Germany

Testing infrastructure

There are many test sites available in Germany, some are still under construction others are already in operation. At a short glance find below a list of the well-known ones (list is not exhaustive):

• “Digitales Testfeld Autobahn” (DTA) on the German motorway A9. Platform mainly for communication technologies (5G).
• “DLR Application Platform for Intelligent Mobility” (AIM) in Braunschweig. Urban research platform for connectivity, automation and human factors, extension to motorway planned in 2018
• “Testfeld Autonomes Fahren” in Baden-Württemberg, urban, rural roads and motorway
• “Digitales Testfeld Dresden”, urban and rural roads for connectivity technologies and automation
• “ITS Test site Merzig” (ITeM), V2V and V2I test site on urban and rural roads
• “Test site Aldenhoven”, closed test ground for sensing and automation with private access
• Test field “simTD”, ITS G5 – test field for development and deployment of C-ITS V2V and V2I services
• “C-Roads test field Germany” (Hessenmobil and Lower Saxony), test site for ITS G5 day 1 and day 1,5 application. Focus on deployment.
• Test site Düsseldorf, urban test site for deployment of C-ITS applications (both ITS G5 and traffic management over mobile communication

Procedure description

The relevant regulation document is the “Straßenverkehrs-Zulassungs-Ordnung” (StVZO, English Road Traffic Licensing Regulations).

The vehicle which is subject to dynamic driving tests can have an individual operating permit, granted under §19.6 StVZO (“registration of test vehicles”). Legal wording, translated (§19.6 StVZO): The type-approval of motor vehicles that contain parts which have been altered in the meaning of paragraph 2 (no permission in the case of degradations regarding emissions (noise and exhaust emissions), risk level towards other road users or the type of vehicle) will remain effective, if these motor vehicles are solely used for testing purposes; in this regard, the KBA (regulatory authority) does not require any additional notification. The previous sentence is only valid in case the KBA (regulatory authority) did confirm in the vehicle registration document (German “Fahrzeugschein“) that it has received the notification about the vehicle being used for testing purposes.

In case the vehicle will be testing scopes (i.e. AD functionalities) which are not approved by current law, there’s an exemption approval required (§70 StVZO): The exemption can be granted by the KBA (Kraftfahrt-Bundesamt) (with authorization of the Federal Ministry of Transport and Digital Infrastructure (BMVI)).

Additionally, the law may require the approval of a special permit regarding the rules of the road (German “Verhaltensrecht”) (StVZO).

A major restriction regarding the range of automation functions is given by the EU regulation UN-ECE-R79 on steering systems, which allows a long-term automated steering intervention for velocities below 10 km/h only. The regulation was by June 2018 under revision.

The following steps are recommended for the owner of the vehicle in order to receive the admission:

1. Describe the technical modifications of the vehicle (difference to the serial type) in a technical way. Use references to existing standards and regulations as much as possible (e.g. ASIL-Levels, European EMV directive etc…).
2. Develop an FMEA and/or similar failure analysis models for single modules or the system as a whole. Define technical countermeasures and the way how to control them.
3. Define a data quality management system (such as a description of the software-framework for R&D work and the processes how to test and release your internal versions). It may be required that certain changes in SW have to be released by an internal quality process
4. Define organizational guidelines for your R&D-staff and for your technical personnel: How to get the keys, who has internal permission to develop and download code on the system, how do you (long-term) educate your personnel, how to prevent misuse etc…
5. Once you have prepared the documentation above select an independent testing institution and contract it for consultation and for preparing an assessment report about the technical modifications of the vehicle, its safety and organizational issues/countermeasures. This assessment report may contain new requirements that you have to face to.
6. Get in contact with the regional government where you plan to conduct the tests. Make sure that the independent testing institution is involved in this process – the regional government may ask for the independent assessment report in order to align its requirements
7. Provide documentation you have created in advance of the process to the independent testing institution and prepare a demonstration with the vehicle where you show the driving functions in different situations (and e.g. with emulated mal-functions of components).
8. Do not forget to contact your insurance and your internal safety department of your organization – they may have additional requirements. It is recommended to contact them when the assessment report is finalized.

For the operation of vehicles on German public roads another regulation is of high relevance: The Straßenverkehrs-Ordnung (StVO, English Road Traffic Regulations).

The StVO is, inter alia, implementing the Vienna Convention on Road Traffic. The amendment which became effective in 2016 allows for SAE-Level-3-Functions to be used on public roads, as the driver may (temporary) leave the operation of the vehicle to an automation system. However, fully automated or driverless vehicles are not covered by the content of the StVO, yet.

The StVO is currently under revision.

Organisation(s) in charge

The responsible government body is the “Kraftfahrt-Bundesamt”, KBA (English: Federal Motor Transport Authority).

Contact information

Kraftfahrt-Bundesamt (KBA)

Link to procedure website

Road Traffic Ticensing Regulations – StVZO

Road Traffic Regulations – StVO

Link to documents

UN/ECE R79, rev.4 (2018)

Vienna Convention on Road Traffic (1968)

Amendment to the Vienna Convention (2016)

Further comments

The procedure is under responsibility of the company/institution which is owner of the vehicle. It is based on technical and organizational documentation, a formal risk analysis (including technical and organizational countermeasures) and the steps how to get in contact with the regional government (“Bundesland”).

There is one particularity in Germany: The owner has to get the admission from the regional government in which the tests are planned to be conducted. In the required case of admission-enhancement all over Germany the regional government needs to extend the admission by a certain process, called “Bundes-Länderanfrage”. Usually this process will lead to an all-over-Germany admission without extra-effort.

It is currently planned to harmonize the enhancement-process by defined guidelines that are valid for all regional governments in Germany. But these guidelines will not be available before 2019 and even if they are available it will still be necessary to contact the relevant regional government directly.

After getting through all of the steps described above (estimated duration: a few months) you will have a “Zulassung zum Erprobungsfahrzeug” (single admission for test vehicles) which allows you to conduct you tests on open roads. But it is strongly recommended that you keep in mind that

• there are constraints defined in this admission that has to be fulfilled during the lifetime of the vehicle in your (owners) responsibility
• in case of accidents the judge may compare the constraints with reality of both – technical modification and organizational issues
• there is no necessity to define the concrete experiment and its boundaries in advance of the admission procedure. But this may be required by the insurance company and/or by the institution itself. E.G. the number of safety drivers in a certain scenario might be an important factor constraint (but not the only one)

Furthermore, there exists a difference between OEMs and suppliers when it comes to acquiring except permission to drive AD test vehicles. Two options exist for driving AD test vehicles on public roads in Germany:

• Supplier Option:

1. This is the traditional option for suppliers like Aptiv, Bosch, Continental,…

• OEM Option:

1. Applicable naturally to OEMs
2. Suppliers can also avail of this option
3. More time-consuming (estimated time between 3 to 9 months) but beneficial in the long term
4. Offers more flexibility esp. with regard to shuttled and PODs

The following steps need to be followed, if one follows the supplier option:

• Build up the car and get the certification for this base car from certification authorities like TÜV
• Certificate the AD test vehicle installation regarding fail-safe strategy, take over scenarios and outer shape of the car (concerning pedestrian safety for sharp edges, etc.)
• Register the car with local authorities
• Get the except permission from the local govt. to be able to drive in Germany

The following steps need to be followed, if one follows the OEM option:

• Except permission in this case is granted by the govt. (Kraftfahrbundesamt)
• If suppliers make use of this option, then suppliers can brand the car as an OEM in the vehicle papers
• With such branding certificate (as an OEM), suppliers would be allowed to drive test vehicles on public roads without TÜV approval for each car