Japan tabled document GRRF-75-33. The experts discussed this document as follows:

The group acknowledged that the document does not contain M1 data.

Japan was convinced that even with the minimum figure of fatalities (< 0.5% of total fatalities), as Japan has no intention to mandate LKAS, there will be safety benefits in regulating LKAS with minimum requirements.

OICA then questioned whether the existence of LKAS guidelines would increase the number of LKAS on the road.  OICA stressed that, if the system is not made mandatory, then evidence of the existence of poor systems would justify guidelines/rulemaking. The expert from OICA added that, on the other side, there is no justification for making LKAS mandatory. OICA as a consequence was questioning the motivation for regulating LKAS.

Japan was indeed convinced that the current LKAS are safe, but but was convinced on the need for introducing minimum requirements because there is a fear that the increase of LKAS introduction may make poor systems appear in the market. OICA questioned whether customers would accept such poor systems, i.e. the market would probably self regulate. OICA pointed out that, in addition, UN R79 guarantees minimum limits. The expert from OICA said that a balance must be found
between the limits of the technology and the limits of what the driver is ready to accept, similar to the discussions for AEBS one year ago.

Japan took the example of ESS in R13H, as an if fitted provision and suggested that LKAS could follow the same approach. CLEPA challenged the comparison because LKAS is a CEL system, and informed that, after research, they could not find any road user confusion due to LKAS.

OICA added that some guidelines on ITS do already exist and provide sufficient safety net for LKAS. OICA was of the opinion that no rulemaking should be started on the assumption that poor systems will be introduced in the market.

Japan pointed out having no intention to impose the Japanese guidelines on the ad hoc group. The Republic of Korea was not convinced about LKAS, but found adjustable speed-limiting devices (ASLD) a similar case with minimum requirements. The delegate found necessary to improve UN R79 for correctly covering LKAS.