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No person shall install or cause to be installed in or on a motor vehicle and no motor vehicle shall have installed therein or thereon a visual display unit other than a visual display unit that may be installed...
Dear Hon Charles Mok, JP:
We recently acquired a Tesla Model S and learn that its telematics technology has been stripped due to the limitations specified in CAP 374A regulation 37.
I am a long time EV driver and have had 6 BEVs since 1999. The telematics functions in which CAP 374A reg 37 restricted would limit the growth in IT development in Hong Kong. In additions, as one of the many unhappy Model S owners commented "every taxi I have ever seen in HK has a phone mount that violates the above legislation. A smartphone in front of and within reach of the driver violates the law; and that there is no prosecutions for the violation."
I started using telematics system since the purchase of a Nissan LEAF in Feb, 2011. Since then, I purchased two Toyota Rav4-EVs, two Tesla Model Ss. I also test drove many BEVs such as the BMW i3, fiat 500E, Ford Focus EV, Honda Fit EV, Mercedes B-Class ED, Mitsubishi i-MiEV, etc. All of which I drove have telematics which allow broadcasting capability. It has helped me in many ways and have never come across any safety issue.
As ensuring safety on the road is important, not being able to execute/control the situation could make the situation worse. Perhaps allowing web browsing on a "permanently vehicle mounted display" and disallow the use of keypad/trackpad when the vehicle "is not in motion" would have better control. It is because the auto manufacturers have control over enabling/disabling the function when the vehicle is in motion. This way, prohibiting the mounting of telematics/cellular/transmitting devices within reach of driver seats could be easier to spot by prosecutors.
I am writing to request that CAP 374A regulation 37 be re-evaluated so to allow telematics advancement in the auto industry and that safety will still be kept in the top priority.
I can be reached either by email or cell: 5109 xxxx. I will be happy to drive to your office to do show and tell of the telematic system in the Model S.
Best Regards,
From: Michelle Lam <[email protected]>
Subject: Re: Telematic Advancement in HK
Date: September 11, 2014 at 12:52:48 AM PDT
To: [email protected]
Cc: Charles Mok Office <[email protected]>
Dear Waidy,
Thanks for your email. We have reviewed the relevant legislation and will follow-up the issue of restrictions on in-vehicle telematic systems during the coming LegCo year.
If you have any recommendation or examples about similar law amendment elsewhere, please share with us.
Best regards,
Michelle Lam
Research Officer
Office of the Hon Charles Mok, Legislative Councillor (IT)
Room 917, Legislative Council Complex, 1 Legislative Council Road, Central, Hong Kong
Tel: 3758 2616
---------- Forwarded message ----------
From: Waidy Lee <[email protected]>
Date: Tue, Sep 9, 2014 at 10:16 AM
Subject: Telematic Advancement in HK
To: Charles Mok <[email protected]>
Dear Hon Charles Mok, JP:
We recently acquired a Tesla Model S and learn that its telematics technology has been stripped due to the limitations specified in CAP 374A regulation 37.
I am a long time EV driver and have had 6 BEVs since 1999 The telematics functions in which CAP 374A reg 37 restricted would limit the growth in IT development in Hong Kong. In additions, as one of the many unhappy Model S owners commented "every taxi I have ever seen in HK has a phone mount that violates the above legislation. A smartphone in front of and within reach of the driver violates the law; and that there is no prosecutions for the violation."
I started using telematics system since the purchase of a Nissan LEAF in Feb, 2011. Since then, I purchased two Toyota Rav4-EVs, two Tesla Model Ss. I also test drove many BEVs such as the BMW i3, fiat 500E, Ford Focus EV, Honda Fit EV, Mercedes B-Class ED, Mitsubishi i-MiEV, etc. All of which I drove have telematics which allow broadcasting capability. It has helped me in many ways and have never come across any safety issue.
As ensuring safety on the road is important, not being able to execute/control the situation could make the situation worse. Perhaps allowing web browsing on a "permanently vehicle mounted display" and disallow the use of keypad/trackpad when the vehicle "is not in motion" would have better control. It is because the auto manufacturers have control over enabling/disabling the function when the vehicle is in motion. This way, prohibiting the mounting of telematics/cellular/transmitting devices within reach of driver seats could be easier to spot by prosecutors.
I am writing to request that CAP 374A regulation 37 be re-evaluated so to allow telematics advancement in the auto industry and that safety will still be kept in the top priority.
I can be reached either by email or cell: 5109 XXXX. I will be happy to drive to your office to do show and tell of the telematic system in the Model S.
Best Regards,
Waidy Lee
Mok's office replied my email. They are giving me "home work". I will have to do some research. If any one of you have "samples about similar law amendment", or "recommendation", or anything you want to say, please email to Michelle and Charles directly. Since I am not given a "reference number", perhaps anyone who wants to write to them should reference the subject line "Telematic Advancement in HK".
Thanks all for your supports.
Mark, did you have any issues accessing the car via your mobile app after your firmware upgrade? The service centre had upgraded my firmware and now I can't access it via my Android phone.
Nope. No problems for me.
Dear Charles and Michelle: First and foremost, thanks for your attention to this matter.
As the auto industry is moving toward M2M (machine to machine) for self driving and automation, IT remains a critical path for it to succeed. M2M deploys any wireless technologies ranging from Z-wave, ZigBee, Mods, Pulse, 802.11, etc. etc.
In California, live video is the only broadcasting means that is not allowed in the reach of driver. Tesla disabled youtube viewing on web browsing in their cars. I believe this is a federal law. Back seat passengers can watch cartoons (and whine "are we there yet") to their heart's contents at the backseats.
Please see V C Section 27602 Television
(amended 4 times already).
Some of the current "on vehicle IT" are Homelink, navigation, and web browsing; in which are not allowed in HK vehicles.
Homelink is under the jurisdiction of the FCC since that is simply 315MHz consumer band spectral allocation and usage. Anyone can build a transmitter if it’s following the modulation and power restrictions dictated by them. It is not bidirectional communication, just a remotely activated (radio) power switch. No biggie. Gee, those regulations must date back to the 1950’s! .. Homelink has been available for majority of of EVs (electric vehicles) and ICEs (Internal Combustion Engine) for decades. I do not see why Hong Kong dis-allows such technology in the vehicles.
As for Navigation, TomTom and other dash mounted consumer navigation units in which are banned in HK: GPS works world wide. I find that total bunk as forbidden to use inside the vehicle. That should be impetus to change that section of the law.
So the only thing would be web browsing. Many auto makers have started manufacturing automobiles with display in the reach from the driver seat. The most technological telematic display is in the Model S made by Tesla Motors which focus on technology extends from the creation of the car to the car itself. As for the Tesla Model S, it has a 17" screen. Using the Tesla screen is light-years ahead of the screen/button mix that is found in most "high-tech" cars. And since the screen is so big, the "keys on the keyboard" are also larger and more legible and easier to hit while driving. I will have to admit, despite knowing that our eyes belong on the road at all times and should not be typing at the in-car keyboard screens, we all at some point tap away at our cars' keyboard for web browsing. I would suggest Hong Kong would add a provision to allow use of in-vehicle web browsing while the vehicle is not in motion (this is something that the vehicle manufacturers can do). In another word, the keyboard in doing web browsing would be locked while the vehicle is in "drive"/"reverse" mode. [NOTE: This method provides a better control as compares to drivers using their cell phones to tap away their messages or doing web browsing].
Hong Kong is clearly in the early stages of the telematics policy debate. I hope you would find my request for reevaluation is valid and a good approach.
Best Regards,
Dear Waidy,
Thanks for your very detailed information. Charles has raised this issue in a LegCo written question to the government today:
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The government's response shows they have no intention to make changes at the moment.
We will continue to convey your comments to seek re-evaluation from different channels. Thanks!
Best regards,
Michelle Lam
Research Officer
Office of the Hon Charles Mok, Legislative Councillor (IT)