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Proposal to revise Annex 3, item 2 regarding “ADS failure to achieve a mitigated risk condition when necessary.” The revised text maintains the four bullet points describing when such occurrence is expected to be reported when an MRC is required. The rationale states the regulatory text does not require reporting when an MRC is achieved but in an unsafe stop location, which is not defined in the regulation, nor when an MRC is achieved but conflicts occur during the MRC.
Proposal to clarify MRC for ADSF-2 in para. 6.1.5.4.1. The revised text corrects the assertion that ADSF-2 features can meet a lower standard for MRC because of fallback user presence in ADSF-1. It clarifies that ADSF-2 features do not include an ADS fallback response requiring a fallback user, though such features may be present in vehicles with human users. Both ADSF-1 and ADSF-2 features must aim to bring the ADS vehicle to a stop in a safe location complying with traffic rules following ODD exit.
Proposal to update the explanation on reportable occurrences in Annex 1 (GTR) and 3 (UNR). The revision refines language in the requirement describing the manufacturer’s Safety Management System by removing “expected” to avoid implying obligation and clarifying the link between occurrence monitoring, reporting, analysis, system updates, improvements, and continuous improvement processes.
Proposal to clarify EDR provision in Annex on thresholds. For vehicle categories M2, M3, N2, and N3, the revised text clarifies that UN Regulation No. 169 does not include a representative delta V threshold. The manufacturer could determine their own delta-V trigger for a critical occurrence, including one based on a subset of EDR triggers, with no obligation to do so.
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