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● TRAFFIC MANAGEMENT CENTERS ● WIRELESS COMMS ● NHTSA AND V2V ● INTRODUCING IR2B
™
™
TheintelligentchoiceforITS
TECHNOLOGY
Will governments give the
go-ahead to the evolution of
driverless transportation? p34
TRAFFIC INFORMATION
Bernie Wagenblast reports after
spending the past four decades
in traffic, p44
TRAVEL INFORMATION
How Arapahoe County,
CO, innovated itself out of a
potentially sticky situation, p38
STATE FOCUS
The past, present and
dazzlingly bright future
of ITS Florida, p48
thinkinghighways.com
Volume 9 Number 1 March/April 2014
thinkinghighways.com
NORTH AMERICA
EDITION
INTELLIGENT TRANSPORTATION SYSTEMS AND ADVANCED TRAFFIC MANAGEMENT
UNDER DEVELOPMENT
OR UNDERDEVELOPED?
How do you measure the progress
of ITS, asks David Pickeral
SMART MOBILITY
Is vehicle transportation
really getting smarter?
Guy Fraker investigates
Paul Hutton on what’s possible (and what’s not)
in the realm of smart safety solutions
A SAFER FUTURE
Smart Safety Solutions
documentary available NOW!
PLUS: Listen to our range of podcasts!
documentary available NOW!
Podcast LISTEN NOW AT
thinkinghighways.com/podcasts
thinkinghighways.com24 Vol 9 No 1 North America
OPINION PIECE Implementation
A
s the Smarter Transportation community world-
wide prepares to convene once again in North
America for the 21st World Congress on Intelligent
Transportation Systems in September, it is appropriate to
take stock of what has happened in the past few years since
the Orlando ITS WC. Since then, the
global economy has by most measures
improved. The transportation com-
munity – aided by social networking,
wikis, crowdsourcing and other inter-
active media – has become increas-
ingly focused on understanding and
planning the enhancements that must
be made to ensure ongoing viability
and sustainability.
Most importantly, operators under-
stand more than ever what is needed
to bring about the convergence of physical and digital infra-
structure that will be essential to optimize networks both
collectively and individually, greatly supported by a regula-
tory climate that fosters innovation.
The February decision by the US Department of
Transportation’s National Highway Traffic Safety
Administration (NHTSA) requiring that passenger vehi-
cles built after 2015 must incorporate connected vehicle
technology1
is indicative of that climate. NHTSA’s action
underscores that we have every reason to be optimistic
that the framework is in place for real – and positive
– change.
Yet ours is and will ever remain an industry enam-
ored of gadgetry, and this does not
always serve us, or our constituen-
cies, well.
All too often, technologies are
developed, procured and deployed
in isolation, or, far worse, redun-
dancy. We can not afford another
cycle of the proprietary stovepipe
or siloed technologies that were
essential to incentivize first gen-
eration deployment of ATMS, ETC
and AFC systems over the past two
decades, but which would be a significant bar to progress
going forward.
Fundamentally, then, what is the true measure of progress
in ITS development?
“Ours is and will ever
remain an industry
enamored of gadgetry,
and this does not always
serve us, or our
constituencies, well”
NOTE
1 http://icsw.nhtsa.gov/safercar/ConnectedVehicles
“Do what you can, with what you have, where you are.” So said
Theodore Roosevelt (1858-1919), 26th President of the
United States and 120 years later his words still ring true when
you apply them to the global ITS efforts, says David E Pickeral
Defining development
Destination Detroit: the ITS community
is due to descend on North America
for the first time since 2011
WHAT DOES PROGRESS LOOK LIKE?
This point is worth exploring in detail. Terms like cloud,
analytics, virtualization and of course Big Data are pop-
ping up everywhere in transportation planning. Much of
the traveling population now grasps the potential of better
and more customized information to enhance their experi-
ence – and welcome its availability. This is a good, even great,
development for those of us who have followed the fortunes
of ITS for multiple decades. However, it requires focused
and appropriate application at every phase of the process to
ensure this is properly channeled into technology selection
choices that stand the test of time.
The good news here is that being disruptive need not
offer a lot of disruption. Despite sending a clear message
that progress must be made, the NHTSA ruling recognizes
this, and acknowledges the reality that, more so than ever
before, industry, citizens and government at all levels are
collaboratively leading the process to find solutions that
are cost effective and both backward and forward compat-
ible. That is a significant positive indicator of progress, but
it is only part of the equation in defining the real state of
development.
INTELLIMOBILITY
ITS (an overused acronym, with its main redeeming char-
acteristic being less labored than ‘IVHS’ or others that came
before it) and telematics emerged as parallel but distinct dis-
ciplines. The former grew up along the roadside with and the
latter’s lineage in V2X systems developed by OEMs. Now, the
distinction is blurred as in-vehicle systems become increas-
ingly connected to the ICT ecosystem at large, and in-vehicle
systems (along with personal mobile devices and an expo-
nentially growing array of sensors of all types) provide an
increasingly robust stream of data for roadside-and-beyond
thinkinghighways.com 25North America Vol 9 No 1
Implementation
“The distinction between ITS and telematics is blurred as in-vehicle
systems become increasingly connected to the ICT ecosystem at
large, and in-vehicle systems provide an increasingly robust stream
of data for roadside-and-beyond systems to analyze”
The US Department of Transportation is requiring
all passenger vehicles built after 2015 to
incorporate connected vehicle technology
systems to analyze. Even in 2014, one wonders whether
these are really separate environments at all, to which I
would offer the rejoinder: does it matter anymore?
Call it ‘IntelliMatics,’ or perhaps better yet (to underscore it
is not just about cars) ‘IntelliMobility.’ This connectivity con-
tinues to evolve organically, both from technologists pressing
forward and end users working backward, taking advantage
of the ability of mobile devices and their networks to inter-
connect and interact through the benefit of open standards.
At this point ICT very well emulates a much older system of
systems: plumbing. How many bits and bytes can be moved
from one location to another; what is disposed of, recycled,
treated and otherwise and processed along the way; who
needs what sized pipe; how is contamination avoided or mit-
igated; and where in all of this process does storage, control,
apportionment and ownership take place?
While this model appears simplistic, it allows us to get
back at the root question here—understanding the state of
development. Just as human society evolved (sometimes
with fits and starts) from single household wells and privies
in the backyard to a largely transparent system of hydration
and sanitation, so too must the progress of ITS be measured
not from the metrics of the overlay of the entire transporta-
tion ecosystem it represents but as an aggregate of individual
success stories—literally one traveler at a time.
COLLABORATION OVER CONSTRUCTION
While self-driving cars, Magnetic Levitation trains, and per-
sonal rapid transit vehicles and systems are now a reality, they
are for now niche markets for limited deployment and care-
ful study in the places where resources can support them.
Public and private sector leaders recognize that in serving
worldwide travelers, there is a lot of work to do before ubiq-
uitous deployment of these and other “wow-factor” technol-
ogies. Deployment of less glamorous, but absolutely essential
technologies is what has to happen in between.
Making the One Traveler vision a reality hinges on an
acceptance that what is doable is always the more straight-
forward than how. This admittedly obtuse point is perhaps
best illustrated by two anecdotes from my own experience in
my previous life as a management consultant:
Several years ago on an assignment for a major inter-
national development bank I was working with a former
state-owned post transport and telecommunications agency
(PTT) that had recently been privatized. The objective start-
ing out was to help the PTT expand—institutionally and
technologically—from an analog public switched telephone
(PSTN) network to a more modern service provider offer-
ing digital ICT services. As part of the assessment process,
local ICT entrepreneurs were sought out to determine what
they had already put in place. The discovery was – quite a lot.
They had started very modestly with interlinking internet
cafes and personal WAN/PAN systems to create the initial
notes of the system. Then between satellite earth stations,
microwave hops, and selectively deployed new fiber rings,
these entrepreneurs had cobbled together a very effective,
interlinked, IP-based communication network within and
between these nodes. As my portion of the engagement con-
cluded, dialogue had just started about how the PTT’s huge
customer base and operating authority combined with the
latest technology and thinking that the entrepreneurs had
quietly brought in through the back door could be combined
in a mutually beneficial yet still competitive environment.
Sporadic updates I get to this day from friends on the ground
there remain encouraging.
A few years later, I was working in a highly developed
Western European country developing the business model
for a new state-of-the art RUC system. A significant – and
very expensive – part of the project requirement involved
the deployment of dedicated fiber to connect the charging
points, back office, transactions clearing, control center, etc.
In exploring our options, the project team made a call on
the local commercial ICT service providers. It soon devolved
that one of them, desirous of putting in as much capacity as
possible for the expense of excavating its right-of-way, had
installed a significant amount of dark fiber that was ready
and waiting under the streets to support the new RUC
scheme. As we calculated the cost of long-term leases versus
from-scratch deployment, the reduction of this project cost
was tremendous, realizing huge savings for the scheme oper-
ator as well as rewarding the ICT provider for its foresight.
These two stories illustrate the single most impor-
tant aspect of this industry: The ambient state of available
thinkinghighways.com26 Vol 9 No 1 North America
The revamped Cobo Center in Detroit, MI, venue
for the 2014 ITS World Congress
technology should never be guesswork and it is always worth
time – sometimes surprisingly little time – to take stock of
what is really there. Both transport and ICT resources are
always there in some form, from 30-year old transit buses
to dark fiber loops and from buried copper strands to brand
new LTE mobile networks and devices perhaps just shipped
in by Amazon and unloaded at the airport this morning.
Likewise, there are smart, forward-thinking people all over
the world, and in every community, who are deeply involved
and highly committed to mobility. There are Jitney drivers
with no formal education but an intimate knowledge of their
communities, and where their passengers are, and want to
go. There are university research departments with tireless
PhD candidates building algorithms to synthesize petabytes
of data into comprehensible information sets as part of a doc-
toral thesis.
Leveraging all this talent and all these resources may not be
easy at least at first (hint: open meetings, forums, and collab-
oration sites erring on the side of inclusion with egos checked
at the door is a good start!) but dividends can immeasurably
outweigh the cost. To the extent that lead stakeholders, be
they government, industry or citizens, are willing to step
up as a clearinghouse of sorts, by gathering information,
facilitating partnerships, and above all providing a means to
compile data and turn it into real, useful information – all
without (yet) laying down, a single meter of fiber, track, run-
way or roadway, or building a single new vehicle.
In the end, all of the regulatory decisions, ambitious
enhancement projects, industry rollouts and global initia-
tives come down to that one metric—the aggregate and indi-
vidual impact on the individual journey-taker, anywhere
in the world, through the routes they travel and the modes
they have, and with the devices they carry in or outside the
vehicle. Now. It is the synthesis of those real time adjustments
and Five Year Plan enhancements by which the true degree of
development is ascertained.
THE NECESSITY OF REINVENTION
The experience of the ITS community over the past two dec-
ades has underscored the need to bring about fundamental
institutional change to the industry rather than rely on a
series of disparate one-off use cases. As suggested previously,
the change stems from an ability to combine resources and
galvanize opinions to meet critical needs—of reinvention by
necessity.
Since Orlando, ITS in North America has seen tremen-
dous innovation along these lines. ITS America, through the
Leadership Circle initiative launched last year, has provided a
unique forum that synthesizes both government and indus-
try both to provide their unique perspectives as well as pro-
vide a common synthesis for action.
ITS Canada has evolved significantly under the three year
leadership of Carl Kuhnke in bringing together industry,
national, provincial and local thought leadership. In both
cases – as well as through the initiatives of ERTICO, ITS
Asia-Pacific and ITS organizations worldwide – a culture
that facilitates collaboration over duplication has emerged,
and taken hold with a vengeance. When the 21st ITS WC
convenes in September, it will see a larger, more efficient and
better prepared ITS community than has ever been known.
The next important element in the collaboration will
be through better modal integration. As an advocate and
practitioner in the area of urban transport, I will attend
the American Public Transportation’s triennial Expo in
Houston, Texas a month after the ITS WC, and am looking
forward to seeing how what I know has been an ongoing
dialogue with the ITS community will shape the informa-
tion agenda of this industry. I am likewise looking for-
ward to see how the thinking of tolling, highway, port and
airport communities continues to coalesce implementing
their information strategies that gives real operational
context to the buzz words.
thinkinghighways.com 27North America Vol 9 No 1
“TheexperienceoftheITScommunityoverthepasttwodecadeshas
underscoredtheneedtobringaboutfundamentalinstitutionalchangeto
theindustryratherthanrelyonaseriesofdisparateone-offusecases”
||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
 David Pickeral is Transportation Sector Lead for
the IBM Industry Smarter Solutions Team based in
Reston, Virginia, USA.
 depicker@us.ibm.com
 www.linkedin.com/in/pickeral
So how far has the industry progressed since the last time
the US hosted the ITS World Congress in Orlando, 2011?
Implementation

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TH 4-14 - Development

  • 1. ● TRAFFIC MANAGEMENT CENTERS ● WIRELESS COMMS ● NHTSA AND V2V ● INTRODUCING IR2B ™ ™ TheintelligentchoiceforITS TECHNOLOGY Will governments give the go-ahead to the evolution of driverless transportation? p34 TRAFFIC INFORMATION Bernie Wagenblast reports after spending the past four decades in traffic, p44 TRAVEL INFORMATION How Arapahoe County, CO, innovated itself out of a potentially sticky situation, p38 STATE FOCUS The past, present and dazzlingly bright future of ITS Florida, p48 thinkinghighways.com Volume 9 Number 1 March/April 2014 thinkinghighways.com NORTH AMERICA EDITION INTELLIGENT TRANSPORTATION SYSTEMS AND ADVANCED TRAFFIC MANAGEMENT UNDER DEVELOPMENT OR UNDERDEVELOPED? How do you measure the progress of ITS, asks David Pickeral SMART MOBILITY Is vehicle transportation really getting smarter? Guy Fraker investigates Paul Hutton on what’s possible (and what’s not) in the realm of smart safety solutions A SAFER FUTURE Smart Safety Solutions documentary available NOW! PLUS: Listen to our range of podcasts! documentary available NOW! Podcast LISTEN NOW AT thinkinghighways.com/podcasts
  • 2. thinkinghighways.com24 Vol 9 No 1 North America OPINION PIECE Implementation A s the Smarter Transportation community world- wide prepares to convene once again in North America for the 21st World Congress on Intelligent Transportation Systems in September, it is appropriate to take stock of what has happened in the past few years since the Orlando ITS WC. Since then, the global economy has by most measures improved. The transportation com- munity – aided by social networking, wikis, crowdsourcing and other inter- active media – has become increas- ingly focused on understanding and planning the enhancements that must be made to ensure ongoing viability and sustainability. Most importantly, operators under- stand more than ever what is needed to bring about the convergence of physical and digital infra- structure that will be essential to optimize networks both collectively and individually, greatly supported by a regula- tory climate that fosters innovation. The February decision by the US Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) requiring that passenger vehi- cles built after 2015 must incorporate connected vehicle technology1 is indicative of that climate. NHTSA’s action underscores that we have every reason to be optimistic that the framework is in place for real – and positive – change. Yet ours is and will ever remain an industry enam- ored of gadgetry, and this does not always serve us, or our constituen- cies, well. All too often, technologies are developed, procured and deployed in isolation, or, far worse, redun- dancy. We can not afford another cycle of the proprietary stovepipe or siloed technologies that were essential to incentivize first gen- eration deployment of ATMS, ETC and AFC systems over the past two decades, but which would be a significant bar to progress going forward. Fundamentally, then, what is the true measure of progress in ITS development? “Ours is and will ever remain an industry enamored of gadgetry, and this does not always serve us, or our constituencies, well” NOTE 1 http://icsw.nhtsa.gov/safercar/ConnectedVehicles “Do what you can, with what you have, where you are.” So said Theodore Roosevelt (1858-1919), 26th President of the United States and 120 years later his words still ring true when you apply them to the global ITS efforts, says David E Pickeral Defining development Destination Detroit: the ITS community is due to descend on North America for the first time since 2011
  • 3. WHAT DOES PROGRESS LOOK LIKE? This point is worth exploring in detail. Terms like cloud, analytics, virtualization and of course Big Data are pop- ping up everywhere in transportation planning. Much of the traveling population now grasps the potential of better and more customized information to enhance their experi- ence – and welcome its availability. This is a good, even great, development for those of us who have followed the fortunes of ITS for multiple decades. However, it requires focused and appropriate application at every phase of the process to ensure this is properly channeled into technology selection choices that stand the test of time. The good news here is that being disruptive need not offer a lot of disruption. Despite sending a clear message that progress must be made, the NHTSA ruling recognizes this, and acknowledges the reality that, more so than ever before, industry, citizens and government at all levels are collaboratively leading the process to find solutions that are cost effective and both backward and forward compat- ible. That is a significant positive indicator of progress, but it is only part of the equation in defining the real state of development. INTELLIMOBILITY ITS (an overused acronym, with its main redeeming char- acteristic being less labored than ‘IVHS’ or others that came before it) and telematics emerged as parallel but distinct dis- ciplines. The former grew up along the roadside with and the latter’s lineage in V2X systems developed by OEMs. Now, the distinction is blurred as in-vehicle systems become increas- ingly connected to the ICT ecosystem at large, and in-vehicle systems (along with personal mobile devices and an expo- nentially growing array of sensors of all types) provide an increasingly robust stream of data for roadside-and-beyond thinkinghighways.com 25North America Vol 9 No 1 Implementation “The distinction between ITS and telematics is blurred as in-vehicle systems become increasingly connected to the ICT ecosystem at large, and in-vehicle systems provide an increasingly robust stream of data for roadside-and-beyond systems to analyze” The US Department of Transportation is requiring all passenger vehicles built after 2015 to incorporate connected vehicle technology
  • 4. systems to analyze. Even in 2014, one wonders whether these are really separate environments at all, to which I would offer the rejoinder: does it matter anymore? Call it ‘IntelliMatics,’ or perhaps better yet (to underscore it is not just about cars) ‘IntelliMobility.’ This connectivity con- tinues to evolve organically, both from technologists pressing forward and end users working backward, taking advantage of the ability of mobile devices and their networks to inter- connect and interact through the benefit of open standards. At this point ICT very well emulates a much older system of systems: plumbing. How many bits and bytes can be moved from one location to another; what is disposed of, recycled, treated and otherwise and processed along the way; who needs what sized pipe; how is contamination avoided or mit- igated; and where in all of this process does storage, control, apportionment and ownership take place? While this model appears simplistic, it allows us to get back at the root question here—understanding the state of development. Just as human society evolved (sometimes with fits and starts) from single household wells and privies in the backyard to a largely transparent system of hydration and sanitation, so too must the progress of ITS be measured not from the metrics of the overlay of the entire transporta- tion ecosystem it represents but as an aggregate of individual success stories—literally one traveler at a time. COLLABORATION OVER CONSTRUCTION While self-driving cars, Magnetic Levitation trains, and per- sonal rapid transit vehicles and systems are now a reality, they are for now niche markets for limited deployment and care- ful study in the places where resources can support them. Public and private sector leaders recognize that in serving worldwide travelers, there is a lot of work to do before ubiq- uitous deployment of these and other “wow-factor” technol- ogies. Deployment of less glamorous, but absolutely essential technologies is what has to happen in between. Making the One Traveler vision a reality hinges on an acceptance that what is doable is always the more straight- forward than how. This admittedly obtuse point is perhaps best illustrated by two anecdotes from my own experience in my previous life as a management consultant: Several years ago on an assignment for a major inter- national development bank I was working with a former state-owned post transport and telecommunications agency (PTT) that had recently been privatized. The objective start- ing out was to help the PTT expand—institutionally and technologically—from an analog public switched telephone (PSTN) network to a more modern service provider offer- ing digital ICT services. As part of the assessment process, local ICT entrepreneurs were sought out to determine what they had already put in place. The discovery was – quite a lot. They had started very modestly with interlinking internet cafes and personal WAN/PAN systems to create the initial notes of the system. Then between satellite earth stations, microwave hops, and selectively deployed new fiber rings, these entrepreneurs had cobbled together a very effective, interlinked, IP-based communication network within and between these nodes. As my portion of the engagement con- cluded, dialogue had just started about how the PTT’s huge customer base and operating authority combined with the latest technology and thinking that the entrepreneurs had quietly brought in through the back door could be combined in a mutually beneficial yet still competitive environment. Sporadic updates I get to this day from friends on the ground there remain encouraging. A few years later, I was working in a highly developed Western European country developing the business model for a new state-of-the art RUC system. A significant – and very expensive – part of the project requirement involved the deployment of dedicated fiber to connect the charging points, back office, transactions clearing, control center, etc. In exploring our options, the project team made a call on the local commercial ICT service providers. It soon devolved that one of them, desirous of putting in as much capacity as possible for the expense of excavating its right-of-way, had installed a significant amount of dark fiber that was ready and waiting under the streets to support the new RUC scheme. As we calculated the cost of long-term leases versus from-scratch deployment, the reduction of this project cost was tremendous, realizing huge savings for the scheme oper- ator as well as rewarding the ICT provider for its foresight. These two stories illustrate the single most impor- tant aspect of this industry: The ambient state of available thinkinghighways.com26 Vol 9 No 1 North America The revamped Cobo Center in Detroit, MI, venue for the 2014 ITS World Congress
  • 5. technology should never be guesswork and it is always worth time – sometimes surprisingly little time – to take stock of what is really there. Both transport and ICT resources are always there in some form, from 30-year old transit buses to dark fiber loops and from buried copper strands to brand new LTE mobile networks and devices perhaps just shipped in by Amazon and unloaded at the airport this morning. Likewise, there are smart, forward-thinking people all over the world, and in every community, who are deeply involved and highly committed to mobility. There are Jitney drivers with no formal education but an intimate knowledge of their communities, and where their passengers are, and want to go. There are university research departments with tireless PhD candidates building algorithms to synthesize petabytes of data into comprehensible information sets as part of a doc- toral thesis. Leveraging all this talent and all these resources may not be easy at least at first (hint: open meetings, forums, and collab- oration sites erring on the side of inclusion with egos checked at the door is a good start!) but dividends can immeasurably outweigh the cost. To the extent that lead stakeholders, be they government, industry or citizens, are willing to step up as a clearinghouse of sorts, by gathering information, facilitating partnerships, and above all providing a means to compile data and turn it into real, useful information – all without (yet) laying down, a single meter of fiber, track, run- way or roadway, or building a single new vehicle. In the end, all of the regulatory decisions, ambitious enhancement projects, industry rollouts and global initia- tives come down to that one metric—the aggregate and indi- vidual impact on the individual journey-taker, anywhere in the world, through the routes they travel and the modes they have, and with the devices they carry in or outside the vehicle. Now. It is the synthesis of those real time adjustments and Five Year Plan enhancements by which the true degree of development is ascertained. THE NECESSITY OF REINVENTION The experience of the ITS community over the past two dec- ades has underscored the need to bring about fundamental institutional change to the industry rather than rely on a series of disparate one-off use cases. As suggested previously, the change stems from an ability to combine resources and galvanize opinions to meet critical needs—of reinvention by necessity. Since Orlando, ITS in North America has seen tremen- dous innovation along these lines. ITS America, through the Leadership Circle initiative launched last year, has provided a unique forum that synthesizes both government and indus- try both to provide their unique perspectives as well as pro- vide a common synthesis for action. ITS Canada has evolved significantly under the three year leadership of Carl Kuhnke in bringing together industry, national, provincial and local thought leadership. In both cases – as well as through the initiatives of ERTICO, ITS Asia-Pacific and ITS organizations worldwide – a culture that facilitates collaboration over duplication has emerged, and taken hold with a vengeance. When the 21st ITS WC convenes in September, it will see a larger, more efficient and better prepared ITS community than has ever been known. The next important element in the collaboration will be through better modal integration. As an advocate and practitioner in the area of urban transport, I will attend the American Public Transportation’s triennial Expo in Houston, Texas a month after the ITS WC, and am looking forward to seeing how what I know has been an ongoing dialogue with the ITS community will shape the informa- tion agenda of this industry. I am likewise looking for- ward to see how the thinking of tolling, highway, port and airport communities continues to coalesce implementing their information strategies that gives real operational context to the buzz words. thinkinghighways.com 27North America Vol 9 No 1 “TheexperienceoftheITScommunityoverthepasttwodecadeshas underscoredtheneedtobringaboutfundamentalinstitutionalchangeto theindustryratherthanrelyonaseriesofdisparateone-offusecases” ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||  David Pickeral is Transportation Sector Lead for the IBM Industry Smarter Solutions Team based in Reston, Virginia, USA.  depicker@us.ibm.com  www.linkedin.com/in/pickeral So how far has the industry progressed since the last time the US hosted the ITS World Congress in Orlando, 2011? Implementation