Current RD-ASEP derives the regulatory level based on the certified value without accounting for margin against regulatory values of the certified value. RD-ASEP additionally regulates partial acceleration, unlike current ASEP which only stipulates full-throttle acceleration. It is proposed that RD-ASEP should take into account a margin against the regulatory values of the certification values, similar to current ASEP, to prevent quiet vehicles such as BEVs from being unfairly deemed NG.