Chair: Mr. Gunneriusson (S)
Vice Chair: Mr. Hirose (J)
Secretary: Mr. Fontaine (OICA)

Spain informed having no particular position on this subject for the time being and was present as an observer.

The representative from the Republic of South Korea (ROK) informed being mandated from the Korea Transportation Safety Authority, and therefore being a delegate from the national authorities.

a. Mandate from GRRF
The Chair recalled that GRRF in its 75th session did not agree on the creation of an informal group, therefore there is no official mandate from GRRF with regard to this ad-hoc group for the time being.

b. Terms of reference

Japan presented the document LKAS-01-02 as a proposal from J for an activity plan of the LKAS ad-hoc group.

OICA found it premature to discuss another meeting date (ref Table 1 of the document). The expert from OICA explained that there is currently no vision on the future and the strategy of the ad hoc group. He suggested to discuss this item when clarification about the issues and their possible solutions will be available, at the end of the meeting.

Conclusion: item to be discussed again at the end of the meeting (see item XXX).

At the end of the meeting, the Secretary recalled that GRRF did not provide any mandate to the group, rather suggested Japan to discuss with the interested parties on this issue. Hence a simple report to GRRF would be sufficient. Japan said that the meeting permitted to make clear what kind of items must be clarified.

LKAS-01-02 | Draft activity plan of the Lane Keeping Assist System ad hoc discussion group

Japan explained the Japanese idea of the work per document LKAS-01-03:

• Preventing drivers being confused by poor HMI should the system not be regulated (e.g. confusion on vs. off states of the system)
• Ensuring minimum performance requirements such that the driver knows what minimum system intervention he may expect.

OICA understood the document as a summary of the objectives for the future rule or guidelines, but was keen 1st that all parties have a common understanding of the objectives of the meeting. The delegate suggested to 1st define the status of LKAS.

Japan claimed having already shown justifications for the work, with relevant safety benefits.

Germany questioned whether systems showing the problems shown in slide 1 of the document 01-03 still exist.
Japan clarified that Japanese guidelines prevent these systems from the market.

OICA acknowledged the above, but recalled that Japan is not signatory to UN R79, while other parts of the world are. He added that the current text of UN R79 could prevent poor systems from the market and that no data today show that LKAS has caused any accidents.

Japan informed [of its intention] to sign UN R79 in the near future, hence reviewed its text in depth, and found that the regulation does not well protect from the confusions and issues tabled in document LKAS-01-03. The expert from Japan stressed that this is why Japan proposes guidelines.

CLEPA pointed out the CEL annex of UN R79, which provides all the necessary requirements that the safety of the system must fulfil to get an approval.

The group had a debate on the way to proceed, and agreed that some further discussions and clarifications are still needed, such that the group decided to get back to this item later.

LKAS-01-03 | Objective of Making Technical Requirements in LKAS (Lane Keeping Assist System) Presentation on the objectives and considerations behind the proposal to establish technical requirements for lane-keeping assist systems.

Japan tabled document GRRF-75-33. The experts discussed this document as follows:

The group acknowledged that the document does not contain M1 data.

Japan was convinced that even with the minimum figure of fatalities (< 0.5% of total fatalities), as Japan has no intention to mandate LKAS, there will be safety benefits in regulating LKAS with minimum requirements.

OICA then questioned whether the existence of LKAS guidelines would increase the number of LKAS on the road.  OICA stressed that, if the system is not made mandatory, then evidence of the existence of poor systems would justify guidelines/rulemaking. The expert from OICA added that, on the other side, there is no justification for making LKAS mandatory. OICA as a consequence was questioning the motivation for regulating LKAS.

Japan was indeed convinced that the current LKAS are safe, but but was convinced on the need for introducing minimum requirements because there is a fear that the increase of LKAS introduction may make poor systems appear in the market. OICA questioned whether customers would accept such poor systems, i.e. the market would probably self regulate. OICA pointed out that, in addition, UN R79 guarantees minimum limits. The expert from OICA said that a balance must be found
between the limits of the technology and the limits of what the driver is ready to accept, similar to the discussions for AEBS one year ago.

Japan took the example of ESS in R13H, as an if fitted provision and suggested that LKAS could follow the same approach. CLEPA challenged the comparison because LKAS is a CEL system, and informed that, after research, they could not find any road user confusion due to LKAS.

OICA added that some guidelines on ITS do already exist and provide sufficient safety net for LKAS. OICA was of the opinion that no rulemaking should be started on the assumption that poor systems will be introduced in the market.

Japan pointed out having no intention to impose the Japanese guidelines on the ad hoc group. The Republic of Korea was not convinced about LKAS, but found adjustable speed-limiting devices (ASLD) a similar case with minimum requirements. The delegate found necessary to improve UN R79 for correctly covering LKAS.

GRRF-75-33 | Traffic Accidents caused by Lane Departure in Japan Presentation to further discussions on Japan's proposal to establish a new UN Regulation on lane-keeping assistance systems.

Sweden was keen to introduce their vision. The Chair, as representative of Sweden, introduced LKAS-01-09, made by the
Swedish Transmport Administration. Background: project dated 2002. In 2008, a “vision zero” program was established in S. he clarified that the document provides the vision, but the practical goal is reducing by half, i.e. 210 fatalities, the number of
fatalities per year in Sweden. He stressed the following items:

• Page 5: Just after the lauch by s of their program, the EU decided to reduce by half the number of fatalities in 2020 compared to 2010. This made problem to Sweden, with a new goal of 133 fatalities a year. Hence a Swedish working group was established (pages 11 and 13).
• Page 24: the representative of Sweden showed that Industry predicted that 100% of the vehicles would be equipped with LKAS in 2015. It was questioned wether the existing fleet was taken into account.

OICA found a conflict with the LDWS EU commitment. The delegate from S clarified that the document was tabled to explain the commitment of Sweden in the ad hoc group. The delegate stress that the authorities usually rely very much on the good functionning of fthe driver assistance systems, which explains the need for a certain level of performance.

The expert from OICA pointed out that passenger cars are not driven by trained professionals, rather by usual customers (e.g. rental cars). The experts were informed that in addition, Sweden believes the LKAS to be a corner stone toward autonomous driving (in Sweden, by 2016).

OICA stressed that current LKAS are used only above a certain speed, in straight roads, etc. the experts questionned whether S has the objective of making the system work in all conditions. It was stressed by OICA that there are two kinds of systems currently on the market, comfort systems and safety systems. The expert wondered whether excluding low cost vehicles because the system may be too expensive for them. J was ready to discuss this item, relating to the content of the requirements.

LKAS-01-09 | Sweden: Review of interim Targets and Indicators for Road Safety in 2010–2020 Analysis based upon data from the Swedish Traffic Accident Data Acquisition System (STRADA) to inform decision-making on future road safety targets and performance indicators.

OICA presented document LKAS-01-08. The expert explained that CLEPA/OICA there is currently no sufficient evidence nor urgency on the need to regulate LKAS and recommended that further investigation be conducted for assessing the best way forward.

The European Commission questioned how UN R79 can guarantee that LKAS can be overridden, and how technical services can test that. TRW clarified that the threshold is usually < 3 Nm on the steering wheel. European Commission suggested that threshold values are not limiting the designers, but that some self declaration is requested such that there is some
check of the technology.

The European Commission saw some conflict between the requirement of tendency for self center, and the autonomous steering, where the radius decreases and LKAS follows the lane.

OICA clarified that the manufacturers are sensitive to their liability, and that, should a system work in a curve, then the manufacturer would have to demonstrate the safety of the system in all modes and situation, via the CEL annex.

The Chair questioned the threshold as from which a system should be regulated.

OICA answered that only continuous systems would be in stake, and that autonomous driving is currently of concern from the Contracting Parties rather than the manufacturers, as the technology is not mature for the market.

The Chair questioned the process of Type Approval if the manufacturer only discusses with the technical service. It was clarified that the Technical Services do tell the manufacturer what they have to do, rather than the inverse. The Netherlands clarified that the
CEL annex usually focuses on failure management rather than respect of the limit values. The CEL annex is more an assessment of the safety philosophy provided by the manufacturer.

A tour de table was organized for getting an overview of the Contracting Parties’ opinions about the question of regulating LKAS:

Germany found it premature to regulate LKAS due to lack of experience. The expert requested more justification for what makes confusion to the driver e.g. in the existing systems.

The Netherlands found it strange to create guidelines on LKAS, because documents LKAS-01-04 and LKAS-01-05 address corrective or automatically commanded steering, and it is too early to regulate autonomous steering. The delegate from
the Netherlands said that perhaps some additional provisions in UN R79 addressing the maximum time for corrective steering would be of interest. Concerning the guidelines, the expert found this of no interest as the ISO standard will play that role, i.e. new guidelines would be a redundancy with the existing ISO standards. Finally, the expert found added value for safety in a system similar to AEBS, whereby the vehicle would turn around an obstacle. The Chair recalled that LDWS only addresses heavy vehicles.

The Republic of Korea found that basic features like warning types (acoustic, optical and haptic), threshold for system performances and suppression conditions should be added to UN R79.

The European Commission found these upcoming systems beneficial, and found it a waste to prevent from introduction of the technology, but on the other hand feared the introduction of dangerous systems. The European Commission would oppose minimum performance requirements, but would agree with basic rules (qualitative text). Yet some non negotiable parameters should be defined (e.g. maximum steering wheel torque that needs to be overcome to regain control). The delegate from the European Commission was of the opinion that systems permitting e.g. to read the newspaper while driving should be forbidden (autonomous steering system). He was keen that a text exist for discriminating the autonomous systems from the others.

Spain had no official position.

J recalled their intention: minimum requirements for maitaining safety.

LKAS-01-08 | OICA / CLEPA views on LKAS Presentation to explain OICA and CLEPA view that lane-keeping assist systems are not presently an appropriate subject for the development of a new regulation.

Japan introduced document LKAS-01-05 as a skeleton paper providing the basic requirements and their justifications for a legal document concerning LKAS.

After revision of document LKAS-01-05 by the group, the Chair clarified that his intention was to consider the option of no regulation, and taking account of the LKAS, perhaps per adaptation of UN R79. The Chair stated that the exercise of assessing document LKAS-01-05 with regard to R79 coverage would permit the group to have a view on whether the discussions should take the direction of guidelines, new regulation, amendments to R79 or other. Should the group
decide not to stop discussions, then some further investigation would be needed.

The Netherlands found guidelines inappropriate because ISO standards can already be considered as guidelines. The delegate from the Netherlands added that guidelines would not bring safety benefits, and UNECE would not be the good platform for this type of document. He said that should Contracting Parties want to mandate a system which brings safety improvement, then a regulation would be the right choice. But as long as LKAS is considered a comfort system, then UN R79 adaptation would solve all the issues. The European Commission fully supported the Netherlands.

The Republic of Korea also found that UN R79, perhaps adapted with a new annex dedicated to LKAS, could provide an appropriate basis for addressing LKAS, in particular Annex 6 which provides a concept wide enough for integrating the safety
aspects of a new technology.

Japan found that amendments to UN R79 would be better than guidelines.

Germany mostly agreed with the Netherlands that a new regulation is not a good solution for the
moment. The delegate from Germany added that Germany currently does not want to judge about guidelines vs amendment to UN R79 as the right way to proceed and found that further discussions seem to be needed.

Sweden found amendments to UN R79 as the best way forward.

OICA found necessary that some further investigation is conducted on this. Regarding amending UN R79, it could depend on the added requirements. OICA committed to review all this at the forthcoming GERF meeting.

The Chair concluded that it is too early to consider performance limits. With regard to comfort vs safety, the Chair found that LKAS could be regarded as both, depending on the situation.

LKAS-01-05 | Candidate lane-keeping assist system requirements Proposals for LKAS regulatory provisions.

LKAS-01-05/Rev.1 | Candidate lane-keeping assist system requirements (revised) Draft list of LKAS regulatory provisions pursuant to the discussions held during the first LKAS expert group session as prepared by the group secretary.

The Chair questioned how the manufacturers could do today between ITS, LDWS, ISO, Vienna Convention, product liability, UN R79, for approving a vehicle.

Japan presented the document LKAS-01-04. The expert from Japan informed the group that this document was an attempt to cover Industry’s concerns with regard to LKAS.

OICA found that a column showing the items covered by UN R79 was missing (warning, failure modes, whether in the core of the text or in the CEL annex).

The expert from OICA pointed out that each item was covered in some way or another by UN R79, ISO or the current Japanese guidelines. The delegate was seeking clarification about the “purpose” column in the document LKAS-01-04, e.g. the purpose of provisions for operating speed. Japan found this similar to the provisions in the introduction of AEBS regulation. Japan was keen that some fruitful discussions take place on these items.

LKAS-01-04 | Outline of LKAS requirements Concordance of existing texts from Japan, ISO, UN lane departure warning system (LDWS), and ADAS design principles pertinent to lane-keeping assist systems.

Japan presented document LKAS-01-05. The expert from J clarified that in general, the option numbering is from the most severe (1) to the most relax (4).

The Chair found it necessary to study in depth the documents because it shows that, even if the LKAS is covered by different texts, their interpretation is such that the level of performance can differ very much (even be opposite).

Japan was also keen to discuss the document in depth, then decide the way to proceed.

It was suggested to add a column in document LKAS-01-05 showing how UN R79 addresses each item. Conclusion: the group agreed to add a column, for assessing whether the items are covered by R79. The aim was that, at the end of the exercise, the group should decide the way to proceed, i.e. amending UN R79, elaborate new guidelines, or any other option. The Secretariat then created the document LKAS-01-05-Rev.1

LKAS-01-05 | Candidate lane-keeping assist system requirements Proposals for LKAS regulatory provisions.

LKAS-01-05/Rev.1 | Candidate lane-keeping assist system requirements (revised) Draft list of LKAS regulatory provisions pursuant to the discussions held during the first LKAS expert group session as prepared by the group secretary.

Definitions
A debate took place about the definitions in UN R79 with regard to the different systems. Paragraph 2.3.4. specifies that “the driver remains at all times in primary control of the vehicle” i.e. the driver must control the steering control (in the frame of the steering system regulation); the secondary control of the vehicle is provided by systems like LKAS. J found the definitions sufficient as

LKAS is clearly a corrective steering system. Yet at the time of autonomous steering system, it may be opportune to improve the definitions of UN R79. The European Commission contested the reading of UN R79, because of the texts of paragraphs 2.3.4.1. and 2.3.4.2., where PAS is part of advanced driver assistance, without the driver having the hands on the steering wheel.

Scope
Japan was keen not to exclude any category, but proposed to focus on M1 w/o excluding any other category. In addition, the expert from Japan informed that LKAS currently requires electric steering system.

OICA clarified that heavy vehicles are currently implementing LDWS, and do not have LKAS. Still OICA found LKAS not mature for a rulemaking because on M1 vehicles, different systems are still under development. Yet the concern of a wide scope would be that a Contracting Party mandates LKAS on vehicles fitted with hydraulic steering.

CLEPA was confused that the figures of the Japan documents justified LKAS on heavy vehicles, while Japan proposes that the ad-hoc group focuses on LKAS for M1 category.

Japan clarified that data only exist for heavy vehicles, and they extrapolated them for light vehicles.

Operating speed
Japan suggested option 2 because the key parameter is to maintain road safety (avoid driver’s confusion).

Japan announced being flexible about minimum performance requirements (e.g. operating speed limit), i.e. would agree deleting.

Japan justified the 60km/h limit of option 2 per the limit in LDWS regulation, and LKAS is designed for primarily use on highway. OICA found it necessary that flexibility be provided in operating speed limit, because there is no clear limit in
state of the art systems. CLEPA challenged the proposed wording (shall) because this may prevent the driver from the control of the vehicle. J conceded that this was subject to the presence of a manual switch. OICA clarified that it is
impossible today to determine an operating speed limit and that there is a need for a manual switch because this is no emergency system.

Conclusion: item not covered by UN R79. Group to decide later about possible speed limit

Acceleration etc. caused by the operation of the system
Japan commented that this item is necessary to avoid driver’s confusion, but Japan was ready to hear the other delegations’ opinions.

OICA pointed out that the item raised in document LKAS-01-04 is covered by UN R79, yet the proposal from J per document LKAS-01-05 is not covered the regulation.

The Netherlands found that the lateral acceleration is covered by UN R79, but the longitudinal acceleration is covered by UN R13. In addition, a good understanding of the CEL annex would prevent dangerous systems, even while no value is specified.

The group was informed that UN R13H by selective braking permits deceleration up to zero.

CLEPA was of the opinion that the requirement that the driver can always override the system would cover this item because the driver can simply apply the necessary force on the steering wheel.

Conclusion: need for further discussions on this item.

Road shape
OICA found the value of 1000m reasonable.

The Chair pointed out that having a small curve limit would mandate the system to detect lane markings up to this limit. OICA stressed that this was covered by one of the comments raised by OICA at GRRF, that a limit would prevent systems designed for straight road.

CLEPA added that a too low limit would not be convenient to the driver on country roads.

Japan supported a clear distinction between LDWS and LKAS as LKAS in intrusive. Japan also supported the 1000m limit.

The Netherlands found that for a safety systems, it does not matter whether it is comfortable, because if the driver is not happy, then he can switch off the system.

Lane marking
Japan clarified their proposal for option 2 because of the need for early detection by LKAS; the expert indicated the need for time and space for initiating control of the steering system. He said that, in addition, state of the art systems are different according to the markets. J agreed that the wording should be improved.

Industry indeed challlenged the proposed wording.

Korea informed that the country has blue lane markings.

The Netherlands recalled that the UN regulations must cope with mutual recognition and that it would be counterproductive to have provisions limiting this concept.

OICA pointed out the technical challenge behind the discussion Germany repeated the need not to exclude systems which can function without lane marking. Japan was of the opinion that such systems would be out of scope. CLEPA pointed out that
the absence of markings on certain portions would make the system switch from activation to deactivation repeatadly with inconveninece for the driver.

Japan stressed that the current situation is that a system approved per UN R79, could face approval problems in Japan.

Conclusion: need for further discussions.

LKAS performance requirement
Should some criteria be adopted, some amendments to UN R79 or other regulation should be initiated.

Conclusion: not covered by UN R79.

Functional limitation of the system
Japan found this item necessary for avoiding confusion. The group agreed to pay attention to the meaning of “operating”.

CLEPA challenged the reference to “high priority warning” because it is not yet sure whether LKAS discussed in this group addresses safety system or comfort system.

Conclusion: need for further discussions.

Requirement for the end of the system operation
OICA recalled that the CEL annex covers this for avoiding roll-over, etc. “easy and safe handling of the vehicle up to maximum speed”.

The Chair raised the concern of the situation when the system looses the marking within a curve: how does it give back the control to the driver?

CLEPA clarified that the end can be done smoothly in the case the marking cannot be detected anymore. Yet if the system becomes out of order (failure), then the end should occur abruptly.

The Netherlands said that a Technical Service should check per CEL annex, assessing what would be the consequences if such event would occur, and added that a Technical Service may request to perform a test. The criterion would be that the
vehicle remains stable, yet UN R79 does not contain any test nor value for this.

Germany informed that such systems abruptly releasing the control do exist, yet the forces/moments are so low that they do not make the vehicle unstable.

CLEPA confirmed that the systems currently in the market do not have safety issues thanks to the level of torques.

OICA also recalled that UN R79 is clear that the automatic systems, per Annex CEL, cannot cause any deterioration of the steering system handling.

The group convened that there is no intention to bring suspicion on the Technical Services, and was keen to provide assistance when felt necessary.

Holding a steering wheel by the driver
The Netherlands was keen that the system avoids overreliance. The expert favoured option 1 (the operation shall be cancelled when there is no steering operation of the driver for more than 5s) + an optical warning. The expert also questioned the 5 second value.

CLEPA was of the opinion that a sleeping driver cannot remove the hands from the steering wheel.

OICA questioned whether switching off the system when the driver is asleep would always be a good point for safety.

The Chair supported that point of view because the system may give the conditions for sleeping, then switch off the assistance.

Japan favoured option 3 because the Vienna Convention is clear that the driver should not be asleep. The expert from J informed that J assumes that the driver controls the vehicle even if the hands are not on the steering wheel.

CLEPA suggested that the warning be repeated if there is no reaction from the driver.

OICA pointed out that there must be a balance between the avoiding over-reliance and too frequent alarms.

Conclusion: not covered by R79.

NL, supported by the European Commission, found the criterion important because the assistances should not provide the driver too much tools to leave the control to the system.

Korea found this important for safety. The expert favoured haptic or acoustic warning.

Germany found a warning necessary, with no suggestion

Spain had no opinion.

Conclusion: important item, partially covered by UN R79.

Override
Conclusion: Fully covered by UN R79.

Condition of non-operational being allowed
There was a debate about whether actionning the direction indicator can be considered as “overriding” the system.

Conclusion: Option 3 favoured by the group and paragraph 5.1.6. of UN R79 addresses this.

ON/OFF switch
The group was informed about the discussions currently being held at WP1 that a system not covered by a UN regulation must be overridable or capable of being switched off.

CLEPA would recommend default off, with a mandatory switch that the driver can voluntarily switch on the system.

The European Commission would favour a default on, with a switch such that the driver can switch off the system.

Some CLEPA experts pointed out that LKAS is a system internening when normally driving, hence would recommend default off.

Japan justified their position that almost all current LKAS are “last memory” systems and Japan favoured a default off system.

OICA stressed that the criterion is the acceptability from the driver, a default on system is acceptable if it does not burden a driver. The expert suggested not to be too restrictive today, until the time there are lots of systems in the market.

The group was informed that in addition, the “switch” can be a software button in a menu.

The Netherlands thought that a comfort system should be default off with a switch.

Korea found that a mandatory system should be default on.

The European Commission did not find important whether it is default on or off, and supported a switch and would favour default on system. Germany fully supported the European Commission.

Conclusion: need for further discussion

Malfunction warning / Status display
OICA clarified that UN R79 does cover this per the CEL annex.

Japan clarified that “operating” means passive activation and was keen to distiguish functional from internal failures.

CLEPA did not find beneficial for the driver that the system indicates whether it can detect the lane markings, rather whether it can intervene.

The European Commission found sufficient that the system indicates whether there is a malfunction (electric, sensor, etc). The rest was considered not relevant as mainly for maintenance purpose.

Conclusion: covered by R79, + need for more discussions.

Information to be known to users
Japan was not keen for such requirement.

OICA pointed out that the document reflects the current situation. UN R79, paragraph 5.5.2. It must be possible to verify in a simple way the correct operational status of those Electronic Systems, which have control over steering. If special information is needed, this shall be made freely available. This is only for PTI.

The Secretariat was of the opinion that the driving license covers this.

Conclusion: no need for requirement.

Failsafe

CLEPA supported that there is a request for redundancy.

Conformity with the safety aspects of complex electronic control systems

Japan supported the current wording of UN R79

There was no comment from the group.

EMC
Acceptable, no comment.

[None.]

The Chair raised the question of a further meeting: the objective of the next meeting would be to check the list of items not covered by UN R79, identifying which are of importance to safety and assessing whether amending UN R79 is relevant.

Japan committed to prepare for a next meeting a recollection of the important items of the document LKAS-01-05, together with the relevant amendments for UN R79.

The Netherlands said that GRRF could not do fruitful action with a document available at such a short notice. The expert suggested that no further meeting take place before the next GRRF session, rather a report on the outcomes of this meeting.

It was suggested to establish a written report 3 weeks before GRRF session, taking into account the Industry point of view via email exchange during the month of January.

Japan was ready to wait for the results of the discussions with all ad hoc group members, then make a decision. Japan clarified that there is no obligation to report back to GRRF, yet Japan was keen not to delay input to GRRF. However Japan favoured holding a 2nd meeting before the next session of GRRF.

After discussions, Japan agreed to aim the September GRRF session.

Conclusion:
• Report to be delivered to GRRF by end of January.
• In the meantime, email discussion for having a consolidated report containing the positions of all parties.
• No second meeting before February session of GRRF.