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National Highway Traffic Safety Administration (NHTSA), Department of Transportation (DOT).
Notice of grant of a petition for a temporary exemption from three provisions of Federal Motor Vehicle Safety Standard (FMVSS) No. 500, "Low-speed vehicles."
This notice grants the petition of Nuro, Inc. (Nuro) for a temporary exemption from three requirements of FMVSS No. 500 under two bases: (1) That an exemption would make the development or field evaluation of a low-emission motor vehicle easier and would not unreasonably lower the safety level of that vehicle; and (2) that compliance with these requirements would prevent Nuro from selling a motor vehicle with an overall safety level at least equal to the overall safety level of a nonexempt vehicle. The vehicle that Nuro intends to manufacture under this exemption—the "R2X"—is a highly automated, electric, low-speed vehicle (LSV) that lacks seating positions and manual driving controls and is smaller, lower, and narrower than conventional vehicles. The exemption applies to the requirements that an LSV be equipped with exterior and/or interior mirrors; have a windshield that complies with FMVSS No. 205, "Glazing materials"; and a backup camera system that meets the requirement in FMVSS No. 111, "Rear visibility," limiting the length of time that a rearview image can remain displayed by the system after a vehicle's transmission has been shifted out of reverse gear.
Nuro's petition is granted as of February 11, 2020.
Daniel Koblenz, Office of Chief Counsel, Telephone: 202-366-2992, Facsimile: 202-366-3820. The mailing address for this official is: National Highway Traffic Safety Administration, 1200 New Jersey Avenue SE, Washington, DC 20590.
This document grants a petition submitted by Nuro Inc. (Nuro) for a temporary exemption of a vehicle from three requirements of FMVSS No. 500, Low-speed vehicles. Nuro's vehicle, the R2X, is a highly automated (SAE Level 4 or L4), low-speed (25 mph maximum), electric-powered delivery vehicle.
Nuro seeks exemptions from various FMVSS that are designed to provide safety benefits for occupants. Since the R2X does not accommodate any occupants, Nuro argues that these FMVSS do not serve their intended functions in the R2X. Accordingly, Nuro has sought exemptions from these requirements. NHTSA has analyzed the request for exemption and is granting them in accordance with its exemption authority under the Vehicle Safety Act and its implementing regulations in part 555.
Pursuant to the Vehicle Safety Act, NHTSA may grant an exemption from an FMVSS if NHTSA determines that such exemption is consistent with the public interest and the Act, and meets at least one of four additional bases for exemption, described further below.
The three substantive requirements in FMVSS No. 500 from which the agency is granting an exemption are the exterior and/or interior mirror requirement (S5(b)(6)), the windshield requirement (S5(b)(8)), and the backup camera "Linger time" requirement (S5(b)(11)).
NHTSA made its decision to grant Nuro's petition after making several statutorily mandated agency findings, including its finding that exempting the R2X from three of the requirements in FMVSS No. 500 would not lower the safety of the R2X as compared to a compliant version of the vehicle—which, as described below, means that this finding is sufficient for the safety determinations required under both the "Low Emission Vehicle" (LEV) and the "equivalent overall safety" (EOS) bases. To examine the effects of the requested exemptions and make this finding, NHTSA compared two nearly identical versions of the same vehicle: A compliant version of the R2X
The question of whether an exemption would lower the safety of an exempt version of the R2X as compared to a compliant version of the vehicle turns on the very limited differences between those two versions of the R2X, which are only that the exempted R2X would not comply with the certain requirements described in this notice. Importantly, under the Vehicle Safety Act, manufacturers are permitted include any design feature they want on a vehicle so long as the vehicle conforms to the FMVSS, and the vehicle does not contain a defect that poses an unreasonable risk to safety. As discussed in more detail below, because NHTSA does not currently have in place FMVSS requirements that regulate Automated Driving System (ADS) driving capability, and NHTSA does not have any basis to believe that it poses an unreasonable risk to safety, no barrier prevents including such a system on a vehicle. Moreover, because LSVs (unlike most vehicle classes) are not required to have human-operated driving and signaling controls, nothing in the FMVSS prevents a manufacturer from producing an LSV without manual controls that is operated exclusively by an ADS. Given that both an exempted and compliant R2X would have no occupants and would operate without a human driver, compliance with the three requirements from which Nuro seeks an exemption would not provide a safety benefit.
First, the requirement for internal and external mirrors is meant to improve situational visibility for human drivers, who internalize information about the driving environment through direct or reflected line of sight. In a vehicle without manual controls that operates using an ADS, mirrors do not serve a safety purpose because the ADS perceives the driving environment using cameras and sensors that directly feed it information about the vehicle's surroundings. Moreover, because exterior mirrors protrude from the side of the vehicle, they may act as a potential hazard to other road users in certain situations. Second, the requirement for a windshield made of compliant glazing material is meant to protect human occupants from intrusion, ejections, or laceration while ensuring driver visibility. In an occupantless vehicle that operates using an ADS, there are no human occupants for the glazing to protect, and, as we have already noted, visibility through the windshield is not a concern because the ADS obtains information about the driving environment through the use of cameras and sensors. Lastly, the requirement that a rearview camera image cease to be illuminated (
Based on its engineering expertise and the information available to it, NHTSA finds that exempting the R2X from these three requirements would result in a vehicle that is at least as safe as a compliant version of the R2X. NHTSA has also determined that an exemption would be consistent with the public interest and the Safety Act because, by allowing for the manufacture and commercial deployment of their desired design vehicle, an exemption would further the development of innovative technologies used in the R2X (most notably, its ADS), which could lead to safety, environmental, and economic benefits to the communities in which the R2X operates, and could eventually lead to benefits for other communities where ADS vehicles are deployed in the future. Moreover, an exemption would further the development and implementation of innovative business models, like Nuro's delivery service, for putting those technologies to use. This determination is consistent not only with NHTSA's exercise of its longstanding safety authority and expertise on motor vehicle issues, but also, with the broad authority that Congress vested in the Secretary of Transportation to grant exemptions in the public interest.
The R2X will be the first ADS vehicle exempted under NHTSA's general exemption authority, and, according to Nuro, will be deployed as part of a commercial operation that will involve frequent interaction with the public. Accordingly, the agency has taken efforts to ensure the vehicles operate in as safe a manner as a non-exempted vehicle. Specifically, NHTSA has determined that it is in the public interest to establish a number of reporting and other terms of deployment of the vehicles that will apply throughout the useful life of these vehicles—violation of which can result in the termination of this exemption. The agency also notes that it retains the full suite of its investigative and enforcement authorities with respect to Nuro's vehicles and operations.
The National Traffic and Motor Vehicle Safety Act (Vehicle Safety Act), codified at Chapter 301
In exercising this authority, NHTSA must look comprehensively at the request for exemption and find that an exemption would be consistent with the public interest and with the objectives of the Vehicle Safety Act.
(i) Compliance with the standard[s] [from which exemption is sought] would cause substantial economic hardship to a manufacturer that has tried to comply with the standard[s] in good faith;
(ii) the exemption would make easier the development or field evaluation of a new motor vehicle safety feature providing a safety level at least equal to the safety level of the standard;
(iii) the exemption would make the development or field evaluation of a low-emission motor vehicle easier and would not unreasonably lower the safety level of that vehicle; or
(iv) compliance with the standard would prevent the manufacturer from selling a motor vehicle with an overall safety level at least equal to the overall safety level of nonexempt vehicles.
NHTSA's procedural regulations implementing these statutory requirements are codified at 49 CFR part 555, "Temporary Exemption from Motor Vehicle Safety and Bumper Standards."
The statute and implementing regulations provide the Secretary and, as delegated, NHTSA with significant discretion in making these required determinations.
NHTSA defines a low-speed vehicle (LSV) as "a motor vehicle, (1) [t]hat is 4-wheeled; (2) [w]hose speed attainable in 1.6 km [kilometers] (1 mile) is more than 32 kilometers per hour (20 miles per hour) and not more than 40 kilometers per hour (25 miles per hour) on a paved level surface, and (3) [w]hose GVWR [gross vehicle weight rating] is less than 1,361 kilograms (3,000 pounds)."
Unlike other vehicle categories that must meet a wide array of FMVSSs and other vehicle standards, LSVs are only required to meet a single standard: FMVSS No. 500, "Low-speed vehicles." Currently, FMVSS No. 500 requires that LSVs be equipped with headlamps, stop lamps, turn signal lamps, taillamps, reflex reflectors, parking brakes, exterior and/or interior mirrors, a windshield constructed from FMVSS No. 205-compliant glazing, seat belts, a vehicle identification number, and a rear visibility system that complies with S6.2 of FMVSS No. 111 (
NHTSA created the LSV classification and established FMVSS No. 500 in June 1998 in response to safety concerns over the growing use of golf cart-sized, 4-wheeled "Neighborhood Electric Vehicles" (NEVs) on public roads.
NHTSA received Nuro's petition for a temporary exemption on October 23, 2018, seeking an exemption from three of the requirements that apply to LSVs: The exterior and/or interior mirror requirement (FMVSS No. 500, S5(b)(6)), the windshield requirement (FMVSS No. 500, S5(b)(8)), and the backup camera "Linger time" and "Deactivation" requirements (FMVSS No. 500, S5(b)(11); FMVSS No. 111, S6.2.4 & S6.2.5). In addition, Nuro requested an exemption from portions of the test procedures in FMVSS No. 111 that relate to the backup camera "Field of view" and "Size" requirements. Nuro submitted its petition under the basis that an exemption would make easier the development or field evaluation of a low-emission vehicle (LEV) and that an exemption would not unreasonably lower the safety of that vehicle. As described in Nuro's petition, the vehicle for which Nuro requested an exemption, the "R2X," would be an occupantless, electric LSV that is designed to be operated almost exclusively by an ADS. According to Nuro, the R2X would not be sold, but rather would be operated by Nuro in partnerships with grocery stores and other merchants to autonomously deliver goods to nearby customers.
Nuro argued in its petition that provisions of FMVSS No. 500 from which it is seeking an exemption require the inclusion of safety features that do not serve a safety purpose on the R2X, due to the fact that the R2X is operated by an ADS and does not have any occupants. Moreover, Nuro argued that including these required features would reduce the safety of the R2X. Nuro's arguments for its three exemption requests are summarized in the table below:
In addition, while
Nuro stated in its petition that granting its exemption would be in the public interest and consistent with the Vehicle Safety Act because the R2X incorporates various design features that enable the ADS to operate reliably, and minimize safety risks that may occur if the ADS malfunctions or otherwise encounters a driving situation it cannot handle. Nuro also argued that enabling it to field test its ADS would lead to downstream environmental improvements and economic productivity.
It is important to note that the most unusual characteristics of the R2X—its lack of occupants and autonomous operation—do not require an exemption to be included on the R2X, as there is nothing in the FMVSSs that preclude Nuro from manufacturing a fully compliant version of the R2X that includes these two novel design features.
NHTSA published its Notice of Receipt of Nuro's exemption petition in the
In response to the Notice of Receipt, NHTSA received 24 comments from a variety of commenters, including trade associations, individual manufacturers, advocacy groups, and individuals. The trade associations that submitted comments were the Alliance of Automobile Manufacturers (the Alliance), the American Trucking Associations (ATA), the Consumer Technology Association (CTA), the Association for Global Automakers (Global), and the National Society of Professional Engineers (NSPE). NHTSA also received comments from the individual vehicle manufacturer Local Motors. The advocacy groups that submitted comments were the American Automobile Association (AAA), the American Association of Motor Vehicle Administrators (AAMVA), Advocates for Highway Safety (Advocates), Center for Auto Safety (CAS), DEVCO, and Securing America's Future Energy (SAFE). In addition, NHTSA received comments from Kroger, Inc., the Mercatus Center of George Mason University, the Center for Autonomous Vehicles and Sensor Systems, Edge Case Research, the Mayor of Scottsdale, Arizona, and the Scottsdale, Arizona Chief of Police. In addition, NHTSA received a comment from the petitioner itself. The major points raised by the commenters are briefly summarized below, and are discussed in greater detail in later sections of this document.
The principal comments made by commenters who were generally critical of Nuro's petition were:
• The LEV basis is an inappropriate basis under which to consider Nuro's petition because the purpose of that exemption basis is to encourage the development of low-emission propulsion technologies.
• The petition did not include sufficient information about the ability of the ADS to perform the driving task (especially as compared to a human driver), the R2X's Operational Design Domain (ODD), or the operational details of Nuro's remote operator system.
• The petition did not include documentation demonstrating the efficacy of some of the safety features Nuro describes in the petition, such as pedestrian "crumple zones."
• The petition does not sufficiently address the issue of cybersecurity.
• If NHTSA were to grant the petition, the agency should impose extensive reporting requirements on Nuro that include providing NHTSA and/or the public with information about ADS performance. These reporting requirements should last for the life of the vehicle.
• Nuro should be required to coordinate extensively with local authorities in the communities in which the R2X will operate.
The principal comments made by commenters who were generally favorable to Nuro's petition were:
• The LEV basis is an appropriate exemption basis under which to consider Nuro's petition because the R2X meets the qualifications for being an LEV, and because one benefit of vehicles like the R2X is lower overall emissions.
• The ability of the ADS to perform the driving task should not be considered as part of NHTSA's safety analysis of Nuro's petition, because the compliant version of the R2X against which NHTSA must compare an exempted R2X would also be equipped with an ADS.
• The three requirements from which Nuro sought an exemption do not serve a safety purpose on a vehicle that is operated exclusively by an ADS.
• If NHTSA were to deny the petition, this would effectively require Nuro to equip the R2X with extraneous equipment (
• If NHTSA imposes terms that include mandatory data reporting, it should not be unreasonably broad, and should be limited to the two-year exemption period.
NHTSA also received several comments that were either general discussions of the role of exemptions in the regulation of ADS vehicles, or previously published newspaper articles or academic papers that discuss automated vehicle policy generally. While the policy considerations and issues discussed in these comments are certainly relevant to NHTSA's and the Department's Automated Vehicle policy generally, they are not directly pertinent to the findings that NHTSA must make regarding Nuro's specific petition, and thus are not extensively discussed in this document. However, we note that the agency shares some of the concerns some of the commenters raised about ADS safety, and has conditioned this exemption grant on terms that the agency believes will appropriately mitigate potential risk and ensure the agency can maintain adequate oversight of deployed R2X vehicles.
Following the publication of the Notice of Receipt, at Nuro's written request, NHTSA met with representatives of Nuro on April 11, 2019, at NHTSA headquarters.
NHTSA has determined that it is appropriate to consider Nuro's petition under both the "Low-Emission Vehicle" (LEV) and "Equivalent overall safety" (EOS) exemption bases, and has decided to evaluate Nuro's petition under both bases.
Nuro submitted its petition for an exemption from FMVSS No. 500 under the LEV exemption basis, which authorizes NHTSA to grant an exemption if doing so "would make the development or field evaluation of a low-emission motor vehicle easier and would not unreasonably lower the safety level of that vehicle."
NHTSA received comments on the appropriateness of the LEV exemption basis from AAMVA, Advocates, Global, and SAFE. AAMVA and Advocates both argued that the LEV exemption basis may not be appropriate despite the R2X's LEV status because the specific requirements from which Nuro requested an exemption are unrelated to the R2X's electric propulsion system. According to AAMVA, the NSF basis would be preferable because the design features that are the subject of the exemption relate to the removal of the driver (although AAMVA does not explain why this makes the NSF basis preferable over EOS).
Conversely, Global
First, NHTSA has determined that the LEV basis is appropriate for Nuro's petition. Based upon its interpretation of both the Vehicle Safety Act and part 555, and consistent with prior agency grants of exemption petitions, NHTSA has determined to grant the petition under the LEV basis. The Vehicle Safety Act requires that NHTSA find that the exemption is in the public interest and consistent with the Vehicle Safety Act and (1) that the vehicle is an LEV, (2) that an exemption would make easier the development or field evaluation of the vehicle, and (3) that an exemption would not unreasonably lower the safety of the vehicle. It does not state that NHTSA must find a nexus between the exemption and the LEV status of the exempted vehicle.
We also agree with AAMVA and Advocates that, since innovation related to safety and mobility is the central focus of Nuro's petition, the agency may also consider the petition under the EOS or NSF ground. Nuro, in its comments, expressed openness to being considered under the EOS basis instead of the LEV, though Nuro did not amend its application as part of these comments.
As between the NSF and EOS bases, NHTSA has determined that the EOS basis is more appropriate than the NSF basis here. Although it is possible that an exemption could make easier the development or field testing of a new (
For these reasons, NHTSA has decided to evaluate Nuro's petition under both the LEV and EOS exemption bases.
In order to make the statutorily required safety findings to grant an exemption under either the LEV or EOS basis, NHTSA must first determine whether the level of safety of an exempted vehicle would be lower than that of a compliant vehicle. If, based on this analysis, NHTSA finds that an exemption would not lower overall safety of the vehicle, NHTSA is permitted to grant the petition under both exemption bases. Thus, if NHTSA determines that an exemption would not lower the safety of the vehicle (which would obviate the need under the LEV basis to make the second finding of whether safety is unreasonably lowered), the entire safety analysis under the EOS and LEV bases would be identical. NHTSA's analysis would only diverge under the two bases if NHTSA finds that safety would be lowered, in which case the agency must deny the petition under the EOS basis, and may only grant the petition under the LEV basis upon finding that an exemption would not
Because the mirror, windshield, and backup camera "Linger time" requirements are discrete aspects of vehicle performance, we discuss them individually in separate subsections below. Note that, because NHTSA has deemed moot Nuro's request for exemptions from the backup camera "Deactivation" requirement, it is not included our safety analysis. Rather, the reasons we deemed this request moot are explained in a later section.
NHTSA has determined that an exemption from the requirement that LSVs be equipped with exterior and/or interior mirrors would not lower the safety of the R2X, and in fact may incrementally increase the safety of the R2X, because mirrors would not serve a safety-related purpose on an occupantless LSV operated by an ADS, and the presence of protruding exterior mirrors on such a vehicle may increase strike risk for pedestrians and other vulnerable road users.
FMVSS No. 500, S5(b)(6) requires that LSVs be equipped with an "exterior mirror mounted on the driver's side of the vehicle and either an exterior mirror mounted on the passenger's side of the vehicle or an interior mirror." Nuro argued in its petition and its public comment that, because the safety purpose of these mirrors is to enable a human driver to observe objects to the rear of the vehicle, the mirror serves no safety function on the R2X. First, according to Nuro, the ADS uses an array of sensors to detect objects behind the vehicle. Moreover, Nuro states that mirrors serve no auxiliary safety purpose for people outside of the vehicle, and their omission reduces the risk of striking pedestrians and lowers the mass of the vehicle.
Commenters who discussed the mirror requirement agreed with Nuro that exterior mirrors did not serve a safety function on the R2X. The Alliance,
NHTSA agrees with Nuro and the commenters that that mirrors do not serve a safety function on a vehicle with no occupants that is operated by an L4 ADS, since the ADS perceives the driving environment using a suite of sensors that do not rely on the mirrors. Further, NHTSA has concluded that the fact that the mirrors protrude from the vehicle means that they could potentially increase the risk of injury to pedestrians or cyclists, however incrementally and thus concurs with Nuro's assertion in the petition about this potential benefit.
NHTSA has determined that an exemption from the requirement that LSVs be equipped with a windshield constructed from FMVSS No. 205-compliant glazing materials would not lower the safety of the R2X because a compliant windshield would not serve a safety-related purpose on an occupantless LSV operated by an ADS, due to the fact that a windshield is not necessary to assure (human) driver visibility, nor is it needed to protect occupants in a crash.
FMVSS No. 500, S5(b)(8) requires that LSVs be equipped with "a windshield that conforms to the Federal motor vehicle safety standard on glazing materials (49 CFR 571.205)." FMVSS No. 205, "Glazing materials," is an equipment standard for glazing materials (
Commenters generally did not dispute Nuro's argument that an FMVSS No. 205-compliant windshield would not serve a safety purpose on a vehicle without occupants. The Alliance
In its comment, Nuro explained further why it believes that not equipping the R2X with an FMVSS No. 205-compliant windshield will increase the safety of the R2X.
NHTSA has concluded that an exemption from the windshield requirement would not lower the level of safety of the R2X because the safety concerns that the windshield addresses—protecting occupants from ejection and intrusion, and ensuring occupants (particularly a human driver) can see the driving environment—are not present in the R2X, due to its lack of occupants and its operation by an ADS that relies on cameras and sensors instead of a human driver.
NHTSA has determined that an exemption from backup camera "Linger time" requirement (FMVSS No. 111, S6.2.4) would not lower the safety of the R2X because the safety concern underlying the linger time requirement—driver distraction—does not exist for an occupantless LSV operated by an ADS.
FMVSS No. 500, S5(b)(11) states that LSVs "shall comply with the rear visibility requirements specified in paragraphs S6.2 of FMVSS No. 111." One of the requirements that falls under FMVSS No. 111, S6.2.4, limits the duration of the system's "Linger time," which is the period in which a rearview image continues to be displayed by the backup camera system after the vehicle's transmission has been shifted out of reverse gear. Per S6.2.4, the rearview image produced by the backup camera system "shall not be displayed after the backing event has ended." NHTSA explained in the final rule establishing the backup camera requirement that the safety justification for the linger time restriction was the possibility that a driver would be distracted by a rearview image.
In its petition, Nuro argued that the "Linger time" requirement does not serve a safety purpose on the R2X because the safety risk it is intended to mitigate against—the possibility that a human driver would be distracted by the rear visibility image when traveling in the forward direction—is not a concern for the R2X, since the R2X uses an ADS that is not susceptible to distraction. Nuro further argues that an exemption from the "Linger time" requirement would, in fact, improve the safety of the R2X, as it would eliminate a condition in which the R2X's rear-facing camera and sensors shut off, which Nuro says has the effect of partially blinding the ADS.
NHTSA agrees with Nuro that distraction is unlikely to be a concern for the R2X's ADS, which is not a human and thus would not be susceptible to cognitive distraction.
NHTSA has determined that an exemption from the provisions in the FMVSS No. 111 "Field of view and image size test procedure" relating to fuel tank loading (S184.108.40.206), driver's seating position (S184.108.40.206), and steering wheel adjustment (S14.1.7); and an exemption from the provisions of the FMVSS No. 111 "Image response time test procedure" relating to the driver's door and activation of the starting system (S14.2(a)-(c)); would not lower the safety of the R2X because the R2X's backup camera would still be required to produce a rearview image that meets the substantive performance requirements for "Field of view" (S6.2.1),"Size" (S6.2.2), and "Response time" (S6.2.3).
While Nuro states in its petition that the R2X meets these substantive requirements—and thus meets the minimum level of performance established by the standard—Nuro requested an exemption based on language in a 2016 Chief Counsel's interpretation letter issued to Google in 2016.
In its discussion of FMVSS test procedures, NHTSA's letter to Google explained: "As self-driving technology moves beyond what was envisioned at the time when standards were issued, NHTSA may not be able to use the same kinds of test procedures for determining compliance."
NHTSA notes that the 2016 interpretation letter to Google diverged, without explanation, from NHTSA's longstanding position that manufacturers are not required to certify compliance based on NHTSA's FMVSS test procedures.
Nuro notes that the R2X is an electric vehicle and does not have a gas tank that can be fully loaded with fuel—an express requirement of the FMVSS No. 111 test procedures—and, pursuant to the Google interpretation described above, is therefore incapable of being certified as compliant with the standard.
Similarly, because of the R2X's occupantless design and exclusive ADS operation, the vehicle is not equipped with a driver's seat or a display screen, which means that NHTSA is not able to independently verify this compliance using the test procedures in FMVSS No. 111.
As part of its exemption request, Nuro provided suggestions for how NHTSA could modify the FMVSS No. 111 test procedures to accommodate the R2X's unique design:
Given the design differences between the R2X and a typical LSV, NHTSA has determined that Nuro's proposed modifications to the FMVSS No. 111 test procedures are reasonable, since they would condition the R2X in the same way as would the test procedures in the standards if applied to a conventional vehicle. Most commenters did not discuss whether NHTSA should grant Nuro's request for an exemption from the FMVSS No. 111 test procedures, or their views on the adequacy of Nuro's suggested modifications. The only comment on this subject was from AAMVA, which stated that it was "skeptical" of what is meant by treating the remote operator seat as a driver's seating position. We think that Nuro's suggestion to use the remote operator as a stand-in for the driver, for purposes of compliance certification, is reasonable. The purpose of the FMVSS No. 111 "Field-of-view," "Size," and "Response time" requirements are to ensure that the image displayed communicates information about the area behind the vehicle to the driver in a format that the driver is able to understand from the start of the backing event. If the rearview image meets the "Field of view," "Size," and "Response time" criteria when viewed by a remote operator who is located a similar distance from the rearview image screen as would be a human driver in a conventional vehicle, NHTSA believes this would be sufficient to demonstrate that Nuro exercised reasonable care in certifying the R2X because it indicates that the ADS is receiving the same information that a human driver would receive from the backup camera system in a conventional vehicle, and that this information is being transmitted at the start of the backing event. Similarly, we believe that Nuro's suggestion that it perform test procedures with a fully charged battery in lieu of a fully-loaded gas tank, for purposes of compliance certification, is reasonable.
Advocates claimed that the act of applying a vehicle's brakes to prevent a back over crash is an integral part of the safety purpose of the backup camera, and that NHTSA should therefore incorporate into its analysis whether the R2X would appropriately brake in response to an object in the backup camera zone. We do not agree with Advocates that FMVSS No. 111 extends to how the vehicle must react in response to the presence of an object behind the vehicle. Although Congress enacted the K.T. Safety Act (the statute that mandated NHTSA to create the backup camera requirement) to reduce back over crashes, FMVSS No. 111 requires that the driver be provided with information that would
Based on the contents of Nuro's public petition and the comments received in response to the Notice of Receipt, NHTSA has made the findings required to grant Nuro's petition for an exemption from the mirror, windshield, and backup camera "Linger time" requirements under both the Low-Emission Vehicle basis and the Equivalent Overall Safety basis.
A vehicle is considered a low-emission vehicle for the purposes of § 30113 of the Vehicle Safety Act if it emits air pollutants significantly below the standards for new vehicles applicable to the vehicle set under § 202 of the Clean Air Act. Since the R2X is an electric vehicle and would not emit any such pollutants, it is a low-emission vehicle under § 30113. This issue was not contested in the public comments. Further, as discussed above, there is no need for the agency to find a nexus between the fact that the vehicle is an LEV and the reason the vehicle is non-compliant.
Given that an exemption from the mirror, windshield, and backup camera "Linger time" requirements would not lower the level of safety of the R2X, NHTSA finds that an exemption would not unreasonably lower the safety of the R2X as compared to that of a compliant R2X. In addition, NHTSA finds that, because an exemption from the FMVSS No. 111 test procedure provisions relating to fuel tank loading (S22.214.171.124), driver's seating position (S22.214.171.124), steering wheel adjustment (S14.1.7), and the opening of the driver's door and activation of the starting system (S14.2(a)-(c)) would not affect whether the R2X's backup camera system meets the substantive requirements for "Field of view" (S6.2.1), "Size" (S6.2.2), and "Response time" (S6.2.3), an R2X exempted from these test procedure provisions would not lower the safety of the vehicle. Because NHTSA finds that safety would not be lowered, NHTSA does not reach the question of whether safety would be unreasonably lowered.
An exemption from the mirror, windshield, and backup camera "Linger time" requirements would make easier the development or field evaluation of the R2X because it will permit Nuro to deploy the R2X without equipping the vehicle with extraneous safety features that, as noted earlier, NHTSA has found to not serve a safety function on an occupantless low-speed ADS vehicle.
Nuro argues in its petition that compliance with these requirements potentially imposes costs on Nuro and make it more difficult to field test the R2X because compliance "increases pedestrian strike risk, adds mass, and worsens the impact of collisions." NHTSA agrees that, because compliance would require the R2X to be equipped with additional equipment, compliance with the standard would increase the cost of performing field evaluations of the R2X due to higher manufacturing costs and design restrictions. NHTSA also agrees that increased weight would make field evaluation of the vehicle harder by limiting the utility of the R2X as a delivery vehicle, because extra equipment may increase the curb weight of the vehicle, which could decrease the amount of cargo it can carry. (LSVs are required to have a GVWR of 3,000 pounds or below, regardless of the curb weight of the vehicle.)
While the exemption from the backup camera linger time requirement would not impact the manufacturing cost or weight of the vehicle, NHTSA finds that granting an exemption from that requirement would also make easier the field evaluation of the R2X because it would allow the R2X's ADS to operate continuously with full sensor input at all times, which would aid with Nuro's evaluation of the ADS's performance.
Because an exemption from the mirror, windshield, and backup camera "Linger time" requirements would not lower the level of safety of the R2X, NHTSA finds that an R2X exempted from these requirements would have a level of safety at least equal to that of a compliant version of their R2X. In addition, NHTSA finds that because an exemption from the FMVSS No. 111 test procedures relating to fuel tank loading (S22.214.171.124), driver's seating position (S184.108.40.206), steering wheel adjustment (S14.1.7), and the opening of the driver's door and activation of the starting system (S14.2(a)-(c)) would affect whether the R2X's rearview image meets the substantive "Field of view" (S6.2.1), "Size" (S6.2.2), and "Response time" (S6.2.3) requirements, an R2X exempted from these test procedure provisions would provide a level of safety equivalent to a vehicle tested in accordance with the FMVSS No. 111 test procedures.
Compliance with FMVSS No. 500 would prevent Nuro from commercially deploying the R2X because it requires the R2X to be equipped with the three additional features that are the subject of this exemption (exterior and/or interior mirrors, a windshield
We note that, while the statutory language for the EOS states that NHTSA must find that compliance with the FMVSS would prevent Nuro from "selling" the R2X, this language does not limit the application of the statutory basis to only vehicles that will be offered for sale (which Nuro states the R2X will not). Rather, to grant an exemption under the EOS basis, NHTSA must find that compliance with the standard would prevent Nuro from selling the R2X
As discussed above, the Vehicle Safety Act and its implementing regulations provide the Secretary and, by delegation, NHTSA with broad authority and discretion in determining whether granting the petition is consistent with the public interest and Vehicle Safety Act. Here, NHTSA finds that granting Nuro's petition is consistent with the public interest and 49 U.S.C. Chapter 301 because an exemption would enable a limited-risk deployment
More specifically, allowing for the introduction of the R2X as it has been designed by Nuro to optimize its performance as an occupant-less vehicle could further the development of new and innovative vehicle automation technologies, which may in turn lead to future benefits for vehicle safety, the environment, and the economy. While the extent of the anticipated benefits of ADS vehicles like the R2X are uncertain, commenters Local Motors and SAFE suggested that these vehicles could provide a variety of benefits, including increased safety (because ADS vehicles may reduce the number of crashes caused by human error), decreased emissions (because ADS vehicles could perform the driving task more efficiently and, in the case of the R2X, efficiently combine trips), and socioeconomic benefits (because ADS vehicles could provide expanded goods delivery services to poor and/or underserved communities).
While NHTSA cannot fully predict the extent to which these benefits will materialize in the future and, more specifically, the effect that granting this petition would have on those benefits, the agency understands that development of the ADS technology necessary to make these potential benefits possible requires the technology be used on vehicles that are designed from the ground-up to be automated and in real-world (non-simulated) environments, both to validate the safety of the current ADS technologies and to expose those technologies to new situations in which "machine learning" capabilities can be used to improve performance.
Finally, granting this exemption is in the public interest and consistent with the Vehicle Safety Act because it would encourage the development of new safety and automated technologies, like ADS, with an eye toward future regulatory changes. To this end, NHTSA believes that both the public interest and the goals of the Vehicle Safety Act would be best served if NHTSA were able to maintain a dialogue with Nuro about its experience operating the R2X, which may help inform the agency's future policy decisions towards ADS technologies. Accordingly, NHTSA has decided to condition the grant of an exemption on Nuro providing the agency with specified periodic and incident-based reporting of information about the R2X's ADS, notwithstanding that the driving capability of the ADS is not relevant to the requisite safety findings.
NHTSA has deemed moot Nuro's request for an exemption from the backup camera "Deactivation" requirement (FMVSS No. 111, S6.2.5) because the requirement does not mandate that the backup camera deactivate when the vehicle shifts out of reverse, as Nuro assumed in its petition. Accordingly, an exemption from the "Deactivation requirement" is not necessary for Nuro to design the R2X to operate with the backup camera activated at all times, which was Nuro's stated purpose of requesting an exemption.
The deactivation requirement specifies the circumstances in which the backup camera image may be deactivated,
Since the deactivation requirement in S6.2.5 permits, but does not require, deactivation of the rearview image when the vehicles is taken out of reverse, Nuro's request for exemption from the requirement is moot.
Several commenters raised the issue of whether, and the extent to which, the driving ability of the R2X's ADS was relevant to the safety findings NHTSA must make to grant an exemption under § 30113, under any basis. Advocacy groups, including AAMVA,
According to CAS, the driving ability of the R2X's ADS is relevant because the FMVSS often have "an implicit human operator bias." Accordingly, CAS argues that manufacturers of ADS vehicles must be required to demonstrate that the manufactures "have successfully replicated in their automatic systems the human sensory capability, responses, and judgement implicit in the specific FMVSS for which an exemption is sought." Using the mirror requirement as an example, CAS argues that, for Nuro to be exempted from the LSV mirror requirement, its petition must demonstrate that the R2X's ADS will respond as a human using mirrors would in a potential crash scenario. However, CAS does not cite a legal basis for reading into the FMVSS a requirement that the ADS must react in a certain way in these driving scenarios. While other comments from advocacy groups were not as thorough as CAS in their discussion of the relevance of the ADS, they all roundly criticized Nuro's petition for a perceived lack of information about the ADS and other related subjects (such as the ODD and remote operator system) they claim are relevant to the safety findings NHTSA must make.
On the other side, SAFE, Local Motors, and the Alliance, argued in their comments that the driving capability of the R2X's ADS is not relevant to the safety findings NHTSA must make to grant an exemption. According to SAFE, the R2X's ADS is not relevant to NHTSA's safety findings because the exemption statute requires NHTSA to determine how the safety level of the non-compliant R2X would differ from that of a compliant vehicle, which in this case, would be a compliant occupantless, low-speed ADS vehicle.
NHTSA agrees with SAFE and Local Motors that the ADS does not factor into the comparative safety findings NHTSA must make to grant an exemption under either the EOS or LEV bases in this instance. As we briefly explained at the start of the "Safety Analysis" section, neither the statute nor regulations call upon NHTSA to assess the absolute level of safety of the exempted vehicle in question and find whether the vehicle's safety exceeds some minimum threshold that exists in the abstract. Instead, the agency is tasked with making a judgment about relative safety,
While we agree with the Alliance that the driving performance of the ADS is not germane to the safety findings NHTSA must make to grant Nuro's petition, we do not agree with the Alliance that the VSSA process is the appropriate framework NHTSA should use to exercise oversight of ADS vehicles that are produced subject to an exemption. First, as stated in NHTSA's ADS 2.0 guidance, and reemphasized in the Department's AV 3.0 and other statements, VSSAs are completely voluntary and the agency has no mechanism with which to compel their submission. VSSAs are intended to be documents by which ADS developers convey to the public information about how safety is factored into the development of the ADS in several specific critical areas and, thus, are not intended to be tools of regulatory oversight. Further, the agency is not, in this notice, foreclosing the possibility that, in considering whether to grant an ADS-related exemption petition for a vehicle that is requesting exemption
It is important to note that, while the driving capability of the R2X's ADS was not a factor in NHTSA's findings concerning whether the agency should grant Nuro's petition, as described above, nothing in this decision precludes NHTSA from seeking information about the ADS as part of a defect investigation, just as the agency would be able to seek information about the ADS in an investigation of a FMVSS compliant ADS-equipped vehicle. Neither this decision nor the Vehicle Safety Act prohibits NHTSA from mitigating ADS-related risks in determining the number of vehicles to exempt or the terms that apply to the exemption. Accordingly, NHTSA has conditioned this exemption grant on terms that the agency believes will mitigate risk and ensure the agency can maintain adequate oversight of deployed R2X vehicles. The agency has included several terms that require Nuro to report both general and incident-related information to NHTSA, including certain data about the operation of the R2X and its ADS. As described above, NHTSA believes granting this petition is in the public interest in part because this data will assist the agency both with its oversight of the R2X, and with developing regulatory changes to facilitate the safe introduction of fully compliant ADS vehicles.
Several commenters also raised the issue of whether, and to what extent, NHTSA should require Nuro to report data about the operation of the R2X to the agency. While most commenters agreed that some required post-grant data reporting requirement would be appropriate, the commenters disagreed on whether this reporting should include information about the operation of the R2X using the ADS.
The commenters in favor of broad reporting requirements that cover information about the operation of the R2X and/or its ADS included advocacy groups like Advocates, CAS, and AAMVA, as well as the manufacturer Local Motors. Advocates argued that NHTSA should use the exemption process to increase the agency's understanding of ADS technologies through "required data sharing," though it did not provide detail as to what data it believed would be useful for NHTSA to collect, nor what exactly is meant by "sharing."
Commenters who argued against significant reporting requirements included the Alliance and Nuro itself. The Alliance argued that data reporting on the operation of the R2X and/or its ADS should not be required, both because of what it refers to as the "limited" nature of Nuro's exemption request, and because NHTSA has the VSSA process to obtain this information.
NHTSA has determined that limiting reporting requirements in the way suggested by the Alliance and Nuro would not be appropriate, because it could harm the public interest both by hindering NHTSA's oversight of the R2X and limiting NHTSA's ability to learn from information from Nuro to potentially inform future activities. Accordingly, NHTSA has decided to include terms that would require both crash-related information that is sent to the agency very soon after any crash, and periodic reporting of general information about the operation of the R2X, and that this reporting should extend throughout the useful life of the vehicles produced pursuant to the exemption.
AAMVA argues in its comment that Nuro should be required to apply for an exemption from the requirement that LSVs come equipped with an FMVSS No. 209-compliant seat belt, despite the vehicle's lack of designated seating positions, because AAMVA is concerned that allowing this would set a precedent that manufacturers could simply decide that certain FMVSS requirements do not apply to their vehicles.
Similarly, CAS argues that NHTSA should require that the R2X be equipped with an FMVSS No. 401-compliant trunk release in its cargo compartments as a term of granting the petition.
The question of whether LSVs should be subject to additional performance requirements is outside the scope of this proceeding, and the agency does not have a legal basis to impose additional FMVSS requirements on the R2X, either as a pre-condition of granting an exemption, or as a term for maintaining an exemption grant. However, the agency may consider whether to include a trunk release requirement should we decide in the future to amend the FMVSS to specifically regulate occupantless delivery vehicles, as described in the Notice of Receipt for this petition.
Three commenters—CAS, NSPE, and Patrick Coyle—all raised cybersecurity concerns as well. CAS states that "end-to-end encryption," which Nuro states the R2X's communications will have, is insufficient to assure cybersecurity alone.
Although the agency has no reason to believe that the cybersecurity risk between the R2X and a hypothetical compliant version of the R2X are any different, given the critical importance of cybersecurity, we have decided it would be in the public interest to include terms requiring Nuro to report any cybersecurity incidents and safety-critical cybersecurity vulnerabilities, and cease operation of all R2X vehicles if a cybersecurity incident that has an effect on safety occurs until the incident has been remedied.
Both AAMVA and AAA argue in their comments that community engagement would be important to ensuring the safe operation of the exempted vehicles and to gaining consumer acceptance. AAMVA stated that NHTSA should carefully consider how state and local authorities would be affected by the presence of exempted vehicles, and suggested that the acceptability of features like remote operation as a risk mitigation strategy should be up to State and local authorities.
Although the question of whether Nuro adequately engaged with the local communities in which it is deploying the R2X is not a factor in the safety findings NHTSA must make to grant Nuro's petition, NHTSA agrees that community outreach and compliance with local regulation is important for both the safe operation of the R2X within the community (
The Vehicle Safety Act provides that NHTSA may grant an exemption under the LEV and EOS bases for the production of a maximum of 2,500 vehicles during any 12-month period.
The Vehicle Safety Act grants the Secretary, as delegated to NHTSA significant discretion to condition the grant of an exemption "on terms [NHTSA] considers appropriate." 49 U.S.C. 30113(b)(1) (delegation of authority at 49 CFR 1.95). Pursuant to this authority, NHTSA's grant of an exemption is subject to the terms set out in the Appendix following the preamble. Although, as we have noted, the performance of the R2X's ADS need not be addressed for this exemption, the Vehicle Safety Act does not limit the agency's authority solely to terms and conditions directly relevant to its specific determination. This is particularly true in instances, such as here, where the agency has considered the potential benefits of automation in its public interest finding, and where the party seeking the exemption is using a novel form of technology.
The exemption Nuro is receiving today is the first exemption NHTSA has granted under section 30113 to permit the deployment of an ADS vehicle that will be used for commercial purposes. As such, NHTSA appreciates that there will likely be heightened public interest about the vehicles allowed under this exemption petition, as evidenced by the public comments, and, the agency has decided to include provisions concerning the performance of the ADS in the terms for this exemption. NHTSA notes that violation of these terms may lead NHTSA to determine that the exemption is no longer in the public interest, which is a ground for the agency to terminate the exemption under 49 CFR 555.8(d). NHTSA may also take other appropriate enforcement action.
The terms NHTSA has chosen are designed to enhance the public interest and include post-crash reporting, periodic reporting, particular terms concerning cybersecurity, and certain general requirements. The post-crash reporting requirements would provide NHTSA with information necessary to understand the cause of the crash (including any role the ADS may have played), so the agency can take appropriate remedial action—up to and including requiring a recall, or even terminating the exemption and include the type of information the agency may request as a matter of course in any safety defect investigation involving an ADS-equipped vehicle. The periodic reporting requirements are intended to provide NHTSA with information about the operation of the R2X on public roads to facilitate improved safety oversight. NHTSA has also included restrictions on Nuro to ensure that the company is in a position to learn of and quickly resolve cybersecurity incidents related to safety. The general requirements are intended to ensure that Nuro removes from operation any vehicle determined not to be safe, Nuro comply with all relevant State and local laws, retain ownership of the vehicles, and provide a hotline for safety concerns.
We note that the terms we have included in this notice are similar to terms NHTSA has previously imposed on the importation of noncompliant ADS vehicles under 49 CFR part 591, though, consistent with the differing requirements of part 591, Nuro's exemption will allow for commercial deployment, rather than simply testing and demonstration. Finally, though not included in the terms below, Nuro must also comply, as a matter of law, with the requirements for a label that must be affixed to its exempted vehicles under part 555.9.
In accordance with 49 U.S.C. 30113(b)(3)(B)(iii) and (iv), the agency is granting Nuro NHTSA Temporary Exemption No. EX 20-01 from paragraphs S5(b)(6) and S5(b)(8) of FMVSS No. 500; and paragraphs S6.2.4, S22.214.171.124, S220.127.116.11, S14.1.7, and S14.2(a)-(c) of FMVSS No. 111; provided that Nuro complies with the terms and conditions described in the Appendix to this document. The exemption shall be effective from February 11, 2020 to February 10, 2022.
As soon as practicable, but no later than 24 hours after the R2X is involved in any crash in which either (1) the R2X is in motion, or (2) the R2X is struck by another motor vehicle, Nuro must inform NHTSA's Office of Vehicle Safety Compliance (OVSC) that the crash took place.
As soon as practicable, but no later than 7 calendar days after Nuro informs OVSC of a crash, Nuro must report to NHTSA the data elements specified in Table I.
The data elements specified in Table I must be reported in accordance with the range, accuracy, and resolution specified in Table II.
In addition, Nuro must provide NHTSA's OVSC with the following information about the status of the ADS and/or remote operator before and during the crash event:
• If the ADS was in control of the vehicle during the event, a detailed timeline of the 30 seconds leading up to the crash, including a detailed read-out and interpretation of all sensors in operation during that time period, the ADS's object detection and classification output, and the vehicle actions taken (
• If a remote operator took over control of the vehicle prior to the event, a detailed timeline of the 30 seconds leading up to the remote operator taking over control, including a detailed read-out and interpretation of all ADS sensors in operation during that time period, the ADS's object detection and classification output, and the vehicle actions taken (
• If a remote operator was in control of the R2X at any point during or up to 30 seconds before the event, Nuro must provide a detailed timeline of any actions the remote operator took that affected the crash event, as well as any technical problems that could have contributed to the crash (signal latency, poor field of view, etc.).
Finally, Nuro must provide NHTSA with any additional information about the event that NHTSA deems pertinent for determining either crash or injury causation, including additional information related to the ADS or remote operator system.
Beginning 90 days after the date of the exemption grant, and at an interval of every 90 days thereafter, Nuro must submit to NHTSA's OVSC a report detailing the operation of each R2X vehicle in operation during that time period. This report may provide this information either in aggregate or on a per-vehicle basis, but it must include the following:
• A calculation of the total miles the vehicle has traveled using the ADS during the report period, and heat maps of the geofenced area in which the vehicle operates to illustrate travel density. Nuro must provide the same information for miles traveled using a remote operator.
• Detailed descriptions of any material changes made to the R2X's Operational Design Domain (ODD) or ADS software during the reporting period.
• Detailed descriptions of any incidents in which the R2X has violated any local or state traffic law, whether operating using the ADS or under remote operation.
• Detailed descriptions of any incidents in which the R2X has experienced a sustained
• Detailed descriptions of all instances in which a public safety official, including law enforcement, has attempted to interact with an R2X, such as to pull it over, or has contacted Nuro regarding an attempted interaction with the R2X.
• Detailed descriptions of any "minimal risk condition fallback"
In addition, Nuro must make necessary staff available to meet with NHTSA staff quarterly to discuss the status of its deployment program.
• Nuro must have a documented cybersecurity incident response plan that includes its risk mitigation strategies and the incident notification requirements listed below.
• Nuro must cease operations of all R2X vehicles immediately upon becoming aware of any cybersecurity incident
• No later than 24 hours after being made aware of a cybersecurity incident, Nuro must inform NHTSA's Office of Defects Investigations (ODI) of the incident. Nuro must also respond to any additional requests for information from NHTSA on the cybersecurity incident.
• Prior to resuming its operation of R2X vehicles following the discovery of a cybersecurity incident, Nuro must inform NHTSA of the steps it has taken to patch the vulnerability and mitigate the risks associated with the incident, and receive NHTSA approval to resume operation.
• Nuro must be capable of issuing a "stop order" that causes all deployed R2X vehicles to, as quickly as possible, cease operations in a safe manner, in the event that NHTSA or Nuro determines that the exempted vehicles present an unreasonable or unforeseen risk to safety.
• Nuro must coordinate any planned deployment of the R2X or change to the ADS/ODD with state and local authorities with jurisdiction over the operation of the vehicle as required by the laws or regulations of that jurisdiction.
• The R2X must comply with all state and local laws and requirements at all times while in operation. Each vehicle must be duly permitted, if applicable, and authorized to operate within all properties and upon all roadways traversed.
• Nuro must maintain ownership and operational control over the R2Xs that are built pursuant to this exemption for the life of the vehicles.
• Nuro must create and maintain a hotline or other method of communication for the public and Nuro employees to directly communicate feedback or potential safety concerns about the R2X to the company.
49 U.S.C. 30113 and 49 U.S.C. 30166; delegations of authority at 49 CFR 1.95 and 49 CFR 501.4.


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Four businesses from across the Mid Yorkshire region have been crowned winners in the regional heats of the Chamber Business Awards 2019.
The RSPCA Halifax, Huddersfield, Bradford & District alongside St Marks Church, Longwood are introducing a brand-new Animal Blessing Service to celebrate the local animal centre's RSPCA month. The blessing will take place at 3.00-3.45pm on Sunday 20th October at St Marks Church, St Marks Road, Longwood, Huddersfield, HD3 4SZ.
Huddersfield pharmaceutical company Thornton & Ross is expanding, with a new seven-figure state-of-the-art facility due to open at the beginning of January.
Schofield Sweeney have acted for Yorkshire-based property company YPP in their latest acquisition.
Ramsdens Solicitors will be sponsoring and supporting England Netball's newest mixed workplace netball tournament on 7th November.
Business system and database consultants, All My Systems, has secured a deal to replace leading manufacturer Rosehill Polymers Group's existing system with a solution to integrate its end-to-end operations.
Yorkshire's Legal People, Chadwick Lawrence, were crowned winners of the Innovation and People Development Award at the CILEx National Awards Ceremony on 5th September 2019 at Madam Tussauds in London.

subset: commoncrawl


text:
Penny auction sites are really getting popular over the internet. Each day hundreds of people are joining these penny auction sites. For those who are new to this concept we will be clearing the facts very soon in this article, but those who know what these sites actually are and want to know about the risks involved with these sites, can seek their answers later in this article.
So we need to return to the first option – free bets and bonuses with deposit requirement. Actually it's possible to safely extract these promotions with betting system called Matched Betting. You can find more about it by following link below in a resource box. It will eliminate any losing risk. By using this system you can clear many bonuses and free bets and in that way you can build yourself a betting capital without risking to lose anything. For example, you deposit $50 in a bookmaker and they give you $50 bonus. You use matched betting and extract it. Now you have $50 to bet with. Other money used to get this bonus can be withdrawn at any time after you cleared a promotion. You can extract multiple bonuses and ensure yourself even bigger betting bank.
On the other hand, if the Celtics lose by 2 points or less (or wins the game), you win the bet if you happened to place a wager on them. But if they lose by 3 points or more, you lose the bet outright. In this case, the NBA spread was set so that the eventuality for the game to become a push is entirely eliminated. This definitely assures that there will be winners and losers only. There will be no in-between since a winning margin of 2.5 points does not exist in NBA games.
The money line odds system – Also known as American odds these have their figure quotes as either positive or negative without any point spread consideration. For example a fractional odd of 5/1 is quoted as +500 and that of 1/5 as – 500. Even odds are quoted as 100 with the "- "sign not being displayed at times. The positive figure states the profit you will make and the negative the amount you will have to wager to make an amount on the bet.
Over the years past few years, the online sport betting (Sportwetten) has witnessed increased popularity across the world. There are a number of benefits of online sport bets. You no longer have to go cities to place bets on your favorite sport teams; rather you can stake some amount of money from the comfort of your home through several 메이저사이트 추천 sites offering a wide range of sport bets. If you are now planning to bet, just look into your budget. Do not bet more than what you can afford to lose. Always choose a game that you know about. Never stake your bucks on games, which you are not familiar with. If you do so, you may face heavy loss of money instead of earning it. So, be careful!
A low one time membership fee per month. Pay once and receive all your picks for free for the month. You do not have to pay per pick as some professional handicappers might charge.
Once you have your account set up, you will need to put a betting system in place. I recommend you build your own so the books are not making adjustments for it.


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Please note: Unable to enter under 6 years old.*Up to 4 tickets can be purchased per order per purchase.Tickets won't be picked up at the venue. Please make sure to pick up tickets at Seven-Eleven stores from August 18(Tue) 10:00.
Please wait while we process your request. This may take time if the server is busy.


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Carrico has 'no regrets' over swapping Sevilla for coronavirus epicentre Wuhan
Daniel Carrico made one of the more eye-catching transfers of the winter window by moving to Wuhan in the middle of a coronavirus outbreak, but the former Sevilla man insists he had "no regrets".
The virus was first identified in the Chinese city at the start of 2020, and it continues to be one of the areas most affected by a disease that has spread across the globe.
Residents live under virtual lockdown due to quarantine rules aimed to reduce the spread, causing normal life in Wuhan to all but disappear.
Editors' Picks
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In total almost 80,000 of the 87,000 confirmed cases of coronavirus have originated in mainland China, as well as virtually all of the 3,000 deaths from the disease.
All of which made Carrico's decision to move to Wuhan Zall in February all the more curious - but he insists he is excited about the fresh start.
"I don't have any regrets," Carrico told reporters upon completing the switch on Sunday.
"I am really excited because I want to get to know the Chinese league and experience something new."
"[Wuhan] have also guaranteed my safety, assuring that we're going to work in Spain while the situation is complicated in China.
"I did have doubts because at first when the deal was first proposed, because I didn't know anything. Just that the virus was in China; that it was new.
"To start with I was having doubts, asking about the reality and what was happening there. But the coaches eased my doubts. They really wanted me in the team.
"They guaranteed that the team would not go back to China while the situation is complicated, especially in Wuhan.
"In the end, it worked out well for me and for Sevilla, because they've not lost out when my contract would have expired [in the summer]."
The Portuguese defender, 31, faces an extended wait to make his bow for the Super League club.
The Chinese top flight has been suspended indefinitely having originally been scheduled to begin on February 22 as part of public health measures to contain the virus.
Carrico and the rest of the Wuhan team remain in Spain, as the outbreak began when the club's squad were on a European training camp.
"Many players have family there that are stuck at home and can't go out and can hardly communicate with anyone in the city," he added.
"It's a tough situation. Now it's starting in Europe and we have to react, we can't let the virus advance."


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We are the original tart frozen yogurt shop in Charlotte, NC.
We offer original tart frozen yogurt and 20 toppings to choose from. We also sell drinks, chips, granola, and other healthy snacks.
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If so. Which country do u think is the most aggressive?
Why do u say that? Whats the differences betwwen city amnd suburbs?
I don't know. I feel like in the suburbs people are more calm and quiet, they sort of mind their own business. In the city, people are walking around all the time, guys hang out around the streets, stuff like that. I live in a city in Europe and guys will catcall all the time, especially when it's just girls and no guys around.
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Breathtaking views, deep water, great fishing year round and cove protection create the ideal location to build your lakefront dream home! With 80 feet of shoreline and quiet waters at the 55MM you will enjoy the laid back lifestyle that so many dream of. Well established neighborhood ensure your full time or vacation home investment value will be well supported. This lot is priced to move quickly so don't miss out, come see and make it yours and start construction to be moved in by Spring!
Land, Other
Mallard Bay
Exterior / Lot Features
- Parking
- 0 Covered Parking Spaces.
- Lot Dimensions
- 80x103
- Additional Exterior/Lot Features
- Lake Front.
Financial Considerations


text:
Veruca Salt - All Hail Me album flac
Genre: Rock
Title: All Hail Me
Country: US
Released: 1995
Style: Alternative Rock
FLAC version ZIP size: 1985 mb
MP3 version ZIP size: 1763 mb
WMA version ZIP size: 1735 mb
Rating: 4.9
Votes: 560
Other Formats: DMF VOX AAC FLAC VQF APE MPC
Lyrics to "All Hail Me" song by Veruca Salt: So sorry lady, so sorry now. I've killed your baby, I don't know how So sorry, so sorry now. S. .I'm soaked in blood here that did not hurt so ba. Submit Corrections. Writer(s): POST LOUISE LIGHTNER. V. Veruca Salt Lyrics. album: "American Thighs" (1994).
Album Eight Arms To Hold You (1997). Album American Thighs (1994). Video - Listen to 'All Hail Me'. Karaoke scroller.
Veruca Salt American Thighs All Hail Me Yeah-ah-ah-ah-ah So sorry lady, so sorry now I've killed your baby I don't know how So . I'm a bad man, I do what I can I'm a bad man, I do what I can All hail me. So sorry mother I've let you down I'm soaked in blood here I can't get out. So sorry, so sorry now So sorry, so sorry now So sorry, so sorry now. Cause I'm a bad man, I do what I can. I'm a bad man, I do what I can. All hail me. Ha, ha, ha, ha, ha, ha All hail me.
American Thighs is the debut studio album by American alternative rock band Veruca Salt. It was originally released through Minty Fresh on September 27, 1994. The title is a reference to a line from the AC/DC song "You Shook Me All Night Long".
Album: American Thighs, 1994. Veruca Salt - All Hail Me - San Francisco, Live, 7-10-15, front row, Slim's. Nina and Louise back together again! With a new album! Other Tidbits: 'Ghost Notes' was released on July 10th, the same day as the concert. Many fans were listening to it while waiting for the show to start. Spiderman '79 was not on the printed setlist, but the band decided to play it, probably because of all the fan-shouted requests for it, lol. SF was the 2nd show of their 2015 tour.
Veruca Salt took shape in early 1992, when Chicago residents Louise Post and Nina Gordon began touring the local folk circuit. Both were competent singers and guitarists, and a year's worth of coffeehouse performances fueled their desire to recruit additional members for a full-fledged band. Undeterred, Post regrouped Veruca Salt as her own project. Now boasting a revised lineup including guitarist Stephen Fitzpatrick, bassist Suzanne Sokol, and drummer Jimmy Madla, the band left Geffen Records (which had been swallowed by a corporate merger) and inked a new record deal with Beyond. They also entered the studio to record Resolver, a fiery album that dealt with Gordon's departure and Post's failed relationship with Dave Grohl.
Tracklist Hide Credits
|All Hail Me (Remix)
Recorded By, Mixed By – Brad Wood
|My Sharona
Recorded By, Mixed By – Doug McBrideWritten-By – Averre*, Fieger*
Producer – John Leonard
- Written-By – L. Post* (tracks: 1, 3)
NotesTrack 2: recorded and mixed at Gravity, Chicago.
Track 3: recorded live at Studio 3, Manchester England for the Mark Radcliffe Show. First broadcast date: January 17th, 1995.
Barcode and Other Identifiers
- Barcode (Scanned): 4005902308038
Other versions
|Title (Format)
|PRO-CD-4752, none
|Veruca Salt
|All Hail Me (CD, Single, Promo)
|DGC, Minty Fresh
|PRO-CD-4752, none


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A grenade is an explosive device used by Providence and its agents. It is a weapon thrown by hand.
In the battle of the Bug Jar, Wade used her grenades to throw down an EVOs mouth. The EVO, of course, was destroyed by a large explosion.[1]
Season One
- 110. "The Forgotten"
- Although grenades are usually dark colors, Providence's grenades are white.[1]
- ↑ 1.0 1.1 1.10, "The Forgotten"
Community content is available under CC-BY-SA unless otherwise noted.


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A kind of secret: what's wrong with Russian military satellites?
The orbiting constellation of satellites of Russia, according to recent data, includes more than 150 spacecraft, about 90 of which are military satellites
The commission to find out the reasons for the failure to upgrade the military constellation of satellites of Russia will not be able to provide complete information to Vladimir Putin until the end of January 2020, military experts say. At the same time, in his opinion, recently launches have entered a normal rhythm.
Subscribe to Defenseweek channels in Google News or Flipboard. Available for App Store and Google Play!
The orbiting constellation of satellites of Russia, according to recent data, includes more than 150 spacecraft, about 90 of which are military satellites. To update them, it is necessary to maintain a certain pace, said Ivan Konovalov, director of the Center for Strategic Market Studies, in a conversation with Gazeta.Ru.
"The satellites cannot serve for a long time, they have not been given much time. When one of them fails, he needs to be given a replacement. Accordingly, it is necessary to maintain certain rates for their updating," the expert said.
Recently, launches have entered a normal rhythm, the trend is rather positive than negative, Konovalov added, but it is well known about the problems in Roscosmos and they have been identified in the government.
As Deputy Prime Minister Yuri Borisov noted on Friday, Russian President Vladimir Putin ordered the creation of a commission, which should report on the reasons for delays in updating satellites until January 20, 2020.
"Maybe I will give out a certain kind of secret. In December, at the Sochi meetings, where we seriously discussed the state of the space group in the interests of the Ministry of Defense, there was a very tough, serious conversation," Borisov said on the Russia 24 television channel.
The members of the commission also have to "identify problematic issues and find ways to solve them, develop catch-up schedules in order to get into the rhythm and so that such breakdowns are not repeated in future".
"The deadlines were tight and short. Accordingly, the work will be dense, probably during the holidays. Most likely they will be able to report on approaches to the study of all recorded cases of disruption of work," said Konovalov.
At the same time, for such a short time it is difficult to provide complete information, the expert notes. It may take longer to identify the root causes.
In addition, Borisov added that in 2019 Russia did not complete almost half of the announced space launches. "Launch programs have been implemented a little more than 50%. The reasons are different, including shortcomings in the organization of work," the Deputy Prime Minister emphasized.
At the beginning of the year, the head of Roscosmos Dmitry Rogozin announced 45 launches during the year, but in December the corporation announced only 25 completed launches. Rogozin himself said that, speaking of 45 starts, he had in mind launches of all products that are produced by state-owned enterprises, including military missiles.
"We do not include launches, including space rockets, in this number [launches of Roscosmos], but for the solution of certain combat missions. So I can tell you 45, 46, 47, but let my colleagues call it, why will I run into their clearing," said the head of the Russian Space Agency.
By the way, in December, Putin at a meeting in Sochi on the development of the Armed Forces of Russia called for paying increased attention to strengthening the orbital constellation of satellites. According to the president, the composition of the orbital grouping of military and dual-use spacecraft has noticeably been updated in recent years.
"The satellites of the Unified Space System timely detect the launches of ballistic missiles from military bases and from the oceans. They quickly give out information to the country's leadership and to the points of state administration, the Armed Forces," Putin said.
In 2019, the deployment of a full-speed high-speed communications complex in a geostationary orbit was completed, the president noted, in this area Russia intends to provide a serious foundation for the future – promising systems and complexes are being developed in defense organizations.
It is worth noting that a number of launches in the interests of the Ministry of Defense should be carried out with the help of Angara A-5 launch vehicles. However, the first and last launch of a heavy rocket took place in 2014, the resumption of flights was planned for the current year, but in the end, a new launch of the Angara was postponed to 2020.
Angara is a family of launch vehicles of various classes. It includes light carriers "Angara-1.2", medium – "Angara-A3", heavy – "Angara-A5" and a modernized "Angara-A5M", increased payload – "Angara-A5V".
The military hoped to use heavy rockets, in particular, to launch satellites into orbit. The reasons for the systematic transfer of Ankara launches are unknown, but this may be due to an inconsistency between the Russian Space Agency and the Ministry of Defense. For example, the Energia rocket and space corporation explained the delay in delivering the preliminary design of the DM-03 upper stage, which is designed to launch the heavy Angara from the Vostochny cosmodrome.
The corporation handed over a sketch a year later than the deadline, according to RIA Novosti, the delay was due to the fact that for a long time Roscosmos could not agree with the Ministry of Defense on the use of scientific, technical and technological groundwork for the design of upper stages created by OKR "Perseus-KV".


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As a result of the close-down of the UK by the British Government last night, we have made all the Buy/Sell areas read-only until we open back up again, so please have a look at the announcement linked here.
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Everything posted by tedtaylor
Revell's new 1:32 Lynx - includes some HMA8 parts
tedtaylor replied to Iain (32SIG)'s topic in ModernThe 219 UHU is here http://tedtaylor.hobbyvista.com/160-he-219/page-160-revell-he-219-.html
Revell's new 1:32 Lynx - includes some HMA8 parts
tedtaylor replied to Iain (32SIG)'s topic in ModernI have a set of shots and they look OK to me but been busy on He 219 model so have not started it yet it is a Mk 88 and there are plenty of pictures on the web to help out
New Revell 1/32 He-219 InstructionsI have done a build review on my site if you want to look http://tedtaylor.hobbyvista.com/160-he-219/page-160-revell-he-219-.html Ted
Vosper MTB 1/35thIt's a doddle no problems to speak of , all the brass makes up easy and the fit of the parts is excellent. I have built mine OOB so not worried about extras. am just writing a review now to go on my site and hyperscale soon. Ted
A tribute to 'Liberty Belle'
tedtaylor replied to tomprobert's topic in Ready for Inspection - AircraftThought this might fit in here, I liked The Liberty Belle when she landed at Duxford and was sad to see her go. I did a few pics of her and I had a chat with the pilot who brought her in.hope you like Great Model by the way. Cheers Ted
Iwata airbrush help please
tedtaylor replied to billybookcase's topic in AirbrushesYou don't need to spend all that money try the Badger 200 I have been using them for the last 40 years and they are no trouble and no nonsense brushes get the medium set for all modelling and if you want to do fine artwork use the fine set. Ted
is that the one from MOTAT?
Try PVA glue cause that is all Kristal Klear is Ted
RN bucc to RAF (1/48) whats the differenceI have an article on these buccs on my site , some of it may be helpful to you, http://tedtaylor.hobbyvista.com/34-airfix-...er/page-34.html Ted
I have done an article for truck model world which should be out soon I hope, so look there I will also make a page up for my web site later. The paint was Humbrol 19 gloss redbut I believe that the correct colour is available from precision paints. Ted
Jim when I was there the road to Khobar was a dirt road and the town was just a small settlement I used to deliver there when I was trucking. there were F-5 on the runway and all the sediki was in every villa out there. I used to fill up with 90 gallons of diesel and buy 200 Bensons and give the guy £3.00 and get change so not much changes does it, Hey I just saw your mirror aircraft and they look great mate, they had lightnigs when I was there so one on a mirror might be a good Idea Ted
This is an easy build providing you follow the instructions no filler or bad joins and I have not added anything extra what you see is what you get in the box Ted
Hi Jim How is Dahran these days, have not been there since 1976. The manufacturer would not supply me with wings for only one project and they wanted government approval etc etc.
sorry about this being in "Aircraft" but I cold not find another spot for it it certainly isn't armoured and it won't float
Big Red Bus
tedtaylor posted a topic in Ready for Inspection - AircraftI built this from test shots from Revell and no instruction sheets until it was nearly finished. It won't fly I know but what a smashing model to build, it is based on a restored vehicle so there are one or two tiny discrepancies but they are minor. well worth it for the trip down memory lane. and BTW they used to take you to the airport at Heathrow. note, all the seat covers are decals saving a lot of time painting all those stripes of colour. Ted
Revell Halifax
tedtaylor posted a topic in Ready for Inspection - AircraftI built this from test shots that Revell sent me before release of the kit, I am not a Halifax expert so would not know of the problems about the accuracy, until I read some comments on here, but to my tired old eyes it looks like a Halifax to me so thank you Revell for making such a lovely moulded kit even if it is the "worst in the world". Ted
there are Raf roundels on the sheet in the box but on a Canadian ship. Ted
Hi Tony, been not too well lately but you are right it is the Revell Ventura in 1/48th, seems to be OK and I must admit it goes together like a dream, the octopuss is a bit tricky to get on right cheers Ted
Latest finish
tedtaylor posted a topic in Ready for Inspection - Aircraftjust finished this hope you like it very easy build
'foreign debris' in my paint
tedtaylor replied to danielrocks's topic in PaintYou can purchase a proper paint filter from a badger supplier, Part No 50-2016, just thin the paint first in one jar then pour through the filter into the fresh clean jar and screw onto the brush. Then plenty of practice. Ted
newbie with a badger 200-3
tedtaylor replied to steveo3002's topic in AirbrushesThe Badger 200 is one of the best airbrushes for modellers even with 14 inch cars. Your big problem is learning to spray gloss paint, first you need the paint very thin and as you will need the needle fairly wide open for a model that size you will need a mask and good ventilation. you need to mount the body shell on an old wire coat hanger so you can handle the model while spraying, lay on very thin layers in a room with a temperature of 65-75 degrees and by the time you have the first coat on, where you started will be ready for a second coat. You will need to practice a lot to get it right so don't be dissappointed at your first try. PS keep your air pressure down to 20-25 PSI max Ted
F-111E differences with F-111F's?The F-111-F had different exhausts and I think Neil made them in his range of Paragon stuff I used them on my model when they first came out. http://tedtaylor.hobbyvista.com/75-academy...11/page-75.html Ted
S-3 Viking ColoursSpence it is one of the easiest airplanes to paint if you have a grey over white scheme then everything underneath is white including the legs et al so assemble all them first then spray tops of control surfaces and then underside then flop the grey over the top areas, nose cones may be different depending on which machine you choose. on the other hand you may use an allover grey scheme, again easy peasy. Ted
Television Goes Flying
tedtaylor replied to marty_hopkirk's topic in Cold WarNo


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The Aung San Suu Kyi Fund for Democracy, Cultures, and Action will be endowed through the University of Louvain. It has two academic affiliations with the institutes with which the Fund's four founders are affiliated: IACCHOS (Institute for the Analysis of Change in Contemporary and Historical Societies) and JUR-I (Institute pour la recherche interdisciplinaire en sciences juridiques, or Institute for Interdisciplinary Research on the Law). The Fund is governed by three main structures, whose composition and competences are stipulated in a set of bylaws:
- The GOVERNING BOARD consisting of the four academic promoters of this program, researchers working in the context of the program, and a representative of the Louvain Foundation. Outside consultants may be included in some or all of the Governing Board's meetings. The Board oversees the Fund's projects, monitors the coherence of its major research orientations, and establishes its working budget. It delegates the day-to-day management of the Fund to an EXECUTIVE COMMITTEE.
- The STEERING COMMITTEE has been appointed in order to ensure that the Fund maintains close ties to the civil society. The members of this Committee will have been selected from civil society organizations or have been selected for their expertise related to the Fund's subject. The Steering Committee discusses the projects undertaken by the Fund with the Governing Board and seeks counsel wherever necessary. Its distinguished members are:
- The EXECUTIVE COMMITTEE, responsible for day-to-day management, consists of the four academic founders, assisted by additional members (full-time researcher engaged by the Fund, administrative assistant, etc.).


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Samsung recently officially lifted the lid on the Galaxy A8, its slimmest smartphone ever at only 5.9 mm. At the unveiling, Samsung said that the smartphone would first be available in China. Now we've learned that South Korea is getting the smartphone as we speak.
The news comes to us courtesy of SammyHub. According to the site, Samsung released the Galaxy A8 on the 24th of July (today) in South Korea. The white and gold colour options will be available via South Korean network operator SKT for the equivalent of around £382.
To recap, the Samsung Galaxy A8 sports a 5.7-inch Super AMOLED screen with a resolution of 1080 x 1920 pixels (pixel density of 386 ppi), a 16-megapixel rear-facing camera with an f/1.9 aperture that allows for high-quality photos in even the poorest light conditions, a 5-megapixel front-facing selfie-centric camera, 16 GB ot 32 GB of internal storage, a microSD card slot (as much as 128 GB), a Qualcomm Snapdragon 615 64-bit octa-core processor with cores clocked at 1.5 GHz and an Adreno 405 GPU to handle graphics, 2 GB of RAM, a fingerprint scanner integrated into the home button, and a 3,050 mAh battery to keep the lights on. It runs Android 5.1 (Lollipop) out of the box.
Now that we know the Samsung Galaxy A8 is now available in China and South Korea, the question is, will it be available in other international markets? Keep it here at Phones LTD for further updates.


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6 Vegetables
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