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Document 52019SC0096

COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Commission Delegated Regulation supplementing Directive 2010/40/EU of the European Parliament and of the Council with regard to the deployment and operational use of cooperative intelligent transport systems

SWD/2019/0096 final

Table of contents

1.Introduction

1.1.Policy and legal context

1.1.1.EU Policy context

1.1.2.EU Legal context

1.1.3.International cooperation

2.Problem definition

2.1.General problem: Limited deployment and uptake of continuous C-ITS services across the EU

2.2.Main problems

2.2.1.Main problem 1: Solutions are deployed in a slow, costly and fragmented manner, hindering interoperability and continuity across the EU.

2.2.2.Main problem 2: Barriers and uncertainties keep stakeholders from deploying or using C-ITS services

2.2.3.Main problem 3: Failure to provide an enabling environment for further C-ITS deployment.

2.3.Problem drivers

2.3.1.Problem driver 1: Lack of common definition / priority of C-ITS services

2.3.2.Problem driver 2: Uncertainties regarding minimum requirements for interoperability of C-ITS stations (including on communication technologies)

2.3.3.Problem driver 3: Barriers to establishing the necessary trust with regard to cyber security of C-ITS communications

2.3.4.Problem driver 4: Uncertainties regarding to minimum requirements for compliance assessment of C-ITS services

2.3.5.Problem driver 5: Uncertainty on how to comply with rules on privacy and protection of personal data

2.3.6.Problem driver 6: Lack of coordination between relevant bodies

2.3.7.Problem driver 7: Uncertainty about business models

2.4.Most affected stakeholders

2.5.How will the problem evolve?

3.Why should the EU act?

3.1.Legal basis

3.2.Subsidiarity: Necessity of EU action

3.3.Subsidiarity: Added value of EU action

4.Objectives: What is to be achieved?

4.1.General objectives

4.2.Specific objectives

5.What are the available policy options?

5.1.Description of the retained policy measures

5.2.Measures discarded at an early stage

5.3.Description of the policy options

5.3.1.PO0: Baseline scenario

5.3.2.PO1: Light intervention based on non-legislative measures

5.3.3.PO2: Moderate intervention based on specifications under the ITS Directive

5.3.4.PO3: Strong intervention based on V2V mandate + set-up of governance bodies

6.What are the impacts of the policy options?

6.1.Social impacts

6.2.Economic impacts

6.3.Environmental impacts

6.4.Fundamental rights

6.5.Distributional impacts & Sensitivity Analysis

7.How do the options compare?

7.1.1.Effectiveness

7.1.2.Efficiency

7.1.3.Coherence

7.1.4.Proportionality

8.Preferred option

9.How will actual impacts be monitored and evaluated?

Glossary

Term or acronym

Meaning or definition

3GPP

3rd Generation Partnership Project

5G

5th generation of communication networks

CCAM

Connected, Cooperative and Automated Mobility

CEPT

European Conference of Postal and Telecommunications Administrations

C-ITS

Cooperative Intelligent Transport Systems

CP

Certificate Policy for C-ITS security

EEA

European Environmental Agency

GDP

Gross domestic product

GDPR

General Data Protection Regulation

GSR

General Safety Regulation

IRC

Impact Reduction Container

ITS

Intelligent Transport Systems

ITS-G5

IEEE 802.11p (wifi) communications protocol for C-ITS communication

I2I

Infrastructure-to-infrastructure communication

LTE

Long Term Evolution

LTE-V2X or C-V2X

Cellular communications protocol for C-ITS communication

RISM

Road Infrastructure Safety Management

RSU

Road-side unit

SP

Security Policy for C-ITS security

CCMS

C-ITS Security Credential Management System

V2I

Vehicle-to-infrastructure communication

V2V

Vehicle-to-vehicle communication

V2X

Vehicle-to-everything communication

VOC

Volatile Organic Compounds (air pollutants)

VRU

Vulnerable Road User



1.Introduction

The increasing volume of road transport in the European Union poses several challenges. Road transport is responsible for the bulk of transport emissions, in terms of greenhouse gases and air pollutants. While there have been improvements in road safety in the EU over the last few decades, this trend has recently slowed down and it is unlikely that the EU will reach the objective of a 50 percent reduction in fatalities between 2010 and 2020. Finally, congested roads incur huge costs to the EU economy. Coordinated action across a number of fronts is required to tackle these issues and prevent them from having strong negative effects on the European population, economy, environment and climate.

The development of new technologies aimed at improving the efficiency, safety and environmental performance of road transport are playing a significant role in achieving the Commission’s goals in this area. One such emerging field is that of Cooperative Intelligent Transport Systems (C-ITS). 1 C-ITS enable vehicles to interact directly with each other and with the surrounding road infrastructure. In road transport, C-ITS typically involves communication between vehicles (Vehicle-to-Vehicle, V2V), between vehicles and infrastructure (Vehicle-to-Infrastructure, V2I) and/or Infrastructure-to-Infrastructure (I2I), and between vehicles and pedestrians or cyclists (Vehicle-to-everything, V2X), which enable a wide range of information and cooperation services.

The benefits of C-ITS span a range of areas, including improving road safety, reducing congestion, optimising transport efficiency, enhancing mobility, increasing service reliability, reducing energy use and environmental impacts, and supporting economic development. At the same time, attention should be given so that potential negative effects of C-ITS are avoided, e.g. that these improvements lead to induced traffic demand, drivers experience information overload due to information coming from numerous sources, or that the additional data sharing leads to increased cyber security or privacy risks.

Over the past decade, there have been remarkable new developments in technologies that facilitate C-ITS. However, this has not yet led to large-scale deployment despite the potential benefits. In 2011, the EU car manufacturers united in the CAR2CAR consortium 2 stated their intention to start large-scale deployment by 2015 in a Memorandum of Understanding 3 , as the system would be technologically ready by then. However, it became clear that this large-scale deployment was not possible without a common approach between the main stakeholders on both technical and non-technical aspects.

This is why the Commission created the C-ITS Platform, a Commission expert group conceived as a cooperative framework including national authorities, C-ITS stakeholders and the Commission, in view to develop a shared vision and concrete implementation solutions for the interoperable deployment of C-ITS in the EU. The results of the extensive work of the platform and its working groups was summarized in the final reports of Phase I (2014-2016) and Phase II (2016-2017). 4  

Within the C-Roads Platform and through significant investments at national and EU level (EUR 199 million, of which 107 EUR million co-funded through the Connecting Europe Facility), 16 Member States have started work to harmonise V2I C-ITS services and make them interoperable, allowing for example messages about road-works to be understood consistently across different geographical environments. Through further cooperation with the CAR2CAR consortium, increased consistency has been achieved in vehicle to vehicle and vehicle to infrastructure messages.

This work of the C-ITS platform was an essential input in the European strategy on Cooperative Intelligent Transport Systems (COM(2016)766) 5 , which aimed to facilitate the convergence of investments and regulatory frameworks across the EU, in order to enable deployment as quickly as possible, starting with mature C-ITS services in 2019. It also clearly sets out the need to adopt an appropriate legal framework at the EU level by 2018, possibly through delegated acts under the ITS Directive or other legal instruments.

Deploying these services and connecting all vehicles with each other and all infrastructure operators also requires a common security solution. This is a necessary condition to ensure trust in an open system. At the same time, the strategy defined the so-called hybrid communication approach, which combines complementary and mature technologies for a full and optimal implementation of all services.

All these elements constitute minimal requirements for interoperability, backward compatibility and continuity of services. Most stakeholders agree that without a clear legal framework, deployment will remain slow and fragmented (81% of respondents (strongly) agreed in the public consultation (PC)) as a result of the problem drivers identified (70-80% of respondents felt that the different problem drivers were very or moderately important) and that the objectives should be achieved at EU level (68-86% considered that is was absolutely essential or very important that the different objectives are achieved through EU, rather than national or international action).

The subject of this initiative is creating the legal framework for C-ITS, incorporating the minimum requirements for interoperability, as mandated by the ITS Directive, to enable the start of large-scale deployment in 2019. The focus lies on “Day 1” and “Day 1.5” services 6 , C-ITS services that will be deployed in the short and medium term and which contribute particularly to improve road safety and traffic efficiency. Specifications and standards for interoperable Day 1 services, as well as a common security solution, are now available as a result of cooperation between a broad group of industry stakeholders and MS authorities.

1.1.Policy and legal context

1.1.1.EU Policy context

In 2008, the Commission adopted an action plan for the deployment of Intelligent Transport Systems (ITS) in the EU (COM(2008)886 final) 7 , which identified the potential of C-ITS and that its development should be promoted, in particular by defining a harmonized approach and specifications, as well as through a mandate to the European Standardisation Organisations (ESOs) to develop harmonised standards.

This 2009 mandate (M/453 EN) 8 , indicated that a sufficient critical market mass is needed to achieve the potential of C-ITS and that common specifications and standards are needed to ensure interoperability and continuity of C-ITS services across the EU. While the development of these specifications and standards is principally carried out by the industry, the mandate already indicates that to ensure true EU-wide interoperability essential parts of the standards would need legal enforcement measures.

The Commission’s 2011 Transport White Paper (COM(2011)144 final) 9 sets the framework within which EU transport policy is currently developed. While it did not make an explicit reference to C-ITS, it clearly identified the need and relevant initiatives to develop and deploy Intelligent Transport Systems (ITS).

The Roadmap for the Energy Union (COM(2015)80 final) 10 and the ensuing Low Emission Mobility Strategy (COM(2016)501 final) 11 stated that a EU framework for the deployment of C-ITS should be provided, which was delivered through the C-ITS Strategy. 

On 13th March 2018 the European Parliament adopted an opinion on the C-ITS Strategy. 12 The opinion calls for the introduction of interoperable C-ITS services throughout Europe without delay and highlights the need for a clear legal framework to support the deployment of C-ITS. The opinion considers that in the further development of C-ITS, the link to cooperative, connected and automated mobility and urban driving, including interaction with vulnerable road users, should get additional attention.

Link to cooperative, connected and automated mobility

The deployment of cooperative, connected and automated mobility (CCAM) – when fully integrated in the whole transport system and accompanied by the right support measures and synergies between driverless mobility and decarbonisation measures – is expected to contribute significantly to bringing down the number of road fatalities, reducing harmful emissions from transport and reducing congestion.

The ability of vehicles to communicate will be key to integrate automated vehicles in the overall road transport system, including its interfaces with other modes. For example, C-ITS can improve an automated safety feature such as adaptive cruise control, by more quickly informing the system about changes in other vehicle’s speed than possible through cameras, and help vehicles perform complex manoeuvres such as lane-merging and overtaking, which cannot (or not as efficiently) be done by automation alone. 13 This cooperation will also help optimizing the performance of the whole transport network, rather than the performance of the individual vehicle alone. C-ITS are thus a key initial component in the broader development towards CCAM (including the work towards a pan-EU network of 5G Corridors for CCAM) and there is a clear need for the convergence between connectivity and automation.

That is why, in the Declaration of Amsterdam 14 , the Transport Ministers called upon the Commission to work towards a coherent European framework for the deployment of interoperable connected and automated driving, which should be available, if possible, by 2019.

The ‘Europe on the Move’ Communication (COM(2017)283 final) 15 , discusses the role of C-ITS in enabling cooperative, connected and automated mobility (CCAM). 16 It highlights the need for demonstration projects, the importance of developments in communication technologies, and the relevance of work being undertaken in the context of the Digital Single Market Strategy. 

Compatibility between infrastructure and vehicle solutions for safety, traffic efficiency and automation will need to be assured across the EU in order to fully benefit from these solutions. This shows how important a holistic approach is. That is why the Third mobility package, adopted by the Commission in May 2018 17 , combined a new road safety policy, with legislative proposals on vehicle and pedestrian safety 18 (COM(2018)286 final – General Safety Regulation(GSR)) and on infrastructure safety management 19 (COM(2018)274 final – Directive on Road Infrastructure Safety Management (RISM)).

The package also included an EU strategy for connected and automated mobility 20 (COM/2018/283 final), which sets out a common vision for the future development of the sector and ensuring that the EU legal and policy framework on key issues is ready for the market deployment of new products and services. The Commission prepared the ground for this strategy with an extensive stakeholder and Member State consultation process, in particular through the C-ITS platform and the GEAR 2030 high-level group which adopted recommendations 21 on automated and connected vehicles on 18 October 2017.

1.1.2.EU Legal context

The main legal and policy framework for C-ITS is set by the ITS Directive (Directive 2010/40/EU) and the 2008 ITS Action Plan.

One of the main obligations for the Commission in the ITS Directive is to adopt specifications ensuring compatibility, interoperability and continuity for the deployment and operational use of ITS in different priority areas (Article 6(3) of the Directive). C-ITS is covered under priority area IV – “Linking the vehicle with the transport infrastructure”. The Annex of the Directive (Priority Area IV, point 1.2) 22 defines that these specifications and standards shall include i.a. (1) the use of a standardised message format for the exchange of data or information between the vehicle and the infrastructure (2) the definition of a communication infrastructure for data or information exchange between vehicles, infrastructures and between vehicle and infrastructure and (3) the use of standardisation processes to adopt the respective architectures.

At the same time, the framework for electronic communications and the protection of personal data has significantly evolved over the last years.

·The General Data Protection Regulation (EU) 2016/679 repealing Directive 95/46/EC provides a comprehensive legal framework concerning personal data, to which also C-ITS shall comply.

 

·In addition, the following Directives contain additional rules on data protection and electronic communication that can be relevant for C-ITS:

oDirective 2002/58/EC ‘concerning the processing of personal data and the protection of privacy in the electronic communication sector’ (and the proposed Regulation to replace the Directive (COM (2017)10 final).

oDirective 2002/19/EC ‘on access to, and interconnection of, electronic communications networks and associated facilities (Access Directive)’ and its proposed recast (COM(2016)590 final).

The GSR is regularly updated to include new mandatory safety features to vehicles, the impacts of which can overlap with or be reinforced through C-ITS. A new proposal 23 proposes to include inter alia advanced emergency braking, lane-keeping assist system and pedestrian and cyclists' detection systems for trucks.

1.1.3.International cooperation

International cooperation in the area of cooperative, connected and automated vehicles is fundamental as markets are developing globally. The EU has already benefitted from cooperation with Australia, Japan, Singapore and the US in areas such as research, security and harmonisation of standards.

The EU should continue engaging with international partners to continue benefitting from their experiences, especially those gained from large-scale deployment initiatives. This includes promoting international standardisation (e.g. vehicle regulation and traffic rules in the United Nations Economic Commission for Europe), protecting the privacy of individuals and their personal data and cyber security, addressing legal aspects and enabling the coordination of research (e.g. through twinning of Horizon 2020 research and innovation projects).

2.Problem definition

Figure 1: intervention logic presents the intervention logic of the initiative, identifying the general problem, the main problems and problem drivers, as well as the general and specific objectives.

2.1.General problem: Limited deployment and uptake of continuous C-ITS services across the EU

The general problem that the initiative intends to tackle is the limited deployment and uptake of continuous C-ITS services across the EU, and the resulting negative impacts on the development of connected, cooperative and automated mobility in the EU.

NOTE: This Impact Assessment focuses on the deployment of Day 1 C-ITS services which will be deployed in the short term. While the same problems also apply to Day 1.5 and later C-ITS services, and the analyzed measures/options will thus also have an impact on their deployment, common specifications for these have not yet been developed, are thus not part of the measures considered.

Some specific considerations on Day 1.5 and later C-ITS services are made in the report where relevant, and the impacts of deploying Day 1.5 services is considered as part of the sensitivity analysis in Section 6.4.

The technology for C-ITS is ready and its potential positive impacts on road safety and traffic efficiency have been clearly demonstrated in research and pilot projects. Early deployment projects are currently working on putting interoperable solutions across the EU in place, supported by national and EU funding. However, these initiatives are still fragmented and a clearer framework is needed to ensure that existing and new deployments deliver continuous C-ITS services across the EU. The Amsterdam Declaration and the European Strategy on C-ITS have both highlighted the risk that without an EU level framework, C-ITS deployment and the uptake of C-ITS services will be limited and fragmented.

Without coordinated deployment and quick uptake, the societal, economic and environmental benefits of C-ITS services will fall below their full potential, in particular because C-ITS services exhibit strong network effects. This is because C-ITS enabled vehicles will only be attractive if they can exchange messages seamlessly with a significant number of other transport participants and infrastructure; after which the addition of new services and participants will often have no or marginal extra costs for the existing users.

If on the other hand, solutions are implemented in redundant, non-interoperable systems and services, which is likely as a large number of very different stakeholders are involved, this will lead to a worse cost-benefit ratio for involved stakeholders. This creates the risk that the market may not develop further as no stakeholder may be willing to undertake significant investments as a first mover in this case. The direct implication is that stakeholders need to agree on the (mature) technologies to be used for initial deployment. This does not preclude however that the C-ITS network remains open to the integration of new solutions and technologies 24 .

High level of negative externalities caused by road transport

The deployment of C-ITS services is expected to contribute significantly to bringing down the number of road incidents, reducing congestion and reducing harmful emissions from transport. 25 These still form important negative externalities of road transport that need to be reduced.

In 2016, 25,620 people were killed on EU roads and about 246,000 were seriously injured 26 . For the period 2010-2015, fatalities for all road users decreased by 16%, whereas fatalities of vulnerable road users decreased by 13%, but the reduction has slowed down in recent years. 27 The number of vulnerable road users and therefore their exposure to risk is likely to increase, in particular in urban areas, as a result of the promotion of more sustainable modes of transport.

Under the Baseline scenario (see section 2.5), passenger transport activity (measured in passenger-km) is projected to increase by about 24% between 2015 and 2035 while road and rail freight activity (measured in tonne-km) increase by 39% during the same period. With growing demand for transport, congestion is an increasingly important issue. Congestion results in considerable economic, social and environmental costs, which according to various scientific estimations amount to 1-2% of EU GDP i.e. EUR 146-293 billion per year 28 . According to (Fermi & Fiorello, 2016), only the cost of delays from congestion accounted for EUR 140 billion /year or 1% of GDP in 2015. However, congestion not only results in delays 29 but also in a waste of fuel and additional CO2 and air pollutant emissions. Ultimately, it leads to loss of competitiveness.

Transport (including international maritime) was responsible for 27% of EU greenhouse gas emissions in 2016; road transport accounted for 72% of these. GHG emissions from road transport in 2016 were still 22% higher than in 1990.

According to recent estimates 30 , air pollution from road transport costs up to 2% of GDP to society. The impact of this is felt especially in major urban areas across Europe 31 , but it cannot be neglected on inter-urban routes. According to the EEA, the total number of premature death attributable to air pollution in the EU was around 500.000 in 2013 32 , with emissions from road transport being a main contributor.

Competitiveness

Countries around the world (e.g. US, Australia, Japan, Korea and China) are moving rapidly towards deploying digital technologies in road transport; Japan has already equipped 2.5 million vehicles with short-range communication for a limited set of services. Delays to C-ITS (and consequentially CCAM) deployment would put the European automotive and ITS industry at a disadvantage compared to its competitors, leading to lower levels of new business opportunities and job creation, and less significant research and innovation impacts. As the jobs of millions of Europeans depend directly or indirectly on the automotive industry (12 million people, accounting for 4% of GDP) 33 , it is critical that the sector is provided with the conditions to keep up with global market players.

Figure 1: intervention logic

2.2.Main problems

The general problem identified in the previous section is a result of a number of main problems.

2.2.1.Main problem 1: Solutions are deployed in a slow, costly and fragmented manner, hindering interoperability and continuity across the EU.

The current deployment of C-ITS is characterized by individual projects across the EU. While vehicle manufacturers, road authorities and other stakeholders work together to develop common solutions, many stakeholders consider that without a common framework, we risk a patchwork of C-ITS services, resulting in slow, costly and fragmented deployment, thus hindering the interoperability and continuity of C-ITS services. Continuity of service, i.e. the availability of C-ITS services across the EU for end-users, is the most important factor for swift deployment of C-ITS as highlighted in the C-ITS Strategy.

Considering that the EU has a single market for vehicles and a single European Transport Area, and the complexity due to the number of different stakeholders involved, many consider that a framework at EU, rather than national or international level, is needed. This is also reflected internationally, where there is significant deployment in Japan were such a framework exists, and the US and China which are working towards a framework.

2.2.2.Main problem 2: Barriers and uncertainties keep stakeholders from deploying or using C-ITS services

Certain barriers, such as the uncertainties in relation to the cyber security and data privacy of C-ITS communications, and the lack of a clear governance framework for C-ITS, keep stakeholders from the large-scale deployment and use of C-ITS services. This is because they cannot be sure that their implementation can interact with other implementations, or that it will remain in line with evolving rules and practices, especially when requirements differ from Member State to Member State. Addressing these issues is particularly important to move from relatively controlled pre-deployment, with users that are specifically selected and aware of the system, to large-scale deployment, where the system will be available to regular end-users.

2.2.3.Main problem 3: Failure to provide an enabling environment for further C-ITS deployment.

Without the necessary framework to support pre-commercial deployment and an environment that allows the development of attractive business models, C-ITS uptake will be very slow. Network effects that are necessary to access the economic, social and environmental benefits will not be achieved quickly and efficiently, making it difficult for early deployers to justify investments. Considering the many actors involved in the C-ITS value chain, the development of sustainable business models requires coopetition and coordination. Also developments in C-ITS and CCAM need to be coordinated across the EU to ensure that they reinforce each other, rather than taking divergent paths.

2.3.Problem drivers

2.3.1.Problem driver 1: Lack of common definition / priority of C-ITS services

Work carried out by the C-ITS Platform and via existing deployment projects has shown that there is a need for common definitions for C-ITS services. C-ITS technology is rapidly evolving and without common definitions, each stakeholder with the same intention could develop slightly different services, or implement the same service in a slightly different way, risking that the service is neither interoperable nor continuous across the EU, and thus does not reach its full market potential. The C-ITS Platform Phase II report highlighted the need for developing common definitions for C-ITS services to support continuity and interoperability of services across the EU.

Work has already been carried out in the EU on the definition of C-ITS services and harmonized standards and profiles for services and systems. (Note: Standards often give a number of implementation options. Profiles further define how these options should be implemented to ensure an interoperable solution. Both are thus required together to ensure interoperability):

·The ESOs have developed a large set of standards for C-ITS services and systems, in particular following the mandate given by the Commission in 2009.

·The Car2Car Communication Consortium, which includes a large share of EU vehicle manufacturers, as well as technology and research partners, has worked since 2002 on C-ITS, in particular on V2V services. It has developed harmonised service profiles for Day 1 V2V services, as well as a harmonised system profile for in-vehicle C-ITS stations using short-range communication. The latest version was released in August 2018.

·The C-ROADS Platform, which unites 16 Member States and road operators working on interoperable cross-board C-ITS deployment, in particular on V2I services. It has developed harmonised service profiles for Day 1 V2I services, as well as a harmonised system profile for road-side C-ITS stations using short-range communication. The latest version was released in June 2018.

In addition to common definitions of services, prioritisation of mature safety-relevant C-ITS services would also be beneficial (e.g. by providing a focus on the deployment of Day 1 services) to ensure that stakeholders focus first on deploying a set of common C-ITS services, ensuring quicker network effects and reaping higher benefits as a result.

The definition of C-ITS services was supported by the stakeholders interviewed, with most indicating that this should include technical profiling to ensure interoperability across the EU. The C-Roads Platform representative suggested that safety-related services could be prioritised.

2.3.2.Problem driver 2: Uncertainties regarding minimum requirements for interoperability of C-ITS stations (including on communication technologies)

Having common service definitions is not enough to provide continuous C-ITS services. An integrated C-ITS system relies on the interoperability of its components. That means that systems need to be able to interact with each other, across borders and at different layers: applications, facilities, networking & transport, access and security (see Figure 2 ). This requires open, standardised interfaces and consistent end-to-end security features. Note that this does not require each individual element within a C-ITS station to be interoperable, but rather that C-ITS stations can communicate/understand each other, encouraging innovation and competitive differentiation.

Without any minimum requirements for system interoperability at the EU level, deployment will remain fragmented with limited interoperability and continuity across the EU. As indicated in section 2.3.1, the CAR2CAR Communication Consortium and the C-ROADS platform respectively developed a harmonised system profile for in-vehicle C-ITS stations and road-side C-ITS stations using short-range communication. Work is ongoing in C-ROADS on a harmonised system profile for long-range cellular C-ITS communication.

The creation of technical communications profiles for each technology and for all Day 1 services was recommended by several stakeholders who noted that without clear profiles there will be too much variation in the services deployed and thus no interoperability or continuity of service. However, other stakeholders noted that interoperability requirements should be kept minimal to avoid burdening new technologies.

Figure 2: C-ITS station reference architecture (source: EN 303 665)

Communication technologies

A particular important issue for C-ITS are the communication technologies (the access layer in Figure 2 ) that can be used for delivering C-ITS and how we combine them. This follows directly from the need to ensure everybody is connected to everybody (interoperability), and making sure everybody remains connected to everybody (backwards compatibility).

A first key principle is that – to maximise the benefits of C-ITS and deliver all V2V, V2I and vehicle to everything (V2X) services as efficiently as possible – we need to leverage the distinct advantages of different, complementary technologies. This is the so-called hybrid communication approach and already today combines two types of technologies:

·Short-range communications technologies operate in a dedicated 5.9 GHz frequency band. ITS-G5 was developed specifically for this purpose (based on the IEEE 802.11p protocol) and is currently mature, tested and already deployed.

Short-range technologies are particularly relevant for time-critical services (e.g. warnings of oncoming collisions or other imminent dangers), for instance through the direct communication between vehicles and other traffic participants, and for direct exchange between vehicles and the infrastructure on busy road segments and intersections.

The efficiency of dedicated roadside units depends strongly on the amount of traffic. Considering that roadside unit enable short-range communication, they generally enable more time-critical services that can delivered better than solely through long-range communication, but at an added cost. Thus the decision to deploy roadside infrastructure is expected to be made on a case-by-case basis by public authorities or road operators.

·Longer-range communications technologies leverage the coverage of existing networks and connect large areas,. Mature technologies are cellular 3G/4G, which already provide good coverage in large parts of the Union.

Long-range technologies are currently particularly relevant for less time-critical services (e.g. in-vehicle signage or routing information).

In other words, the practical implementation of the first principle (complementary technologies), combined with the need to ensure interoperability and continuity of services, implies we have to make technological choices. This should however not hinder further innovation. Therefore, a second key principle is that the system should be, as much as possible, independent of the communication technologies used. This means that future technologies can be integrated more easily in the hybrid communication mix, several candidates exist already:

·LTE-V2X is a cellular-based short-range communication technology that could also enter the market in the next few years. Note: if LTE-V2X and ITS-G5 would both be used to deliver the same services, there is a need to address interoperability (or redundancy) between them. Otherwise, everybody will not be connected to everybody, and accidents could still happen between two equipped vehicles.

·5G is the next generation cellular network, which could include both a long-range and a short-range 5G-V2X variant. This technology is still under development and is in particular expected to play a role in particular as an enabler for higher levels of automation.

C-ITS technology: an international perspective 34

In the EU, C-ITS is in an early deployment phase, with 16 Member States and several vehicle manufacturers currently deploying based on the hybrid communication approach (a mix of ITS-G5 and 3G/4G). This deployment builds on extensive testing and evaluation in many field trials with many relevant standards already drafted and published. Early tests are ongoing for LTE-V2X.

The US is also in an early deployment phase, including three large-scale deployment programs planning the deployment of approx. 10.000 C-ITS devices + a support action for each state to equip at least 20 intersections. In 2016, the US Department of Transportation proposed to equip all vehicles with DSRC short-range communication (equivalent to ITS-G5). DSRC deployment is also supported by a large group of states and industry, but the mandate has since been put on hold by the new administration. Early tests are ongoing for LTE-V2X.

In Japan, there is already large-scale deployment of short-range communication similar to ITS-G5/DSRC with some 1,600 roadside units communicating with 2.5 million on-board units fitted to cars for a limited but important set of services.

China is relatively new in the C-ITS space, but looks to move quickly from testing to early deployment. Its recently adopted smart car strategy 35 puts a strong emphasis on deploying C-ITS on cellular based technologies, both for short (LTE-V2X/5G-V2X) and long range.

Australia positions itself to be an early adopter of C-ITS developments. Considering that Australia has a relatively limited automotive industry, applications deployed in Australia would be based on those applications deployed internationally, at least in the initial deployment period. Given that its automotive standards and radio spectrum allocation resemble those in the EU, Australia considers following European standards for C-ITS deployment as the default option.

Stakeholder feedback on communication technologies

Public consultations

The respondents to the public consultation 36 for the 2016 EU C-ITS strategy gave widespread support for the hybrid communication approach: indeed, less than 5 percent disagreed with initial deployment based on ITS-G5, and the vast majority see LTE-V2X or in future 5G cellular communications playing an important role in the long-term. In the 2017 Public Consultation, a strong majority considered that it was important to achieve the objective of interoperability and a forward-looking hybrid communication approach at EU level, but respondents were more split on how this should be achieved.

A vehicle and equipment manufacturer called for ‘co-existence concepts’ for ITS-G5 and LTE-V2X to be developed. An ITS service provider noted that a hybrid communication approach was essential, particularly as short-range broadcasting might not be the best technology for all use cases. Some stakeholders had reservations around requiring interoperability between technologies in a hybrid approach. A vehicle manufacturer called for the hybrid communication approach to allow for both Wi-Fi and C-V2X, despite noting that interoperability between these was not possible at this stage. A vehicle and equipment manufacturer noted that clarifying the role of these two communication technologies was important, as there should not be competing technologies from the first day.

Amongst the stakeholders interviewed for the case studies there was consensus that interoperability is essential for an effective C-ITS system, allowing all vehicles to communicate with each other, but allowing for flexibility of technologies to be chosen. A C-Roads Platform position paper on the use of the 5.9 GHz band of the radio frequency spectrum 37 was submitted which underlined that there should be interoperability between ITS-G5 and LTE-V2X and that road authorities should not be forced to equip their roads with two or more competing technologies. Additionally, it stated that the platform’s members were committed to ‘backwards compatibility’ criteria.

On the other hand, an association representing telecommunications interests (and a similar response from a private company) noted that no technology should be seen as the incumbent; instead the choice should be based on cost-efficiency. They believed it preferential that both LTE-V2X and ITS-G5 co-exist and compete for the same services in the 5.9 GHz radio spectrum frequency band. They also considered that LTE-V2X should not be required to be interoperable and backwards compatible with ITS-G5.

A technology supplier, on the other hand, was critical of the ‘push from the cellular industry’ to bring an unproven technology into the same radio spectrum frequency band in which stakeholders were already deploying ITS-G5, and was concerned that this would affect the deployment of the latter and so not deliver its potential benefits. A vehicle manufacturer noted that feasibility tests are needed to be undertaken on the potential of LTE-V2X to co-exist with ITS-G5 in the 5.9 GHz frequency band.

Further consultations

Throughout the Impact Assessment process, several bilateral consultations with representatives from the automotive industry, technology suppliers, telecommunications industry and MS experts have been held, as well as a number of position papers and letters have been received, with particular emphasis on communication technologies. These largely reflect a similar divergence of opinions, with clear support from some stakeholder groups on clear rules for interoperability starting from mature implementations, while others argued for a technological-neutral framework where the choice of technology is left to the market.

In discussions with MS experts, some MS argued for a technological-neutral framework where the choice of technology is left to the market, but a strong majority agreed with the need for clear EU rules for interoperability, starting from mature implementations available now, and including a clear and transparent path for the inclusion of future solutions and technologies.

2.3.3.Problem driver 3: Barriers to establishing the necessary trust with regard to cyber security of C-ITS communications

As the transport system becomes more and more digitised, it may also become more vulnerable to hacking and cyber-attacks. Secure and trusted communication of messages exchanged between vehicles and infrastructure will therefore be key for the successful deployment of C-ITS services, so users can be sure the message is correct and sent by a trusted source, and that the information they send is sufficiently protected. Both operators and users will need to trust the cyber security of C-ITS communications, otherwise they will refrain from using it, providing a barrier for large-scale deployment.

The C-ITS Platform concluded that cyber security is still a barrier for the deployment of Day 1 C-ITS services in Europe. Without clear rules, adopted at the EU level, the development of security solutions will be fragmented and could put interoperability (see Figure 2 ) and the safety of end-users at risk.

The Phase I report of the C-ITS Platform included a very detailed analysis of the different options for the implementation of a trust model to ensure secure and interoperable exchange of C-ITS messages on across the EU. As an outcome of this process, Member States and industry representatives consensually agreed on the need for a set of common EU technical and organisational requirements.

In Phase II of the C-ITS platform, stakeholder worked together and agreed on the definition of a European Union C-ITS Security Credential Management System (EU CCMS) for C-ITS messages. The EU CCMS is described in two important documents 38 to enable secure and interoperable C-ITS Day 1 Service deployment in the EU:

·C-ITS Certificate Policy for Deployment and Operation of European C-ITS, which was published in June 2017. An update release 1.1 was agreed in June 2018.

·Security Policy & Governance Framework for Deployment and Operation of European C-ITS, published in December 2017.

2.3.4.Problem driver 4: Uncertainties regarding to minimum requirements for compliance assessment of C-ITS services

To ensure that C-ITS services function in a seamless way, it should be checked if C-ITS services and different types of C-ITS stations comply with service and system requirements. Otherwise non-functioning and potential damaging services and systems could be introduced, putting in jeopardy the reliability and trustworthiness of the entire C-ITS system.

Thus an effective compliance assessment framework needs to be set up that allows C-ITS services and different types of C-ITS stations to be checked against EU-wide system requirements. The C-ITS Platform Phase II report highlights the need for a common EU legal and technical framework to implement the proposed roles, requirements and processes for compliance assessment. Currently such a framework does not yet exist.

2.3.5.Problem driver 5: Uncertainty on how to comply with rules on privacy and protection of personal data

Data sent in C-ITS messages is already minimized and pseunodimised for technical and data protection reasons. Nevertheless, data sent in C-ITS messages from vehicles still qualifies as personal data - as data can be directly linked to the vehicle and indirectly to the identity of the vehicle owner - and is therefore related to an identified or identifiable natural person 39 . The risk of tracking individuals has been recognised as a particular issue that could hamper trust in C-ITS, and could lead to end-users and other stakeholders refraining from using or providing C-ITS, limiting its deployment.

From the perspective of the consumer, respondents in the 2016 Public Consultation were asked if they would give consent to allow C-ITS stations to broadcast their data and under which conditions. The responses received indicate that consent to broadcast data is not an overwhelming barrier among the participating stakeholders when:

·The data is being used only for C-ITS services (58% of respondents)

·To enhance safety (67%) or reduce congestion (64%)

·If the user has control at all stages over the sharing of his/ her data (39%), with some respondents caveating their support based on adequate safeguards being in place, and some indicating that different rules should apply according to the end use of the data.

Any successful C-ITS deployment must be compliant with the applicable legal framework for data protection (including the General Data Protection Regulation (GDPR - Regulation 2016/679) and, where applicable, the ePrivacy Directive (Directive 2002/58) 40 to increase trust among users. Data protection by design and data protection impact assessments are of central importance in basic C-ITS system layouts and engineering, especially in the context of the applied communication security scheme.

There is uncertainty among stakeholders on how they can comply with data protection requirements and what legal basis for lawfully processing personal data they can use in the context of C-ITS, given that it is a novel way of information exchange. Some stakeholders also fear that the data protection requirements might be applied differently across MS, hindering the efficient provision of EU-wide services, as these might need to be adjusted between MS.

Thus, stakeholders noted that the GDPR will require some of the previous work in this area to be rethought. There needs to be a clear understanding on how to comply with rules on privacy and protection of personal data, especially for safety-related applications where benefits cannot be generated unless the data is shared.

While both these concerns demand attention, it is important to remind that within the framework of the GDPR a number of mechanisms exist to ensure the consistent application of the data protection rules:

·First, it has to be recalled that the application of GDPR is based on the principle of accountability. Data controllers are responsible to implement the appropriate technical and organisational measures to ensure and be able to demonstrate that processing is performed in accordance with the GDPR.

·Second, the GDPR contains mechanisms to ensure a consistent approach by the data protection authorities on the application of the data protection rules within the EU (such as one-stop-shop and consistency mechanisms).

·Third, the European Data Protection Board has issued a number of guidelines, and will continue to issue guidelines where needed, to ensure a consistent application of GDPR.

In both phases of the C-ITS Platform, a dedicated working group analysed subject of data protection in C-ITS. The focus of the analysis in Phase II was on C-ITS Day 1 use cases in the context processing personal data in accordance with Article 5 of the GDPR. The analysis found that there currently is no law that justifies the processing of personal data for C-ITS, but a mix of contractual obligations between the Data Subject and the Data Controller and between the Data Controllers themselves could be an appropriate legal basis.

The working group then submitted their findings to the representative of the technology subgroup of Article 29 Working Party on the 10th of July 2017. An opinion was received in October 2017 41 , which indicates a number of actions required to support the lawful processing of personal data in the field of C-ITS.

2.3.6.Problem driver 6: Lack of coordination between relevant bodies

As discussed before, a wide range of stakeholders is involved in C-ITS, spanning across different means of road transport, the public sector and different industries, as well as local, regional, national and EU-level actors. With technology rapidly evolving and the public and private sector investing substantial amounts into developing and testing C-ITS technologies, there is a risk that, without adequate coordination, solutions will be developed in a fragmented and inefficient manner. In addition, this means risking that C-ITS do not function as they should, responsibilities for different parts of the system remain unclear, and smaller actors (local/regional authorities, SMEs) cannot get involved.

A lack of coordination across the EU could also hinder the necessary synergies between C-ITS and CCAM, as efforts could be duplicated or contrary to each other. The C-ITS Platform Phase II report identified the need for the European Commission to take enabling actions in order to assist Member States and other stakeholders in implementing C-ITS services and to coordinate this closely with CCAM activities.

Once deployment starts, there is also the need to support harmonized and synchronized implementation through increased cooperation between both public and private actors. Other complex telematics applications in other transport modes have shown the benefits of an effective governance in the implementation phase of such initiatives. Different levels of coordination should be considered to ensure:

·overall governance and supervision

·implementation and update of common specifications

·coordination of operational tasks

Stakeholders noted that the C-Roads Platform already provides some level of coordination and governance regarding deployment activities, but that further coordination is required at the EU level.

2.3.7.Problem driver 7: Uncertainty about business models 

The C-ITS market is not yet a mature market and across the EU, uncertainties exist around how sustainable business models for different stakeholders can be developed. This must be addressed to ensure public acceptance and widespread deployment. While the cost benefit analysis carried out for the 2016 C-ITS Deployment study has already shown that the potential benefits of C-ITS strongly outweigh the costs, these benefits will only materialise over time and depend strongly on coordinated and accelerated deployment.

Part of the issue is that a large part of these C-ITS benefits (increased safety, less time spent in traffic, lower fuel consumption) go directly to the users / society at large, while the costs of investment and operation need to be borne upfront by road operators and vehicle manufacturers. Moreover, the possibility to pass these costs on to users might be limited given the public nature of (some of) the benefits.

On the other hand, several stakeholders have additional incentives to deploy C-ITS which also have to be considered. Car manufacturers are continuously integrating new safety measures in vehicles, and C-ITS can be seen as the natural supplement of camera or radar based Advanced driver-assistance systems (not suffering from line-of-sight limitations and giving earlier warnings). A second reason is the potential of C-ITS to support and enable higher levels of automation. A third reason is that car manufacturers are also becoming service providers, and for vehicles to become a new service platform they need to be connected.

For telecommunication companies there is the potential to provide new services, connections and equipment to generate new revenue streams from connected vehicles. For public transport, the current set of services already includes the possibility to prioritize public transport at intersections, and work is being done to develop C-ITS services for rail intersections, increasing their safety.

As the deployment of C-ITS cannot rely on public funding alone and requires the involvement of stakeholders from different industries and the public sector, a common understanding of business models for deploying C-ITS, and their integration into broader CCAM functionalities, is needed. It is particularly important to ensure that there is a level playing field, which enables the development of attractive business models from a range of potential market actors.

The need for a clearly identified business model was further highlighted during stakeholder interviews. A representative from the C-Roads Platform considered the lack of a common business models for all stakeholders (manufacturers, service providers, authorities, and road operators) as the most important issue preventing C-ITS deployment. They noted that each group involved in deployment has to trust the others to deploy, or risk stranded investments. A representative from C-Roads France also noted that a lack of trust between stakeholders slows deployment, as each stakeholder is waiting for the other to deploy before they invest.

2.4.Most affected stakeholders

If C-ITS services are not deployed to their full potential, important positive impacts on road safety and traffic efficiency will not be achieved. This affects all road users, as road fatalities and serious injuries create suffering for those involved in the accidents and low traffic efficiency leads to significant time lost in traffic and associated increased CO2 and pollutant emissions. In addition, they create costs that are ultimately borne by society as a whole, including the costs of emergency services, health care costs and production losses. It will also be detrimental to road operators and traffic managers, who will have less access to new solutions which allow them to more efficiently manage their networks.

Delays to C-ITS deployment would put the European automotive and ITS industry at a disadvantage compared to its competitors, leading to lower levels of new business opportunities in the digitalisation of transport along with lower levels of job creation, and less significant research and innovation impacts on the overall European economy. As the jobs of millions of Europeans depend directly or indirectly on the automotive and wider transport industries, it is critical that the sector is provided with the conditions to keep up with global market players.

The telecom sector is also affected as C-ITS and CCAM services can use their cellular network and technologies to deliver services and this can thus constitute a new growth market.

2.5.How will the problem evolve?

If no action is taken, only 18% of the vehicle fleet is expected to be equipped with C-ITS by 2035, as stakeholder will not have the necessary certainty on the continuity and interoperability of C-ITS services to move to large-scale deployment. This expectation is based on literature review, expert judgement and stakeholder consultation and considered existing activities and industry announcements. 42

As a result the total number of accidents in the EU is expected to decrease from 1.46 million in 2015, to 1.35 million in 2030 and 1.30 million in 2035. While this is an improvement, it is not enough to reach the EU’s long-term goal of moving close to zero fatalities and serious injuries by 2050 (“Vision Zero”), with an interim target for serious injuries of minus 50% between 2020 and 2030.

Congested roads remain a huge issue in the baseline, with urban travel time costs in the EU expected to increase from €548.6 billion annually, to €618.5 billion annually in 2030 and €627.2 billion annually in 2035.

While emissions of CO2 and air pollutants are expected to decrease, road transport will remain a main source of these emissions, with annual CO2 emissions projected to decrease by 13 percent in 2030 and 15 percent in 2035 compared to 2015 43 . The NOx emissions are expected to decrease by 53 percent during 2015-2030 (60 percent for 2015-2035) while the PM emissions would go down by 38 percent during 2015-2030 (39 percent for 2015-2035) and VOC would decrease by 25 percent during 2015-2030 (24 percent for 2015-2035).

Note that the baseline for this impact assessment, assessed with the ASTRA/TRUST models, builds on the updated 2016 EU Reference scenario used in the impact assessments accompanying the new General Safety Regulation and Road Infrastructure Safety Management Directive proposals (GSR/RISM), but includes additional policy measures and initiatives related to C-ITS. The baseline scenario therefore assumes the application of the current GSR/RISM, as required by the Better Regulation principles.

There is little overlap between the technologies considered in the GSR/RISM baseline and the C-ITS services considered in this study, however there are some overlapping impacts. This is due to the overlapping effects between the impacts of the policies, in the same way as there is nearly always more than one factor in accident causation. Thus, the combined effect of improved road infrastructure, increased vehicle safety and C-ITS measures deployed together is going to be somewhat lower than the sum of their individual effects. In the GSR Impact Assessment, accidents (the only impact modelled) reduce by 7-8 percent in the policy options. To account for the overlap in impacts, we have reduced the benefits of C-ITS services on safety by 10 percent 44 across all C-ITS services in the baseline and policy options modelled.

3.Why should the EU act?

3.1.Legal basis

The Union has shared competence in the field of transport as set out in Article 4 of the TFEU. The ITS Directive is based on Article 91 of the TFEU. Article 6(3) of the ITS Directive requires the Commission to adopt specifications ensuring compatibility, interoperability and continuity for the deployment and operational use of ITS for other actions in the priority areas, including action 4.1.2: The definition of necessary measures to further progress the development and implementation of cooperative (vehicle-vehicle, vehicle-infrastructure, infrastructure-infrastructure) systems.

3.2.Subsidiarity: Necessity of EU action

While C-ITS services are currently already being deployed through projects across the EU, and several Member States and a large number of vehicle manufacturers have already indicated their intention to move to large-scale deployment, many of them have indicated that a legal framework at the EU level is needed. Industry-led standardisation through the ESOs contributes to interoperability, but it is voluntary by nature and can allow for different, non-interoperable implementations, and with some many different actors and strong network effects, no actor can introduce an interoperable solution on its own. This was already recognized in the 2009 standardisation mandate, which indicated that to ensure EU-wide interoperability, essential parts of the standards would need legal enforcement measures. Similarly, setting rules at the national level would likely hinder the provision of continuous C-ITS services in the Single European Transport Area.

Compatibility between infrastructure and vehicle solutions will need to be assured across the EU in order to fully benefit from C-ITS. In addition, to ensure effective synergies with the deployment of new safety technologies and the roll-out of CCAM across the EU a more harmonised approach at EU level is likely needed.

The business case for C-ITS being difficult as it is, no vehicle manufacturers would consider deploying in a small market. Only when reassurance is given that harmonisation is achieved at EU level, implying also, crucially, that vehicles will benefit from infrastructure services all across the Union, does deployment make sense. Similarly, though the business case is calculated differently for the public sector, it makes no sense to invest unless large portions of the fleet are expected to be equipped in the near future.

Thus, without an EU level framework, deployment is expected to remain fragmented and uncoordinated and cannot provide geographical continuity of C-ITS services throughout the Union and at its external borders.

3.3.Subsidiarity: Added value of EU action

The main benefits of EU action lie in the continuous C-ITS services across the EU which the initiative aims to achieve. Travel throughout the EU should become safer and more efficient, whereby less advanced Member States will be able to benefit from the experience of more advanced Member States. This should in turn improve the functioning of the internal market, through a smoother and more coherent travel experience for passenger and freight transport, and support the EU's objective of economic, social and territorial cohesion.

A framework for continuous C-ITS services, supported by a broad group of stakeholders, would also help create a supportive ecosystem for the research and innovation in new C-ITS services and technologies, and the introduction of CCAM in the EU, improving the EU’s international competitiveness in this field.

4.Objectives: What is to be achieved?

4.1.General objectives

This initiative aims to establish a clear framework to support interoperable deployment, by the private and public sector, and uptake of C-ITS services across the EU.

This should help increase the continuity of C-ITS services across the EU, which in turn will help significantly improve road safety and traffic efficiency. It should further improve the contribution from the transport sector to the reduction of CO2 and air pollutant emissions and contribute to competitiveness and growth. In addition, the availability of interoperable and continuous C-ITS services will also serve as a crucial step for the deployment of CCAM.

4.2.Specific objectives

To achieve this general objective, three specific objectives have been defined:

SO1: to ensure interoperability and continuity of C-ITS services across the EU.

SO2: to reduce barriers and uncertainties to enable large-scale deployment of C-ITS.

SO3: to provide an enabling environment to support pre-commercial deployment and enable the development of attractive business models.

These specific objectives are directly linked to the main problems identified in section 2. Overall, there are strong synergies between the objectives. Ensuring interoperability and continuity, and removing uncertainties, will give stakeholders certainty that when they invest in C-ITS equipment or the deployment or development of new C-ITS services, there is a readily available sustainable eco-system with many users across the EU supported by a clear operational framework, which will make the development of attractive business models much more likely. On the other hand, the design of the measures has to be such that they ensure a common approach, but also support and not needlessly restrict innovation, in line with the principles for specifications and deployment of ITS set out in Annex II of the ITS Directive.

5.What are the available policy options?

Based on the impact assessment support study and on contacts with stakeholders (through targeted consultations, the open public consultation, and meetings), the Commission has identified a number of policy measures in line with the specific objectives of the initiative, to address the main problem drivers as listed above.

These policy measures have been combined into policy packages (options). In the development of the policy options, the principles of proportionality, efficiency and effectiveness have been the guiding principles.

5.1.Description of the retained policy measures

Based on literature research and stakeholder input, a long list of policy measures was developed. To help identify and prioritise which measures from the long list should be retained, a scoring system based on a Multi Criteria Analysis (MCA) framework was used. 45 For each of the measures the following criteria were assessed: Technical feasibility, Legal feasibility, Societal acceptance, Effectiveness, Efficiency, Proportionality, Relevance and EU added value.

After this preliminary assessment, 22 policy measures were retained. The retained policy measures are presented below organised according to the main problem driver that they aim to address.

Problem driver 1: Lack of common definition / priority of C-ITS services

No.

Policy measures and policy measure description

1

Non-binding guidelines to support the provision of interoperable Day 1 services 

The Commission would publish non-binding guidelines on its website on the basis of existing standards on interoperability and EU-wide service profiles 46 and system profiles 47 (such as those published by CAR2CAR and C-ROADS).

2

Definition of Day 1 services and their profiles in binding specifications + requirement for other services to be compatible with all Day 1 services

The Commission would define a list of Day 1 services and require that when these are implemented they are implemented according to their service profile, to ensure that they can always be interpreted in the same way. Other services have to be compatible with the day 1 services, to ensure that they do not interfere (e.g. by not using the same data elements for different purposes) with the provision of Day 1 services.

Problem driver 2: Uncertainties regarding minimum requirements for interoperability of C-ITS stations (including on communication technologies)

No.

Policy measures and policy measure description

3

Mandate compliance with EU-wide system profiles in specifications

The Commission would define types of C-ITS stations and their system profiles, and require that C-ITS stations are implemented according to their system profile, to ensure that they can communicate in an interoperable and compatible way. C-ITS stations have to be compatible with the day 1 services, to ensure that they do not interfere with the provision of Day 1 services.

At this stage, the system profiles would be based on the current hybrid approach, combining mature 3G/4G and ITS-G5 technology. At the same time the integration of future technologies is foreseen through a review clause to integrate interoperable and complementary solutions.

4

Mandate to EU level standardisation organisations for further standardization.

The Commission would give an updated mandate to the European Standardisation Organisations to further the standardisation of C-ITS stations and services to improve interoperability, including the integration of new types of stations, services, and technologies.

5

Mandatory deployment of V2V communication

The Commission would mandate vehicle manufacturers to fit all new vehicles with C-ITS stations to deliver (a number of) Day 1 C-ITS services. This measure would come on top of specifications in a delegated act, for instance through a revision of the General Safety Regulation 48 or a separate legal instrument (similar to the eCall approach). This would ensure all new vehicles are capable of delivering and receiving C-ITS messages, strongly increasing the continuity of C-ITS services across the EU.

Problem driver 3: Barriers to establishing the necessary trust with regard to cyber security of C-ITS communications

No.

Policy measures and policy measure description

6

Non-binding guidelines on the European Union C-ITS Security Credential Management System (EU CCMS)

The Commission would publish non-binding guidelines on its website based on existing published documents (the Certificate Policy (CP) & Security Policy (SP)). Participants in the C-ITS network in Europe would need to adhere to these documents, however it would not be legally binding.

7

Binding rules on the European Union C-ITS Security Credential Management System (EU CCMS)

The Commission would adopt binding specifications on the EU CCMS, ensuring the participants in the C-ITS network in Europe fulfil the requirements of the common trust model and that one common interoperable security solution is used, by requiring that every C-ITS station is enrolled in the EU CCMS

This would also include a review clause based on security assessment and technological progress.

Problem driver 4: Uncertainties regarding minimum requirements for compliance assessment of C-ITS services

No.

Policy measures and policy measure description

8

Non-binding guidelines on the compliance assessment process for Day 1 C-ITS services

The Commission would adopt guidelines on the compliance assessment process. It will recommend Member States and other stakeholders to check compliance against the specifications but follow-up actions are not specified and this cannot serve to "approve" C-ITS stations.

9

Definition of compliance assessment criteria for Day 1 C-ITS services + conformity assessment procedure based on internal production control

The Commission would introduce binding specifications on the compliance assessment process. The conformity assessment procedure would be based on internal production control, i.e. the manufacturer checks the conformity of a C-ITS station during both the design and production phase.

10

Definition of compliance assessment criteria for Day 1 C-ITS services + conformity assessment procedure based on external conformity assessment

The Commission would introduce binding specifications on the compliance assessment process. However, in contrast with measure 9, the conformity assessment would be carried out by an external conformity assessment body, ensuring that the assessment is both impartial and independent. This measure would require a legal instrument through co-decision.

Problem driver 5: Uncertainty on how to comply with rules on privacy and protection of personal data

No.

Policy measures and policy measure description

11

Non-binding guidance on the processing of personal data in the context of C-ITS

Building on the opinions and guidelines of the European Data Protection Board, the Commission would publish non-binding guidance on the processing of personal data in the context of C-ITS (underlining the roles and responsibilities of actors, and the requirements applicable to them under GDPR).

In addition the Commission would do a state-of-play of what C-ITS actors do/have done in respect of privacy and data protection (including data protection impact assessments). 

12

Define the purposes for lawfully processing personal data as traffic safety & efficiency, restricting other uses.

The Commission would introduce binding specifications identifying the purposes for lawfully processing personal data in the context of C-ITS as traffic safety and efficiency, while restricting the use of personal data for other purposes.

All these specifications should be without prejudice to the General Data Protection Regulation.

13

Introducing a legal basis for the lawful processing of personal data in C-ITS

The introduction of a legal instrument through co-decision (i.e. on top of specifications in a delegated act, for instance through the V2V mandate (measure 6)) can introduce a legal ground for the processing of personal data related to C-ITS, which would clarify the reasons and simplify the approach to processing C-ITS messages.

Problem driver 6: Lack of coordination between relevant bodies

No.

Policy measures and policy measure description

14

Coordination and Policy Advice through stakeholder platform

The Commission would set-up a cooperative framework including national authorities and C-ITS stakeholders in the form of a Commission Expert Group, in view to further develop a shared vision and guidance on the interoperable deployment of C-ITS in the EU. This would improve knowledge sharing and cooperation, similar to what was done in the C-ITS platform.

15

Enhanced deployment coordination

This would be a more elaborate coordination structure than policy measure 14, including the coordination of deployment projects (such as is currently done in C-ROADS) and the implementation and preparation of revisions of the delegated act.

This will ensure that lessons learnt will be shared across projects. This will help follower countries to access lessons learned from front runner countries and accelerate their uptake. Coordination of deployment will also help ensure that the most effective services are deployed in a similar manner.

16

Non-binding guidelines on governance framework/bodies

To implement C-ITS, a governance framework with several bodies with clearly defined roles is needed, for instance for implementing the security and certificate policy and the compliance assessment process. This will also contribute to improve coordination and cooperation across the EU.

Non-binding guidelines would identify the needed bodies, their roles and the tasks to be carried out, building on the work on the governance framework already carried out under the C-ITS platform and published in the security policy.

Non-binding guidelines would however not ensure that all necessary bodies are set up, operating in the expected way or recognized by all stakeholders.

17

Definition of needed roles in specifications + requirement to report to the Commission on the bodies/authorities in charge.

Instead of the non-binding guidelines in measure 16, the roles and tasks would be defined in legally binding specifications and MS and/or stakeholders setting up these bodies would be required to report this to the Commission.

This will increase transparency and public knowledge, however it would still not ensure that all necessary bodies are set-up.

18

Definition of needed roles in EU law + Assignment of roles to legal bodies

This measure would require that all roles and tasks in the governance framework are assigned and carried out by new or existing legal bodies (e.g. the governance body, supervision body and the security & certificate policy authorities foreseen in the governance framework of the Security Policy). In this way it can be ensured that all essential tasks for managing the C-ITS network in Europe are carried out, and in case of the set-up of European-wide bodies, efficiency gains could be achieved. This measure requires a legal instrument through co-decision.

Problem driver 7: Uncertainty about business models and integration in CCAM

No.

Policy measures and policy measure description

19

Memorandum of Understanding (MoU) between key stakeholders

The EU could support MoUs between key stakeholders to set deployment strategies and targets, given that some MoUs in the area of C-ITS already exist (e.g. between C-Roads and the Car2Car Communication Consortium, and in the context of the letter of intent for CCAM).

This would support coordinated deployment. However, as MoUs are non-binding agreements, actual deployment is uncertain.

20

Funding for development of services beyond the Day 1 list

The Commission would support the development of new future C-ITS services, with an increased focus on services for VRUs and public transport, and the link with CCAM through the continuation of research funding. This would contribute to continued technological development focusing on EU policy objectives.

21

Funding of deployment based on specifications to enable quicker uptake, including requirement on data reporting and sharing for deployment projects

Funding would be provided for the coordinated deployment of mature C-ITS services and equipment based on common specifications to support continuity of services. Funding would be linked to data reporting and sharing obligations (for instance building on the current collaboration between C-ROADS projects, not sharing sensitive business information), to improve monitoring and knowledge sharing.

5.2.Measures discarded at an early stage

The policy measures that were included in the preliminary analysis but were later discarded are presented below providing also the reasons for discarding them.

No.

Policy measures and policy measure description

Reason for discarding

N1

Mandate mature communication technologies (with exception for pilot technologies, cf. EETS Directive)

This measure would require C-ITS stations to operate only using mature and proven communication technologies. This would provide added certainty of the interoperability between C-ITS stations, however it would unnecessarily restrict technological development, and less stringent measures have been included.

N2

Requirement for repository of digital Traffic Management Plans and Traffic Circulation Plans, to be available via National Access Points

The topic of traffic management is relevant for C-ITS, but not directly covered by Day 1 C-ITS services. These measures could be reconsidered/developed under the stakeholder platform. Separate measures on this topic are discarded.

N3

Develop building blocks for digital Traffic Management Plans and Traffic Circulation Plans and the deployment of Cooperative Incident Management

The topic of traffic management is relevant for C-ITS, but not directly covered by Day 1 C-ITS services. These measures could be reconsidered/developed under the stakeholder platform. Separate measures on this topic are discarded.

N4

Human-machine interface functionalities for safety time-critical situations should be harmonised: pictogram formats, colours or positions, auditory warning sounds, haptic warnings.

Very relevant for the functioning of C-ITS, but not within the scope of interoperability of V2V-V2I messaging (thus context, rather than measure in this initiative).

N5

Inclusion of C-ITS stations in EuroNCAP rating

Including C-ITS services in the European New Car Assessment Programme would provide consumers with information on the safety benefits of C-ITS and increase acceptance which could lead to higher demand and thus consumer driven uptake. However, this is an industry action which is not in the remit of the Commission.

N6

Binding application specifications for the GDPR in the context of C-ITS, including the responsibilities and requirements

The possibility of adding binding application specifications is very limited, as the GDPR should not be interpreted through other legislation. Relevant aspects of this measure have been integrated in measure 15.

5.3.Description of the policy options

The retained policy measures were combined into three policy options (PO) (in addition to the baseline scenario (Policy Option 0)), which address all policy objectives and problem drivers, but with different levels of ambition. The precise measures and level of ambition of each policy option are described below.

All policy options are compared to the baseline scenario (Policy option 0). Due to the complementary nature of the measures, Options 1 to 3 are alternatives, but build on one another in an incremental way.

5.3.1.PO0: Baseline scenario

Policy option 0 reflects developments under current trends and adopted policies (i.e. the baseline scenario) as described in section 2.5. No further action at EU level is assumed in policy option 0.

As the Commission has a legal obligation to adopt specifications on cooperative systems (in line with Article 6(3) and Annex I of the ITS Directive), the baseline is not a valid policy option but serves for comparative purposes only.

5.3.2.PO1: Light intervention based on non-legislative measures

PO 1 covers minimum change at minimum cost, including non-legislative, "soft" measures which are relatively easy and quick to implement. It builds on the baseline scenario and includes non-binding guidelines on the interoperability of Day 1 services, secure communication, data protection and compliance assessment. Continued technological development is supported by continued R&I funding for the development of new C-ITS services and a renewed standardisation mandate to the ESOs. Coordination between the stakeholders at the EU-level would be a continuation of the informal C-ITS platform.

While this option does not provide the legal framework foreseen in the C-ITS Strategy, and thus will be less effective in achieving the objectives, this option is retained in the analysis, as in the consultations, there was broad support for non-legislative measures as proposed in this option. At the same time a large share of respondents acknowledged that non-legislative measures would only have a limited effect on addressing the problem drivers and thus the deployment and interoperability of C-ITS, and considered more binding measures would be more effective.

5.3.3.PO2: Moderate intervention based on specifications under the ITS Directive

This policy option is based around legally binding specifications through a delegated act. It is a more stringent option than PO 1, to ensure that C-ITS services deployed in line with these specifications are interoperable across the EU. Nevertheless, Member States and industry retain the free choice to deploy C-ITS. To achieve this, it would in particular require all C-ITS stations to be based on, or compatible with, the current hybrid approach, combining mature 3G/4G and ITS-G5 technology (measure 3) and to be part of the common trust model (measure 7). The integration of future solutions and technologies would be foreseen through a review process, which can introduce updated standards and specifications including new technologies and services. To stimulate the continuity of C-ITS services across the EU, deployment coordination and funding is reinforced at the EU level.

In the public consultation, legally binding specifications were seen by the largest group of respondents to be most appropriate to achieve the objectives, but at the same time many respondents also indicated it as the least appropriate for some objectives. This difference was also reflected in the comments that indicated a need for further clarification of how the measures would exactly work and to ensure that legal measures are proportionate. Important splits could be seen in relation to security where many stakeholder groups preferred binding specifications, but ITS service providers preferred an industry-led approach and in relation to interoperability, where many also preferred binding specifications, but none of the ITS service and telecommunications providers. This is to be expected, as ITS service providers do not want the specifications to restrict other ITS services, and telecommunications providers intend to introduce competing C-ITS technology.

5.3.4.PO3: Strong intervention based on V2V mandate + set-up of governance bodies

This policy option builds further on the legally binding specifications of PO2, by adding a V2V mandate to ensure that all new vehicles will be equipped with C-ITS stations, drastically increasing the uptake rate and thus meeting the threshold for effective service delivery – related to the network effect – much quicker.

As the V2V mandate would require a legislative measure, this policy option also includes additional measures that support the deployment of C-ITS and which cannot be introduced through a delegated act alone:

·The introduction of a legislative measure can introduce a legal ground for the lawful processing of personal data related to C-ITS. This will likely result in the provision of more C-ITS services, by reducing the uncertainty for stakeholders.

·The assignment of governance roles to legal bodies will further ensure coordination and oversight on C-ITS deployment, thus ensuring that barriers to C-ITS uptake are reduced to a minimum.

This option would follow the step-wise approach foreseen in the ITS Directive, in which specifications can be followed-up by a separate proposal for deployment. This also ensures that the scope of the system is clearly defined through specifications, before the implications of deployment are considered in more detail. It is important to note, that this second step is not part of the current initiative, and would require a separate proposal accompanied by an additional impact assessment.

Mandatory deployment of V2V communication will significantly increase overall C-ITS deployment. High levels of uptake of V2V services are also expected to trigger enhanced C-ITS infrastructure deployment, because the guaranteed uptake in vehicles will increase the certainty and attractiveness of infrastructure investments.

When asked if C-ITS equipment should be mandated in vehicles and/or on different parts of the road network to accelerate deployment, respondents were moderately favourable (45-64% (strongly) agreed), with many respondents indicating that mandates would provide the needed certainty about deployment, but specific circumstances and the maturity of the system should be reconsidered before defining mandates. Some respondents also noted that mandating deployment can be difficult given the pace of technological change in the industry, and the lack of agreement on which communications technology to use.

Stakeholders interviewed for the deployment case studies were supportive of the establishment of EU governance, policy and operational bodies, as this was considered important in coordinating deployment across Europe. They largely felt that the C-Roads Platform is helping in this regard, but as deployment continues this will need to be further formalised.

Table 1: Linking policy measures to policy options

No.

Measure

PO1

PO2

PO3

Problem driver addressed

Specific objective addressed

1

Non-binding guidelines to support the provision of interoperable Day 1 services

x

D1/2

SO1/2

2

Definition of Day 1 services and their profiles in binding specifications + requirement for other services to be compatible with all Day 1 services

x

x

D1/2

SO1/2

3

Mandate compliance with EU-wide system profiles in specifications

x

x

D2

SO1/2

4

Mandate to EU level standardisation organisations for further standardization.

x

x

x

D2

SO1/2

5

Mandatory deployment of V2V communication

x

D2

SO1/2

6

Non-binding guidelines on the European Union C-ITS Security Credential Management System (EU CCMS)

x

D3

SO1/2

7

Binding rules on the European Union C-ITS Security Credential Management System (EU CCMS)

x

x

D3

SO1/2

8

Non-binding guidelines on the compliance assessment process for Day 1 C-ITS services

x

D4

SO1

9

Definition of compliance assessment criteria for Day 1 C-ITS services + conformity assessment procedure based on internal production control

x

D4

SO1

10

Definition of compliance assessment criteria for Day 1 C-ITS services + conformity assessment procedure based on external conformity assessment

x

D4

S01

11

Non-binding guidance for the processing of personal data in the context of C-ITS

x

D5

SO2

12

Define the purposes for lawfully processing personal data as traffic safety & efficiency, restricting other uses.

x

x

D5

SO2

13

Introducing a legal basis for the lawful processing of personal data in C-ITS

x

D5

SO2

14

Coordination & Policy Advice through stakeholder platform

x

x

x

D6/7

SO1/2/3

15

Enhanced deployment coordination + Fund EU deployment coordination after current piloting phase

x

x

D1/6/7

SO1/2/3

16

Non-binding guidelines on governance framework/bodies

x

D6

SO1/2

17

Definition of needed roles in specifications + requirement to report to the Commission on the bodies/authorities in charge.

x

D6

SO1/2

18

Definition of needed roles in EU law + Assignment of roles to legal bodies

x

D6

SO1/2

19

MoUs between key stakeholders

x

x

x

D7

SO3

20

Funding for development of services beyond the Day 1 list

x

x

x

D7

SO3

21

Strengthen funding of deployment based on specifications to enable quicker uptake, including requirement on data reporting and exchange for deployment projects

x

x

D1/7

SO1/2/3

6.What are the impacts of the policy options? 49

The main impacts of the initiative are expected to be social, economic and environmental, whereby most benefits are expected to materialise in the form of a reduced number of accidents, travel time and fuel consumption resulting from the increased deployment of C-ITS services. The most significant costs will be incurred through deployment of C-ITS stations, in particular in vehicles.

The expected impacts of the policy options are strongly driven by the deployment of C-ITS stations and services. The deployment assumptions are thus important, in particular in PO1 and PO2 that solely rely on voluntary deployment. That is why these assumptions been developed with a close consideration of the impact mechanisms of the various policy measures, and build on significant expert input and stakeholder consultation that started in 2015. The expected deployment of C-ITS stations is described below. 50  

A model suite has been used for assessing the impacts. The first module of the modelling is a calculation of penetration rates for new vehicles, personal C-ITS devices and infrastructure. The penetration rates are then combined with impact data for different C-ITS services in the scenario module developed by the consultant RICARDO. The outputs from the scenario module, are then run through the macro-economic ASTRA/TRUST modelling framework, a strategic model based on the Systems Dynamics Modelling approach. The outputs from these two models are then processed and combined into RICARDO’s cost-benefit analysis (CBA) model to produce final outputs.

The assumptions used in the quantification of each policy option are provided in Annex 4 "Analytical methods" and further detailed in the Impact Assessment Support Study.

Table 2: Cumulative deployment of C-ITS stations in 2035

Deployment of C-ITS stations

Baseline

PO 1

PO 2

PO 3

New vehicles equipped (vehicles) 51

66.1 mn

76.9 mn

135.0 mn

186.7 mn

Personal C-ITS devices equipped

114.4 mn

134.3 mn

177.9 mn

131.2 mn

Total vehicles equipped

180.6 mn

211.2 mn

312.9 mn

317.9 mn

Infrastructure upgraded (RSU)

40000

121,000

181,000

181,000

New infrastructure deployed (RSU)

8000

21,000

142,000

189,000

Central C-ITS stations deployed

320

370

440

440

Total infrastructure equipped

48,000

142,000

323,000

330,000

Figure 3: Number of C-ITS equipped vehicles

PO 1 is expected to have a small positive impact on deployment. In 2035, an extra 30 million vehicles (new vehicles plus retrofits via personal C-ITS devices) and 94,000 RSUs are expected to be equipped relative to the baseline, with a significant share of the overall fleet still not equipped in 2035. PO2 has significant positive impacts (an extra 132 million vehicles and 275,000 RSUs equipped) reaching 95% coverage in 2035, and PO3 very significant impacts, (an extra 137 million vehicles and 282,000 RSUs equipped), reaching 95% coverage in 2029 due to the V2V mandate.

6.1.Social impacts

Impacts on road safety

A main effect of the policy options is the reduction in the number of road accidents, as several C-ITS services (such as traffic jam ahead warning, hazardous location notification, in-vehicle speed limits, intersection safety etc.) specifically aim to improve road safety and to decrease both the number and severity of accidents.

Despite the large numbers of accidents avoided in the baseline scenario, significant further benefits are observed for all of the policy options.

Table 3: Cumulative accidents and accident costs avoided relative to the baseline for the EU – by accident type, 2030 and 2035 for PO1, PO2 and PO3

Accident Type

2020-2030

2020-2035

Cumulative accidents avoided relative to the baseline

Present value of accident cost avoided relative to the baseline

Annual accidents avoided relative to the baseline

Cumulative accidents avoided relative to the baseline

PO1

Fatalities

1,300

€2 bn

3,700

€4 bn

Serious injuries

15,000

€3 bn

46,000

€8 bn

Minor injuries

69,000

€1 bn

199,000

€3 bn

Total

85,000

€6 bn

249,000

€15 bn

PO2

Fatalities

5,500

€8 bn

14,100

€17 bn

Serious injuries

54,000

€11 bn

152,000

€27 bn

Minor injuries

260,000

€4 bn

700,000

€10 bn

Total

320,000

€23 bn

866,000

€53 bn

PO3

Fatalities

9,500

€13 bn

20,900

€26 bn

Serious injuries

88,000

€18 bn

209,000

€38 bn

Minor injuries

435,000

€7 bn

992,000

€14 bn

Total

533,000

€38 bn

1,222,000

€77 bn

Note: Accidents have been rounded to the nearest 1,000, save for fatalities, which is rounded to the nearest hundred.

PO1 would result in a reduction of 3,2% in the number of accidents compared to the baseline in 2035, or an annual reduction of 4,2 billion euros in social costs (or a reduction of 1.0% of the PV of accident costs, or 15 billion euros, between 2020 and 2035). At Member State level the impacts on accidents range between a 2,2% reduction in Poland and a 4,8% reduction in Luxembourg. While there are numerous factors that underlie this difference between Member States, which cannot be separated out in the modelling, an important factor seems to be speed of fleet renewal, with MS such as Belgium and Luxembourg with high fleet renewal showing larger benefits.

PO2 would result in a reduction of 10,4% in the number of accidents compared to the baseline in 2035, or an annual reduction of 13,6 billion euros in social costs (or a reduction of 3,5% of the PV of accident costs, or 53 billion euros, between 2020 and 2035). At Member State level the impacts on accidents range between a 7,8% reduction in Poland and a 12,7% reduction in Luxembourg.

PO3 would result in a reduction of 11,9% in the number of accidents compared to the baseline in 2035, or an annual reduction of 15,6 billion euros in social costs (or a reduction of 5,0% of the PV of accident costs, or 77 billion euros, between 2020 and 2035). At Member State level the impacts on accidents range between a 9,5% reduction in Poland and a 14,3% reduction in Luxembourg.

While all three policy options deliver a reduction in social costs by 2035 (expressed as present value), the impacts of PO2 and PO3 are 3 to 4 times larger than the impact of PO1.

Impacts on vulnerable road users

A considerable proportion of road accidents currently affect Vulnerable Road Users (VRUs); in 2015, 29 percent of all road deaths were pedestrians and cyclists. 52

Whilst a number of the Day 1 services being deployed in the policy options are aimed at improving safety generally, none of them are specifically aimed at the safety of pedestrians and cyclists. Several stakeholders already foresee the development of specific Day 1.5 services to protect VRUs building on the same C-ITS architecture. However, these services are not yet mature enough to be considered in service specifications or the assessment of impacts. The funding for the development of services beyond Day 1 in all policy options and additionally the coordination mechanisms included in PO2 and PO3 could support this.

Stakeholders advocate that C-ITS that enables interaction between all vehicles – including bicycles – is expected to have potential significant benefits for road safety, including for VRUs. However, it was considered that several issues need to be actively addressed, for instance avoiding that C-ITS are a distraction to the drivers and reducing the risk to VRUs during the introduction and transitional stages towards automated driving.

In this light, more consideration of other modes (including VRUs) in the development of C-ITS could be of wider benefit and better help cities to deliver modal shift. The funding for the development of services beyond Day 1 in all policy options and additionally the coordination mechanisms included in PO2 and PO3 could support this. Concluding, all policy options have a limited impact on the safety of VRUs based on the deployment of Day 1 C-ITS services, while PO2 and PO3 can have a small impact through the coordinated development of additional C-ITS services with specific benefits for VRUs.

6.2.Economic impacts

Investment and operating costs

In the deployment of C-ITS technologies, an important cost factor consists of C-ITS equipment for new vehicles, personal C-ITS devices, roadside infrastructure upgrades, new roadside infrastructure, and central sub-systems. This also includes operating costs such as software development, maintenance, data communications and secure communications.

Table 4: Present value of equipment costs relative to the baseline for EU28 – 2030 / 2035

Scenario

PV 2020-2030

Additional PV costs relative to the baseline in 2030

PV 2020-2035

Additional PV costs relative to the baseline in 2035

Baseline

€9.6 bn

-

€17.7 bn

-

PO1

€12.5 bn

€2.8 bn

€22.6 bn

€4.9 bn

PO2

€20.9 bn

€11.3 bn

€36.8 bn

€19.1 bn

PO3

€30.7 bn

€21.1 bn

€50.0 bn

€32.3 bn

To illustrate the relative importance of different cost items, Figure 4 shows a breakdown of the annual equipment costs each year (in present value terms) relative to the baseline. In all three policy options, in-vehicle C-ITS equipment (new vehicles + personal C-ITS devices) represent the large majority of costs, compared to infrastructure C-ITS equipment. Annual total equipment costs generally increase year on year for PO1 and PO2, but in PO3 they peak in 2028, which is the point at which 100 percent of new vehicles in the fleet have been equipped. 53

Figure 4: Total annual equipment costs: Composition of costs relative to baseline for EU 28

Looking at the distribution of these costs, if we assume that infrastructure costs are borne by the public sector and vehicle & personal C-ITS device costs by the private sector (manufacturers could increase prices to shift (part of) these costs to consumers), most costs are assigned to the private sector (77%, 87% and 91% of total cost in 2035 in PO1, PO2 and PO3 respectively).

Compliance costs

Under PO1, compliance with the guidelines is voluntary and as such, there are no significant compliance costs. PO2 and PO3 put in place a number of legal requirements that have associated compliance costs:

·Security (PO 2&3): the costs associated with the set-up and operation of the CCMS. In the early deployment phase the costs of the common elements are financed through the Connecting Europe Facility, but it is still to be determined how these costs will be covered in the future. The costs of secure communication have been estimated to be only a small part of the overall cost of a C-ITS station 54 and are included in the equipment cost estimates.

·Interoperability (PO 2&3): There will be some costs associated with making existing C-ITS stations compatible with the specifications. However, this only affects a relatively limited number of stations, which will not be interoperable otherwise. Likewise, stakeholders intending to integrate new services or technologies (such as LTE-V2X) into the C-ITS network could incur costs to ensure compatibility with the specifications.

·Governance bodies (PO3): In PO3 governance bodies would be set up, which would require funding. If these are set-up through EU legislation, the costs would also likely be covered at the EU level, and the costs for Member States and C-ITS stakeholders would be limited to participation.

·V2V mandate (PO3): In case of a V2V mandate, the costs associated with in-vehicle C-ITS devices, a very significant part of overall equipment costs (EUR 57 billion out of EUR 78 billion), should be considered compliance costs.

Administrative costs

In PO2 and PO3 55 there are administrative costs associated with the compliance assessment of C-ITS stations, which will fall predominantly on the manufacturer of the C-ITS station, but also on public authorities in the form enforcement costs. However, these costs are considered to be small compared to the overall costs of C-ITS stations, and in the absence of a mandatory compliance assessment process (i.e. in the baseline and PO1), stakeholders would still require reassurance on the functioning of C-ITS stations of other actors.

Additionally, measure 17 (PO2) and measure 21 (PO 2&3) include a reporting obligation on C-ITS bodies and authorities, and on EU funding projects. However, the associated administrative costs are considered insignificant compared to the overall costs of the policy option.

Urban travel time

Some Day 1 C-ITS services reduce urban travel time, namely Hazardous location notification (HLN) and Traffic signal priority request by designated vehicles (TSP). These represent relatively modest reductions in overall annual urban travel time (0,12%, 0,70% and 1,61% in 2035 compared to the baseline for PO1, PO2 and PO3 respectively), but given the high number of hours lost in traffic (and the fact that this is increasing under the baseline scenario), the monetary value of these savings is significant. 56 Furthermore, the introduction of Day 1.5 services is expected to make a significant additional contribution to the reduction of urban travel time. 57

Table 5: Present value total urban travel time savings relative to the baseline for the EU28 – 2030 / 2035

Scenario

PV 2020-2030

PV 2020-2035

PO1

€0.5 bn

€2.0 bn

PO2

€2.5 bn

€10.8 bn

PO3

€7.7 bn

€28.2 bn

Fuel consumption

C-ITS services aimed at smoothing out uneven traffic flow and at reducing urban travel time (e.g. hazardous location notification and traffic signal priority) will additionally lead to a reduction in fuel consumption. Again, these represent relatively modest reductions in overall fuel consumption (PV 2020-2035 fuel consumption costs 58 reduced by 0,1%, 0,4% and 0,7% in PO1, PO2, PO3 respectively compared to the baseline), but the monetary value of these savings is significant.

Improvements in transport efficiency, leading to lower travel times and fuel consumption, can induce increased transport demand, negating some of these benefits (the so-called rebound effect). The model suite used for this Impact Assessment includes feedback loops that reflect this.

Table 6: Present value fuel costs and savings relative to the baseline for EU28 – 2030 / 2035

Scenario

PV 2020-2030

PV 2020-2035

PO1

€1.1 bn

€2.5 bn

PO2

€4.9 bn

€11.2 bn

PO3

€9.2 bn

€18.2 bn

As a result of this reduced fuel consumption, fuel duty revenues are also expected to reduce.

Table 7: Annual fuel duty revenue changes by policy option relative to the baseline for the EU28 – 2030 / 2035

Other economic impacts

Another impact is new job creation related to the manufacturing, installation, maintenance and operation of new C-ITS technologies. The total direct and indirect jobs created are positive but limited: 17.850, 68.810 and 85.370 in 2035 under PO1, PO2 and PO3 respectively. 59 Stakeholder responses in the Public Consultation (PC) were positive on the potential employment impacts of C-ITS. When asked about the impact of the likely new services that will come into the market due to C-ITS and create new jobs, nearly all respondents agreed with the statement that new jobs would be created as a result.

Regarding research & innovation, as C-ITS deployment means an increase in firms sharing electronic data and using ICT, it is expected that companies participating in the market would benefit from increased product innovation. In responses to the Commission’s Public Consultation, most stakeholders (106 out of 135) agreed with the Commission’s suggestion that the deployment of C-ITS will have a positive impact on research and innovation. 60

Many of the case studies show a lot of research and innovation in C-ITS and suggest that the new information made available by C-ITS could lead to innovation as companies identify new ways of using these data. A clearer framework for C-ITS deployment and future funding in Policy options 2 and 3 may further improve R&I impacts compared to the baseline.

An important consideration here is also the link between C-ITS, new technologies and other ITS applications. The creation of a common, interoperable C-ITS network is crucial to create positive network effects and a sustainable eco-system supporting innovation. At the same time, setting specifications (in particular if they are legally binding), requires new technologies to adapt to these specifications, creating potential barriers for their introduction. That is why on open system, based on review of the specifications to integrate new, mature technologies, and ensure synergies with other ITS applications should be at the basis of all policy options.

SMEs are likely to play a significant role in C-ITS, as SMEs are well represented in both the supply of C-ITS technologies, and as data and transport companies; SMEs are also active participants in the current C-ITS deployment projects. In the Public Consultation a number of stakeholders considered that standardisation and ‘legally-enforced transparency’ were important to enable SMEs to access the C-ITS market, although it was considered that binding rules should not result significant compliance and administrative costs or reduce the potential for innovation, as this might limit the participation of SMEs.

The enhanced deployment of C-ITS may also give SMEs greater roles for providing innovative products and services to the market. In this sense, PO 3 is likely to have the greatest impact due to higher deployment, but PO 2 may also give companies in the market much needed regulatory certainty to enable them to make efficient investments in new products and services.

The analysis found insignificant effects on overall GDP and the split between transport modes.

6.3.Environmental impacts

CO2 emissions

As a result of lower fuel consumption, CO2 emissions are also expected to reduce. In 2035, the annual CO2 reductions relative to the baseline for PO1, PO2 and PO3 represent 0.3%, 1.1% and 1.4% of total baseline emissions, respectively.

The cumulative monetary savings relative to the baseline between 2020-2035 resulting from reduced CO2 emissions are greatest in PO3, with present value savings of €5.3 billion by 2035. This is in comparison to €0.7 billion and €3.2 billion by 2035, for PO1 and PO2 respectively.

Pollutant emissions

The analysis also considers the emission of air pollutants, namely NOx, VOC and PM. In 2035, the annual emissions savings relative to the baseline for PO1, PO2 and PO3 represent 0.1%, 0.3% and 0.3% of total baseline emissions, respectively.

The cumulative savings relative to the baseline are greatest in PO3, where they amount to €0.16 billion between 2020-2030 and €0.29 billion between 2020-2035 (in present value terms). In comparison, the cumulative savings between 2020-2035 of PO1 and PO2 are €0.07 billion and €0.20 billion respectively. These are minor compared with the cumulative savings presented for CO2 emissions and fuel consumption.

6.4.Fundamental rights

Personal data

As discussed in Section 2.3.5 and Annex 6, data sent by C-ITS services from vehicles often qualifies as personal data, and this is particularly relevant in the case of cooperative awareness messages (CAMs), which are an essential element for the functioning of C-ITS. With regard to personal data, any successful C-ITS deployment must be compliant with the applicable legal framework for data protection (including the General Data Protection Regulation (GDPR - Regulation 2016/679) and, where applicable, the ePrivacy Directive (Directive 2002/58) 61 to increase trust among users.

Thus, these instruments determine the main requirements for data protection, including in particular the ground for the lawfulness of processing and the need for the data controller to carry out a data protection impact assessment, while the measures under this initiative rather facilitate the compliance with these requirements. Thus all policy options should provide the same level of protection of personal data in C-ITS.

That being said, the policy options differ in how far they support data controllers in complying to data protection rules. Policy option 1 only provides non-binding guidance with limited effect on helping compliance and increasing public acceptance. Policy option 2 would further help by establishing some clear rules and limitations. Most support would come from policy option 3, where the V2V mandate could provide a legal basis for the processing of personal data.

6.5.Distributional impacts & Sensitivity Analysis

Some limitations of the impact assessment are due to uncertainties around the input assumptions for the modelling. In particular, the fact that the impact assessment examines the future impacts of technologies not yet in place beyond trial projects, has some necessary limitations in terms of the information available on potential deployment (assumptions build on the intentions of MS and some industry players to deploy, which is then cautiously extrapolated to the whole EU) and associated impacts (which build on the result of research and pilot projects). 62  

The model suite used for this analysis was primarily designed to calculate EU level impacts. While impacts per MS can be extracted from the modelling output (see Annex 4 "Analytical methods"), these are the result of input assumptions mostly at the EU level, and thus have to be considered with significant caution.

Looking at the impacts at MS level, all but 3 MS in PO1 and all MS in PO2 and PO3 show positive net benefits. MS with a lower average vehicle age seem to have higher positive impacts, which makes sense as this likely implies a quicker penetration of C-ITS in the vehicle fleet. 63 The MS with the lowest (but still positive) absolute benefits and benefits/costs ratio are Malta and Cyprus, which might be explained by the fact that costs for central & infrastructure stations are more significant in the smaller MS.

To assess the impact of uncertainties around these input parameters, we have carried out a number of sensitivity analyses to check if the analysis was robust against changes in assumptions. 64

Table 8: Cumulative net present value (NPV) for each policy option relative to the baseline, with and without sensitivities applied

.

PO1

PO2

PO3

2020-2035

2020-2035

2020-2035

NPV benefits

€15.4 bn

€59.8 bn

€96.5 bn

NPV benefits after 50% equipment cost increase

€13.5 bn

€51.5 bn

€81.8 bn

NPV benefits after 10% impact reduction

€12.6 bn

€48.9 bn

€80.7 bn

NPV benefits after 10% deployment reduction

€11.2 bn

€43.4 bn

€85.5 bn

1.50% cost increase of C-ITS equipment, with stable benefits

While this is a significant cost increase, each policy option still shows a positive NPV even with increased cost assumptions, because total equipment costs are small compared to total societal benefits.

2.10% reduction of C-ITS service impacts 65

As expected, a reduction in the assumed impact of each individual C-ITS service, to account for a possible overestimation of impacts based on research and pilot projects, results in a similar negative change across all impact categories and policy options The reduction of impacts is slightly more than proportional (12 to 14 %) to the 10% decrease.

3.10% decrease of deployment rates 66

As expected, a reduction of the deployment rates, to account for the possibility that MS and industry do not invest in C-ITS as quick as assumed, results in a negative change across all impact categories and policy options. For PO1 and PO2, the reduction of impacts is more than proportional (12 to 25%) to the 10% decrease in deployment. For PO3, the reduction is less pronounced (-9%) due to the V2V mandate in place.

Sensitivity analyses 1,2 and 3 show that the net benefits are quite robust under negative assumptions and they do not change the relative order of the policy options in terms of net benefits (see Table 8).

4.Extension of scope to Day 1.5 services (PO3) 67

This sensitivity considers the impact of adding additional Day 1.5 services 68 to the C-ITS eco-system. It is expected that this will significantly increase overall benefits, while having only a limited impact on costs, as it is expected that existing C-ITS stations can be used to deliver these services with only minor software adjustments. 69  

The addition of Day 1.5 services is expected to result in significantly higher total benefits of 303 billion euros instead of 129 billion euros (PV 2020-2035) in PO3, compared to the baseline. This increase of impacts results in particular from Day 1.5 services which help drivers save time, by providing information on parking availability or enhanced traffic routing. As a result of these time saving services, significant fuel consumption and CO2 emissions savings are achieved. Additionally, services specifically aimed at the protection of vulnerable road users will help further reduce accident costs.

7.How do the options compare?

7.5.1.Effectiveness

The effectiveness of the intervention is measured by the extent to which the specific and general objectives of the policy intervention are met, and the resulting societal, economic and environmental benefits of C-ITS services. Table 9 lists the specific objectives along with their assessment criteria, which are linked to the problem drivers identified in the problem definition. 70

Table 9: Specific objectives and their assessment criteria

Specific Objectives

Assessment criteria

Ensure interoperability and continuity of C-ITS services across the EU

·Establishment of common definition / priority of C-ITS services

·Increased certainty with regards to interoperability requirements for C-ITS stations

Reduce barriers and uncertainties to enable large-scale deployment of C-ITS

·Increased trust with regards to cyber security of C-ITS communications

·Better public acceptance due to the consistent application of rules on privacy and protection of personal data 

·Increased certainty with regards compliance assessment requirements for C-ITS services

Provide an enabling environment to support pre-commercial deployment and enable the development of attractive business models

·Improved coordination between C-ITS bodies & stakeholders

·Increased certainty about C-ITS business models

Table 10: Comparison of options on achievement of objectives

Assessment Criterion

PO1

PO2

PO3

General Objective: Increase deployment and uptake

Deployment/uptake levels

In 2035, an extra 30 million vehicles (new vehicles plus retrofits via personal C-ITS devices) and 94,000 RSUs equipped relative to the baseline, with a significant part of the fleet not yet equipped.

In 2035, an extra 132 million vehicles (new vehicles plus retrofits via personal C-ITS devices) and 275,000 RSUs equipped relative to the baseline.

In 2035, an extra 137 million vehicles (new vehicles plus retrofits via personal C-ITS devices) and 282,000 RSUs equipped relative to the baseline.

As a result of the V2V mandate, this deployment is earlier (95% coverage in 2029) and more certain than in PO2.

Specific objective 1: Ensure interoperability and continuity of C-ITS services across the EU

Establishment of common definition / priority of C-ITS services

Non-binding guidelines will be an important step in providing a common definition of C-ITS services and emphasises the focus on Day 1 services.

While the availability of such guidelines will have a positive impact, the application of common C-ITS service definitions will be limited to where they are voluntarily applied.

The definition of Day 1 services list in specifications and the requirement for C-ITS stations to be compatible with all Day 1 services will ensure that everywhere where C-ITS services are applied common definitions are followed.

Same as PO2

Increased certainty with regard to interoperability requirements for C-ITS stations

Given its non-binding nature, reference to existing standards on interoperability and EU-wide service profiles in non-binding guidelines will have a limited, though positive impact on interoperability.

Mandatory compliance with and EU wide service and system profiles will have a strong positive impact on interoperability.

Ensuring future updates of the specifications through a review clause will ensure that technological developments can be integrated.

Same as PO2. In addition the V2V mandate will ensure deployment in line with the specifications.

Specific objective 2: Reduce barriers and uncertainties to enable large-scale deployment of C-ITS

Increased trust with regards to cyber security of C-ITS communications

The non-binding nature of security guidelines gives a limited but positive effect.

By mandating C-ITS station operators to fulfil the security requirements, a single trust domain for all C-ITS stations is created, significantly increasing security and interoperability of C-ITS communications.

The assignment of tasks to legal bodies will guarantee the necessary coordination and management of security issues, thus ensuring that concerns around security are reduced to a minimum.

Better public acceptance due to the consistent application of rules on privacy and protection of personal data

Provision of non-binding guidance for processing personal date in the context of C-ITS will remove some of the uncertainties, though due to the non-binding nature this measure will result in only small impacts on public acceptance.

Providing specifications on the processing will further remove barriers and increase public acceptance.

Clearly limiting the purposes for lawfully processing personal data to traffic safety and efficiency will alleviate some of the concerns related to personal data use.

Lawfully processing data based on a legal obligation or public interest which is specified in EU law will further remove barriers and increase public acceptance.

Increased certainty with regards compliance assessment requirements for C-ITS services

Non-binding guidelines on the compliance assessment process and to assign roles and responsibilities, will slightly increase certainty, however, the impacts will be limited

Providing compliance assessment criteria and procedures for C-ITS stations based on internal production control will provide increased certainty about conformity

Providing compliance assessment criteria and procedures for C-ITS stations based on external conformity assessment will provide increased certainty around conformity, as well on its impartiality and independence

Specific objective 3: Provide an enabling environment to support pre-commercial deployment and enable the development of attractive business models

Improved coordination between C-ITS bodies & stakeholders

Guidelines on governance structures for security and compliance assessment will help with coordination within MS.

Since these bodies do not have to be set up or reported to the Commission the EU level coordination will be limited.

The set-up of a stakeholder platform will improve the exchange of knowledge and best practices

The requirement to report bodies set up for security and compliance assessment to the Commission will further improve coordination across Europe, under the premise that these bodies are actually set up.

Enhanced deployment coordination will further improve coordination at EU level.

The assignment of roles to legal bodies would ensure that all tasks & roles are carried out.

This will have significant additional impacts on overall coordination between relevant bodies compared to PO2.

Increased certainty about C-ITS business models

Provision of non-binding guidelines will only remove a limited number of uncertainties for C-ITS business models.

Stakeholder platform will help in further elaborating a common vision/approach for C-ITS deployment.

Provision of common binding specifications will significantly increase the change of interoperable implementations and network effects.

Deployment coordination & funding will contribute to sustainability of early deployment.

The V2V mandate, combined with deployment coordination, will strongly speed up deployment and network effects, providing increased certainty for investments.

Societal, economic and environmental benefits

Fuel consumption

Limited impact. PV 2020-2035 fuel consumption costs reduced, 2,5 billion euros or -0.1% compared to the baseline.

Positive impact,
PV 2020-2035 fuel consumption costs reduced, 11 billion euros or -0.4% compared to the baseline.

Positive impact,
PV 2020-2035 fuel consumption costs reduced, 18 billion euros or -0.7% compared to the baseline.

CO2 emissions

Limited impact, PV 2020-2035 CO2 emission costs avoided, 0,7 billion euros or -0.1% compared to the baseline.

Limited impact, PV 2020-2035 CO2 emission costs avoided, 3,2 billion euros or -0.1% compared to the baseline.

Positive impact, PV 2020-2035 CO2 emission costs avoided, 5,3 billion euros or -0.6% compared to the baseline.

Pollutant emissions – PM, NOx, VOC

Limited impact. PV 2020-2035 other pollutant emission costs avoided, 0,1 billion euros or -0.0% compared to the baseline.

Limited impact. PV 2020-2035 other pollutant emission costs avoided, 0,2 billion euros or -0.1% compared to the baseline.

Limited impact. PV 2020-2035 other pollutant emission costs avoided, 0,3 billion euros or -0.1% compared to the baseline.

Accidents

Positive impact. PV 2020-2035 accident costs avoided, 15 billion euros or -1.0% compared to the baseline

Positive impact. PV 2020-2035 accident costs avoided, 53 billion euros or -3.5% compared to the baseline.

Strongly positive impact. PV 2020-2035 accident costs avoided, 77 billion euros or -5.0% compared to the baseline.

Urban travel time

Limited impact. Increased travel time savings relative to baseline between 2020 and 2035 (+ 0.03%) or 2,0 billion euros.

Positive impact. Increased travel time savings relative to baseline between 2020 and 2035 (+0.16%) or 11 billion euros.

Strongly positive impact. Increased travel time savings relative to baseline between 2020 and 2035 (+0.42%) or 18 billion euros.

As the impacts of C-ITS services increase with deployment, the effectiveness of the policy options in terms of delivering benefits (such as reduced accidents, fuel consumption, CO2 emissions, pollutant emissions and travel time) increases from PO1 to PO3. PO3 is the most effective, achieving more than 6 times the benefits of PO1, and 64% more benefits than PO2. In addition, PO3 would provide the most supportive framework for C-ITS, by introducing a stable governance framework and a legal basis for the lawful processing of personal C-ITS data.

7.5.2.Efficiency

The efficiency is assessed by comparing the costs and benefits that have been monetized. Table 10 shows the main monetized costs and benefits associated with the policy options. Section 6.2 discusses additional administrative and compliance costs, but as these are considered very minor compared to the cost items presented here and thus do not alter the assessment (with the exception of the compliance costs for the V2V mandate in PO3), they are not repeated here.

PO3 shows the highest net benefits, followed by PO2 and then PO1. The benefit-costs ratio (approximately 4) is very similar between all three policy options and should not be used to distinguish between the policy options, considering the uncertainties in these estimates and the limitations of the modelling framework.

It needs to be considered that unlike PO1 and PO2 where uptake is voluntary, PO3 includes a V2V mandate, and a large share of the costs for in-vehicle equipment (57 billion euros) should thus be considered as compliance costs in the PO3 (notwithstanding that deploying stakeholders would also incur this costs in a voluntary deployment scenario). In this light, PO1 and PO2 could be considered to be more efficient than PO3 in achieving the objectives, however it should also be acknowledged that the impacts in PO1 and PO2 are less certain, and that PO3 foresees in a stepwise approach in which the efficiency of a mandate can be reassessed.

Table 11: Summary of monetized costs and benefits (PV 2020-2035) compared to the baseline for the different policy options

 

PO1

PO2

PO3

In-Vehicle Equipment costs (PV 2020-2035)

€2.9 bn

€12.8 bn

€23.6 bn

Personal C-ITS Devices costs (PV 2020-2035)

€0.9 bn

€3.8 bn

€5.9 bn

Upgraded RSU costs (PV 2020-2035)

€0.3 bn

€0.5 bn

€0.4 bn

New RSU costs (PV 2020-2035)

€0.1 bn

€1.2 bn

€1.5 bn

Central sub-systems costs (PV 2020-2035)

€0.7 bn

€0.9 bn

€0.9 bn

Total equipment costs (PV 2020-2035)

€4.9 bn

€19.1 bn

€32.3 bn

Accident reduction benefits

€15.0 bn

€53.4 bn

€76.9 bn

Time saved benefits

€2.0 bn

€10.8 bn

€28.2 bn

CO2 emission benefits

€0.7 bn

€3.2 bn

€5.3 bn

Other emissions benefits

€0.1 bn

€0.2 bn

€0.3 bn

Fuel saving benefits

€2.5 bn

€11.2 bn

€18.2 bn

Total Benefits (PV 2020-2035)

€20.3 bn

€78.9 bn

€128.9 bn

% modelled costs incurred by private sector (PV 2020-2035)

76.9%

86.8%

91.2%

% modelled costs incurred by public sector (PV 2020-2035)

23.1%

13.2%

8.8%

Total net benefits (PV 2020-2035)

€15.4 bn

€59.8 bn

€96.5 bn

7.5.3.Coherence

Coherence describes how each policy option is in line with relevant legislation as well as with EU transport policies in a broader perspective. In terms of coherence with the goals of the ITS Directive and broader transport policies, PO2 and PO3 score significantly better than PO1 by ensuring the interoperability of C-ITS services, and thus increasing the certainty of deployment and achievement of benefits relevant for overall transport policy goals. PO3 in addition provides extra support to the continuity of services through the V2V mandate.

All policy options are coherent with legislation related to data exchange (i.e. the GDPR and the e-privacy and EECC proposals), as they do not affect the application of this legislation, but provide more clarity on how C-ITS would function in relation to this legislation. PO1 would provide the lowest level of additional clarity due to its non-binding nature, whereas PO3 would provide the most certainty by providing a legal basis for the lawful processing of personal data.

The coherence assessment is summarized in the table below. Overall, all policy options are considered coherent, but PO2 and PO3 are considered more coherent than PO1 because of the added certainty and the alignment with transport policy goals.

Table 12: Comparison of options on coherence

 

PO1

PO2

PO3

ITS Directive

0

+

++

Transport policies (e.g. Transport White Paper, Low Emission Mobility Strategy

+

++

++

GDPR

0

+

+

E-privacy & EECC proposals

+

+

+

Overall coherence

+

++

++

7.5.4.Proportionality

PO1 relies on non-binding guidance and thus allows Member States and individual deployment projects to decide whether or not to comply with the provided guidelines. In this sense, PO1 is proportional to achieving the intended objective.

PO2 is based on a Delegated Act under the ITS Directive. Compliance would only be mandatory when deploying C-ITS services. While binding EU specifications do require existing C-ITS stations and new technological solutions to adapt to the requirements, these requirements are essential to ensure EU-wide interoperability of C-ITS services, and the foreseen review allows for flexibility in the development of technological solutions. While it is a more stringent measure than PO1, the expected benefits, both direct and indirect, are also proportionally higher.

In discussions with MS experts, some MS argued for a technological-neutral framework where the choice of technology is left to the market, but a strong majority agreed with the need for clear EU specifications to ensure interoperability, starting with mature implementations available now, and including a clear and transparent path for the inclusion of future solutions and technologies. Thus, PO2 is considered proportional.

PO3 would, in a second step following specifications, impose an obligation on vehicle manufacturers to equip all their new vehicle types with C-ITS stations. While some OEMs have already made announcements to equip (parts of) their fleet, this policy option would make that mandatory. Since significant direct and indirect impacts are already expected following the adoption of specifications without resorting to a V2V mandate (See results of PO2), the proportionality and necessity of a mandate can be further assessed, in line with the stepwise approach foreseen in the ITS Directive. This also ensures that the scope of the system is clearly defined through specifications, before the implications of deployment are considered in more detail. It is important to note, that this second step is not part of the current initiative, and would require a separate proposal accompanied by an additional impact assessment.

8.Preferred option

As the different policy options score differently on the various criteria, a trade-off should be made in selecting the preferred option.

·Effectiveness: PO3 is the most effective regarding deployment and benefits, followed by PO2 and PO1. In addition, PO3 also provides the most certainty about the level of deployment through the V2V mandate, whereas PO1 and PO2 rely on voluntary deployment and might lag behind expectations.

·Efficiency: All POs show a similar benefit-cost ratio. PO3 achieves the highest and most certain net benefits, but at the same time the V2V mandate introduces significant compliance costs on car manufacturers, whereas PO1 and PO2 rely on voluntary deployment. Thus, PO1 and PO2 are considered the most efficient in achieving the objectives at this stage.

·Coherence: Overall, all POs are considered coherent with the ITS Directive, legislation on data exchange and broader transport policy objectives, but PO2 and PO3 are considered more coherent than PO1 because of the added certainty for the deployment and achievement of benefits relevant for the transport system.

·Proportionality: Both PO1 and PO2 are proportional – allowing Member States and industry to determine the level of deployment they prefer. PO3 provides higher deployment and added certainty, but also imposes a direct obligation on vehicle manufacturers, the proportionality and necessity of which can be further assessed in a step-wise approach.

Based on this assessment, PO2 is clearly preferred over PO1, as it achieves significantly larger benefits and is more coherent than PO1. PO3 is even more effective and coherent that PO2, providing more certainty on deployment and more effectively addressing the problem drivers of data protection and lack of coordination, but at the same time the V2V mandate would introduce significant compliance costs, and the efficiency and proportionality of the mandate should be further assessed. The preferred approach is thus PO3, following a step-wise approach as foreseen in the ITS Directive, where after the adoption of specifications a proposal on deployment can be made to the European Parliament and the Council, which should take the voluntary deployment of C-ITS following the adoption of specifications into account. It is important to note, that this second step is not part of the current initiative, and would require a separate proposal accompanied by an additional impact assessment.

9.How will actual impacts be monitored and evaluated?

Monitoring and evaluation should build on a simple approach that is transparent and easily accessible. It is not the intention to create a very complex and complicated system of key performance indicators.

More specifically, the Commission services will monitor the implementation and effectiveness of this initiative through a set of core indicators that will measure the progress towards achieving the specific objectives, based on the measures that are part of the preferred option. Some of the indicators are of a qualitative nature and show if the desired deliverables are being achieved and implemented, while others are based on data to be collected that will need to be analysed further. In addition, the social, economic and environmental impacts will be monitored based on available statistics (e.g. the CARE database for accidents, and Eurostat statistics for fuel use and CO2 emissions) and new/updated studies (e.g. for air pollutants and congestion).

Considering that C-ITS is a fast-moving sector, it is foreseen that the Commission services will carry out an evaluation after 3 years to verify whether the objectives of the initiative have been reached. This is intended to determine whether the measures in place have resulted in an improvement of the situation. This evaluation shall be carried out based on the core progress indicators below, in line with Commission requirements on evaluation. The evaluation will also include data collection on investment, operating and compliance costs resulting from C-ITS deployment, and a qualitative and quantitative assessment of any issues that have arisen regarding data collection and management.

Table 13: Monitoring and reporting

 Specific objective

Progress indicators

Source of data

Ensure interoperability and continuity of C-ITS services across the EU

Number of C-ITS stations deployed

% of road network type covered by C-ITS services

Standardisation and profiling of new C-ITS services and communication methods

Revisions of the specifications to take into account technological progress

C-ITS stations registered in the CCMS

Existing voluntary reporting of Member States in the framework of ITS Directive

Standardisation deliverables from European Standardisation Organisations & other organisations

Services profiled, harmonised and deployed

Reduce barriers and uncertainties to enable large-scale deployment of C-ITS

Level of security issues identified

Level of data protection issues identified

Level of compliance assessment issues identified

Reporting of security incidents in the CCMS

Data protection impact assessments carried out by C-ITS data controllers.

Reporting of compliance issues by MS to the Commission.

Provide an enabling environment to support pre-commercial deployment and enable the development of attractive business models

Level and effectiveness of EU funding provided for C-ITS development and deployment

Level and effectiveness of coordination mechanisms

Commission reporting (based on project reporting)

Deliverables of stakeholder platform

MS and industry reporting set up of C-ITS bodies to the Commission

(1)

Annex 5 includes a more detailed description on the general functioning of C-ITS services and the specific services (day 1 & day 1.5) considered in the analysis.

(2)

Including 18 vehicle manufacturers, 40 equipment suppliers and 31 research organisations.

(3)

Available at https://www.car-2-car.org/

(4)

More information of the C-ITS platform and its deliverables, including the Phase I and II final reports can be found at: https://ec.europa.eu/transport/themes/its/c-its_en

(5)

  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52016DC0766 , from now on referred to as “C-ITS Strategy”

(6)

Day 1.5 C-ITS services are considered to be mature, but not quite ready for a large-scale deployment due to a lack of full specifications or standards, and so would be deployed somewhat later. A description of the functioning and classification of all Day 1 and Day 1.5 services considered in this IA can be found in Annex 5.

(7)

https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2008:0886:FIN:EN:PDF

(8)

http://ec.europa.eu/growth/tools-databases/mandates/index.cfm?fuseaction=search.detail&id=434

(9)

https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A52011DC0144

(10)

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52015DC0080&from=EN

(11)

https://eur-lex.europa.eu/resource.html?uri=cellar:e44d3c21-531e-11e6-89bd-01aa75ed71a1.0002.02/DOC_1&format=PDF

(12)

http://www.europarl.europa.eu/sides/getDoc.do?type=TA&reference=P8-TA-2018-0063&language=EN&ring=A8-2018-0036

(13)

Studies have quantitatively shown that automation without connectivity could potentially lead to worsening traffic conditions: https://ec.europa.eu/jrc/en/publication/connected-and-automated-vehicles-freeway-scenario-effect-traffic-congestion-and-network-capacity

(14)

https://www.regjeringen.no/contentassets/ba7ab6e2a0e14e39baa77f5b76f59d14/2016-04-08-declaration-of-amsterdam---final1400661.pdf

(15)

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52017DC0283&from=EN

(16)

The concepts of “Connected, Cooperative and Automated Mobility” and “Connected and Automated Mobility” are used in parallel. This document makes reference to Connected, Cooperative and Automated Mobility and its acronym (CCAM) wherever possible.

(17)

See https://ec.europa.eu/transport/modes/road/news/2018-05-17-europe-on-the-move-3_en for further details.

(18)

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018PC0286

(19)

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018PC0274

(20)

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52018DC0283

(21)

https://ec.europa.eu/growth/content/high-level-group-gear-2030-report-on-automotive-competitiveness-and-sustainability_en

(22)

It should be noted that action on (Priority Area IV, point 1.1) on an open-vehicle platform and the broader topic of access to in-vehicle data, is outside the scope of this initiative.

(23)

REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on type-approval requirements for motor vehicles and their trailers, and systems, components and separate technical units intended for such vehicles, as regards their general safety and the protection of vehicle occupants and vulnerable road users, amending Regulation (EU) 2018/… and repealing Regulations (EC) No 78/2009, (EC) No 79/2009 and (EC) No 661/2009

(24)

See section on communication technologies for more details

(25)

The expected impact of the mature day 1 and 1.5 services is described in Annex 5.

(26)

Source: CARE database, based on police reports.

(27)

-1.3% between 2013 and 2016

(28)

Numerous sources, including: CE Delft, INFRAS, Frauenhofer ISI, External Costs of Transport in Europe, Delft, November 2011. Christidis, Ibanez Rivas, Measuring road congestion, JRC Technical Notes, 2012; Fermi, F., & Fiorello, D. (2016). Study on Urban Mobility – Assessing and improving the accessibility of urban areas - Task 2 Report – Estimation of European Urban Road Congestion Costs.

(29)

Victoria Transport Policy Institute, Transportation Cost and Benefit Analysis II – Congestion Costs: http://www.vtpi.org/tca/tca0505.pdf

(30)

OECD (2014), The Cost of Air Pollution: Health Impacts of Road Transport, OECD Publishing. http://www.oecd.org/env/the-cost-of-air-pollution-9789264210448-en.htm.

(31)

See e.g. http://www.irceline.be/en/air-quality/measurements/nitrogen-dioxide/history for Belgium

(32)

http://www.eea.europa.eu/highlights/stronger-measures-needed/table-10-1-premature-deaths

(33)

  https://ec.europa.eu/growth/sectors/automotive_en

(34)

For detailed case studies on deployment projects in the EU, and country case studies on the US, Japan and Australia, please see Annex D of the support study.

(35)

http://www.ndrc.gov.cn/yjzq/201801/t20180105_873146.html

(36)

Report on the analysis of responses: https://ec.europa.eu/transport/sites/transport/files/2016-c-its-deployment-study-public-consultation.pdf

(37)

C-Roads Platform (no date) “Radio frequencies designated for enhanced road safety in Europe - C-Roads position on the usage of the 5.9 GHz band”

(38)

Available at: https://ec.europa.eu/transport/themes/its/c-its_en

(39)

See Annex 6 for more detail on the use and protection of personal data in C-ITS.

(40)

A proposal for the revision of the ePrivacy in currently being negotiated.

(41)

Article 29 Working Party Opinion 03/2017 on processing personal data in the context of Cooperative Intelligent Transport Systems (C-ITS, available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=610171

(42)

More details on the establishment of the baseline can be found in the support study.

(43)

The Baseline scenario developed for this impact assessment does not reflect the recent initiatives proposed by the Commission that have a direct impact on CO2 emissions (e.g. CO2 standards for new light duty vehicles for 2030, CO2 standards for heavy goods vehicles for 2030, revision of the Clean Vehicles Directive, etc.)

(44)

Compared to the benefits originally determined for C-ITS services in the support study. This reduction applies to all modelling scenarios, and is separate from the sensitivity analysis in Section 6.4.

(45)

See section 4.2 of the support study for more details.

(46)

Detailed specification of the purpose of the service and the content & triggering conditions for the message to be sent.

(47)

Detailed specification of how the system should be designed and operated, specifying settings of parameters defined in standards.

(48)

The impact assessment for the May 2018 proposal for a revision of the GSR ( https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018SC0190&from=EN , Annex 11) considered including C-ITS in the scope, but discarded it as the standards and specifications were not available at the time, and that work should first be carried forward.

(49)

Note: unless indicated otherwise impacts in this section are presented for the EU as a whole (EU-28). Items labelled as “PV 2020-2035” indicate monetized impacts between 2020 and 2035 in present value (2017), using the social discount rate of 4 percent.

(50)

The deployment of C-ITS services is strongly linked to the deployment of C-ITS stations, as the same station can provide multiple services, but needs to be differentiated between different types of transport, roads and C-ITS stations. Thus here only the deployment of C-ITS stations is presented.

(51)

The figures in this table for vehicles and personal C-ITS device are net of scrapping, i.e. C-ITS stations that have reached the end of their life-time are excluded.

(52)

ETSC, 2016. Briefing: Prioritising the safety potential of automated driving, European Transport Safety Council. [Online] Available at: http://etsc.eu/wp-content/uploads/2016_automated_driving_briefing_final.pdf

(53)

A detailed description on the estimation of cost elements and their sources can be found in Annex B.2.4 of the support study.

(54)

Euro 2,56 for an in-vehicle C-ITS station per year, compared to Euro 290 total upfront cost.

(55)

Also in PO1, C-ITS manufacturers will likely face costs associated to compliance assessment, as other C-ITS operators have to be reassured that systems can work together.

(56)

The monetary value was calculated based on the cost of time values from the Handbook of External Costs, see section 5.2.2.3 of the support study for more details.

(57)

See section 6.4 on sensitivity analysis.

(58)

The fuel price is calculated as a weighted average of prices of gasoline, diesel, CNG, LPG and electricity, based on energy consumption of road transport modes, excluding excise duties and VAT.

(59)

These results should be considered with care as they may be offset by job losses in other areas which are not reflected in the analysis. See Section 5.2.5 of the Support Study for more details.

(60)

See Figure 2-28 in the Public Consultation report.

(61)

A proposal for the revision of the ePrivacy in currently being negotiated.

(62)

The limitations of the analysis are described in more detail in chapter 7 of the support study.

(63)

No such relationship was found for MS with higher fatalities/capita or front-runners in C-ITS deployment, where this might have been expected.

(64)

More details can be found in Annex 4, section 2 and chapter 7 of the support study

(65)

Within the modelling framework, sensitivity analyses 2 and 3 require significant changes to the modelling scenarios. PO2 and PO3 sensitivities have been fully modelled in the ASTRA/TRUST environment and the CBA model. As PO1 is discarded in section 8, its sensitivity impacts have been estimated from the modelled changes between PO2 and the PO2 deployment sensitivity.

(66)

For PO1 and PO2 both the in-vehicle and infrastructure deployment has been decreased by 10%. For PO3 however, only the infrastructure deployment has been decreased as the vehicle deployment is fixed through the V2V mandate.

(67)

As this analysis requires significant changes to the modelling framework, it has only been carried out for the most ambitious policy option, as it considers future extension of the C-ITS eco-system.

(68)

Services considered to be mature, but not quite ready for a large-scale deployment due to a lack of full specifications or standards, and which are thus not included in the main policy options.

(69)

Given their limited size and unpredictability, these increased costs have not been included in the sensitivity for reasons of simplification.

(70)

While several problem drivers are linked to multiple main problems, in this section each assessment criterion is only mentioned under one specific objective to improve the presentation.

Top

Table of contents

Annex 1: Procedural information

1.Lead DG, Decide Planning/CWP references

2.Organisation and timing

3.Consultation of the RSB

4.Evidence, sources and quality

Annex 2: Stakeholder consultation synopsis report

1.Introduction

2.Consultation Methods

3.Results of consultation activities

4.Conclusion and use of results

5.Further Information

Annex 3: Who is affected and how?

1.Practical implications of the initiative

2.Summary of costs and benefits

Annex 4: Analytical methods

1.Description of analytical models used

1.1.Pre-processing of data to calculate impacts

1.2.ASTRA and TRUST modelling

1.2.1.ASTRA Model

1.2.2.TRUST model

1.2.3.Application of the modelling tools

1.3.Cost Benefit Analysis Model

2.Reliability and Appropriateness of the models used

3.Detailed results per member state

Annex 5: Key aspects of C-ITS

1.Introduction

2.C-ITS services and messages

3.C-ITS Stations

4.Trusted and secure communication

Annex 6: The use and protection of personal data in C-ITS

Glossary

Term or acronym

Meaning or definition

3GPP

3rd Generation Partnership Project

5G

5th generation of communication networks

CCAM

Connected, Cooperative and Automated Mobility

CEPT

European Conference of Postal and Telecommunications Administrations

C-ITS

Cooperative Intelligent Transport Systems

CP

Certificate Policy for C-ITS security

EEA

European Environmental Agency

GDP

Gross domestic product

GDPR

General Data Protection Regulation

GSR

General Safety Regulation

IRC

Impact Reduction Container

ITS

Intelligent Transport Systems

ITS-G5

IEEE 802.11p (wifi) communications protocol for C-ITS communication

I2I

Infrastructure-to-infrastructure communication

LTE

Long Term Evolution

LTE-V2X or C-V2X

Cellular communications protocol for C-ITS communication

RISM

Road Infrastructure Safety Management

RSU

Road-side unit

SP

Security Policy for C-ITS security

CCMS

C-ITS Security Credential Management System

V2I

Vehicle-to-infrastructure communication

V2V

Vehicle-to-vehicle communication

V2X

Vehicle-to-everything communication

VOC

Volatile Organic Compounds (air pollutants)

VRU

Vulnerable Road User



Annex 1: Procedural information

1.Lead DG, Decide Planning/CWP references

Decide Reference

Short title

Foreseen adoption

PLAN/2017/662

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

4th quarter 2018

2.Organisation and timing

The Inter Service Steering Group (ISSG) for the Impact Assessment was set up in April 2017 and includes the following DGs and Services: SG, SJ, CONNECT, GROW, JRC, CLIMA, ENER, ENV, RTD, COMP, REGIO and DIGIT.

 

Five meetings of the Steering Group were organised between 5 April 2017 and 3 September 2018. Further consultations with the ISSG were carried out by e-mail.

 

The ISSG approved the Inception Impact Assessment. The ISSG also discussed the main milestones in the process, in particular the consultation strategy and main stakeholder consultation activities, the task specifications to launch the contract for the external IA support study, key deliverables from the support study, and the draft impact assessment report before the submission to the Regulatory Scrutiny Board.

3.Consultation of the RSB

The impact assessment was submitted to the Commission’s Regulatory Scrutiny Board on 13 September 2018. Following the meeting on 10 October 2018, the Board issued a positive opinion with reservations on 12 October 2018. The Board made recommendations. Those were addressed in the revised IA report as follows:

Main considerations

Modification of the IA report

(1) The report does not make sufficiently clear the need for a step-wise approach to reach the objectives of the initiative. As a result, the choice of the preferred option does not clearly flow from the analysis and presentation of the report. The option concerning a stronger intervention based on V2V mandate and governance structure does not allow to address fully the issues at stake.

The distinction between the different policy options and the considerations behind them have been reviewed and clarified throughout the document, in particular in sections 5.3, 7 and 8.

(2) The report does not explain why it does not (yet) address stakeholder concerns on the safety of vulnerable road users and environmental impacts.

The impact of C-ITS on VRUs has been further clarified in section 6.1 and 6.5, while clarifying that VRU specific C-ITS services are not yet mature to be included in specifications and thus the policy options considered in this impact assessment. The stakeholder concerns have been described in more detail in Annex 2.

Further considerations and adjustment requirements

(1) The report should show why it is advisable to address interoperability now and deployment later. The analysis should take into account the risks of such a stepwise approach, in particular in terms of collusive behaviour of the car industry. The report should further clarify that a strong intervention based on V2V mandate and governance structure (option 3) is not a standalone option. It would require an additional impact assessment and a different legal proposal to implement. In addition, the report should discuss why a strong intervention is premature or not possible at this point in time. Finally, the report should briefly explain the rationale for retaining the light intervention based on non-legislative measures (option 1), given how little it would seem to deliver on the objectives.

The distinction between the different policy options and the considerations behind them have been reviewed and clarified throughout the document, in particular in sections 5.3, 7 and 8. The need for a separate impact assessment for additional legislative measures, including a V2V mandate, is explicitly included.

Rationale for PO1 as well as the step-wise approach has been reviewed.

(2) The report should better demonstrate that options are future proof. It should explain how newly emerging standards fit into the framework in the future while remaining backward compatible with older versions. It should provide more information on the role that different technologies can play in cooperative intelligent transport systems.

The role of different technologies in C-ITS is further explained in section 2.3.2.

The role of the review process is further elaborated in section 5.3.3.

(3) The report should better explain how it addresses the concerns of vulnerable road users, such as pedestrians and cyclists, and how the initiative might affect them. In this context, the report should clarify what services intelligent transport systems already deliver and which ones they will plausibly deliver in the future.

The impact of C-ITS on VRUs has been further clarified in section 6.1 and 6.5, while clarifying that VRU specific C-ITS services are not yet mature to be included in specifications and thus the policy options considered in this impact assessment.

Annex 2 and 4 have also been updated in this regard.

(4) The report should take care not to create unrealistic expectations with regard to safety and environmental benefits. It could make clearer that the initial focus is on road safety. This discussion should also include an explanation of how these benefits depend on the deployment of specific services (for example, Day 1 and Day 1.5 services), so that some benefits will materialise sooner than others. The report should be more transparent on the contribution (in terms of magnitude and timespan) of the preferred option to road safety and transport emissions, in comparison to what a stronger intervention on V2V (option 3) is expected to deliver.

The sensitivity analysis in section 6.5 has been expanded to all policy options, and adjustments have been made throughout the report to better differentiate the policy options.

Annex 4, section 2 has been updated to reflect that day 1 services have a strong focus on safety and further clarify the limitations of the analysis.

(5) The report should elaborate on the role of road-side C-ITS infrastructure and the extent to which it is needed for C-ITS to function efficiently and effectively. This should describe the necessary contributions from and choices available to national, regional and public authorities.

The role of road-side units has been further explained in section 2.3.2. It is clarified that    the decision to deploy roadside infrastructure is often expected to be made on a case-by-case basis by public authorities or road operators.

(6) The report should add information about how the initiative addresses data protection issues. The report should clarify the nature and scope of the data at stake and where additional data protection adjustments are needed when data is processed for road safety and traffic efficiency (i.e. data minimisation). It should also clarify what data protection the different options propose.

Section 6.4 has been added to discuss the data protection impacts of the different policy options. Annex 6 has also been updated in this regard.

4.Evidence, sources and quality

The starting points of the drafting of the Impact Assessment were the final reports of the C-ITS Platform Phases I and II 1 . The Platform 2 was conceived as a cooperative framework including national authorities, C-ITS stakeholders and the Commission in the form of a Commission Expert Group, in view to develop a shared vision on the interoperable deployment of C-ITS in the EU.

Information provided by the stakeholders through the stakeholder consultation activities were an important source of information (see Annex 2). It was completed by information provided ad hoc by different stakeholders to the Commission, as well as by experts appointed by MS in the ITS expert group, that met 12 times between 23 May 2016 and 5 September 2018.

The Commission sought external expertise through a contract for a support study with RICARDO Energy & Environment, supported by TRT and TEPR, which was launched in September 2017. The findings of the impact assessment report build on the final report from this contract. 3

Overall, the sources used for the drafting of the Impact Assessment report are numerous, diverse and representative of the different stakeholder groups.



Annex 2: Stakeholder consultation synopsis report

1.Introduction

In the context of the preparation of the Impact Assessment, various stakeholder consultation activities were carried out. Consultation activities sought both qualitative (opinions, views, suggestions) and quantitative (data, statistics) information. Some of these activities were part of the Impact Assessment support study (by an external contractor, RICARDO), which was launched in September 2017.

This annex provides an overview of the stakeholder groups that were consulted as well as a summary and analysis of the responses received. The consultation covered all aspects of the Impact Assessment (problem definition, EU dimension, options and potential impacts).

The consultation process 4 engaged main target groups through different methods, combining:

·Work in the C-ITS Platform

·Publication of the Inception Impact Assessment

·a Public Consultation

·Targeted consultations included in-depth interviews for EU and international case studies

·a stakeholder workshop with follow-up survey

·meetings with experts appointed by Member States

Throughout the period of preparing the Impact Assessment, Commission services have additionally met with a wide variety of stakeholders, and received several position papers.

2.Consultation Methods

Work in the C-ITS Platform

In early 2014, the Commission decided to take a more prominent role in the deployment of connected driving, by setting up the C-ITS Deployment Platform. The Platform was conceived as a cooperative framework including national authorities, C-ITS stakeholders and the Commission, in view to develop a shared vision on the interoperable deployment of C-ITS in the EU.

The Platform consisted of an expert group (E01941), with experts representing key stakeholder groups selected following an open call for application. The work of the plenary (8 meetings in 2014-2017) was supported by 18 working groups working on specific topics during the two phases.

The first phase of the C-ITS platform (2014-2016) provided policy recommendations for the development of a roadmap and a deployment strategy for C-ITS in the EU and identify potential solutions to some critical cross-cutting issues.

The second phase (2016-2017) of the platform further developed a shared vision on the interoperable deployment of C-ITS towards connected and automated mobility (CCAM) in the European Union.

The final reports of both phases, endorsed by the plenary of the Platform, and all its deliverables can found on the Commission website. 5

Publication of the Inception Impact Assessment

The Inception Impact Assessment 6 for the initiative was published on 22 May 2017 and was open for feedback until 19 June 2017. Two responses were received through the feedback mechanism, one from a public authority and one from a business association. The responses were generally favourable of the initiative and asked for the following additional aspects to be considered: the link to automation, the need for harmonization and ensure equal access to data.

Public Consultation (PC)

The Public Consultation was launched on the Commission website on 10 October 2017 and was open for responses until 12 January 2018 (13 weeks). 7 The questionnaire for the consultation was prepared by DG MOVE, together with the members of the steering group and the consultant for the support study. It invited stakeholders' opinions on the key elements of the Impact Assessment: the main problems, their drivers, possible policy measures and their likely impacts and the relevance of EU level action. The consultant summarised the results of the public consultation in a detailed report. 8

Figure 1: Overview of participants to PC according to main country of operation/residence

The public consultation received 138 responses from 18 EU Member States, of which 40 by companies, 37 by associations, 32 by public authorities, 11 by individual citizens and 8 by NGOs.

Table 1: Overview of participants to PC according to main interest (multiple options possible)

Stakeholder type 9

Stakeholder engagement activity

Public consultation

Case studies & data requests

Stakeholder workshop 10

Vehicle and equipment manufacturers/suppliers/repairs

33

3

25

Road/transport operators

18

-

2

Regional or local public authorities

14

-

9

National Public Authorities

14

9

14

Societal interests and/or consumer rights

11

-

6

Research/Academia/Consultancies

9

-

28

ITS service providers

9

3

8

Telecom service providers

6

1

6

Road authorities

4

4

2

Other

24

-

9

The geographical distribution of respondents ( Figure 2 ) shows a particular strong response from front-runner countries in C-ITS deployment as can be expected (e.g. Germany, Austria, France, Netherlands, Sweden), plus many responses from Belgium, including EU-level organisations.

The analysis of the responses also suggested that a total of 30 responses (22% of total responses, with the largest coordinated response consisting of 7 responses) were coordinated, following a template for answers. Since respondents were free to adapt the answers to express their own views, coordinated responses have been analysed individually.

The indicated interests ( Table 1 ) shows a diverse coverage of interests with a particularly strong response from vehicle and equipment manufacturers/suppliers/repairs and road/transport operators, which fits with the expectation that these stakeholders are expected to make the most substantial investment into C-ITS stations.

In addition to the responses to the questionnaire, 46 additional contributions and position papers were submitted, which have also been analysed.

Targeted consultations included in-depth interviews for EU and international case studies

As part of the support study, a number of case studies where carried out: 9 on EU C-ITS deployment projects (plus 1 for the coordination C-ROADS platform) + 3 case studies on international C-ITS deployment (US, Australia and Japan), which included interviews with senior representatives (see Table 1 ) between October 2017 and February 2018. All case studies focused on the objectives, progress, barriers and data collection on cost and performance of C-ITS deployment within the case study subject; for the EU case studies respondents were additionally asked to provide feedback on the problem definition, policy measures & options, and monitoring & evaluation for this policy initiative.

To complement the information of the case studies on cost and input data for the modelling, the consultant carried out 7 additional interviews / surveys with key stakeholders.

Stakeholder workshop with follow-up survey

A stakeholder workshop was held on 9th February 2018, to gather specific information and data and obtain views and suggestions from experts and stakeholders. The workshop was well attended with more than 140 participants.

In the morning session the project team presented the overview and status of the study and the results of the online public consultation. In the Q&A important elements, including the design of the draft policy options, were discussed. 23 stakeholders presented their views on C-ITS, including among others C-ITS deployment initiatives, car manufacturers, technology and telecommunications providers, organizations representing road users, public transport and cities, and researchers.

The afternoon session consisted of an interactive presentation on the modelling framework for the study, in which the approach and assumptions used in the study were discussed, allowing stakeholders to offer detailed views and help to correct or amend the analytical approach. Some key elements discussed were the cost data and the uptake scenarios in vehicles and infrastructure. The presentations from the consultant and the stakeholders can be found on the Commissions C-ITS webpage 11 .

The discussion in the workshop was complemented by an online survey of attendees to get individual responses on the discussion items. The survey was open for two weeks following the workshop, during which time 19 completed responses were submitted.

Meetings with experts appointed by Member States

In the preparation of this initiative, 12 meetings have been held with an expert group (E01941) 12 consisting of experts appointed by Member States plus Norway and Switzerland, between May 2016 and September 2018, with the aim to assist the Commission in the preparation of the initiative and to coordinate and exchange views on C-ITS. As part of these meetings, the experts have been closely informed on the methodology and progress of the Impact Assessment and consulted on key elements, including the problem definition, policy measures & options and the modelling approach.

3.Results of consultation activities

The remainder of the report presents the main findings from the analysis of stakeholder contributions to the consultation process. These are structured following the areas of a) problem definition, b) objectives & need for EU action, c) policy measures & options and d) impacts

Problem definition

In the public consultation, a large majority (81%) of respondents in the PC (strongly) agreed with the main problem definition that “deployment is being delayed due to several barriers and uncertainties... Without a clear legal framework, C-ITS deployment is expected to remain slow and fragmented, resulting in interoperability issues and hindering continuity of services. This in turn will hinder the deployment and uptake of C-ITS and the realization of their full benefits, in particular with regards to road safety and traffic efficiency.” The assessment is similar across stakeholder groups, with at least 77% in each main stakeholder group (strongly) agreeing. In the other consultation activities, the problem definition received a similar support and comments.

Several stakeholders considered however, that additional issues should get more consideration, in particular the investment costs and funding for C-ITS, the need for action on access to in-vehicle data and the need to make C-ITS relevant for vulnerable road users & public transport. Associations representing cities and public transport also emphasized the latter during the stakeholder workshop.

Regarding the problem drivers, a large majority of respondents across groups (strongly) agreed (70-80%) with all drivers identified. Several stakeholders considered that the uncertainty on costs & benefits (and attention to user needs), access to in-vehicle data and liability should be more prominent in the problem analysis. While the agreement was high across all stakeholder groups, private companies scored the importance of problem drivers lower that other stakeholder categories. While respondents agreed that “incompatible communication technologies” are an important driver of the problem, stakeholder were divided on how this driver should be tackled, with some arguing that a clear technology choice should be made to create certainty to investment, while others arguing that this should be left to the market. In the other consultation activities, the problem definition received a similar support and comments.

Objectives

Regarding the objectives, a large majority of respondents across groups (68-90%) in the PC considered all objectives identified as absolutely essential or very important. However, for the objective “ensure a forward-looking hybrid communication approach”, there were a large number of comments on how this objective should be interpreted or achieved, which is strongly linked to the discussion on communication technologies. Several respondents considered that the initiative should also consider the ownership of (personal) data and the importance of informing and engaging consumers.

A large proportion of respondents across groups (68-86%) indicated as well that it was absolutely essential or very important for all objectives to be achieved at EU level, as opposed to only at national level or international standardisation.

In the position papers and other responses received during the Impact Assessment process, as well as in the discussions with MS experts, much emphasis was put on the objectives of interoperability and the forward-looking hybrid communication approach, and the perceived trade-off between them (discussed further below).

Policy measures & options

At the stage of the public consultation, the policy measures & options were not yet defined in detail. Respondent were rather asked what they considered the most appropriate type of action to achieve the objectives: (1) Legally binding EU specifications (2) Soft legislation (3) Industry-led approach.

Table 2: stakeholder response on type of action

 

Legally binding EU specifications

Soft legislation

Industry-led approach

Ensure continuous availability of C-ITS services for users across the EU, by clearly defining a set of priority C-ITS services

55 (most appropriate)

43

35

23 (moderately appropriate)

68

32

55 (least appropriate)

18

59

Ensure security of C-ITS communications by establishing common rules

76

27

28

16

84

22

39

18

73

Ensure the practical application of Data Protection in the area of C-ITS

80

33

18

20

82

22

31

14

86

Ensure a forward looking hybrid communication approach 

37

40

52

30

69

23

61

17

48

Ensure interoperability of C-ITS services by establishing common rules

66

39

26

13

73

35

51

13

64

Ensure seamless deployment of C-ITS service by establishing a compliance assessment

56

50

24

25

64

34

50

12

68

When analysing these responses, it becomes clear that legally binding specifications are often seen by the largest group of respondents to be most appropriate, but at the same time it is also seen by many respondents as the least appropriate. This difference is also seen in the comments that indicated a need for further clarification of how the objectives would effectively be addressed and to ensure that legal measures are proportionate. Important splits can be seen in relation to security where many respondent groups prefer binding specifications, but ITS service providers prefer an industry-led approach and interoperability, where many also prefer binding specifications, but none of the ITS service and telecommunications providers.

When asked if C-ITS equipment should be mandated in vehicles and/or on different parts of the road network to accelerate deployment, respondents were moderately favourable (45-64% (strongly) agreed), with many respondents indicating that mandates would provide the needed certainty about deployment, but specific circumstances and the maturity of the system should be considered when defining mandates. However, some respondents noted that mandating deployment can be difficult given the pace of technological change in the industry, and the lack of agreement on which communications technology to use.

In the later consultation activities (case studies, stakeholder workshop, expert group meetings), stakeholder were consulted on the policy measures & options. In terms of the scope, several stakeholders considered that the topics of investment costs and funding for C-ITS, the need to make C-ITS relevant for other modes & public transport and the need for action on access to in-vehicle data should receive added attention. Where relevant and within the scope of this initiative, this feedback has been used to further fine-tune the policy measures & options.

Regarding the proposed policy measures, several government stakeholders considered that a mandate for C-ITS equipment in vehicles should be explicitly considered. On interoperability (including communication technologies) there was very substantial stakeholder input from the automotive industry, technology suppliers and telecommunications industry, including through many stakeholder-initiated meetings and position papers, with strongly diverging positions. These largely reflect a similar divergence of opinions, with clear support from many stakeholders (including vehicle manufacturers, technology suppliers and road operators) on clear rules for interoperability starting from mature implementations, while others (including manufacturers, technology suppliers and telecommunications companies) argued for a technological-neutral framework where the choice of technology is left to the market through industry-led standardisation.

In discussions with MS experts, some MS argued for a technological-neutral framework where the choice of technology is left to the market, but a strong majority agreed with the need for clear rules for interoperability starting from mature implementations, and including a clear and transparent path for the inclusion of future solutions and technologies.

Impacts

In the Public Consultation, respondents were asked to give feedback on the initial assessment of impacts by the Commission (which was largely based on the previous deployment study). While most respondents agreed on most of the initial assessments, in particular that the deployment of C-ITS would have positive impacts on road safety, traffic efficiency and research and innovation, this was less the case for the costs associated with C-ITS, with several respondents indicating costs items that they considered very uncertain and which should be further addressed.

Some stakeholders also indicated that the impacts on modal shift, vulnerable road users and the link with automation should get more consideration, including possible negative impacts on the safety of vulnerable road users (e.g. if drivers would get distracted by or too reliant on C-ITS information) and environmental impacts (e.g. if the improvements through C-ITS would lead to a rebound effect with increasing road traffic).

While there is currently no evidence of these negative impacts 13 , and they would also be influenced by the exact implementation of C-ITS in vehicles (e.g. on how to combine C-ITS information with other information and how to present this to the driver), and wider transport policies, which are beyond the scope of the current initiative, these issues should be considered in the deployment of C-ITS and in future research.

Regarding impact on SMEs, a large majority indicated that they (strongly) agreed with the assessment that “common specifications for C-ITS will help ensure that progress is made by all actors across the value chain in a consistent and harmonised manner. This in turn is expected to reduce administrative burden and to broaden the C-ITS market and make it more accessible, in particular for Small and Medium Enterprises.”, although some respondents considered that this benefit is not specific to SMEs and that the link with administrative burden should be further clarified.

Around the stakeholder consultation workshop, stakeholders were consulted on the main assumptions underlying deployment of C-ITS and its cost and benefits, inter alia through a survey. The feedback received was used by the consultant to further refine the assumptions used in the modelling framework. 

4.Conclusion and use of results

In general, the stakeholder consultation process has shown a strong support for a legal framework to support the deployment of C-ITS.

The findings from the consultation activities have been used to analyse the problems, define the right policy alternatives and fine-tune the proposed measures. Input from stakeholders with a high level of technical expertise also served to validate the information from existing reports and studies. Where relevant, references have been made in the Impact Assessment Report to the outcome of the stakeholder consultations.

In particular, qualitative and quantitative feedback was used to update the modelling framework and the assumptions behind the policy scenarios (more details in annex B of the support study). Also, while a large number of stakeholders have been strongly supportive of (elements of) the preferred policy option of legally binding specifications, the scope and details of the measures, in particular on items with diverging stakeholder positions (e.g. interoperability (including communication technologies), the use of data, and the scope of services) have been carefully adjusted to be both effective and proportionate for the aim to be achieved:

·Interoperability: the system profiles, and their application, have been extensively reviewed and discussed with MS experts and the industry, to ensure that they are limited to the minimum requirements needed to ensure interoperability, in line with the principle of technology neutrality. While interoperability requirements can only be based on mature and tested implementations, a clear link to the integration of future technologies and services has been made through the inclusion of a clear review process.

·Use of data: on the use of data, the consultation process helped clarify the scope of the initiative (e.g. that the scope of this initiative does not include access to in-vehicle data) and that the requirements for lawfully processing personal data are provided by horizontal legislation, in particular the GDPR, and that measures under this initiative rather only facilitate the compliance of data controllers with these requirements, and are thus more limited in scope. As data protection remains a key element in C-ITS, further cooperation on this has been explicitly included in the implementation provisions of the specifications.

·Scope of services: The consultations made it clear that the inclusion of C-ITS services related to VRUs and public transport would further enhance the relevance of C-ITS, in particular in urban areas. While legally binding rules can necessarily only be based on the mature Day 1 services, specific emphasis on the development of C-ITS related to VRUs and public transport is put in the supporting measures, such as R&I.

5. Further Information

Further information on the process of stakeholder consultation is provided in the External Support Study for this Impact Assessment, in particular in its annexes A and E.



Annex 3: Who is affected and how?

1.Practical implications of the initiative

For clarity, this section includes the measures foreseen in PO2 (equivalent to the first step in the step-wise approach in PO3), as the measures foreseen in the second step of PO3 require a follow-up initiative.

Measure

Obligations for whom?

Costs

1

Definition of Day 1 services and their profiles in binding specifications + requirement for other services to be compatible with all Day 1 services

C-ITS station installers (vehicle manufacturers / road operators / local authorities)

Minor compliance costs (to ensure technological compatibility)

Not quantified

2

Mandate compliance with EU-wide system profiles in specifications

C-ITS station installers (vehicle manufacturers / road operators / local authorities) & technology providers

Minor compliance costs (technological compatibility)

Not quantified

3

Mandate to EU level standardisation organisations for further standardization.

ESOs / Commission

Cost to Commission (payment to ESOs), typically mandate costs approx. 1 million euro (depending on tasks)

4

Binding rules on the European Union C-ITS Security Credential Management System (EU CCMS)

C-ITS station operators (vehicle manufacturers / road operators / local authorities)

Set-up, management and operation of the secure communications architecture. Estimated at around 3 euros per C-ITS station per year (noted: secure communication needed regardless of requirement)

Implementation of Phase I of the EU C-ITS Security Credential Management System 2018-2021 is financed through the CEF (4 million euros)

5

Definition of compliance assessment criteria for Day 1 C-ITS services + conformity assessment procedure based on internal production control

C-ITS station manufacturers (charged to vehicle manufacturers / road operators / local authorities)

Costs for carrying out compliance assessment (considered limited compared to C-ITS station costs)

6

Define the purposes for lawfully processing personal data as traffic safety & efficiency, restricting other uses.

None (substantial requirements already imposed by GDPR)

None (substantial requirements already imposed by GDPR)

7

Coordination & Policy Advice through stakeholder platform

Commission to manage platform

Costs of participation (all)

Costs of organisation (Commission)

8

Enhanced deployment coordination + Fund EU deployment coordination after current piloting phase

Commission & MS manage platform

Costs of participation (all)

Costs of organisation (Commission & MS, possible through EU funding)

9

Definition of needed roles in specifications + requirement to report to the Commission on the bodies/authorities in charge.

Set-up of bodies to fulfil tasks (MS or industry)

Reporting obligation when setting up bodies (MS or industry)

Cost of operating bodies (MS or industry) (considered limited compared to C-ITS station costs)

10

Funding for development of services beyond the Day 1 list

None

EU research funding

11

Strengthen funding of deployment based on specifications to enable quicker uptake, including requirement on data reporting and exchange for deployment projects

Data reporting on co-funded deployment projects (MS & industry)

Cost of reporting (considered limited compared to C-ITS station costs)

EU deployment funding

2.Summary of costs and benefits

I. Overview of Benefits (total for all provisions) – Preferred Option

Description

Amount

Comments

Direct benefits

Casualties prevented (fatal, serious and slight) by safety measures

EUR 15 billion

Estimates for PO2, benefit for transport users

Reduced costs of urban travel time due to increased traffic efficiency

EUR 11 billion

benefit for transport users

Reduced fuel costs

EUR 11 billion

benefit for transport users

Reduced CO2 emissions

EUR 3.2 billion

benefit for whole society

Reduced pollutant emissions

EUR 0.2 billion

benefit for whole society

Indirect benefits

Potential for harmonisation of technical requirements for C-ITS services

Not quantified

Reduced costs for variants due to standardisation, benefits for C-ITS station installers and technology providers that can be reflected in lower prices.

II. Overview of costs – Preferred option

Citizens/Consumers

Businesses

Administrations

One-off

Recurrent

One-off

Recurrent

One-off

Recurrent

Measures 1/2

Direct costs

Minor compliance costs (not quantified)

Measure 3

Direct costs

EUR 1 million (Commission

Measure 4

Direct costs

Secure communication costs (only when deployed, included in system costs)

EUR 4 million (CEF)

Measure 5

Direct costs

Costs for carrying out compliance assessment ( not quantified)

Measures 7/8/9/

Indirect costs

Costs of participation & organisation (not quantified)

Measures 10/11

R&I and deployment funding



Annex 4: Analytical methods

1.Description of analytical models used

A series of steps were required to produce the modelling outputs for this Impact Assessment. This involved an extensive data collection exercise (described in more detail in Annex B.2.3 and B.2.4 of the support study) and definition of a series of deployment assumptions (described in Annex B.2.2 of the support study), followed by a series of modelling steps centred around the ASTRA and TRUST models, as shown in Figure 1 1 .

Figure 11: Key steps in producing CBA modelling outputs

The following figure shows the data flows for the modelling framework, which consists of several sub-models. The first module of the pre-processing is a calculation of penetration rates for vehicles, personal C-ITS devices and infrastructure. These are based on uptake assumptions and stock data. The penetration rates are then combined with impact data in the scenario module. The outputs from the scenario module, namely percentage improvements across the different policy options and country groupings, are then run through the macro-economic ASTRA/TRUST modelling framework. The outputs from these two models were then processed and combined into the RICARDO cost-benefit analysis (CBA) model to produce final outputs.

Figure 12: Data flows in the modelling

1.1.Pre-processing of data to calculate impacts

The pre-processing modules were developed in the context of the 2016 C-ITS deployment study by Ricardo. It has been revised and updated in the context of the Support Study for this Impact Assessment. The tool is a spreadsheet-based model implemented in Microsoft Excel.

Penetration rate estimates are made in the penetration calculation module of the modelling framework as shown in Figure 1 2 .

Uptake rates are used to estimate the penetration of C-ITS services into the total vehicle fleet, through new vehicles and personal C-ITS stations. Different uptake rates across cars, trucks and buses are considered. Total annual vehicle fleet size and annual vehicle sales for EU28 countries were provided by TRT from their ASTRA model run for the baseline scenario as well as EUROSTAT data for 2015. In the ASTRA model, car stock is modelled as well as new cars entering the fleet each year. Both stock and new vehicles are segmented by fuel, Euro standard and vehicle age.

Penetration rates of C-ITS services can be consistently applied on new or existing vehicles by vehicle age as the size of vehicle fleet stock and annual sales are not affected by the assumptions on C-ITS. In fact, the development of the car fleet in the ASTRA model does not depend on the penetration of C-ITS solutions nor C-ITS services equipment is included among the characteristics of vehicle fleet segmentation in the ASTRA model. These input uptake assumptions (in terms of percentage penetration of the fleet) are unaffected by the ASTRA/TRUST modelling but the resulting impacts (in terms of percentage change) are combined in ASTRA/TRUST with the actual activity/fleet for each Member State.

Similarly, uptake rates are used to estimate the extent of roads equipped with C-ITS supporting infrastructure. Separate rates are defined for C-ITS that is delivered through cellular and ITS-G5 (RSU) technologies. Different uptake rates for TEN-T Core, TEN-T Corridor, other motorways and other inter-urban roads are also considered. Total network road length by road type was provided by TRT based on the TRUST model road network for the EU28countries.

The detailed uptake assumptions for the baseline and policy options can be found in Annex B.2.2 of the support study.

The penetration rates obtained from the penetration calculation module are further processed in the scenario model, which combines uptake with impacts for different C-ITS services, covering: reductions in fuel consumption, reductions in CO2 and pollutant emissions, reduction of accident rates and change in average speed.

The full list of impact inputs considered in the model is presented in Annex B.2.3 of the support study. Since a number of C-ITS services covered in this study have similar functionality, multiple services are likely to overlap and be applicable to the same driving scenarios. The approach for accounting for the overlap between services in order to avoid double-counting impacts is described in Annex B.2.3.5 of the support study.

For each policy option and country grouping combination the module calculates the percentage improvements over time. This information is then further processed in the ASTRA/TRUST modelling framework.

1.2.ASTRA and TRUST modelling

ASTRA is a strategic model based on the Systems Dynamics Modelling approach, which simulates the EU transport system in combination with the economy and the environment. It is calibrated to reproduce major indicators such as fuel consumption, CO2 emissions and GDP according to the main European reference sources such as Eurostat until 2015. On the other hand, TRUST is a European transport network model that can compute energy consumption, pollutant emissions and accidents by road classification (TEN-T Corridors, Core TEN-T etc.). The following sections provide details of the two models.

1.2.1.ASTRA Model

ASTRA is a strategic model based on the Systems Dynamics Modelling approach simulating the transport system in combination with the economy and the environment. The model is made of different modules that are linked to each other.

As illustrated in Figure 1 3 , ASTRA consists of different modules, each related to one specific aspect such as the economy, transport demand or the vehicle fleet. The main modules cover the following aspects:

·Population and social structure (age cohorts and income groups)

·Economy (including input-output tables, government, employment, consumption and investment)

·Foreign trade (inside EU and to partners from outside EU)

·Transport (including demand estimation, modal split, transport cost and infrastructure networks)

·Vehicle fleet (passenger and freight road vehicles)

·Environment (including pollutant emissions, CO2 emissions, fuel consumption).

Geographically, ASTRA covers all EU 28 Member States 14 plus Norway and Switzerland.

Figure 13: Overview of linkages between the modules in ASTRA

The macro-economic module simulates the fundamental economic variables. Some of these variables (e.g. GDP) are transferred to the transport generation module, which uses the input to generate a distributed transport demand. In the transport module, transport demand is split by mode of transport. The traffic performance by mode is associated with the composition of the fleet (computed in the vehicle fleet module) and the emissions factors (defined in the environmental module), in order to estimate total emissions.

Several feedback effects take place in the model. For instance, the economic module provides the level of income to the fleet module, in order to estimate vehicle purchase. The economic module then receives information on the total number of purchased vehicles from the fleet module to account for this item of transport consumption and investment. Furthermore, changes in the economic system feed into changes of the transport behaviour and alter origins, destinations and volumes of European transport flows.

The treatment of the linkage between transport and the economy is particularly detailed due to some 'micro-macro bridges'. For instance, transport expenditures in the transport module produce changes in sectoral consumption and GDP at the national level: closing the feedback loop therefore implies to establish either macro-micro bridges (e.g. from GDP and sectoral output to goods flows) or vice versa micro-macro bridges (e.g. from transport investments into vehicle fleets to overall investments). This is important in this study, as ASTRA allows us to carry out analysis of the macro-economic impacts of the proposed policy options.

The main micro-macro bridges link:

·Passenger transport and sectoral consumption

·Transport and sectoral investment

·Transport and sectoral employment

·Freight transport and total factor productivity

·Transport and intermediate inputs of input-output tables

·Transport and exports.

In addition, government revenues and expenditures are differentiated as far as possible into categories that can be modelled endogenously by ASTRA and one category covering other revenues or other expenditures. Categories that are endogenous comprise, for example, VAT and fuel tax revenues, revenues from transport charges, and transport investments. Intermediate demand is modelled by means of an explicit Input-Output mechanism that describes the technical coefficients between the economic sectors.

The environment module uses input from the transport module (in terms of vehicle-kilometres-travelled per mode and geographical context) and from the vehicle fleet module (in terms of the technical composition of vehicle fleets), in order to compute fuel consumption, greenhouse gas emissions and air pollutant emissions from transport. ASTRA also estimates the upstream emissions (well-to-tank) due to fuel production and vehicles production. Therefore, well-to-wheel emissions can be provided as well.

In terms of road transport time, ASTRA simulates the impacts of traffic and/or infrastructure network in a simplified way. In fact, the effect of speed-flow functions is included in the model indirectly: in other words, the increase of traffic flow has an impact on transport time but the functions and capacity values are not implemented directly in the tool. The road network is differentiated into three “categories”: Urban, Non-Urban – short distance, Non-Urban - long distance. For each category, the impact of speed-flow functions is simulated separately.

ASTRA is calibrated to reproduce major indicators such as transport performance, fuel consumption, CO2 emissions and GDP according to the main European reference sources such as Eurostat until 2015. For future trends, it builds on the updated EU Reference scenario 2016 used in the impact assessments accompanying the new General Safety Regulation and Road Infrastructure Safety Management Directive proposals (GSR/RISM) 15 , but includes additional policy measures and initiatives related to C-ITS.

More details on the ASTRA model and its applications can be found at the ASTRA website: http://www.astra-model.eu/ .

Recent developments

Compared to the version of ASTRA used in the 2016 C-ITS deployment project, the current version includes two recent developments.

First, the model has been expanded in terms of geographical coverage to now cover Croatia.

Second, the simulation of the impacts of TEN-T projects in terms of time and cost variations is improved and directly linked to the TRUST network model results (where the physical changes are implemented in the road and rail network), taking into account different demand segments and geographical dimensions.

Finally, the model has been recalibrated to reproduce observed statistics of transport activity, energy consumption, accidents until 2015. For future years, it builds on the updated EU Reference scenario 2016 used in the impact assessments accompanying the new General Safety Regulation and Road Infrastructure Safety Management Directive proposals (GSR/RISM), but includes additional policy measures and initiatives related to C-ITS.

Baseline

In the baseline scenario the ASTRA model estimates that in EU28 countries passenger transport activity (in terms of pkm) will grow as much as 24% between year 2015 and year 2035 (1.1% per year). At the same time. freight transport activity for road and rail modes (in terms of tkm) is estimated to increase by 39% between 2015 and 2035 (1.66% per year), with road transport (HDV and LDV) increasing by 37.5% (1.7% per year).

In the year 2015, the annual number of fatalities, serious and slight injuries in EU28 countries for motorised road modes 16 is about 1,051,000 accidents. According to the ASTRA baseline projections, the number of total accidents 17 is expected to decrease by 11.3% by 2035 relative to 2015, i.e. about 932,000 accidents in 2035. The decrease is different according to the seriousness of the accidents: the number of fatalities would decrease by 17.9%, while the reduction in the serious and slight injuries would be lower at 11.3% and 11.2%. Adding in the analysis also non-motorised modes (cyclists and pedestrians), the number of total accidents is about 1,460,400 in 2015, projected to decrease to 1,294,200 in 2035 (by 11.4%).

In terms of energy consumption, according to the ASTRA baseline, the road transport modes 18 are expected to decrease their energy use by 9.3% by 2035 (-0.5% per year), relative to 2015. As a consequence, tank-to-wheel annual CO2 emissions from road transport would fall by 15% by 2035 relative to 2015 (-0,8% per year) 19 . Reduction of CO2 emissions is larger than reduction of energy consumption because of a different energy mix, with larger shares of low-carbon fuels.

With reference to road safety, the ASTRA model covers the following categories of accidents: fatalities, serious injuries, and slight injuries. The estimation is endogenously performed for cars, vans, buses and heavy goods vehicles, while exogenous parameters are applied to estimate accidents related to motorized 2-wheelers, cyclists and pedestrians.

In terms of air pollutant emissions, the ASTRA model estimates the impacts on VOC, NOx and PM. According to the ASTRA baseline projections, the pollutant emissions are expected to decrease until the year 2035 on an annual basis respectively by 2.4% for PM, 4.5% for Nox and 1.3% for VOC.

1.2.2.TRUST model

TRUST (TRansport eUropean Simulation Tool) is a transport network model developed by TRT in the VISUM software environment for the assignment of Origin-Destination matrices at the NUTS3 level of detail for passenger and freight demand.

The matrices of tonnes and passengers are estimated from various sources, including Eurostat, national statistics and ETIS. Intra-NUTS3 demand is not part of the matrices as it is not assigned to the network, but implicitly considered as pre-load on links.

The model is calibrated to reproduce tonnes-km and passengers-km by country consistent to the statistics reported in the Eurostat Transport in Figures pocketbook (net of intra-NUTS3 demand, which is not assigned to the network). At Member State level, the trend of road transport activity has been aligned to the trend of road transport demand in the ASTRA model.

All of Europe is covered, including Accession and Neighbouring countries. A less detailed zoning system is used for other European countries (e.g. European Russia, Ukraine).

The TRUST road network includes all the relevant links between the NUTS3 regions, i.e. motorways, primary roads as well as roads of regional and sub-regional interest. Also ferry connections (Ro-Ro services) between European regions and between European regions and the North Africa are explicitly modelled with their travel time and fare. Road network links are separated in different classes, each with specific features in term of capacity, free-flow speed and toll. The link types distinguish different road categories (e.g. motorways). Within the same category link types distinguish roads with other different features, in particular toll level. Specific flags are used to identify links belonging to the Core TEN-T Network, to each TEN-T corridor and to the Comprehensive network.

Matrices are in terms of trips or tonnes in an average day (24 hours). Trips and tonnes are endogenously translated into vehicles loaded onto the road network by means of average occupancy and load factors.

Table 11: Occupancy / Load factors in the TRUST road model

Demand segment

Occupancy factor / Load factor

Passenger

Short distance (< 100 km) commuting

1.5 pers/veh

Short distance (< 100 km) non-commuting

1.8 pers/veh

Long distance (> 100 km)

1.9 pers/veh

Freight

Domestic Short distance (<= 50 km)

4 t/veh (empty trips are considered)

Domestic average distance (50 – 150 km)

10 t/veh (empty trips are considered)

Domestic Long distance (>= 150 km)

10 t/veh (empty trips are considered)

International

14 t/veh (empty trips are considered)

Source: TRT, TRUST model

For each Origin/Destination pair, the model distributes demand among available alternative routes using a logit algorithm. The utility of each path is measured in terms of generalised cost i.e. the sum of monetary costs and monetary equivalent of travel time 20 . Travel time on each link of the road network depends on link features and on the level of congestion through specific speed-flow functions. Travel cost depends on link-based tolls and on cost parameters representing the variable operating costs (fuel and, for trucks, driver costs) relevant for path choice. Variable operating costs are different across freight demand segments to reflect that lighter vehicles are used on short distances rather than on long distances. In addition, values of travel time, used to compute the generalised cost, are different among the freight demand segments.

The main output of the model is the load on network links in terms of vehicles per day (see example below, Figure 1 4 ).

Using traffic load as an input parameter, the model also provides emissions by link for VOC, NOx, CO, PM and CO2. Emissions factors based on COPERT functions and on the average fleet composition are used in the model to estimate total emissions. When the model is run for forecasting purposes for future years, the emission factors are updated considering the ASTRA projections regarding the evolution of the fleet in the selected year.

Accidents are estimated based on traffic load by link with the application of accident rates.

Figure 14: TRUST model link flows

Source: TRUST model

Recent developments

The TRUST model underwent two main revisions since 2016. First, the classification of roads has been updated. In particular, the identification of the TEN-T comprehensive network has been improved and made fully consistent to the official TENtec classification 21 . Second, the model has been re-calibrated for future years; it builds on the updated EU Reference scenario 2016 used in the impact assessments accompanying the new General Safety Regulation and Road Infrastructure Safety Management Directive proposals (GSR/RISM), but includes additional policy measures and initiatives related to C-ITS.

1.2.3.Application of the modelling tools

In carrying out the modelling analysis, the different scenarios are translated into specific inputs for the two models.

The ASTRA model is used to produce indicators at the national level, including e.g.: mode split, transport energy demand, CO2 emissions, pollutant emissions (VOC, NOx and PM), road accidents, average individual expenditure for mobility, macro-economic impact on GDP. ASTRA is run on an annual basis until the year 2035: the impacts of each scenario are observed over time in terms of aggregated indicators.

The TRUST network model is used to produce indicators by mode (cars and trucks) based on road network links, such as fuel consumption, CO2 emissions, pollutant emissions (NOx, VOC and PM) and accidents. Four different categories of road network are considered: TEN-T Corridors, Rest of TEN-T Core network, TEN-T comprehensive, other interurban roads. TEN-T comprehensive roads are considered representative of ‘other motorways’, which is the designation used in this study. The TRUST model is run every five years from 2015 to 2035, simulating the relevant changes on the supply side (evolution of road network over time due to the completion of TEN-T core and non-core network) and on the demand side (i.e. updated origin-destination matrix). The matrix update is based on the growth rates of demand by mode, country, Origin-Destination and spatial domain provided by ASTRA.

Figure 15: Use of the modelling tools for scenarios simulation

1.3.Cost Benefit Analysis Model

A specific cost benefits analysis model had been developed in the context of the 2016 C-ITS deployment study by Ricardo. It has been revised and updated in the context of the Support Study for this Impact Assessment. The tool is a spreadsheet-based model implemented in Microsoft Excel.

In the CBA, the EU-level impacts determined in the ASTRA & TRUST models are converted to monetised benefits using typical values for the external cost of transport from the Handbook on External Costs of Transport. 22

Cost data are combined with the uptake and penetration rates for different services for the different scenarios determined in the scenario model to be translated into costs.

2.Reliability and Appropriateness of the models used

This impact assessment, which examines the future impacts of technologies not yet in place beyond trial projects has some necessary limitations in terms of the information available on potential deployment and associated costs and benefits. This is also why existing transport models used in isolation would not be useful to analyse the impacts of policy options to speed up the deployment of C-ITS, as these models do include neither detailed C-ITS measures nor impacts. A excel-based cost-benefit tool as the one used for this Impact Assessment has the advantage of providing a transparent understanding of links between inputs, assumptions and outputs, more closely related to the reality of deploying C-ITS services.

To address the limitations in data availability and other uncertainties, an extensive review of documentation available on deployment projects, case study interviews and other wider stakeholder engagement activities were carried out to gather further information, and various policy options/deployment scenarios were tested with different C-ITS uptake profiles between 2019 and 2035.

The assessment of the potential impacts of different C-ITS service offerings is based on existing research, and in some cases, where there is no research available, an estimate based on comparable C-ITS services. Once large-scale deployment is under way, it may be that the actual impacts of the various C-ITS services are different than those estimated in this impact assessment. A related aspect to this is the fast-moving nature of the technology itself. For example, no benefits of time-critical safety services for personal C-ITS devices were modelled, but in the future, this technology may be available in such devices.

It has to be considered that this Impact Assessment has a strong focus on Day 1 services, which are predominantly services for road safety. For most V2V services, it was expected that non-safety impacts would be minimal, and this was confirmed by other studies that often did not consider non-safety impacts or found them to be insignificant. For example, the Drive C2X study concluded that non-safety impacts were insignificant for ‘Traffic jam ahead warning’ (TJW). More non-safety related impacts were identified in the literature for I2V services, although safety impacts remain the most common primary objective. While it should be expected that impacts from Day 1 services will be mainly related to safety, it is appreciated that other impacts may be underestimated due to less of a focus in existing studies.

In section 7.2 of the Impact Assessment support study, a number of simplifications made for modelling purposes and their effects are discussed. As the methodology, inputs and assumptions behind the modelling have been developed together with relevant experts, and consistently consulted with stakeholders both in this Impact Assessment process and the preceding deployment study, the results are considered to be robustly displaying the relevant trends in the baseline and in the policy options, and provide the appropriate means for comparing the baseline and the policy options between themselves.

3.Detailed results per member state

This section presents the detailed social, economic and environmental impacts by Member State for each policy option.

The model suite used for this analysis was primarily designed to calculate EU level impacts. While impacts per MS can be extracted from the modelling output, these are the result of input assumptions mostly at the EU level, and thus have to be considered with significant caution. Due to limitations in the modelling, these disaggregated impacts can only be presented in monetary terms.

Cost of accidents in 2035

Country

PO1

PO2

PO3

Baseline

AT

€ 4.529.719.861

€ 4.155.504.079

€ 4.073.726.467

€ 4.670.883.320

BE

€ 5.046.610.575

€ 4.612.569.311

€ 4.511.005.145

€ 5.259.803.909

DK

€ 720.949.859

€ 666.789.693

€ 652.271.405

€ 744.623.671

ES

€ 8.589.160.725

€ 7.994.902.278

€ 7.866.610.124

€ 8.866.592.513

FI

€ 989.315.598

€ 913.548.008

€ 897.301.605

€ 1.017.309.889

FR

€ 10.671.275.102

€ 9.812.744.238

€ 9.631.257.973

€ 10.997.055.651

UK

€ 17.737.894.525

€ 16.328.285.029

€ 16.071.371.196

€ 18.496.375.457

DE

€ 33.475.892.865

€ 30.831.692.147

€ 30.307.773.509

€ 34.475.451.723

EL

€ 1.837.910.245

€ 1.713.137.546

€ 1.687.653.943

€ 1.893.547.889

IE

€ 890.891.845

€ 829.534.850

€ 813.652.343

€ 922.962.368

IT

€ 18.863.763.974

€ 17.495.028.888

€ 17.206.597.693

€ 19.532.141.688

LU

€ 230.263.265

€ 211.057.386

€ 207.259.436

€ 241.778.233

NL

€ 2.514.318.730

€ 2.308.111.061

€ 2.265.504.392

€ 2.595.720.591

PT

€ 2.475.034.404

€ 2.300.856.614

€ 2.261.654.943

€ 2.556.003.303

SE

€ 1.782.919.099

€ 1.641.233.497

€ 1.617.392.537

€ 1.841.108.182

BG

€ 782.321.157

€ 733.792.975

€ 719.356.054

€ 804.449.817

CY

€ 103.255.703

€ 97.359.449

€ 95.512.460

€ 105.659.282

CZ

€ 1.866.499.133

€ 1.724.287.212

€ 1.687.184.649

€ 1.928.288.584

EE

€ 107.243.239

€ 98.849.552

€ 96.834.389

€ 111.719.185

HU

€ 1.330.170.754

€ 1.245.671.113

€ 1.220.809.233

€ 1.366.687.973

LV

€ 288.895.202

€ 270.729.852

€ 266.220.595

€ 298.071.331

LT

€ 323.616.749

€ 304.641.301

€ 300.239.798

€ 332.694.186

MT

€ 46.095.015

€ 42.593.363

€ 41.809.479

€ 48.339.771

PL

€ 4.301.998.692

€ 4.055.260.003

€ 3.982.792.631

€ 4.399.124.512

RO

€ 2.671.982.213

€ 2.502.119.733

€ 2.455.644.526

€ 2.742.301.558

SI

€ 724.203.864

€ 667.019.395

€ 656.577.383

€ 752.772.030

SK

€ 781.021.797

€ 725.430.653

€ 708.166.100

€ 804.462.520

HR

€ 879.468.151

€ 826.114.620

€ 814.035.696

€ 906.689.861

EU28

€ 124.562.692.341

€ 115.108.863.847

€ 113.116.215.704

€ 128.712.618.998



Urban travel time costs in 2035

Country

PO1

PO2

PO3

Baseline

AT

€ 10.419.049.499

€ 10.359.038.957

€ 10.257.985.360

€ 10.425.968.708

BE

€ 17.367.761.973

€ 17.177.294.661

€ 16.962.458.980

€ 17.433.329.489

DK

€ 3.798.066.341

€ 3.776.845.989

€ 3.740.823.754

€ 3.801.696.843

ES

€ 53.542.886.573

€ 53.068.373.014

€ 52.569.750.217

€ 53.706.963.601

FI

€ 5.475.639.695

€ 5.455.031.584

€ 5.410.656.662

€ 5.476.902.597

FR

€ 100.928.537.013

€ 100.631.906.658

€ 99.775.081.583

€ 100.904.222.177

UK

€ 114.566.701.184

€ 114.116.246.945

€ 113.082.969.511

€ 114.561.271.909

DE

€ 118.370.601.066

€ 117.506.993.290

€ 116.358.895.841

€ 118.567.420.096

EL

€ 10.745.767.135

€ 10.645.642.286

€ 10.554.341.720

€ 10.781.845.424

IE

€ 4.819.549.610

€ 4.803.968.636

€ 4.764.476.357

€ 4.817.272.587

IT

€ 62.191.258.255

€ 61.817.320.711

€ 61.268.143.551

€ 62.284.898.401

LU

€ 1.121.867.076

€ 1.116.100.835

€ 1.104.909.906

€ 1.122.184.289

NL

€ 23.204.425.705

€ 23.131.371.721

€ 22.938.196.966

€ 23.202.295.743

PT

€ 6.105.569.958

€ 6.088.363.491

€ 6.039.473.758

€ 6.102.672.928

SE

€ 11.626.802.673

€ 11.594.413.066

€ 11.505.471.171

€ 11.625.072.043

BG

€ 3.605.797.246

€ 3.603.591.295

€ 3.582.592.551

€ 3.601.962.836

CY

€ 92.600.988

€ 92.323.845

€ 91.676.647

€ 92.588.603

CZ

€ 13.255.858.875

€ 13.109.139.140

€ 12.955.212.739

€ 13.311.477.901

EE

€ 943.661.466

€ 935.160.838

€ 924.784.983

€ 947.003.553

HU

€ 6.570.467.983

€ 6.473.140.514

€ 6.397.968.282

€ 6.622.427.387

LV

€ 2.777.326.878

€ 2.764.653.921

€ 2.744.162.883

€ 2.780.325.823

LT

€ 4.928.837.450

€ 4.921.181.210

€ 4.891.573.727

€ 4.924.118.686

MT

€ 422.892.250

€ 419.557.270

€ 415.019.798

€ 423.925.446

PL

€ 31.246.601.342

€ 31.013.690.504

€ 30.754.262.369

€ 31.329.217.115

RO

€ 9.444.525.876

€ 9.362.638.112

€ 9.272.429.540

€ 9.470.578.100

SI

€ 2.272.405.576

€ 2.258.365.394

€ 2.236.607.753

€ 2.275.230.659

SK

€ 4.751.140.648

€ 4.723.778.987

€ 4.677.742.474

€ 4.759.986.882

HR

€ 1.836.490.523

€ 1.830.634.878

€ 1.815.736.501

€ 1.833.265.674

EU28

€ 626.433.090.856

€ 622.796.767.753

€ 617.093.405.585

€ 627.186.125.500



CO2 emission costs in 2035

Country

PO1

PO2

PO3

Baseline

AT

€ 1.821.708.171

€ 1.805.941.199

€ 1.801.024.868

€ 1.826.153.539

BE

€ 2.458.233.392

€ 2.433.716.401

€ 2.422.206.393

€ 2.466.166.937

DK

€ 933.996.335

€ 924.981.349

€ 921.127.319

€ 936.686.693

ES

€ 6.646.551.310

€ 6.589.306.215

€ 6.566.055.883

€ 6.664.379.966

FI

€ 867.020.804

€ 859.554.905

€ 856.262.792

€ 868.874.326

FR

€ 9.880.621.143

€ 9.797.997.079

€ 9.770.712.645

€ 9.902.614.014

UK

€ 8.504.866.956

€ 8.433.965.789

€ 8.411.498.196

€ 8.527.364.137

DE

€ 10.440.868.941

€ 10.344.201.435

€ 10.318.476.393

€ 10.466.405.363

EL

€ 1.292.905.578

€ 1.284.011.997

€ 1.280.522.603

€ 1.295.191.935

IE

€ 1.081.353.104

€ 1.072.943.128

€ 1.069.526.714

€ 1.084.070.935

IT

€ 7.382.622.905

€ 7.321.154.892

€ 7.303.182.427

€ 7.404.712.865

LU

€ 697.384.275

€ 691.277.107

€ 688.382.653

€ 700.518.796

NL

€ 2.214.936.929

€ 2.195.152.042

€ 2.188.219.312

€ 2.220.443.535

PT

€ 1.219.575.323

€ 1.210.522.813

€ 1.207.986.473

€ 1.221.916.252

SE

€ 1.697.149.091

€ 1.682.995.805

€ 1.678.637.122

€ 1.700.988.675

BG

€ 594.344.548

€ 590.278.850

€ 588.043.319

€ 595.325.028

CY

€ 132.210.767

€ 131.032.061

€ 130.630.319

€ 132.614.811

CZ

€ 1.484.716.134

€ 1.470.026.104

€ 1.463.390.756

€ 1.488.977.118

EE

€ 176.845.028

€ 175.291.360

€ 174.518.984

€ 177.487.929

HU

€ 909.474.355

€ 902.047.281

€ 898.295.790

€ 911.893.675

LV

€ 209.876.228

€ 208.576.049

€ 207.974.536

€ 210.340.930

LT

€ 328.840.739

€ 327.053.232

€ 326.263.725

€ 329.317.405

MT

€ 37.405.589

€ 37.059.261

€ 36.877.831

€ 37.428.864

PL

€ 4.847.479.329

€ 4.812.129.608

€ 4.797.449.175

€ 4.857.761.252

RO

€ 1.380.197.255

€ 1.369.422.574

€ 1.364.848.987

€ 1.383.187.473

SI

€ 433.827.962

€ 429.534.297

€ 428.121.638

€ 435.295.311

SK

€ 614.504.574

€ 609.148.095

€ 606.613.939

€ 616.190.233

HR

€ 505.061.073

€ 501.695.985

€ 500.542.498

€ 505.989.669

EU28

€ 68.794.577.840

€ 68.211.016.912

€ 68.007.393.289

€ 68.968.297.664



Other pollutant emissions costs (NOx, VOC, PM) in 2035

Country

PO1

PO2

PO3

Baseline

AT

€ 443.720.317

€ 445.334.005

€ 447.183.505

€ 444.393.013

BE

€ 499.222.366

€ 496.994.422

€ 496.015.943

€ 500.748.497

DK

€ 109.057.344

€ 108.767.061

€ 108.629.333

€ 109.213.263

ES

€ 640.745.238

€ 639.173.060

€ 638.706.724

€ 641.856.807

FI

€ 54.478.567

€ 54.330.800

€ 54.284.450

€ 54.544.100

FR

€ 2.757.394.009

€ 2.750.873.228

€ 2.749.164.004

€ 2.760.577.047

UK

€ 1.503.418.939

€ 1.501.159.991

€ 1.501.322.340

€ 1.504.295.196

DE

€ 3.632.507.225

€ 3.623.687.454

€ 3.621.534.935

€ 3.636.734.725

EL

€ 95.835.677

€ 96.258.296

€ 96.447.674

€ 95.601.062

IE

€ 111.089.928

€ 110.943.814

€ 110.913.557

€ 111.175.700

IT

€ 1.731.867.954

€ 1.731.845.201

€ 1.736.006.487

€ 1.733.873.863

LU

€ 86.691.164

€ 86.351.027

€ 86.224.216

€ 86.992.225

NL

€ 365.962.074

€ 365.206.935

€ 365.081.125

€ 366.371.057

PT

€ 87.492.220

€ 87.679.068

€ 87.772.783

€ 87.454.416

SE

€ 120.762.716

€ 120.418.473

€ 120.350.477

€ 120.920.860

BG

€ 140.473.187

€ 140.438.724

€ 140.332.821

€ 140.437.728

CY

€ 5.768.867

€ 5.747.401

€ 5.737.129

€ 5.777.332

CZ

€ 432.200.774

€ 430.725.973

€ 430.124.835

€ 432.966.242

EE

€ 15.594.570

€ 15.537.168

€ 15.514.215

€ 15.634.169

HU

€ 281.741.070

€ 280.832.413

€ 280.478.371

€ 282.268.079

LV

€ 33.473.676

€ 33.454.416

€ 33.444.574

€ 33.489.474

LT

€ 49.288.820

€ 49.276.216

€ 49.281.389

€ 49.292.077

MT

€ 4.411.890

€ 4.407.134

€ 4.402.390

€ 4.393.241

PL

€ 1.193.243.290

€ 1.191.056.920

€ 1.190.503.347

€ 1.194.863.077

RO

€ 408.606.110

€ 407.979.698

€ 407.714.864

€ 408.787.631

SI

€ 70.989.749

€ 70.696.880

€ 70.602.870

€ 71.153.533

SK

€ 224.952.562

€ 224.108.128

€ 223.735.668

€ 225.406.125

HR

€ 93.890.896

€ 93.858.139

€ 93.858.623

€ 93.921.043

EU28

€ 15.194.881.198

€ 15.167.142.042

€ 15.165.368.649

€ 15.213.141.583

 

PO1 - Annual 2035

PO2 - Annual 2035

PO3 - Annual 2035

Country

Total Costs

Total Benefits

Net Benefits

Total Costs

Total Benefits

Net Benefits

Total Costs

Total Benefits

Net Benefits

AT

€ 18.434.363

€ 169.519.455

€ 151.085.092

€ 75.754.399

€ 675.801.483

€ 600.047.084

€ 94.715.966

€ 879.610.541

€ 784.894.575

BE

€ 25.090.408

€ 316.195.522

€ 291.105.114

€ 106.878.502

€ 1.053.438.092

€ 946.559.590

€ 139.015.434

€ 1.422.113.330

€ 1.283.097.897

DK

€ 11.560.205

€ 40.151.004

€ 28.590.799

€ 48.564.307

€ 158.190.729

€ 109.626.422

€ 63.117.291

€ 226.715.758

€ 163.598.466

ES

€ 55.415.704

€ 523.818.023

€ 468.402.320

€ 241.501.888

€ 1.854.852.601

€ 1.613.350.713

€ 295.918.081

€ 2.586.630.378

€ 2.290.712.297

FI

€ 7.034.126

€ 38.294.222

€ 31.260.097

€ 30.691.252

€ 170.727.928

€ 140.036.676

€ 36.587.582

€ 247.044.942

€ 210.457.360

FR

€ 99.173.927

€ 404.501.820

€ 305.327.893

€ 437.862.721

€ 1.941.051.670

€ 1.503.188.950

€ 565.621.650

€ 3.103.417.062

€ 2.537.795.411

UK

€ 127.177.685

€ 858.032.527

€ 730.854.842

€ 536.556.433

€ 3.045.493.645

€ 2.508.937.213

€ 697.004.884

€ 4.436.094.542

€ 3.739.089.658

DE

€ 141.648.511

€ 1.318.892.436

€ 1.177.243.925

€ 585.276.872

€ 5.282.970.085

€ 4.697.693.214

€ 752.198.686

€ 7.073.041.819

€ 6.320.843.133

EL

€ 5.753.787

€ 102.200.299

€ 96.446.513

€ 23.237.615

€ 367.767.566

€ 344.529.951

€ 23.064.782

€ 500.146.736

€ 477.081.954

IE

€ 15.400.836

€ 42.219.813

€ 26.818.977

€ 43.888.277

€ 157.151.633

€ 113.263.357

€ 53.472.110

€ 227.647.222

€ 174.175.112

IT

€ 80.098.808

€ 869.024.715

€ 788.925.907

€ 320.681.118

€ 2.903.244.593

€ 2.582.563.476

€ 380.961.889

€ 3.821.023.218

€ 3.440.061.329

LU

€ 8.749.715

€ 26.375.225

€ 17.625.510

€ 17.330.024

€ 79.318.804

€ 61.988.780

€ 20.638.108

€ 107.350.691

€ 86.712.583

NL

€ 22.260.719

€ 105.387.111

€ 83.126.392

€ 93.010.124

€ 477.597.646

€ 384.587.521

€ 117.253.950

€ 745.174.967

€ 627.921.017

PT

€ 8.581.262

€ 88.882.476

€ 80.301.214

€ 39.433.936

€ 322.057.712

€ 282.623.776

€ 48.548.481

€ 421.736.499

€ 373.188.019

SE

€ 20.124.933

€ 75.039.593

€ 54.914.660

€ 84.859.833

€ 317.517.095

€ 232.657.262

€ 108.597.489

€ 451.411.000

€ 342.813.511

BG

€ 11.326.094

€ 22.725.058

€ 11.398.964

€ 23.803.159

€ 91.835.494

€ 68.032.335

€ 23.469.905

€ 137.297.465

€ 113.827.560

CY

€ 6.782.570

€ 4.200.415

-€ 2.582.155

€ 9.025.481

€ 15.618.773

€ 6.593.292

€ 9.221.940

€ 19.864.103

€ 10.642.162

CZ

€ 14.924.225

€ 137.555.862

€ 122.631.637

€ 60.390.022

€ 494.691.157

€ 434.301.135

€ 72.508.968

€ 716.018.959

€ 643.509.991

EE

€ 7.861.602

€ 10.642.450

€ 2.780.847

€ 12.987.882

€ 34.286.387

€ 21.298.505

€ 13.915.410

€ 49.973.319

€ 36.057.909

HU

€ 13.705.027

€ 100.099.209

€ 86.394.182

€ 34.699.670

€ 316.740.611

€ 282.040.941

€ 38.364.762

€ 433.912.294

€ 395.547.532

LV

€ 8.048.784

€ 14.235.147

€ 6.186.363

€ 13.131.679

€ 50.787.567

€ 37.655.888

€ 13.827.272

€ 78.404.917

€ 64.577.645

LT

€ 8.187.817

€ 6.465.836

-€ 1.721.981

€ 13.641.818

€ 40.969.879

€ 27.328.061

€ 14.396.296

€ 78.397.805

€ 64.001.510

MT

€ 6.566.463

€ 3.380.943

-€ 3.185.520

€ 8.027.444

€ 11.735.635

€ 3.708.192

€ 8.227.712

€ 17.849.914

€ 9.622.202

PL

€ 38.967.639

€ 228.447.722

€ 189.480.083

€ 132.449.267

€ 872.032.685

€ 739.583.418

€ 138.803.183

€ 1.270.916.688

€ 1.132.113.505

RO

€ 16.072.944

€ 110.063.293

€ 93.990.349

€ 43.388.952

€ 410.931.772

€ 367.542.819

€ 44.903.133

€ 568.071.852

€ 523.168.719

SI

€ 3.401.654

€ 38.384.960

€ 34.983.306

€ 13.664.851

€ 129.809.905

€ 116.145.053

€ 17.094.538

€ 168.516.278

€ 151.421.740

SK

€ 12.398.361

€ 40.430.651

€ 28.032.290

€ 31.104.159

€ 148.567.888

€ 117.463.729

€ 35.281.020

€ 223.598.317

€ 188.317.297

HR

€ 10.021.718

€ 28.233.728

€ 18.212.010

€ 19.817.588

€ 102.711.640

€ 82.894.052

€ 21.112.324

€ 134.856.306

€ 113.743.982

EU28

€ 804.769.887

€ 5.723.399.516

€ 4.918.629.630

€ 3.101.659.272

€ 21.527.900.675

€ 18.426.241.403

€ 3.847.842.845

€ 30.146.836.923

€ 26.298.994.078

Annex 5: Key aspects of C-ITS

1.Introduction

This Annex provides a description of key aspects of Cooperative Intelligent Transport Systems (C-ITS). C-ITS enable cooperation between transport participants (including vehicles, vulnerable road users, road operators and others), based on the exchange of messages, to improve road safety and traffic efficiency. It is important to note that C-ITS services, stations and communications can evolve over time, and that this description is thus informative and does not preclude the further development C-ITS in any way.

Figure 7: Illustration of typical interactions existing within a C-ITS network

Every unit of a C-ITS network, being mobile, standing roadside or central, sends data and exploits the data received from other devices to generate strategic warnings, tactical advices and driver information. While vehicle units broadcast data about their position, speed and driving direction or event-driven information, such as an obstacle or changing environmental conditions, roadside units deliver local data such as speed limits, signal phases and timing of traffic lights or information about traffic diversion.

The vehicle units integrate all data received to form a picture of the local traffic situation and generate information and warnings directly relevant for the drivers. For example, based on the exchanged data between vehicles and vehicles and vehicles and infrastructure a driver would receive information via an ergonomic Human Machine Interface (HMI) about works blocking the road ahead or would be warned regarding situations requiring attention.

Using the sensors of the vehicle' driver assistance systems and the communication capabilities of cooperative systems, hazardous locations like slippery roads or black ice and aquaplaning areas detected by one vehicle can be communicated to other approaching vehicles.

C-ITS services are provided through the exchange of messages between C-ITS stations in the C-ITS network. This should be distinguished from value-added services that can be based on C-ITS services (e.g. through aggregation and analysis of data), or other complementary ITS services that can be provided through the wider internet (such as infotainment).

2.C-ITS services and messages

The communication architecture underlying C-ITS in principle allows the exchange of a wide variety of data and services. However, the current work puts emphasis on the deployment of the so-called “Day 1” services, which are considered to be mature in the EU from 2019 and thus ready for quick deployment. Day 1.5 C-ITS services are considered to be mature, but not quite ready for a large-scale deployment due to a lack of full specifications or standards, and so would be deployed in a second phase from 2025 onwards. 23  An overview of both the Day 1 and Day 1.5 services in the scope of this Impact Assessment is presented in the table below.

The Day 1 services have a relatively strong focus on vehicle-to-vehicle and infrastructure-to-vehicle communication to improve road safety on highways. However the industry already has plans for building a large number of progressively more sophisticated services based on the same C-ITS architecture, which would also add more emphasis on other environments (urban, secondary roads), users (public transport and vulnerable road users) and impacts (traffic efficiency and environmental impacts), which is already evident in the Day 1.5 services.

The Day 1 services are primarily based on the exchange of a number of standardized messages: CAM, DENM, IVIM, SPATEM, MAPEM. In particular the cooperative awareness message (CAM) and the dynamic environmental notification message (DENM) play an essential role in many of the services.

CAMs are messages exchanged in the C-ITS network between C-ITS stations to create and maintain awareness of each other and to support cooperative performance of vehicles using the road network. A CAM contains status and attribute information of the originating C-ITS stations. The content varies depending on the type of the C-ITS stations. For vehicle C-ITS stations the status information includes time, position, motion state, activated systems, etc. and the attribute information includes data about the dimensions, vehicle type and role in the road traffic, etc.

From both the short and midterm perspectives, the CAM will increase the vehicle’s capability to better anticipate traffic situations due its greater line of sight range and its ability in non-line of sight conditions to “see” around the corner or “through” other vehicles than any other current sensor. These performance features are already usable in current Advanced Driver Assistance Systems (ADAS) applications like Adaptive Cruise Control (ACC), Blind Spot Monitor, Lane Change Assistant, Collision Avoidance Systems, etc. as they extend the visibility on the neighboring horizon (“e-horizon”). There is furthermore a real interest not only to create awareness of potential hazards to supplement driver awareness but to maintain awareness to stabilize the traffic flow of a limited number of vehicles as well as there is interest to increase the safety of Vulnerable Road Users (VRUs) such as pedestrians. Therefore, some capabilities are not only needed to improve service operations in the first few years of deployment, but will also be necessary for more advanced partially- or full-automated driving and VRU safety.

The time-critical provision of state information received from surrounding vehicles to alert or warn the driver of potential crashes would be the primary and most beneficial use of the CAM for road safety improvement. Thus CAMs need to be sent frequently and continuously. When a distance between current and past position has been changed more than 4 meters or the speed is changed more than 0.5 m/s compared to the last time, a CAM is sent but at least once a second and at the most 10 times per second under normal conditions.

In contrast, DENM messages are event-based. It is only sent if a vehicle senses special conditions or incidents such as black ice or sudden upcoming fog. It is meant for emergency situations. A vehicle DENM is sent in addition to, not instead of. the CAM. DENM can also be sent from the infrastructure to vehicle, to inform traffic participants on special conditions, such as road works or closed lanes.

Table 4: overview of Day 1 and Day 1.5 services

Service

Description

Service Time-frame

V2V/ V2I

Impact

Safety

Fuel Consumption

Pollutant Emissions

Congestion/

Travel time

Emergency electronic brake light (EBL)

Aims to prevent rear end collisions by informing drivers of hard braking vehicles ahead. Drivers will be better prepared to adjust their speed accordingly.

Day 1

V2V

+ +

o

o

o

Emergency vehicle approaching (EVA)

Gives an early warning of approaching emergency vehicles, prior to the siren or light bar being audible or visible. This should allow vehicles extra time to clear the road for emergency vehicles and help to reduce the number of unsafe manoeuvres.

Day 1

V2V

+

o

o

o

Hazardous location notification (HLN)

Gives drivers an advance warning of upcoming hazardous locations in the road. E.g. a sharp bend in the road, steep hill, pothole, obstacle, or slippery road service.

Day 1

V2V

+ +

o

o

+ 24

Slow or stationary vehicle(s) (SSV)

Intended to deliver safety benefits by warning approaching drivers about slow or stationary/broken down vehicle(s) ahead, which may be acting as obstacles in the road. The warning helps to prevent dangerous manoeuvres.

Day 1

V2V

+

o

o

o

Traffic jam ahead warning (TJW)

Provides an alert to the driver on approaching the tail end of a traffic jam at speed. This gives the driver time to react safely to traffic jams by giving them more time to react.

Day 1

V2V

+ +

o

o

o

In-vehicle signage (VSGN)

Informs drivers of relevant road signs in the vehicle’s vicinity, giving advance warning of upcoming hazards and increasing driver awareness.

Day 1

V2I

+

o

o

o

In-vehicle speed limits (VSPD)

Intended to prevent speeding and bring safety benefits by informing drivers of speed limits. Speed limit information may be displayed to the driver continuously, or targeted warnings may be displayed in the vicinity of road signs.

Day 1

V2I

+ +

+ +

+ / - 25

- 26

Probe vehicle data (PVD)

The purpose of probe vehicle data is to collect and collate vehicle data, which can then be used for a variety of applications. For example, the data can be used to inform drivers about adverse road or weather conditions.

Day 1

V2I

+ +

o

o

o

Road works warning (RWW)

Enables road operators to communicate information about road works and restrictions to drivers. This allows drivers to be better prepared for upcoming roadworks and potential obstacles in the road, therefore reducing the probability of collisions.

Day 1

V2I

+

o

o

o

Shockwave Damping (SWD)

Shock wave damping aims to smooth the flow of traffic, by damping traffic shock waves.

Day 1

V2I

+ +

o

o

o 27

Weather conditions (WTC)

Aims to increase safety through providing accurate and up-to-date local weather information. Drivers are informed about dangerous weather conditions ahead, especially where the danger is difficult to perceive visually.

Day 1

V2I / V2V

+ +

o

o

o

Green Light Optimal Speed Advisory (GLOSA) / Time To Green (TTG)

Provides speed advice to drivers approaching traffic lights, reducing the likelihood that they will have to stop at a red light, and reducing the number of sudden acceleration or braking incidents.

Day 1

V2I

+

+

+

o

Signal violation / Intersection Safety (SigV)

The primary objective of this service is to reduce the number and severity of collisions at signalised intersections, by warning drivers of possible red light violations.

Day 1

V2I

+ +

o

o

o

Traffic signal priority request by designated vehicles (TSP)

Allows drivers of priority vehicles (for example emergency vehicles, public transport, HGVs) to be given priority at signalised junctions. 28

Day 1

V2I

o

+ +

+ +

+ +

Information on fuelling & charging stations for alternative fuel vehicles (iFuel)

The objective of this service is to broadcast electric vehicle charging point availability and AFV fuelling point information to relevant vehicles.

Day 1.5

V2I

o

o

o

o

Off street parking information (Pinfo)

Intended to bring efficiency benefits to drivers and help to reduce emissions in urban areas by reducing the time spent ‘cruising’ at low speeds.

Day 1.5

V2I

o

+

+

+

On street parking management and information (PMang)

Intended to bring efficiency benefits to drivers and help to reduce emissions in urban areas by reducing the time spent ‘cruising’ at low speeds.

Day 1.5

V2I

o

+

+

+

Park & Ride information (P&Ride)

Intended to reduce congestion in urban areas and also shift travel from cars to public transport.

Day 1.5

V2I

o

+

+

o

Traffic information & Smart routing (SmartR)

The provision of traffic information and smart routing services to vehicles is intended to improve traffic efficiency and aid traffic flow management.

Day 1.5

V2I / V2V

o

+ +

+

+ +

Vulnerable Road user protection (VrU)

This is a safety focussed service, which is intended to protect vulnerable road users. In this case vulnerable road users are considered to be pedestrians and cyclists only.

Day 1.5

V2X

+

o

o

o

3.C-ITS Stations

The C-ITS architecture distinguishes between different types of C-ITS stations, which have different roles in the C-ITS network.

·Vehicle C-ITS stations, which are fully integrated in the vehicle, thus having secure and instant access to vehicle information, such as speed, direction, lights and breaks. This allows them to send messages to support safety-critical C-ITS services (such as the CAM message and collision warnings). In this Impact Assessment, Vehicle C-ITS stations are assumed to be equipped with hybrid communication capabilities, i.e. both short-range and long-range communication.

·Personal C-ITS stations, which can either be used stand-alone, e.g. by pedestrians or cyclists, or in a vehicle, to enable C-ITS in vehicles that are not yet equipped with a vehicle C-ITS station. In this Impact Assessment, personal C-ITS stations are assumed to be integrated in devices already owned by consumers for other purposes (e.g. smartphones or navigation devices). As personal C-ITS stations are not fully integrated in the vehicle typically they won’t have secure and instant access to vehicle information and thus are currently not capable to support safety-critical C-ITS services.

·Roadside C-ITS stations, which are integrated into roadside infrastructure. Roadside units can provide local C-ITS services based on short-range communication which cannot be replicated with long-range communication, or not with the same quality level. A good example is local traffic management at intersections, which could depend on local radars and radio signals from nearby vehicles, in particular priority vehicles. Roadside units can also replace other transport infrastructure and save costs in the medium to long term. Examples here include induction loops (used to detect vehicles at traffic lights) or variable message signs (electronic traffic signs typically used to display special events).

It is important to note that roadside C-ITS stations are not intended to cover the whole transport network. They will only be used in areas where they have a clear added value, such as busy roads and intersections, at the discretion of the road authority and/or operator. The rest of the infrastructure are expected be covered by C-ITS services based on long-range communication reusing existing networks.

·Central C-ITS stations, which are not directly linked to vehicles or infrastructure, but rather provide C-ITS messages from a central point. These stations could for example be integrated in a traffic management system, provide trusted and secure messages based on the aggregation of traffic data collected from a variety of sources. These message can then be distributed in different, for instance directly to vehicle and personal C-ITS stations through long-range communication, or forwarded through Roadside C-ITS stations using short-range communication.

4.Trusted and secure communication

In many C-ITS communication scenarios, an ad-hoc network with many-to-many communication is used, which is very different from other communications, such as peer to peer communication or broadcast (one to many). As the receiver needs to be able to able to process with no delay, the first message received from transmitting equipment that appears in range, it is essential that the authenticity and integrity of the messages containing information such as position, velocity and heading can be quickly and consistently verified. This authenticity and integrity allows to assess the trustworthiness of the sent information. At the same time the impact on privacy of road users should be minimized.

To ensure those main objectives, an EU security architecture with support of a Public Key Infrastructure (PKI) using commonly changing pseudonym certificates, has been developed which allows all C-ITS stations to operate within one single trusted C-ITS network in Europe, regardless of the technology used. The requirement of ensuring authenticity and integrity of all C-ITS messages being exchanged between C-ITS stations through their enrolment in one single trust domain ensures trust of C-ITS messages to all actors in the C-ITS network at all times.



Annex 6: The use and protection of personal data in C-ITS

This annex describes some of the key aspects of the use of personal data in C-ITS, the associated risks, and the measures taken to mitigate these risks. This section builds on expert input from the CAR2CAR consortium 29 , but should nonetheless be considered only a preliminary analysis to clarify the issue in the scope of this impact assessment, and in no case as a data protection impact assessment. Under the GDPR, data controllers (so also those implementing C-ITS services) are required to perform a data protection impact assessment when introducing new forms of processing personal data which present high risks to the rights and freedoms of individuals (Article 35 GDPR).

Processing operations and purpose of the processing

The day 1 services are primarily based on the exchange of a number of standardized messages: CAM, DENM, IVIM, SPATEM, MAPEM (see Annex 5 for more details on C-ITS services). IVIM, SPATEM and MAPEM messages are originated by (road-side) infrastructure and do not contain personal data, whereas CAM and DENM messages can include personal data. The content of the messages is determined by the relevant standard for the message type and the service profile for the individual service. All Day 1 services have clearly defined purposes of road safety and/or traffic efficiency.

Data sent by C-ITS services from vehicles often qualifies as personal data - as data can be directly linked to the vehicle identification and indirectly to the identity of the vehicle owner - and is therefore related to an identified or identifiable natural person. When this information is sent in an ad-hoc network with many-to-many unencrypted communication (as foreseen for short-range communication), there exists a risk for the misuse of personal data as this information can be received by any C-ITS station in their direct communication range, which ranges between 300 and 500 meters in average conditions. This issue concerns both CAM and DENM messages, but is particularly relevant for the CAMs ( as they are send frequently and continuously (a CAM message is sent at least once a second and at the most 10 times per second under normal conditions), where DENMs are event based and only sent when there is an important road safety related event.

Necessity and proportionality of the processing operations

The CAM message supports the need for every vehicle in the vicinity to permanently maintain awareness about the status and presence of other vehicles to avoid crash imminent situations and to optimize / stabilize the flow of traffic. To limit the CAM to only certain vehicles (e.g. to vehicles just behind a transmitting vehicle) would exclude vehicles posing danger from a lateral side.

Allowing the option to choose to transmit or not transmit a CAM while keeping the rest of the system active, or to exchange only partial messages without sending the full CAM message would be detrimental to the functioning of the system for 2 reasons: 

§Incomplete state and other definition from the CAM would in turn lead to incomplete information on the movement of the target vehicles and would decrease the effectiveness of the CAM to prevent collision between two moving vehicles.

 

§It would undermine the cooperative principle and design of C-ITS, which is based on a contribution-to-benefit principle. Withholding sending of a full CAM would cause the transmitting vehicle to accrue some benefit without giving a similar contribution. For example, one could consider transmitting CAMs only when receiving a DENM. However, this approach is unrealistic, because DENM emission is in turn dependent on receiving CAM information.

What are the key risks associated to the use of personal data in C-ITS? Are there specific high risks cases?

In order to address the risk of a personal data breach due to the transmission and subsequent reception of single CAMs, CAMs and DENMs in the single trusted C-ITS network in Europe are only transmitted in a pseudonymised form, i.e. in a form that cannot be attributed to a data subject with the use of data that is publicly available or available to a single entity. Pseudonymisation means that the CAMs and DENMs include a pseudonym, i.e. and identifier that can only be related to an individual with the collusion of two certification authorities, and only if those certification authorities previously archived information related to the issuing of the certificates to the vehicle or road equipment. This implies that the risk of a data breach either to outsiders or insiders is low. Additionally, CAMs and DENMs should be deleted or stripped of the identifiers after reception and processing in order to ensure that they do not contain personal data so to avoid further data breaches to insiders.

An additional risk that has been identified is that of location linking, i.e. the risk of re-attributing the CAMs to a vehicle/person due to the transmission and subsequent reception of a chain/trace of CAMs during the entire duration of an individual’s trip. Therefore, it is planned that the data that would enable the attribution of single positions as a trace to an individual, appropriately changes during the trip, so to prevent the linking of the CAMs.

The CAM contains data elements that never directly identify a concrete vehicle, its owner or its driver, unlike readily available alternative sources such as license plates, registration information, vehicle VIN. CAM have been conceived to exclude as much as possible data that might be used to reasonably link – as a practical matter - a CAM to a specific person “on a persistent basis without unreasonable cost or effort, either in real time or retrospectively, given available data sources” 30

In how far, and in which cases, are these risks additional to already available means of identification?

Already available means of identification “include physical surveillance (i.e., following a car by visual observation), placement of a specialized GPS device on a motor vehicle, physical access to Onboard GPS logs, electronic toll transactions, cell phone history, vehicle specific cell connections (BT signals), traffic surveillance cameras, electronic toll transponder tracking, and databases fed by automated license plate scanners … many of these non V2V tracking methods may be cheaper, easier, require less (and/or no skill) under certain scenarios”.

What data protection measures have been taken in the current specifications?

Data minimization was addressed in European standards for CAM & DENM messages (see EN 302 367-2 for CAM and EN 302 637-3 for DENM). Data minimization is already required by the system due to the size of the frequency bandwidth, which does not allow the exchange of a large amount of data. Other data are also broadcasted only in specific situations (e.g. size of the vehicle is only displayed in dense traffic situations and the weight is not provided).

Data likely to identify a vehicle has been specifically studied and minimized. As an example, in the aforementioned European standards, the vehicle size is defined at a precision level which does not enable the recipient to precisely recognize a model within a very broad range of car dimensions.

The current security mechanisms in the C-ITS communications are designed to fulfil the requirements of road safety applications, i.e. satisfying the needs for real-time, low-latency communications and high data reliability and integrity. The design of the C-ITS security system provides solution for authentication and authorization of C-ITS entities to access safety-based services and send messages on the communication network. Privacy and Cyber Security features have been realized by design by defining the EU Certificate and Security Policy (which is an integral part of the specifications) based on PKI management and pseudonymizing of the messages.

Why pseudonymizing (rather than anonymizing) is needed for the functioning of the system: 

·A short period of vehicle tracking is absolutely necessary for road safety purposes as an important C-ITS design component to enable the system and make applications work; 

·The AT (pseudonym certificate) shows that the user is recognized by the system and can be trusted; 

·The system also allows the so-called ‘revocation of trust’, which removes senders of unauthentic or unauthorized messages from the system by refusing the provision of new authorization tickets. 

How the issue of data retention is addressed in the standards & specifications:

·A received CAM shall not be forwarded/broadcast.  

·A received DENM may be forwarded/ broadcast only within a limited predefined geographical area. 

·Driving conditions data are kept in memory from a few seconds to a few minutes, depending on the need of the service. They are erased as soon as their emission conditions are over, and at each start of the engine. 

·No CAM is relayed to a vehicle manufacturer back-end.

Were additional mitigation measures considered?

There exists a risk of vehicle tracking by establishing the relation between 2 successive ATs used by the same device which disappear / appear in the same time (pseudonym change-over). This risk could be mitigated by introducing a silent period between 2 certificates, or a cryptographic protection of the change period.  

These solutions can be studied, although they are not included in the current ETSI release 1 standards or in deployment specifications. However, these solutions would have a negative impact in terms of safety because in the silent period, the vehicle would not deliver CAM information to its direct environment, significantly affecting the effectiveness of some C-ITS services.

Encryption of the C-ITS basic communications (i.e. safety messages such as CAM and DENM) has been considered but found not to provide any benefit. This because of the nature of the system that is an ad-hoc network with a many to many communication, which is very different to the normal cases where encryption is used, such as peer to peer communication or broadcast (one to many). As the receiver needs to be able to able to process with no delay the first message received from transmitting equipment that appears in range, the receiver would have to know the decryption key in advance. However, the receiver has no knowledge of who the sender is, so it is not possible to use different keys for different transmitters, thus everyone will have the same keys. This very wide distribution of the same key in combination with the short messages means that the encryption will be broken relatively fast and the encryption would be worthless.

Residual risks

There are two kinds of residual risk against data protection in C-ITS:

·The risk that a legitimate data controller uses the data for other purposes

·The risk that an illegitimate data controller (eavesdropper) takes possession of the data.

A legitimate controller in C-ITS is a controller that operates at least one ITS-Station that is enrolled with the C-ITS Security Credential Management System and that has an active role in road safety and traffic efficiency.

The first risk is mitigated by applicable data protection laws (GDPR). Any controller, i.e. a company needs to operate some sort of information security / data protection management system that ensures that data is not processed for other purposes and which should be properly audited.

The second risk is addressed in the C-ITS Security Credential Management System, especially against local eavesdroppers and long-range spot-check attackers

Both those threat scenarios are deemed possible (i.e., with likelihood >0) and have an impact. The impact however is reduced to almost zero by the AT change strategy in most cases.

No other threat scenarios with a significant likelihood have been identified. The threat scenario of ubiquitous eavesdropping is deemed as not probable (i.e., probability ~ 0 ) unless an illegitimate controller (i.e. an unofficial or unlawful organization – in C-ITS terms) can be demonstrated to have both the resources and the interest to build up an ubiquitous network to survey an area of interest such as a region or city.

(1)

Available at: https://ec.europa.eu/transport/themes/its/c-its_en

(2)

http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3188

(3)

Final report to be published together with the Impact Assessment

(4)

More detail can be found in Annex A of the support study

(5)

https://ec.europa.eu/transport/themes/its/c-its_en

(6)

http://ec.europa.eu/info/law/better-regulation/initiatives/ares-2017-2592333_en

(7)

https://ec.europa.eu/info/consultations/public-consultation-specifications-cooperative-intelligent-transport-systems_en

(8)

Published online in March 2018: https://ec.europa.eu/transport/sites/transport/files/2017-c-its-opc-analysis.pdf and included in annex E of the support study

(9)

Stakeholder type based on most frequently indicated categories of interest in the Public Consultation (the total of 142 is higher than the amount of responses (considering that some stakeholders indicated multiple interests). In other consultation activities this was not explicitly asked and the figures are only indicative of the different interests represented.

(10)

Signed in participants only

(11)

https://ec.europa.eu/transport/themes/its/events/stakeholder-workshop-cooperative-intelligent-transport-systems_en

(12)

http://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=1941&NewSearch=1&NewSearch=1

(13)

See also annex B.2.3 of the support study on C-ITS service impact data.

(14)

Croatia has recently been added to the model.

(15)

SWD(2018) 175 final.

(16)

P2W, car, bus, HDV and LDV

(17)

Fatalities, slight and serious injuries

(18)

car, bus, HDV, LDV

(19)

The baseline scenario developed for this impact assessment does not reflect the recent initiatives proposed by the Commission that have a direct impact on CO2 emissions (e.g. CO2 standards for new light duty vehicles for 2030, CO2 standards for heavy goods vehicles for 2030, revision of the Clean Vehicles Directive, etc.)

(20)

Value of Time parameter is estimated by mode (car or truck), distance band (short, long) and country based on HEATCO D5, Developing Harmonised European Approaches for Transport Costing and Project Assessment (2006)

(21)

  http://ec.europa.eu/transport/infrastructure/tentec/tentec-portal/site/en/maps.html

(22)

Ricardo-AEA, TRT, TEPR, DIW Econ, CAU (2014), Update of the Handbook on external costs of transport, available at https://ec.europa.eu/transport/sites/transport/files/handbook_on_external_costs_of_transport_2014_0.pdf

(23)

Ricardo, 2016. Study on the deployment of C-ITS in Europe: Final report, available at: http://ec.europa.eu/transport/sites/transport/files/2016-c-its-deployment-study-final-report.pdf

(24)

The eSafetyForum Intelligent Infrastructure Working Group estimated a lower bound of a 2% increase in average speed for this service.

(25)

The impact of VSPD varies across pollutants. There is a slight reduction in CO and NOx, a slight increase in VOC and while there is a small reduction in PM on motorways, on other interurban roads there is a significant increase in PM.

(26)

The available evidence shows a reduction in speeds in urban areas.

(27)

In TRT’s ASTRA model, traffic efficiency impacts are only modelled on urban roads. This service is not expected to have an impact on urban roads, therefore the impact on traffic efficiency for the purpose of this study was assumed to be zero.

(28)

Only applied to buses in urban areas

(29)

https://www.car-2-car.org/fileadmin/documents/General_Documents/C2CCC_TR_2051_Data_Protection.pdf

(30)

These and following quotation are taken from the Privacy Impact Assessment carried out by the US National Highway Traffic Safety Administration for the Notice of Proposed Rulemaking on V2V Communications. Available at: https://www.transportation.gov/individuals/privacy/vehicle-vehicle-v2v-nprm-–-december-20-2016

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