Proposal for guidance on operational states, including remote termination and a diagram illustrating ADS and feature operational states, update guidance on terms “on”, “off”, “available,” “active,” “unavailable,” and “disabled” as canonical operational state terms for ADS descriptions and clarify that “active” applies only to features.

This document presents AAPC comments on AI-09-06, a consolidated reference document on artificial intelligence in regulated automotive safety systems. The proposed structure consolidates AI uses, use cases, and risk management into single chapters supported by annexes containing tables and bibliographies. The document should support future regulatory deliberations without pre-empting regulatory requirements, presenting factual statements in neutral language. Considerations should address risks not captured by conventional testing. Examples to illustrate system-specific aspects that impact whether the application of AI presents new concerns and determines the nature of responses include predictive window defogging, predictive vehicle maintenance, and AI vehicle knowledge systems.

For vehicles equipped with an Automated Driving System, it shall be possible to retrieve DSSAD time-stamp data elements specified under paragraph 5.2. of Annex 8 of UN Regulation No. 185 recorded within at least the last 30 seconds prior to triggering of the respective EDR event, regardless of whether the DSSAD and the EDR are implemented as a single system or as separate systems. The time-stamp data elements retrievable from the DSSAD shall include the record for the last activation or deactivation of the feature used at the time of the event within the same power cycle. The data elements shall be retrievable in the format specified in Annex 8 of UN Regulation No. 185, though DSSAD location data may be omitted and dates and times recorded may be replaced with information representing the time elapsed between the recording of each DSSAD data element and the triggering of the EDR.