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OICA comments on the 2018 WP.29 draft programme of work
Document WP.29-174-08/Rev.1
13 March 2018

OICA comments on EDR versus DSSA and on Driver Availability Recognition as well as relationship of automated driving efforts with the 1998 Agreement.

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Previous Documents, Discussions, and Outcomes
2.2. | Coordination and organization of work: Programme of work and documentation

25. The secretariat presented the programme of work with a strategic introduction on the main priorities of the WP.29 work. Top priorities for the work of the World Forum in the field of automated vehicles pave the way for a regulatory framework supporting the introduction of these emerging technologies towards future autonomous vehicles and in electro-mobility to address the challenges of limited fossil fuel resources, environmental protection and climate change. The priorities would include further development in the implementation of the 1958, 1997 and 1998 Agreements, the main horizontal activities and the main topics addressed by the subsidiary bodies of WP.29 (ECE/TRANS/WP.29/2018/1). WP.29 reflected on ways to best allocate resources to efficiently address its priorities. WP.29 invited delegations to prepare positions to make decisions on this allocation for the short and medium term at its 175th session. The delegations of the China, EU, USA, UK, France, Germany, Japan, Korea discussed the pros and cons of the different options for the most appropriate working structure of GRs. The representative of the European Union expressed its preference for the option of keeping 6 GRs which was considered in AC.2 (para. 22). The representative of the United States of America requested more information regarding the responsibilities and tasks of each GR under the respective options (see para 23). The representative of Germany suggested that a good solution would be to pursue the topic under GRRF as an interim solution (see para. 22) under the condition that there will be a dedicated (possibly additional) GR for automated/autonomous vehicles in the medium or long term. The Chair concluded by urging delegations to consider the restructuring and prioritization in good time for the next session and to submit their views to the UK delegate for consolidation for preparing a proposal for decision to be discussed at the June 2018 WP.29 session.

26. WP.29 adopted the programme of work for 2018 based on document ECE/TRANS/WP.29/2018/1.

17. | Exchange of information on new priorities to be included in the programme of work

139. AC.3 resumed discussion on ECE/TRANS/WP.29/2018/34 aimed at providing an overview of the priority of the Programme of Work (PoW) of the development of UN GTRs or amendments to the existing ones.

140. The representative of ETRTO indicated that ECE/TRANS/WP.29/2018/34 was already outdated and suggested that it be amended.

141. The representative from OICA introduced WP.29-174-08/Rev.1 underlining that clarification was needed for the development of a UN GTR on Event Data Recorders (EDR), since EDRs need to be clearly distinguished from Data Storage Systems for Automated Driving (DSSAD), from a regulatory point of view. He explained that in EDRs, data such as vehicle speed, speed reduction, service brake, etc., is only recorded when triggered in the event of an accident, and EDRs can be applicable in conventional and automated vehicles to understand the conditions surrounding an accident. On the other hand, he stated, the DSSAD is necessary to support the vehicle information on automated driving, namely that data stored in these devices reflects whether the automated driving system is on or off, whether there is a transition demand from the system to the driver or does the driver ask the system to take over, does the driver take over, is there a minimum risk manoeuvre being executed, etc. He explained that this data might have to be registered any time and over a period of time in order to trace the behaviour of the autonomous vehicle, in other words whether the driver or the system was responsible for its actions. He emphasized that DSSADs are not relevant for conventional vehicles but only for automated vehicles with levels of automation three, four and five.

142. The representative of OICA also stated that clarification is needed on the priority area identified as Driver Availability Recognition, namely the level of automation that the system would be applicable for, in order to secure consistency with other documents developed in this context that link the system applicability to level three and higher automation.

143. The representative of OICA expressed support for the remaining items of the PoW (ECE/TRANS/WP.29/2018/34), in accordance with the comments provided in WP.29-174-08/Rev.1, except for the Longitudinal Control item, stating that the example given in the PoW refers to systems that are by definition level one, which as such would not require a new regulation to be developed. He noted that if the PoW refers to longitudinal control levels three and above, the issue should be handled under the item Framework Regulation on automated/autonomous vehicles level 3-5.

144. The representative of the European Union presented WP.29-174-18, jointly prepared by Japan and the European Union, which contains the seven priority areas of work on automated driving. The document proposes a distribution of activities among working parties, time horizon for their initiation and/or finalization as well as additional clarifications concerning the tentative steps to be taken.

145. The representative of the United States of America thanked the representatives of Japan and the European Union for their joint efforts to identity additional priorities, with approaches and possible timeframes to initiate the work. She stated that due to the importance of the work identified in the PoW for governments and industry stakeholders, the United States of America would review the document with the proposed regulatory approaches with national stakeholders and provide constructive comments at the next session of the World Forum.

146. Upon request for clarification from the representative of the United States of America, AC.3 experts explained that the “framework regulation” mentioned in the document was intended to contain provisions applicable to automated and autonomous vehicles in the context of both self-certification and type approval systems, supporting harmonization at global level.

147. The Chair of AC.3 proposed to defer discussions on ECE/TRANS/WP.29/2018/34 to the fifty-third session of AC.3, which was scheduled to be held on 20 June 2018, and to develop for that session a document as a basis for further deliberations on the PoW.