Proposal to improve the text with editorial clarifications and restructuring.

Presentation raising concerns over discrepancies and risks of misinterpretation in the application of the regulation by technical services.

Proposal to clarify the text with regard to:

1. paragraph 2.6., Definition of an imminent collision
2. paragraphs 5.1.9 and 7.1.4., Lifetime of the system
3. paragraph 5.2.3.3., Traffic Rules and Safety Distance to the front
4. paragraph 5.2.5.2. – “anticipated TTC” in cut-in scenario
5. paragraph 6.2.5.1., Deactivation by input to driving controls
6. paragraph 6.2.6., Transition to assisted driving
7. paragraph 6.4.4., Examples of information to the driver
8. Annex 5 – Tests
   • Section 5.1. contains physical tests that have to be performed at the time of type approval
   • Section 5.2. aims to confirm at the time of type approval, that the system complies with the corresponding provisions of the main text. This confirmation shall be done by at least one physical test per provision, if possible due to the nature of the provision, and may be supported by further evidence.
   • Section 5.3. is a collection of additional scenarios, that the ALKS could encounter. Whether they are relevant to the ALKS depends on its ODD. So either the manufacturer explains why his system will not need to handle these scenarios, or has to explain the behaviour of the ALKS.
   • larify the content of par. 5.2. by rewording the provisions similar to that of the core text.

Proposal to address risks related to activities other than driving and to clarify that a declaration of a maximum operational speed that exceeds 60 km/h is possible, but not required.

Proposal to amend the proposal from Germany regarding lane-change functionality:

1. paragraph 5.2.1. – lane keeping
2. paragraph 5.2.6.1. – risk to safety of the vehicle occupants and other road users
3. paragraphs 5.2.6.2. and 5.2.6.3. – preconditions for a lane change procedure
4. paragraph 5.2.6.5. – timing of a lane change maneuver
5. paragraph 5.2.6.6. and its sub-paragraphs – criticality of a lane change maneuver
6. paragraph 7.1.3. – rear detection range
7. Annex 5. – test cases for rear detection range, lane change.

The proposal aims to correct 5 types of inconsistencies:

1. The reference to Annex 4 is repeated in each sub-paragraph and should instead be stated once in each paragraph.
2. Acronyms are used inconsistently. Proposal to use them consistently throughout similar to UN-R79, e.g. Emergency Manoeuvre (EM), and when used in the text as “emergency manoeuvre”
3. Each sub-paragraph has a heading, this helps understand the structure and should be carried over to par. 8.1., 9.1. and 9.2. as well, the wording for the heading of par. 9.1. and 9.2. are derived from UN-R155 and UN-R156 respectively.
4. Consistent use of term throughout, e.g. R₁₅₇SWIN without blank, Cyber Security as two words as used in UN-R155
5. Editorial corrections, e.g. missing paragraph numbers, missing full stop in the paragraph number.

The intention of the proposed amendment is to clarify the existing text on continued support of an ACSF B1 if the boundary conditions are exceeded.

Proposal to include all vehicle categories M and N in the scope of UN R157.

Under the initial ALKS regulation and its reference to the new cyber security requlation, manufacturers are permitted to use an alternative software identification system instead of the proposed RxSWIN format. This proposal seeks to clarify the use of such alternative identifications in the approval process.

This document was produced during an informal meeting (on 23 September 2020) of interested experts who reviewed the ALKS-related documents presented at GRVA on 24 September 2020.