Proposal for amendments to UN Regulation No. 79
Document GRRF-78-05
27 August 2014

Proposal to introduce a definition and provisions for lane-keeping assist systems (LKAS).

Status: Superseded
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Previous Documents, Discussions, and Outcomes
3. (c) | Clarifications
8. (a) | Vehicle automation

36. The expert from Japan recalled the purpose of GRRF-78-14, presented at the seventy-eighth session of GRRF, proposing the deletion, in some circumstances, of the 10 km/h speed limit for systems operating an Automated Controlled Steering Function. The Chair of GRRF proposed to further discuss this item together with item 9(b) below.

9. (a) | Regulation No. 79
9. (b) | Lane Keeping Assist System (LKAS) and Parking Assist Systems (PAS)
12. (b) | Consolidated Resolution on the Construction of Vehicles (R.E.3)
2. | LKAS

J presented document LKAS-02-02 as the results of the discussions that took place at GRRF-78, where the Chair requested wording improvements, and the status of the system as “ready to intervene”.

NL questioned the case when the system is intervening then the markings disappear, hence the LKAS turns to switched-off status. NL was of the opinion that, in that case, the LKAS should continue warning after it is turned into switched-off status.

CLEPA recalled that the group agreed that the driver is assumed to be monitoring the driving tasks.

OICA presented the OICA input amending GRRF-78-11. This document was amended by the group as follows (changes can be found in document LKAS-02-04):

Paragraph 5.1.6.2.:

  • The European Commission challenged a reference to paragraph 5.1.1., as unnecessary as paragraph 5.1.1. should anyway be fulfilled. The expert nevertheless found the original text clearer than the OICA proposal.
  • A debate took place on the wording “fade out in a progressive manner”:
    • Redundant hence confusing statement (repetition of paragraph 5.1.1.)
    • No time or moment figure available from Industry
    • As the technology is still rather immature for being regulated, J found that general requirements should be preferred to precise figures
    • Yet the OICA proposal refers to figures currently existing in UN R79
    • The system is not designed to work in tight curves, rather in “highway conditions”.
  • J could support the proposal from OICA; yet the expert wanted to ensure whether the Technical Services could assess the system under such wording.

Conclusion paragraph 5.1.6.2.: the group agreed on a final wording (see LKAS-02-04 sent to the group as ECE-TRANS-WP29-GRRF-2015-XXe (LKAS adhoc group) R79 draft LKAS V1).

Paragraph 5.1.6.5.:
NL challenged the wording “in primary control”. A debate took place on this wording:

  • NL keen that the system does not become automatically commanded steering sold as an LKAS, hence suggested that the system gives up control after some time (as requested by the J guidelines).
  • The system can ensure that the driver IS in the loop, yet cannot ensure that the driver IS NOT in the loop; even when all the phisionomical characteristics of the driver are monitored by the system, it cannot guarantee the that the driver is attentive. The driver can have the hands on the steering wheel, be attentive and nevertheless be detected as inattentive because providing no input to the wheel.
  • J informed that the J guidelines do leave the door open to future detection technology. J is keen not to prevent any future technology.
  • OICA raised the case of a system detecting driver’s drowsiness w/o driver’s hands surveillance, e.g. by monitoring the number of LKAS interventions. Some systems use the intervention as a part of the warning and of the detection. OICA was keen that such basic systems are not prohibited.
  • Limited duration of LKAS operation was challenged:
    • Would jeopardise sophisticated systems
    • Would not prevent from misuse
    • Current manual steering systems also do not prevent the driver to leave the steering wheel
    • The nature of the function is that it is non-continuous, but is designed to function with no time limit.
  • J proposed to accept the SDG original text, because the proposal from OICA could not make unanimity. Question about whether the key critrerion is the misuse or the driver’s inattention.
    • Manufacturers: the target is to address misuse and overreliance generated by the system, rather than monitoring driver’s attention in all situations. The latter would be a much wider scope than only LKAS. OICA was of the opinion that the group should focus on the effect of LKAS only.
    • Contracting Parties: driver’s inattention (a regulation never prevents foolish drivers from having strange behaviours)

NL and the representative of the European Commission proposed the following wording:
“5.1.6.5. The system Lane Keeping Assistance System shall have at least 1 type of means to detect driver attention e.g. by sensing the driver’s hands on the steering wheel. When the system is available and detects inattention of the driver, it shall give an effective warning, which shall be at least two means out of optical, acoustic and appropriate haptic, until the driver is attentive again.”

OICA and CLEPA challenged this wording as it would generate a lot of unwanted alarms in the vehicles. The wording would lead to a detection system, i.e. covering a far more extended scope than LKAS.

After subsequent discussions, the group arrived to the following conclusion: Process:

  • Secretary to send to Contracting Parties and Industry OICA approach text with the 3 options
  • All to answer with their preferred option to Secretariat before 15 November 2014
  • Secretariat to table official document to GRRF-79 as an official document with the 3 options
  • Final decision to be done by the group at its next meeeting on 16-17 December at the European Commission.

3. | Automatically controlled steering function (ACSF)

J presented the document LKAS-02-05, proposing amendments to GRRF-78-14 for introduction of ACSF provsions into UN R79.

3. (b) | Explanation of GRRF-78-14

The European Commission welcomed LKAS-02-05 as automatic driving is a subject that is currently discussed at EU level, yet found that the subject goes a bit beyond the usual Type Approval regulations.
CLEPA also welcomed the document
OICA presented a short PPT presentation on lane changing maneuvre on highways. The driver must voluntarily activate the system.
OICA supported CLEPA, and supported opening UN R79 to this technology.
NL found the document a good starting point but found necessary to get more precise requirements.
J pointed out that the requirements can be different according to the systems. The expert recalled that the aim is to maintain road safety via an “if fitted” regulation. He acknowledged that this proposal mainly provides design requirements.

The Chair, as S representative, found it a good start: lane keeping and lane changing system.
J found lane changing assist a very important system and was keen to put the necessary resources to provide the relevant requirements, primarily focusing on highway situation. The expert wondered whether such system, in particular for emergency lane change, are covered by the Vienna Convention.
OICA made the comparison with ESP, where the driver must provide an input, but the system intervenes only when the driver cannot anymore master the situation. Concerning the text, OICA found the structure improved compared to the document presented at GRRF-78, e.g. regarding the modified definition of Automatically Commanded Steering Function
The secretary pointed out that there is a need to open the regulation for permitting the Industry to start designing the technology.
CLEPA found the proposal wise as restricted to certain use cases, and the expert was of the opinion that the regulation could evolve in the future with the evolution of the technology.
OICA informed that regins do not have the limitation of 10km/h and that there is a need that the UN region can take profit of the new technologies. The expert voiced that UNECE should not be left behind, but should rather open up to such new technologies, with appropriate requirements to ensure safety.

The group went through LKAS-02-03 document.

Paragraph 5.1.6.2.4. (b):
- The group convened that the transient from auto mode to manual mode is a key to the system safety. As there is a need for a certain time, J found the 2 seconds a minimum. There is a need also to find a consensus wording avoiding different interpretations. Yet the different situations should be taken into account, and there is no guarantee that the system can predict the future such in advance.
- There was a debate about the origin of the 2-second value, in comparison of the limits adopted at AEBS. Some experts indeed feared that the 2-seconds requirement is too demanding.
- Other case: degraded mode
- Sub-paragraph (b) in J approach was clarified: it addresses both fault and non-fault conditions; while (b) in CLEPA approach only addresses non-fault conditions (fault conditions are addressed in sub-paragraph (c) ).

Paragraph 5.1.6.2.4. (c):
- Agreed that the CLEPA proposal addresses the fault conditions

Paragraph 5.5.2.
- OICA informed having very much challenges with regard to PTI and OBD, and suggested that this PTI item is extracted from AEBS up-to-date regulation.
- J was keen to explain a proposal for OBD.
- NL supported a text aligned on that of AEBS, having no connector, rather a simple warning lamp. The delegate insisted that PTI should remain a quick and simple check.
- CLEPA challenged as well the Japanese approach: no standardized connector, data, protocols, etc.
- The European Commission informed about high probability that the EU requires an OBD-X (safety related OBD)

3. (b) | Automated Connections between Vehicles ( ACV)
9. (a) | Regulation No. 79 (Steering equipment)
9. (b) | Lane Keeping Assist System (LKAS) and Parking Assist Systems (PAS)

42. The expert from Sweden presented GRRF-78-43, supporting GRRF-78-05 submitted by the LKAS small drafting group, introducing definitions and related LKAS requirements in to UN Regulation No. 79. The expert from OICA introduced GRRF-78-11 amending GRRF‑78‑05 and revising the warning requirements for the driver in the case that their attention to the task of steering could not be assured. GRRF agreed to resume discussion at its February 2015 session based on revised proposals.

43. The experts from Japan and Sweden presented GRRF-78-14 amending UN Regulation No. 79 aimed at (i) starting a discussion on the removal of the speed limitation for the Automatically Commanded Steering Function, (ii) introducing safety functions such as warnings and (iii) introducing On-Board Diagnostics (OBD) requirements permitting to verify the correct operational status of Electronic Systems assisting the steering. A number of GRRF experts considered some of those requirements to be design-restrictive. The Chair noted that the proposal was beyond the usual mandate of GRRF and he announced his intention to seek the guidance of WP.29 at its November 2014 session.

44. GRRF requested the secretariat to keep GRRF-78-14 as a reference document on the agenda, inform the IWG on ITS about this proposal and distribute GRRF-78-05 with an official symbol for consideration at the next GRRF session.

Related and Previous Documents
GRRF-78-11
GRRF-78-14
GRRF-78-43
LKAS-02-02
GRRF/2015/2
Relates to LKAS | UN R79 |