Type approval for ADS: Considerations for the ODD

The rapid introduction of new Automated Driving Systems (ADS) in the last years has led to an urge for robust methodologies for the type approval of vehicles equipped with such technologies. As a result, different Regulations addressing this field have been adopted. These Regulations are mainly based in the New Assessment and Testing Methodology (NATM) developed within the World Forum for the Harmonisation of Vehicle Regulations (WP29). However, the complexity of the regulatory ecosystem extends beyond type approval. This complexity requires a thorough analysis in order to avoid any possible gap which may jeopardise the feasibility of Automated Driving Vehicles deployment. This paper analyses the possible mismatches among the different regulations currently in place or under development and proposes a holistic approach, where the concept of the Operational Design Domain (ODD) takes a relevant role.