Comments on the proposal for amendments to the UN Regulation on Cyber Security Management.

Proposal to introduce new text concerning activation: “Notwithstanding the activation criteria above and following the activation request at any type of road by a deliberate action with the same means as for ACSF of Category B1, the ACSF of Category C may turn automatically to standby mode when entering a type of road as described above.”

Proposal for a provision to address use of a steering robot with mechanical power greater than 1200 W to enable testing of certain direct (low) steering gear ratio systems due to the given 0.7 Hz sine frequency.

Proposal to clarify the interpretation of “engine start/run cycle”.

Proposal to clarify a logical cascade of actions regarding activation of ACSF B1 and C and the indication on when the vehicle has entered an eligible road based on the following:

1. When the same means is used by the driver to simultaneously activate the Automatically Commanded Steering Function of Category B1 (ACSF B1) and of Category C (ACSF C), both functions switch to standby mode when the vehicle enters an ACSF C eligible road. But if the road is non-eligible to ACSF C, then only the ACSF B1 is activated.
2. With the current text of the regulation, once the vehicle moves to an ACSF C eligible road, the driver must operate again the means to activate the ACSF C. This second deliberate action is confusing for the driver since it makes the manipulation more complex. The current wording discourages most drivers from using this assistance function.
3. The proposed wording permits the following, logical, cascade of actions:
   1. The driver has done a deliberate action to activate ACSF B1 and ACSF C (on a non-eligible road); then
   2. He drives into an eligible road, and is clearly informed thereof; then
   3. He initiates a lane change procedure by activating e.g. the direction indicator.
4. This amendment further clarifies the requirement on the indication of when the vehicle enters an eligible road. It gives some examples of the type of indication to be given to the driver, e.g. additional popup or blinking indication, without being design restrictive.
5. A dedicated status indication of an ACSF C off-mode is by nature already different from the standby or active indication. Therefore, the driver is already sufficiently informed on a potential status change.

Proposal to clarify a logical cascade of actions regarding activation of ACSF B1 and C and the indication on when the vehicle has entered an eligible road.

Proposal to clarify a logical cascade of actions regarding activation of ACSF B1 and C and the indication on when the vehicle has entered an eligible road.

Proposal to add the text, "In case that saturation of the front tyres happens before the above calculated magnitude angle, this angle may be used as the final steering amplitude, but only if this angle is greater or equal to 6.5 A.” based on the following justification:

1. Reaching fixed amplitude, i.e., fixed steering wheel angular speed due to given 0.7 Hz sine frequency, needs much more torque with quick steering gear ratio systems than with slow steering gear ratio systems, and produces much more wheel steer.
2. Car behavior (yaw rate, lateral acceleration and thus trajectory) is similar for all amplitudes above approx. 7 to 8 A (i.e., more than 7 times the steering wheel angle corresponding to 0.3 g), because front tires are saturated. More steer of the tires doesn’t provide more lateral force, so yaw rate and lateral acceleration don’t increase. Continuing to increase steering wheel amplitude after front tire saturation doesn’t give more information.
3. There might appear in the future some vehicles which have significantly low steering gear ratio (i.e., quick steering characteristics) and may need too much steering wheel torque to achieve the 270 degrees sine amplitude at 0.7 Hz (not reachable by conventional steering robots), then jeopardizing the easy approval of future beneficial steering equipment e.g. steering-by-wire systems.

Proposal to permit crossing of lane markings by ACSF of category B1 to assist the driver in forming an access corridor for emergency and enforcement vehicles in slow-moving traffic (based on provisions adopted for UN R157).

Proposal to clarify the provisions for ACSF Cat. A “Remote Controlled Parking (RCP)” for vehicle combinations. The current definition for RCP S_RCPmax sets a maximum limit of 6m distance to the motor vehicle, which is insufficient in situations where the operation is supervised by the driver located behind the vehicle combination.

This document amends the formal proposal in document GRVA/2023/9.

Proposal to clarify the application of the proposed changes with regard to electro-mechanical braking.

Proposal for editorial improvements for clarity and consistency across regulations.

Proposal to clarify the wording on "“initiation of each engine start/run cycle” relative to automatic re-instatement of the AEBS default status.

Proposal to clarify the wording concerning automatic re-instatement of the AEBS default status at the “initiation of each engine start/run cycle”.

Proposal to allow a mechanical locking device as an alternative to the friction parking braking to hold the vehicle.

Proposal to allow a mechanical locking device as an alternative to the friction parking braking to hold the vehicle.

Proposal to amend provisions concerning full power steering to address technological advances such as steer-by-wire systems.

Proposal for amendments, including view that the original proposal changes the conditions for approval and therefore should be in the form of a new series of amendments with transitional provisions.

Proposal to clarify provisions on Automatically Commanded Steering Function (ACSF) of category A.

Proposal for amendments to the proposal to permit the use of a positive lock type system as an alternative to a friction type parking brake system.

Proposal to amend the proposal to permit the use of a positive lock type system as an alternative to a friction type parking braking system.