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Proposal to explain para. 8.3.3.1.1. The revised text clarifies that relevant standards supporting the assessment of laboratories could include ISO/IEC 17025 Testing and calibration laboratories, which sets requirements for competence, impartiality, and consistent operation. Applied to ADS testing, it ensures measurements are traceable, validated, and reproducible so results are technically reliable and defensible for approval/certification purposes. However, there is no obligation for the manufacturer or third-party organization involved in the testing to be accredited according to ISO/IEC 17025.
Proposal to explain para. 8.3.2.4.1.4. The revised text divides guidance between ADS users and other road users. For ADS users, representativeness means including a range whose behaviours, skills, and characteristics reflect those reasonably expected to use the ADS, with testing not limited to engineers. For other road users, representativeness means capturing a sufficiently broad range of real-world behaviours and characteristics relevant to the ODD. The revised proposal also addresses statistical significance, encouraging manufacturers to provide calculations explaining their choice of participant numbers and underlying assumptions.
Proposal to explain paragraph 8.3.2.1.2. The revision clarifies that coverage can be evaluated based on the following items and their interdependencies: Operational Environment, Behavioural competency, Scenario-type/category, and Rules of road compliance. A footnote acknowledges that no single item alone can robustly document coverage.
Proposal to explain para. 7.3.2.14. The revised text simplifies the definition of ‘sufficient’ to refer to the scope of tests performed on the fall-back response. With respect to scenarios, the manufacturer is encouraged to describe reasoning behind scenario choice and justification for the overall number chosen, acknowledging that scenario diversity depends on intended use case and operational design domain. References to user numbers and statistical methods for sample size assessment have been removed.
Proposal to replace “multiple separate light sources” with “multiple light sources” in the provision governing rear position lamps reciprocally incorporated with stop lamps.
Proposal to introduce Automated Driving System (ADS) requirements into the Regulation and correct figures in Appendix 8. The proposal inserts new introductory paragraphs addressing vehicles of categories X and Y equipped with an ADS; amends paragraph 1.3 to include ADS control requirements; inserts new paragraph 2.9.4 on ADS presence; extensively revises paragraph 2.12 on immunity related functions to include ADS-related functions; deletes paragraphs 2.26 and 2.27; inserts new paragraph 2.32 defining “ADS test configuration”
Proposal to amend Paragraph 5.3.1.3 (GTR) / 7.3.1.3 (UNR) in Safety Case. The revision replaces “no new behaviours or traffic flows” with “no new behaviours or traffic flows density or dynamic element types” and adds “or traffic behaviour” to the text regarding traffic laws because ODD does not include a definition of traffic behaviour, making the original sentence factually incorrect.
Proposal to amend paragraph 5.3.1.3 (GTR) / 7.3.1.3 (UNR) in Safety Case. The revised text adds “attributes and their respective values” to replace “parameters” in the sentence about links/dependencies between ODD parameters, to ensure consistent terminology and reflect that dependencies exist not only between attributes but also between their values.
SAE comments on the working document for ADS safety requirements.
Japan comments on the FRAV list of ADS safety discussion topics.
Updated working document integrating comments received as of 6 January 2021.
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