规则加速零排放车辆部署 //www.ludikid.com/2020/07/carb-adopts-advanced-clean-trucks-rule-to-speed-zero-emission-vehicle-deployment/ 凯文波龙卡兹和约翰米泽拉克 Wed,01JUL202016:47:21+00 交通策略 非分类化 加利福尼亚航空资源局 EPA公司 卡车排气 //www.ludikid.com/?p=7284 p对齐='Center'###p>加利福尼亚空气资源局一致通过高级清洁卡车规则,该规则旨在加速采行零排放中型和重型车辆(“ZEV ”) 。 到2045年,全州售出的新卡车中百分之百为ZEVs,与州到当年实现碳中和的大目标一致规则的Continue Reading…

The California Air Resources Board unanimously adopted the Advanced Clean Trucks rule, which is designed to accelerate the adoption of zero-emission medium and heavy duty vehicles ("ZEV").  By 2045, 100% of new trucks sold in the state will be ZEVs, consistent with the state's broader goal of becoming carbon neutral by that year.

The rule's main component is a ZEV sales quota.  Manufacturers who certify Class 2b through 8 chassis or complete vehicles with combustion engines will be required to sell zero-emission trucks as an increasing percentage of their annual California sales:

Model Year Class 2b-3 Class 4-8 Class 7-8 Tractors
2024 5 9 5
2025 7 11 7
2026 10 13 10
2027 15 20 15
2028 20 30 20
2029 25 40 25
2030 30 50 30
2031 35 55 35
2032 40 60 40
2033 45 65 40
2034 50 70 40
2035 55 75 40

The new rule is part of CARB's broader strategy to target emissions from trucks.  According to CARB estimates, heavy duty diesel vehicles emit roughly one quarter of smog-forming nitrogen oxides (NOx) within the state, despite accounting for roughly only seven percent of vehicles registered.  Later this year, CARB is expected to enact a rule that would make NOx standards more stringent by a factor of ten, which would create an incentive for manufacturers to move towards ZEVs.  The agency also is also implementing programs to control emissions from vehicles already in use, such as continuing to strengthen the heavy duty onboard diagnostics program it pioneered, and developing a heavy duty inspection and maintenance program.

Upon adoption of the rule, CARB said it was zeroing-in on air pollution in the most disadvantaged and polluted communities adjacent to ports, railyards, distribution centers and freight corridors.  And the rule specifically cites as its purpose reduction of emissions of not only greenhouse gases, but criteria and toxic air pollutants as well.

The mandate operates through a deficit and credit accounting mechanism.  Deficits are calculated for each model year by applying the percentages in the table to a manufacturer's annual sales volume, along with weight class modifiers (ranging from 0.8 for vehicles in the Class 2b-3 group, to 2.5 for vehicles in the Class 7-8 tractor group).  Credits are generated by sales of ZEVs and NZEV⁠s⁠—near zero emission vehicle⁠⁠s—which are plug-in hybrid electric vehicles with a minimum all-electric range.  For each model year, manufacturers must obtain credits in excess of their deficits for all truck categories and specifically for the Class 7-8 tractor category.  Credits may be traded and banked, but have a limited lifetime.  The rule also contains a fleet monitoring component, requiring large employers including retailers, manufacturers, brokers, and others to provide information about shipments, shuttle services, and fleet operations.

California must seek a waiver of preemption from U.S.EPA执行更严格机动车标准前。 CARB决议通过规则指示机构向EPA提交规则并请求放弃先发制人或确认规则属于现有放弃范围The Clean Air Act requires EPA to grant a waiver unless it finds that California does not need the standards to meet compelling and extraordinary conditions, the state's standards are not, in the aggregate, as protective as federal standards, or there is inadequate lead-time for the development and application of the requisite technology.  Although EPA has historically granted California's waiver requests, EPA under the Trump Administration withdrew California's waiver to enforce its Advanced Clean Car program for light-duty vehicles, which includes both the state's more stringent greenhouse gas standards as well as its ZEV mandate.  Withdrawal of the waiver has been challenged in the D.C.电路上诉法院目前正在诉讼中.

California州获EP豁免新规则,很可能产生全局效果. 多州,特别是东北州,表示支持新规则,并可能选择使用清洁空气法第177节将它应用到自己的程序中. 这可能为ZEVs创建国家市场,帮助实现程序成功所需的燃料基础设施.

IoT更新:NHTSA继续研发自动化驱动技术 //www.ludikid.com/2020/04/iot-update-nhtsa-continues-to-ramp-up-exploration-of-automated-driving-technologies/ 内部能源 mon,20Apr202015:54:02+00 交通策略 非分类化 自主车辆 连通自动化车辆 交通部 //www.ludikid.com/?p=7206 p对齐='中心'#####################################################################################################################################################################################################################Continue Reading…

The wheels continue to turn with the National Highway Traffic Safety Administration's ("NHTSA") efforts to modernize vehicle safety standards, including for connected and automated vehicles ("CAVs").  Most recently, NHTSA issued a Notice of Proposed Rulemaking ("NPRM"), seeking public comment on its endeavors "to improve safety and update rules that no longer make sense" for certain CAVs, "such as requiring manual driving controls on autonomous vehicles."  According to NHTSA, the NPRM is a "[h]istoric first step for the agency to remove unnecessary barriers to motor vehicles equipped with automated driving systems" ("ADS").

Comments on the NPRM are due by May 29, 2020.

NHTSA's Drive to Update Safety Standards

NHTSA's mission is to save lives, prevent injuries, and reduce the economic costs of motor vehicle crashes on U.S.roads.  To that end, NHTSA has developed the Federal Motor Vehicle Safety Standards ("FMVSS"), which provide the minimum safety performance requirements for motor vehicles or items of motor vehicle equipment.  The FMVSS specify certain design, construction, and performance elements of motor vehicles to protect against unreasonable risk of serious injuries and fatalities resulting from crashes involving such vehicles.  One set of standards pertains to "crashworthiness," which covers occupant protection to reduce death and injury resulting from crashes.  The "crashworthiness" standards are the subject of the NPRM.

The FMVSS were drafted to reflect the traditional driving paradigm with a driver who sits behind a steering wheel to control a vehicle, and a passenger beside the driver.  This drafting has resulted in significant barriers for CAV manufacturers (in NHTSA's parlance, makers of ADS-equipped vehicles) trying to meet, and certify compliance with, FMVSS while developing and deploying their products.  ADS generally refers to hardware and software that are collectively capable of performing the entire dynamic task of driving on a sustained basis.  With respect to the SAE automation levels, ADS typically describes Levels 3, 4, and 5 of driving automation systems.

With high rates of motor vehicle injuries and fatalities persisting around the country, NHTSA has recognized that advanced vehicle technologies such as ADS may play a critical role in saving lives.  The recent NPRM therefore reflects NHTSA's broader efforts to modify and update the FMVSS to explore the promises of ADS-equipped vehicles in working toward NHTSA's mission.  For instance, the recent NPRM follows NHTSA's grant of Nuro's petition for a temporary exemption from certain FMVSS to deploy its driverless delivery vehicles.  (Note, however, that NHTSA has yet to issue a response to a petition submitted by General Motors for exemption from FMVSS requiring a steering wheel and pedals.)

The NPRM

The NPRM has two overarching aims:  to remove "unnecessary regulatory barriers to ADS-equipped vehicles" in the crashworthiness FMVSS, while seeking to maintain current levels of occupant protection under these standards.  The NPRM additionally proposes to clarify the application of the crashworthiness standards to ADS-equipped vehicles that lack manual controls, and facilitate the certification and compliance verifications of these vehicles for occupant protection, as required by NHTSA.

To these ends, the NPRM proposes various changes to the crashworthiness FMVSS.  First, the NPRM proposes to revise, modify, and relocate certain definitions in the crashworthiness standards to make them applicable for ADS-equipped vehicles.  For instance, although the NPRM proposes to maintain the definition of "driver" itself (and also not to add "ADS"), the NPRM seeks to modify definitions that reference the "driver" (e.g., "driver air bag," "driver designated seating position," and "passenger seating position") to cover ADS-equipped vehicles in addition to traditional vehicles with human drivers.

The NPRM also proposes to revise standards based on assumptions that are not clearly applicable to ADS-equipped vehicles.  As an example, certain standards reference the designated seating positions of occupants.  But not all ADS-equipped vehicles have occupants (e.g., occupant-less trucks), creating barriers for ADS-equipped vehicles that seek certification and compliance with standards that reference "designated seating positions."  As a result, NHTSA is proposing revised standards clarifying that they apply to "trucks with at least one designated seating position," as opposed to trucks generally.  According to NHTSA, such a revision maintains current safety standards because a vehicle without occupants would not need to conduct specified occupant safety tests.

Similarly, the NPRM proposes changes where the absence of a steering control system may alleviate some traditional safety concerns.  It also seeks to clarify how airbag requirements apply when there is not a traditional driver's seat, as well as how to protect children when they are in that traditional driver's seat spot.

In making its proposal, NHTSA announces that it seeks to remain technology neutral, which is consistent with previous U.S.万博体育app手机登录Department of Transportation ("DOT") guidance.

The Longer Road

This NPRM, and NHTSA's broader efforts with respect to CAVs more generally, are not issued in isolation.  DOT released AV 4.0 earlier this year, which describes in greater detail the various efforts of 38 federal departments and agencies to promote, support, and provide accountability for users and communities with respect to autonomous mobility.  Meanwhile, on Capitol Hill, lawmakers have been working on a bipartisan, bicameral basis to develop comprehensive CAV legislation.  Earlier this year, legislators sent out draft sections of AV legislation for stakeholder comment.  The draft sections cover arbitration, cybersecurity, and consumer education!they follow previous portions of the draft, released last fall, which pertain to exemptions, testing and evaluation, and the creation of an automated vehicles advisory council.

With the COVID-19 pandemic some CAV initiatives have slowed.  Nonetheless, CAVs have shown promise in the effort to stem the crisis, including autonomous shuttles that have transported COVID-19 tests in Florida.  CAV-related technologies have also provided critical assistance in combatting COVID-19, including autonomous robots in hospitals, as well a range of other solutions that we have detailed here.  This latest NPRM suggests that NHTSA may not take its foot off the gas in eliminating regulatory barriers to CAV progress.

This post is a part of Covington's CAV blog series, which covers CAV developments across the world.  To access prior CAV blog posts and webinars and to learn more about our team and our work, please visit Covington's CAV website.

万博体育app手机登录IOT更新:DOT引入第四轮自动化车辆指南 万博体育app手机登录//www.ludikid.com/2020/01/iot-update-dot-introduces-fourth-round-of-automated-vehicles-guidance-av-4-0/ 内部能源 Tue 2020年1月21日 19:43:17+00 交通策略 非分类化 自主移动 自主车辆 //www.ludikid.com/?p=7161 p对齐=center+#p交通秘书Elaine Chao在美国消费者电子秀揭幕万博体育app手机登录交通部预期四轮自动车辆指南AV4.0正式命名AV4.0万博体育app手机登录Continue Reading… p对齐=scenter交通秘书Elaine Chao在美国消费者电子秀揭幕万博体育app手机登录Department of Transportation's ("DOT") long-anticipated fourth round of automated vehicles guidance, "AV 4.0."  Formally entitled, "Ensuring American Leadership in Automated Vehicle Technologies," AV 4.0 is less regulatory guidance and more regulatory aggregator.  The document lists in great detail the various Administration efforts—across 38 federal departments and agencies—geared toward promoting, supporting, and providing accountability for users and communities with respect to autonomous mobility.

Federal Efforts to Drive Autonomous Mobility

AV 4.0 arrived in a broader Washington context for autonomous mobility: the states remain the leading jurisdictions for action on autonomous vehicle regulation.  As Congress continues to slowly consider bipartisan, bicameral autonomous vehicles legislation, the states have added to their codes and regulations.  California, for example, recently incorporated autonomous delivery vehicles into its autonomous vehicle permitting regime at the state's Department of Motor Vehicles.  And other states, notably Arizona, Florida, and Nevada, continue to make efforts to facilitate private sector innovation and operations within their jurisdictions by creating relatively lightweight permitting and testing regimes, which shift the onus for ensuring safety toward companies and the insurance markets, rather than state regulators.

AV 4.0, therefore, was anticipated perhaps to include slightly more formal regulatory guidance than its predecessor, AV 3.0, which sought to define the federal government's role as one to facilitate rather than regulate.But AV 4.0 maintained the DOT's hands-off approach to autonomous vehicles.

AV 4.0's Promises and Principles

AV 4.0 reiterates AV 3.0's promise to "modernize or eliminate outdated regulations that unnecessarily impede the development of AVs—or that do not address critical safety, mobility, and accessibility needs—to encourage a consistent regulatory and operational environment."  And it continues to promote "consistency" among sub-national jurisdictions, and international law to encourage a "seamless" national and international industry.  For example, AV 4.0 discusses the U.S.'s participation in seeking "voluntary consensus standards" that can help to harmonize technical standards and regulatory policies with "international partners."  However, AV 4.0 does not specify how the standards should be developed, or what they might say.

Similarly, the document lays out a set of principles to represent the U.S.提供统一姿势指导工作这些原则力求优先安全性、强调网络安全性、确保隐私和数据安全性、增强运动性以及通过保留技术中立性与现代化规则促进高效市场。

万博体育app手机登录举例说,DOT机构(/em>、Federal汽车运输安全管理局、FederalTerver管理局和FederalTea外加DOT 美国卫生与公众服务部内务局和美国司法部都拥有无障碍权限,AV4.0强调这些部门通过部署自主车辆提高机动性的承诺最近DOT发布https://www.transportation.gov/horplement/us-dement-transport-releases-%E2.809C兼容设计-challenge%E2.809D-requen-Information>>能源局 联邦通信委员会 美国Department of Homeland Security, and the National Institute of Standards and Technology, among others, which all play critical roles in the facilitation of infrastructure, access to spectrum and connectivity, and security and cybersecurity standards.

Although AV 4.0 provides an informative overview of the landscape DOT seeks to shape with its list of unifying principles, the document does not go into great detail as to how each principle will be accomplished.

Convergences with the Transportation Sector's Energy Footprint

Notably, AV 4.0 does detail the many convergences between autonomous mobility and the transportation sector's energy footprint.  As the document notes, transportation accounts for nearly one-third of the energy used in the United States, and autonomous vehicles hold the promise to "reduce energy use associated with driving."  AV 4.0 highlights a number of government efforts aimed at addressing transportation efficiency alongside autonomous technology development.举例说,DOE通过高级研发项目局启动sem>NEXTCAR /em>程序,目的是使用连通自动化联机车电技术AV技术提高车级燃油效率。报告同样描述DOE支持8级卡车挂图作为实现重载卡车节能的一种手段。局正在建模土地使用变换并汇总各种数据集以创建对基础设施收费需求(并因此电网需要和约束)更全局化视图Sandia国家实验室正与联邦国家安全机构合作,进行与车辆对网收费和连通应用相联的网络安全风险评估。

IoT更新:智能城市和连通汽车从彼此获益 //www.ludikid.com/2019/03/iot-update-how-smart-cities-and-connected-cars-may-benefit-from-each-other/ 内部能源 图族2019年3月28日15:19:28+00 交通策略 非分类化 //www.ludikid.com/?p=7080 i/p全球创新领头者正在投资技术将城市转换为智能城市-环境数据采集分析高效管理资产和资源。智能城市技术可以提高安全性、交通交通系统管理并节能,前一文章中曾讨论过这一点。重要方面成功Continue Reading… sidetechmedia.com+8/08/03/best-practice-Servering-universe-in-city-projects/成功智能城市的一个重要方面是确保基础设施到位支持新技术Federal investment in infrastructure may accordingly benefit both smart cities and smart transportation, as explained in another post on connected and autonomous vehicles ("CAVs").

Given the growing presence of CAVs in the U.S., and the legislative efforts surrounding them, CAVs are likely to play an important role in the future of smart cities.  This post explores how cities are already using smart transportation technologies and how CAV technologies fit into this landscape.  It also addresses the legal issues and practical challenges involved in developing smart transportation systems.  As CAVs and smart cities continue to develop, each technology can leverage the other's advances and encourage the other's deployment.

Case Study: Smart Columbus

In 2016, Columbus, Ohio received a grant of up to $40 million from the United States Department of Transportation ("DOT") and up to $10 million from Paul G.AllenVulcan公司as part of the DOT's Smart City Challenge.  The city will use this grant toward its Smart City initiative, "Smart Columbus," consisting of nine projects that "seek to demonstrate how an intelligent transportation system and equitable access to transportation can have positive impacts on every day challenges faced by cities."  The first project will be deployed starting in April 2019, with the remainder of the projects beginning in 2019 and 2020.

One of the grant-funded Smart Columbus projects is the Connected Vehicle Environment ("CVE") project, which will incorporate smart traveler applications, automated vehicles, connected vehicles, and smart sensors into Columbus's transportation network.  The CVE project aims to enhance safety and mobility throughout Columbus's transportation system and will focus on areas of the city with high rates of collisions.  One of the project's major components is the Columbus Traffic Signal System, a high-speed network backbone that will connect the city's traffic signals and enable coordination throughout the system.  Safety applications, including an emergency electronic brake light warning and a forward collision warning, will also be installed on transit, emergency, freight, and private vehicles.

A related project is the Connected Electric Autonomous Vehicle ("CEAV") project, in which self-driving vehicles will be used as a transit service for residents.  These CEAV vehicles are intended to communicate with CVE vehicles, initially driving along certain pre-determined routes and eventually—contingent on the project's success—expanding to future routes in similar environments.

Like any connected system that collects and utilizes personal data from its users, Smart Columbus confronts privacy issues.  Accordingly, Smart Columbus has published a draft Data Privacy Plan that provides a framework for protecting the security of personal information that is collected and used, in line with applicable laws.  Under this plan, the city is to provide prospective participants of the CVE project with a presentation addressing the privacy risks associated with their participation and then seek their informed consent.

More Cities Implementing Smart Transportation Systems

Several other U.S.城市正在设计自己的智能交通系统,这些系统可增加CAVs使用量。例如,在pitsburgh/a>pthe city plans to add 150 new signals over the next two years.  Similarly, Austin, Texas has deployed dedicated short-range communication technology at five intersections, which increases pedestrian and vehicle safety by allowing connected vehicles to communicate with the traffic signal controller.  Last year, the Austin Transportation Department tested smart parking meters and gathered data about parking turnover rates and revenue as part of its Smart Mobility Program.

Cities are also considering the use of CAVs to provide public transportation and ride sharing services as part of their smart city initiatives.  Denver, Colorado, for example, has launched a pilot electronic autonomous shuttle service, which currently travels along a one-mile route and connects to a smart-city community in Denver.  Cincinnati, Ohio entered into a partnership with a ride sharing company last year to identify potential improvements to shared mobility services and to public transportation.  Combining data such as drop-off and pick-up activity with insights derived from local transit agencies, the Cincinnati Mobility Lab aims to equip transit agencies with the best information on how they can plan for their future.

Proposed Legislation and Government Action

Lawmakers are increasingly recognizing the benefits to cities and states from smart transportation systems and their ability to interact with CAVs, with measures including:

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#Smart交通将是任何智能城市程序的一个重要方面 。 公有和私有利害相关方在设计实施智能城市工作时会考虑整合交通和CAVs.

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