Proposal to modify the introductory comments of the LDWS regulation in order to emphasize the focus on highway driving and impracticality of deploying LDWS on certain types of vehicles such as off-road equipment or special purpose vehicles.

Explanation of OICA’s requests to exempt certain vehicles from mandatory AEBS and/or LDWS requirements due to their uses and the technical limitations of these systems. For example, the sensors used by the systems cannot operate reliably on certain special purpose equipment (such as snow plows) where the equipment and the nature of the operating environment are prohibitive.

Proposal to modify the scope of the regulation in order to exempt certain vehicles from mandatory compliance with its provisions in cases where technical obstacles prevent the reliable use of lane-departure warning systems given the current state of the technology. This document includes a detailed explanation of the vehicle categories for exemption.

Proposal to include a footnote in the scope of the regulation alerting type approval authorities to the possibility for exemptions to the lane departure warning systems requirements based upon reasonable technical feasibility, cost/benefit, and/or other evidence. The broad notion is that LDWS is intended to prevent accidents due to inattention while driving long distances, especially on highways. Therefore, vehicles designed for purposes not given to such monotonous long-distance travel should, under this proposal, logically be exempted on a case-by-case basis from LDWS requirements.