Change request to amend para. 4.1.6.2. to add a condition that an ADSF-1 shall execute a fallback to an MRC if there is insufficient time available for transition or if it has not been possible to complete a system-initiated deactivation procedure. The revision ensures that in situations where an ADSF-1 does not have time to safely transition to the fallback user, it should fallback to an MRC to avoid having a fallback user that is unprepared and unable to safely take back control.

Proposal to insert new provisions requiring the system to inform users of deactivation procedure initiation and continuation using at least an optical signal and an auditory or haptic signal until completion or termination, escalate the warning using stronger and/or more frequent optical, auditory and/or haptic signals if the user is not re-engaging in the DDT within an expected time after deactivation initiation, maintain the escalated warning while the user is not re-engaging in the DDT, de-escalate the warning when the user is re-engaging in the DDT with sufficient time available for transition, include a haptic component when an immediate user response is required, and require manufacturers choosing to implement warning escalation for user-initiated deactivations to meet the same requirements as system-initiated deactivations.

Proposal to insert provisions requiring the ADS to terminate the deactivation procedure and execute a fallback to an MRC if the user is not suitably engaged after the time available for transition has expired, to permit the ADS to terminate the deactivation procedure and resume its previous operating state in the case of user-initiated deactivation instead of a fallback to an MRC, and to require the user be promptly informed that the deactivation process has been terminated and the reason for termination.

Change request to clarify ADS response to user-initiated deactivations. Proposes to amend para. 4.2.2.3.3 to specify that for ADSF-2 systems, deactivation procedures shall only be initiated if the ADS can assess the user to be available to assume the role of the driver according to fallback user provisions in para. 4/6.2.2.1.6 a), and to renumber para. 4.2.2.3.4 as para. 4.2.2.3.3.1. The original text could be misinterpreted as requiring the ADS to initiate deactivation whenever requested by the user.

Change request to add new paragraph clarifying that an advance notification that the fallback user should prepare for a system-initiated deactivation shall not be considered as the start of the deactivation procedure. The existing text does not clearly define when a system-initiated deactivation procedure begins. Advance notification is a necessary tool to prepare the fallback user for re-engagement without prematurely starting the deactivation procedure.

Change request to establish a method to transfer vehicle control between the ADS and the user during the deactivation procedure. The ADS shall maintain safe control of the vehicle until the deactivation procedure is completed, gradually reduce its vehicle control action in response to the user assuming vehicle control, and may increase its control action if the reduction is leading to an unsafe vehicle response.

Proposal to modify para. 4.2.2.3.8.1 to add a requirement that a user be in a physical position to operate the driving controls, to allow gaze to be directed to multiple driving task-relevant areas rather than a single area, and to add a requirement that the user have demonstrated an appropriate response to transition of control.

Proposal to insert a requirement that at the start of the deactivation procedure, any non-driving related activities provided or enabled by the ADS vehicle that were permitted because an ADS feature is active shall be automatically suspended. The requirement applies only to activities provided or enabled by the ADS vehicle and only to NDRA permitted because an ADS feature is active, not to activities such as listening to music or navigation permitted while an ADS feature is not active.

Proposal to clarify that the ADS must respond to user requests to deactivate, require multimodal signals at the start of and during deactivation procedures that continue until completion or termination, require escalation of warnings for system-initiated deactivations if the user is not re-engaging as expected, require gradual reduction of ADS control action during deactivation while maintaining safe vehicle control, allow the ADS to retake full control if the vehicle is not being controlled safely, terminate the deactivation procedure if the user is not suitably engaged and the time available to transition has expired, replace the requirement for contact with the steering wheel with being in a physical position to operate the driving controls, suspend non-driving related activities at the start of the deactivation procedure, and modify the DDT section to require fallback to an MRC instead of a deactivation procedure if there is insufficient time for transition.