Presentation by IWG PTI on their proposal ECE/TRANS/WP.29/2021/148

Proposal to ensure that the information provided regarding software updates is accessible for use in type approval, conformity of production, market surveillance, recalls and Periodic Technical Inspection (PTI).

32. The expert from UK, Co-Chair of the IWG on CS/OTA, introduced ECE/TRANS/WP.29/GRVA/2020/29, proposing guidance on how to interpret UN Regulation No. [156] (Software Updates and Software Updates Management Systems). He answered to the question raised by the expert from Spain on the reference to ISO 9001 in the document, which is a very general quality standard.

33. The expert from CITA introduced GRVA-07-44, aimed at clarifying the interpretation of para. 7.1.1.12. GRVA did not support the proposal as it was agreed that the interpretation document should not indirectly introduce additional requirements to the Regulation. GRVA offered the expert of CITA to further discuss the idea proposed in the document at the IWG level.

34. GRVA endorsed ECE/TRANS/WP.29/GRVA/2020/29 as amended by GRVA-07-50 (see Annex IV of the session report) and recommended its adoption by WP.29 at its November 2020 session. (GRVA noted the submission by the IWG of GRVA-07-51, which is content-wise identical with GRVA-07-50 but with a different format).

Proposal to amend Annex 8 (Test requirements for Corrective and Automatically Commanded Steering Functions (ACSF)), paragraph 3.5. (Tests for ACSF of Category C) in order to clarify that enabling of the system as part of the test procedure is only necessary when the system is not yet enabled.

41. GRVA adopted ECE/TRANS/WP.29/GRVA/2020/23 and requested the secretariat to submit it as supplement to the 03 series of amendments to UN Regulation No. 79 for consideration and vote by WP.29 and AC.1 at their March 2021 sessions.

Provisions to define a reference value for particle number

11. The Chair requested GRPE to have GRPE-81-19 introduced under agenda item 5 as GRPE-81-18 planned under that agenda item dealt with a similar issue.

29. The representative from CITA introduced GRPE-81-18 and GRPE-81-19 proposing the introducing of Particulate Number (PN) reference value tests in UN Regulations Nos. 24 and 83, that could be used, for example, as part of roadworthiness tests during the lifetime of the vehicle. The representative from CITA explained this first introduction to the documents was primarily aiming at gathering the interest of GRPE to work on such issue.

30. The representative from OICA regretted that both informal documents had been submitted soon before GRPE, and therefore limited time was available to carefully study the proposals. He highlighted GRPE-81-19 was not in line with GRPE-81-28 proposed by OICA (para. ‎32). He finally wondered if the proposals from OICA would have an impact on the cost of Periodic Technical Inspections (PTI).

31. The representative from EC deplored a premature proposal given the importance of the issue for assessing Diesel Particulate Filters (DPFs) deterioration. She stated the EC would be willing to redefine the test included in UN Regulations Nos. 24 and 83 to include PN. The representatives from NL, which is likely to include PN tests during PTI as of 2021, declared his willingness to work on a more refined proposal. The representative of Germany also supported the initiative and stated he would be happy to contribute.

32. The representative from OICA briefly introduced GRPE-81-28 proposing to remove UN Regulation No. 24 from the scope of UN Regulation No. 49. The representative from EC underlined such proposal was not on the table at this stage.

33. The Chair proposed GRPE to consider a full package during the next session of GRPE in January 2021 including the views of stakeholders having shown interest to work on the topic.

Defines a reference value for particle number measurement.

11. The Chair requested GRPE to have GRPE-81-19 introduced under agenda item 5 as GRPE-81-18 planned under that agenda item dealt with a similar issue.

29. The representative from CITA introduced GRPE-81-18 and GRPE-81-19 proposing the introducing of Particulate Number (PN) reference value tests in UN Regulations Nos. 24 and 83, that could be used, for example, as part of roadworthiness tests during the lifetime of the vehicle. The representative from CITA explained this first introduction to the documents was primarily aiming at gathering the interest of GRPE to work on such issue.

30. The representative from OICA regretted that both informal documents had been submitted soon before GRPE, and therefore limited time was available to carefully study the proposals. He highlighted GRPE-81-19 was not in line with GRPE-81-28 proposed by OICA (para. ‎32). He finally wondered if the proposals from OICA would have an impact on the cost of Periodic Technical Inspections (PTI).

31. The representative from EC deplored a premature proposal given the importance of the issue for assessing Diesel Particulate Filters (DPFs) deterioration. She stated the EC would be willing to redefine the test included in UN Regulations Nos. 24 and 83 to include PN. The representatives from NL, which is likely to include PN tests during PTI as of 2021, declared his willingness to work on a more refined proposal. The representative of Germany also supported the initiative and stated he would be happy to contribute.

32. The representative from OICA briefly introduced GRPE-81-28 proposing to remove UN Regulation No. 24 from the scope of UN Regulation No. 49. The representative from EC underlined such proposal was not on the table at this stage.

33. The Chair proposed GRPE to consider a full package during the next session of GRPE in January 2021 including the views of stakeholders having shown interest to work on the topic.

The proposal to clarify that enabling the system under the test procedure is only necessary in cases where the system is not already in the enabled state.

47. The expert from OICA presented GRVA-05-52, introducing GRVA-05-30 with amendments to the provisions applicable to ACSF of Category C.

48. The expert from CITA introduced GRVA-05-50 with amendment proposals to Annex 8.

49. The expert from Germany introduced GRVA-05-53 with amendment proposals to para. 5.6.4.7. (critical situation).

50. GRVA requested the secretariat to distribute GRVA-05-30, GRVA-05-50 and GRVA-05-53 with official symbols at its September 2020 session.

List of elements that could be left to national/regional determination (i.e., not harmonized at the global level).

Proposal for DSSAD elements for use in the type approval of low-speed, on-highway automated lane-keeping systems.

Proposal to introduce and improve provisions to detect and protect against tampering with emissions control devices.

20. The representative from CITA introduced GRPE-80-10 proposing amendments to the 07 series of amendments to UN Regulation No. 83. He also introduced GRPE-80-11 and GRPE-80-12 that are of similar content proposing to amend UN Regulations Nos. 24 and 96 respectively. All three proposals sought to improve the design of vehicles to make tampering of emissions systems more difficult and to facilitate its detection. The representatives from Italy, the United Kingdom of Great Britain and Northern Ireland and EC highlighted the importance and relevance of the topic and required more time and deeper impact assessments to gauge the potential consequences of such new provisions.

21. The representative from Australia wondered why the representative of CITA had not proposed amendments to UN Regulation No. 49 along the same lines and asked if all the proposals might be tackled as a whole for all vehicle types. The representative from CITA explained that GRPE-80-10, GRPE-80-11 and GRPE-80-12 represented a first step and the other UN Regulations would be looked after at a later stage.

22. The representative from Euromot reiterated that all technical changes require a technical assessment and that in the case of Non-Road Mobile Machinery (NRMM) engines, many principles detailed in the proposal from CITA were already addressed today (e.g. on software version and emission control system). The representative from CITA welcomed this statement and the comments received and he stated CITA will further work to improve those proposals.

23. The representative from the Netherlands requested CITA to especially further elaborate the justification part of the proposals to include for example root-cause assessment and/or cost/benefit analysis to better understand what CITA wants to achieve and to assess the effectiveness of the proposals. The representative from EC highlighted the consensus from all stakeholders that the issue of tampering prevention is important and urgent but that further discussions would be required, for example in a dedicated group to work in-depth on the topic. The Chair confirmed the sense of importance especially with the risk that tampering is undermining all the efforts made at type approval.

24. The representative from OICA agreed the issue needed to be looked at and encouraged not to place all the burden and car manufacturers and to have a holistic view, for example by looking at new tools to analyse at environmental performance on a more regular basis and by complementing the administrative provisions.

25. GRPE agreed to keep the topic on the agenda and to create a dedicated agenda item on lifetime compliance from the next session of GRPE in June 2020. GRPE also agreed to invite a representative from GRVA to share the latest progress on the work of the Task Force on Cyber Security and Over The Air (OTA) software updates (CS/OTA) operating under the auspices of GRVA, on Integration of Regulation X Software Identification Number (RxSWIN).

38. The expert from OICA informed GRPE that OICA withdrew ECE/TRANS/WP.29/GRPE/2020/8 from consideration by GRPE. A recent better understanding of the issue following informal discussions with various stakeholders showed the proposal needed to be reconsidered.

39. The representative from CITA introduced GRPE-80-11 together with GRPE-80-10 and GRPE-80-12, as all documents were of similar nature (see para. 20).

41. The representative from CITA introduced GRPE-80-12 together with GRPE-80-10 and GRPE-80-11, as all documents were of similar nature (see para. 20).

Proposal to introduce and improve provisions to protect against tampering with emissions control devices.

20. The representative from CITA introduced GRPE-80-10 proposing amendments to the 07 series of amendments to UN Regulation No. 83. He also introduced GRPE-80-11 and GRPE-80-12 that are of similar content proposing to amend UN Regulations Nos. 24 and 96 respectively. All three proposals sought to improve the design of vehicles to make tampering of emissions systems more difficult and to facilitate its detection. The representatives from Italy, the United Kingdom of Great Britain and Northern Ireland and EC highlighted the importance and relevance of the topic and required more time and deeper impact assessments to gauge the potential consequences of such new provisions.

21. The representative from Australia wondered why the representative of CITA had not proposed amendments to UN Regulation No. 49 along the same lines and asked if all the proposals might be tackled as a whole for all vehicle types. The representative from CITA explained that GRPE-80-10, GRPE-80-11 and GRPE-80-12 represented a first step and the other UN Regulations would be looked after at a later stage.

22. The representative from Euromot reiterated that all technical changes require a technical assessment and that in the case of Non-Road Mobile Machinery (NRMM) engines, many principles detailed in the proposal from CITA were already addressed today (e.g. on software version and emission control system). The representative from CITA welcomed this statement and the comments received and he stated CITA will further work to improve those proposals.

23. The representative from the Netherlands requested CITA to especially further elaborate the justification part of the proposals to include for example root-cause assessment and/or cost/benefit analysis to better understand what CITA wants to achieve and to assess the effectiveness of the proposals. The representative from EC highlighted the consensus from all stakeholders that the issue of tampering prevention is important and urgent but that further discussions would be required, for example in a dedicated group to work in-depth on the topic. The Chair confirmed the sense of importance especially with the risk that tampering is undermining all the efforts made at type approval.

24. The representative from OICA agreed the issue needed to be looked at and encouraged not to place all the burden and car manufacturers and to have a holistic view, for example by looking at new tools to analyse at environmental performance on a more regular basis and by complementing the administrative provisions.

25. GRPE agreed to keep the topic on the agenda and to create a dedicated agenda item on lifetime compliance from the next session of GRPE in June 2020. GRPE also agreed to invite a representative from GRVA to share the latest progress on the work of the Task Force on Cyber Security and Over The Air (OTA) software updates (CS/OTA) operating under the auspices of GRVA, on Integration of Regulation X Software Identification Number (RxSWIN).

38. The expert from OICA informed GRPE that OICA withdrew ECE/TRANS/WP.29/GRPE/2020/8 from consideration by GRPE. A recent better understanding of the issue following informal discussions with various stakeholders showed the proposal needed to be reconsidered.

39. The representative from CITA introduced GRPE-80-11 together with GRPE-80-10 and GRPE-80-12, as all documents were of similar nature (see para. 20).

41. The representative from CITA introduced GRPE-80-12 together with GRPE-80-10 and GRPE-80-11, as all documents were of similar nature (see para. 20).