Proposal to delete “the examples given below is not the only possible approach,” add clarification that examples are non-comprehensive and represent one possible approach for documenting claims, arguments and evidence, modify example descriptions to point to regulation requirements 5/7.3.3.2 (a) and (b), and incorporate examples from ADS-20-09 by removing the placeholder “Examples to be provided.”
Proposal to remove the placeholder for guidance on expectations concerning mitigation risk condition end states in para. 7.3.1.14. and replace it with text from ADS-20-09 with one paragraph removed based on ADS-20-50. The revised text specifies that while ADS Performance of DDT requirements set out when an MRC is required, they do not specify the process to achieve the MRC or its end state. MRC end states are expected to be fully stopped with parking brake applied and could include activation of hazard lights. The process to reach an MRC is expected to vary depending on the situation and system capabilities, and possible end state examples include stopping in lane, on shoulder, exiting highway, or navigating to nearest parking spot.
Proposal to remove brackets from the ODD paragraph in section 7.3.1.3. The proposal removes square brackets that were included as a result of the ADS-20-46/Rev.3 discussion. The bracketed text addresses scenarios where a new area falls within existing ODD bounds, where deployment in that area might not require ODD modification, and where modifications to the area of operation would not require ODD modification provided conditions and environment in new areas of operation have been considered, but where operation in an area with different traffic laws or behaviour than those for which the ADS’s ability to comply has been demonstrated would require an amendment to the safety case.
Proposal to clarify guidance on reporting of system failures that compromise DDT performance by amending the description of reportable system failures, including modifying language regarding loss of redundancy or reduction in capabilities of ADS features to perform the entire DDT, replacing “failure in an actuator used by the ADS” with “hardware failure that compromises the capability of an ADS feature to perform the entire DDT,” and retaining the existing provision regarding degradation in computational capability.
Proposal to clarify guidance on reporting uncompleted system-initiated deactivations by deleting “i.e.” and “the user has not properly taken over control of the”, inserting “is left to the user,” after “vehicle control”, inserting “An” before “ADS”, inserting “feature” after “ADS”, inserting “, or” after the clause on driving responsibility, and inserting “The user is not properly re-engaged as defined paragraph 4.2/6.2 of the regulation.” as an additional reporting criterion.
Proposal to modify the explanation on performance issues constituting an unreasonable risk to safety by specifying that this occurrence should be understood as deviations, degradations, or performance limitations shown by an ADS feature that affect its ability to perform the DDT within the declared ODD, triggered by events that present an unreasonable risk to safety and/or are beyond expected variability or acceptable degradation, replace “may” with “might” in references to discrete failures and risk existence, replace “Violation of” with “Non-compliance with respect to the”, delete references to identified reduction in safety margins and exceeding overall hazard exposure thresholds, replace “the rate of hazardous event occurrences” with “hazardous event exposure:”, and replace “suggests” with “could suggest”.
Proposal to add an interpretation of the term “other road user” in para. 2.21. of Definitions. The proposal defines “other road user” (ORU) as any entity making use of publicly accessible road infrastructure, covering users making intentional use of roadways with knowledge of traffic rules and other sentient entities that might be found in vehicle paths but cannot be expected to respond predictably based on vehicle signals or traffic rules, such as children and animals. The safety case would address both classes of ORU with appropriate adaptation to account for lower predictability of child and animal behaviours where relevant to the ODD of an ADS feature.
Proposal to add examples to the guidance on reporting noncompliance with DDT performance requirements under para. 6, specifying that failures include systematic or repeated deviations from DDT performance requirements defined under para. 6, non-compliance with respect to DDT performance requirements and requirements on interactions between the ADS and its user or other requirements under para. 6, and deviation from Remote Interaction/Intervention as described in the Safety case, with a note that some examples can reveal unreasonable risk to safety requiring only a single report noting this aspect.
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