Proposal to clarify the EDR trigger input in the case of vehicles approved to UN R169 (M₂, M₃, N₂, N₃) equipped with airbags (Supplemental Restraint Systems).

The change request seeks clarification that “real-time” operational and tactical functions of the DDT, particularly “sensing and perception” and “planning and decision”, could be achieved through real-time sensor inputs alone or through integration of sensor inputs with other contextual information such as map-based data, to aid technical inspectors during testing and assessment of ADS systems.

The ADS regulations (GTR and UNR) include definitions for reporting thresholds based on EDR triggering. Time-series data recording for heavy vehicles under UN R169 requires triggers and trigger thresholds to record data in specified time periods, which may not immediately precede, follow, or coincide with crashes. Last Stop, Safety Systems, and Sudden Deceleration triggers are unreliable crash indications. Sudden Deceleration is too sensitive for storing time-series data over several months. Optional SRS or a new independent trigger alongside Detected Collision offers the only viable possibility for effective time-series data recording.