SAE comments on the working document for ADS safety requirements.

Protected with a password for use by GRVA stakeholders: contact the secretariat for access.

25. The expert from the United Kingdom and Northern Ireland, Co-Chair of the Task Force (TF) on Cyber Security and Over-The-Air issues (CS/OTA), presented the outcome of the TF. He introduced the proposed draft UN Regulation on Cyber Security and Cyber Security Management System (ECE/TRANS/WP.29/GRVA/2020/2 (withdrawn), ECE/TRANS/WP.29/GRVA/2020/3 amended by GRVA-05-05). He mentioned that the revised proposal entailed a recent proposal from Germany and the European Commission (paragraphs 5.3.1.-5.3.3.) in square brackets. He recalled that the TF was planning to deliver further documents accompanying the UN Regulation: a resolution and an interpretation document. He stated that these documents would be further elaborated during the next session of the TF and would distillate the learnings of the test phase in 2019. He informed GRVA that the work on a UN Global Technical Regulation (GTR) had to start.

26. The expert from Japan introduced GRVA-05-20 proposing amendments to paragraph 7.3.8. on the use of cryptographic modules.

27. The expert from the European Commission introduced GRVA-05-22, aimed at clarifying the consequences of the Cyber Security Management System certificate expiration.

28. The expert from Japan introduced GRVA-05-13, expressing strong objections to the proposed paragraphs 5.3.1.-5.3.3. establishing prerequisites to the granting of type approvals not in line with the 1958 Agreement and posing a sovereignty risk. The expert from the Russian Federation expressed a similar position and proposed to draft an alternative proposal.

29. The expert from France introduced, GRVA-05-29 proposing an alternative to the proposed paragraphs 5.3.1.-5.3.3. as well as amendments proposal for paragraph 7.4 and Annex 5.

30. The expert from the European Commission introduced a compromise proposal (GRVA-05-42) for paragraphs 5.3.1.-5.3.3. aimed at addressing the proposals from Japan and France.

31. The expert from OICA introduced GRVA-05-33. He stated that the test phase’s general outcome was the confirmation of the applicability of the former draft. He explained their major concerns with the current text. He mentioned their concerns from the industry point of view regarding the major type approval procedure modifications introduced by paragraphs 5.3.1.-5.3.3. and the major delay associated risks.

32. He stated that insufficient considerations were given to existing vehicle architectures and requested the introduction of transitional provisions. He also stated that the reporting provisions were excessive. He called on GRVA to consider these concerns and to resolve them on a consensus basis.

33. The expert from FIGIEFA introduced GRVA-05-15, proposing a process flow for national/regional authorities to define objective minimum compliance criteria for the UNECE cybersecurity regulation and a way forward for aftermarket issues.

34. GRVA reviewed in detail GRVA-05-05, having in mind the presentations received (paragraphs 26-32 above).

1. GRVA discussed the scope of the draft Regulation (keeping vehicles of Categories S, R, T, O in square brackets).
2. GRVA discussed GRVA-05-17 and agreed to keep the proposed paragraph 1.4.
3. GRVA agreed that the Regulation and the 1958 Agreement would not be prescribing the mutual recognition, among Contracting Parties, of CSMS (and Software Update Management System) certificates.
4. The expert from Singapore requested clarifications concerning the reporting obligations according to the draft Regulation and wondered whether any reporting would only be shared among the Contracting Parties of the 1958 Agreement. The Co-Chair of the TF explained that the current draft did not impose reporting on existing cyber security threats. He explained that there were already information sharing platforms such as Automotive Information Sharing and Analysis Center (AutoISAC) in the United States of America. GRVA invited the TF to address the question raised.
5. GRVA resumed discussion on the paragraphs 5.3.1.-5.3.3. The expert from the Russian Federation explained that provisions regarding the competencies of Technical Services should be introduced in Schedule 2 to the 1958 Agreement. He added that GRVA-05-42 was not enough and that not trusting Approval Authorities was not a good idea, as it would be time consuming and expensive. He stated that the Database for Exchange of Type Approval documentation (DETA) could have a useful role to play, that the TF could be entitled to learn from type approvals and propose relevant Regulation amendments to GRVA, as necessary, and he proposed the corresponding regulatory wording (GRVA-05-51). The expert from the Republic of Korea stated that these paragraphs could be misused. The expert from CEN proposed an alternative procedure based on the so-called common criteria approach and referred to WP.29-179-28 and WP.29-179-29. The TF Co-Chair noted that the common criteria approach was not complete. The expert from FIA introduced GRVA-05-16. GRVA requested the TF to provide comments on this document. GRVA noted to availability of GRVA-05-02 reproducing ISO/SAE DIS 21434 addressing aspects of the draft Regulation but not the mutual recognition aspect.

35. The Secretary produced a consolidation of the draft Regulation based on the input received during the session (GRVA-05-05/Rev.1). GRVA agreed to use this consolidation as a basis for further work until the next GRVA session.

SAE paper authored by Michael Hamm, Wolfgang Huhn, and Johannes Reschke of Audi AG concerning automated vehicle “light-driven messages” to pedestrians.

21. The expert of SAE delivered a presentation on standardization of technical requirements for forward lighting LED replacement light sources (GRE-80-34) and offered to organize a live demonstration at the next session of GRE. The expert from FIA highlighted the advantages of using LED retrofits for front lighting application of vehicles in use and argued in favour of developing regulations in this area (GRE-80-33). He suggested that TF SR should prepare proposals. In this regard, some GRE experts expressed doubts whether this issue could be solved by UN Regulations and felt that it should be treated within national law. Those experts were also of the view that TF SR should finalize LED substitutes for front-lighting applications and then stop its activities without addressing LED retrofits. GRE decided to revert to this discussion at the next session and requested TF SR to continue its work in the interim.

Proposal to require red retro-reflectors to identify the rear sides of a vehicle (presently not required for vehicles less than six meters in length).

24. GRE considered a proposal for a new 07 series of amendments prepared by the former Co-Chairs of the Task Force on Headlamp Switching (TF HS), which updated the requirements for headlamps and daytime running lamps (DRL) (ECE/TRANS/WP.29/GRE/2018/44, GRE-80-09 and GRE-80-10). The experts from EC and Japan, Russian Federation, OICA and SAE commented on the proposal (respectively, GRE-80-22, GRE-80-29, GRE-80-18 and GRE-80-07). Separately, the expert from EC proposed a new requirement of mandatory presence of emergency stop signal (ESS) on all categories of motor vehicles and trailers (GRE-80-08) and the expert from SAE submitted an amendment proposal on side retro-reflectors (GRE-80-17).

25. Following a brief exchange of views on the above proposals, GRE noted that each of them would require a new series of amendments to UN Regulation No. 48 with its own transitional provisions. To avoid amending this UN Regulation too many times and practical complications, GRE was of the view that all proposals should be consolidated into a single new 07 series of amendments. The expert from OICA offered to host in December 2018, at their premises in Paris, a special meeting of interested parties with a view to drafting a consolidated proposal for the next session of GRE.

18. The expert from the GRE special interest group introduced a consolidated proposal for a new 07 series of amendments (ECE/TRANS/WP.29/GRE/2019/11, GRE-81-09 and GRE-81-10). The expert from France proposed an additional modification (ECE/TRANS/WP.29/GRE/2019/4). Following in-depth discussion, GRE agreed that, given the complexity of the proposal, further work should be pursued by means of a task force. The experts from the Netherlands and Finland volunteered to act as Chair and Co-Chair, respectively, while the expert from OICA agreed to become secretary. GRE noted that the next session of the special interest group/task force would be convened on 16 and 17 May 2019 at the OICA office in Paris (GRE-81-24). The expert from SAE invited the task force to also address the earlier proposal of SAE on side retro-reflectors (GRE-80-17). Finally, GRE agreed to continue consideration of proposals for a new 07 series of amendments at the next session.

Proposal to amend the Headlamp Switching Task Force text aimed at updating requirements for headlamps and daytime running lamps.

24. GRE considered a proposal for a new 07 series of amendments prepared by the former Co-Chairs of the Task Force on Headlamp Switching (TF HS), which updated the requirements for headlamps and daytime running lamps (DRL) (ECE/TRANS/WP.29/GRE/2018/44, GRE-80-09 and GRE-80-10). The experts from EC and Japan, Russian Federation, OICA and SAE commented on the proposal (respectively, GRE-80-22, GRE-80-29, GRE-80-18 and GRE-80-07). Separately, the expert from EC proposed a new requirement of mandatory presence of emergency stop signal (ESS) on all categories of motor vehicles and trailers (GRE-80-08) and the expert from SAE submitted an amendment proposal on side retro-reflectors (GRE-80-17).

25. Following a brief exchange of views on the above proposals, GRE noted that each of them would require a new series of amendments to UN Regulation No. 48 with its own transitional provisions. To avoid amending this UN Regulation too many times and practical complications, GRE was of the view that all proposals should be consolidated into a single new 07 series of amendments. The expert from OICA offered to host in December 2018, at their premises in Paris, a special meeting of interested parties with a view to drafting a consolidated proposal for the next session of GRE.

Discussion of protections against rupture of containers in the Compressed Hydrogen Storage System (CHSS).

Recent amendments to the Canada Motor Vehicle Safety Standard (CMVSS) 108 allows UN Regulation
headlamps to be used on vehicles in Canada. CMVSS 108 specifically refers to the existing UN Regulations. In order to continue the acceptance of headlamps compliant with UN Regulations in Canada after the switch to the new Road Illumination Devices (RID) regulation, the current regulations should make clear references to RID before they are frozen and superseded.

8. On behalf of the Informal Working Group on Simplification of the Lighting and Light-Signalling Regulations (IWG SLR), the expert from GTB reported on the finalization of stage 1 of SLR (GRE-79-28). He further provided a draft schedule for stage 2 which would include two steps. Step 1 would cover objectives which could be achieved by the end of 2019, such as introducing technology neutral and performance based requirements, as well as objectively testable provisions. Step 2 would start in 2020 with the aim to simplify the installation Regulations Nos. 48, 53, 74 and 86. As an additional task, he suggested harmonization with the applicable standards in China. GRE experts also proposed other issues for stage 2 of SLR.

9. The expert from GTB presented the full package of amendment proposals drafted by IWG SLR under stage 1 of SLR:

a) The three new simplified UN Regulations on Light-Signalling Devices (LSD), Road Illumination Devices (RID) and Retro-Reflective Devices (RRD) (ECE/TRANS/WP.29/GRE/2018/2, ECE/TRANS/WP.29/GRE/2018/3, ECE/TRANS/WP.29/GRE/2018/4, GRE-79-10 and GRE-79-14);

b) Draft amendments to Regulations Nos. 48, 53, 74 and 86 that group the definitions and introduce references to the new simplified Regulations (ECE/TRANS/WP.29/GRE/2018/6, ECE/TRANS/WP.29/GRE/2018/7, ECE/TRANS/WP.29/GRE/2018/8, ECE/TRANS/WP.29/GRE/2018/9, ECE/TRANS/WP.29/GRE/2018/10, ECE/TRANS/WP.29/GRE/2018/12, ECE/TRANS/WP.29/GRE/2018/13, ECE/TRANS/WP.29/GRE/2018/14, ECE/TRANS/WP.29/GRE/2018/15, ECE/TRANS/WP.29/GRE/2018/17, ECE/TRANS/WP.29/GRE/2018/30, GRE-79-08, GRE-79-09 and GRE-79-13);

c) Transitional provisions to “freeze” Regulations Nos. 3, 4, 6, 7, 19, 23, 27, 38, 50, 69, 70, 77, 87, 91, 98, 104, 112, 113, 119 and 123 (ECE/TRANS/WP.29/GRE/2018/11).

10. The expert from EC was not in a position to support the indefinite validity of type approvals granted under the frozen Regulations, as proposed in ECE/TRANS/WP.29/GRE/2018/11, because of the General Safety Regulation of the European Union. He proposed revised transitional provisions for these Regulations (GRE-79-31, part I), together with new transitional provisions for the installation Regulations Nos. 48, 53, 74 and 86 (GRE-79-31, part II). While several experts agreed in principle with part I, they were not in a position to support part II. The experts from Finland and UK made study reservations. The expert from OICA expressed the concern that the revised transitional provisions might be rejected by WP.29.

11. To not delay the submission of the whole package of amendment proposals that had been developed in stage 1 of SLR, GRE decided to provisionally adopt the transitional provisions in ECE/TRANS/WP.29/GRE/2018/11, but to put in square brackets the third transitional provision for each Regulation mentioned in the document. At the same time, GRE recognized the urgency of the issue raised by the expert from EC and requested all GRE experts, as well as IWG SLR, to carefully consider the EC proposals with a view to taking a final position at the next session.

12. The expert from IWG SLR proposed correcting minor errors and inconsistencies identified in the documents mentioned under para. 9 (a) above (GRE-79-14). GRE adopted these corrections, as laid down in Annex II.

13. The expert from IWG SLR also suggested rectifying minor errors and inconsistencies in the documents listed in para. 9 (b) above (GRE-79-13). GRE adopted these corrections, as laid down in Annex III, and decided to opt for the alternative wording (in square brackets) of paragraph 6.3.9. of different series of amendments to Regulation No. 48.

14. The expert from India suggested corrections to ECE/TRANS/WP.29/GRE/2018/2 and ECE/TRANS/WP.29/GRE/2018/3 (GRE-79-17-Rev.1 and GRE-79-18-Rev.1 new text). GRE adopted the corrections, as laid down in Annexes IV and V. The expert from India withdrew GRE-79-19, in order to first present it at the next session of IWG SLR.

15. The expert from IWG SLR recalled that all identical definitions should only be kept in Regulation No. 48. Thus, he proposed to review the definitions in Regulations Nos. 53 and 74 (GRE-79-08 and GRE-79-09, respectively). GRE adopted these modifications, as contained in Annex VI.

16. The expert from IWG SLR presented the concept of “change index” developed for the LSD, RID and RRD Regulations (GRE-79-12-Rev.1). He further introduced amendment proposals on the change index to Regulations Nos. 48, 53, 74 and 86 (ECE/TRANS/WP.29/GRE/2018/16, ECE/TRANS/WP.29/GRE/2018/18 and GRE-79-11). GRE adopted these proposals, as amended by Annex VII). In addition, GRE agreed to include transitional provisions on the change index in the text of the LSD, RID and RRD Regulations (GRE-79-10 and Annex VIII). The expert from India pointed out that he would refer GRE-79-22 to IWG SLR.

17. Subject to the modifications mentioned in paras. 10–16 above, GRE adopted the package of amendment proposals drafted by IWG SLR and listed in para. 9 a) – c). The secretariat was requested to submit the amendments proposals to WP.29 and to the Administrative Committee of the 1958 Agreement (AC.1) for consideration and vote at their November 2018 sessions. GRE noted that any modification of the transitional provisions, mentioned in para. 11 above, that GRE might agree upon at the next GRE session in October 2018, would be submitted to the November 2018 session of WP.29 as corrigenda to the basic SLR package which otherwise would be issued in August 2018.

18. The expert of SAE proposed to keep Regulations Nos. 98, 112, 113 and 123 “alive” for the purpose of the recently updated Canadian Federal Motor Vehicle Safety Standard (CMVSS) No. 108 (GRE-79-32-Rev.1). GRE referred this document to IWG SLR for consideration.

SAE proposals regarding the proposal (document GRE-78-21/Rev.1) from the Task Force on Headlamp Switching to clarify requirements for electrical connections for headlamps, daytime running lamps, and related lighting devices.

26. The experts from the Task Force on Headlamp Switching (TF HS) and from SAE introduced alternative proposals which corrected and clarified the requirements for Daytime Running Lamps (DRL) (ECE/TRANS/WP.29/GRE/2018/20, ECE/TRANS/WP.29/GRE/2018/22 and GRE-79-26). The expert from Japan commented on the proposals (GRE-79-03-Rev.1). Following a brief exchange of views, GRE invited the Co-Chairs of TF HS to prepare a consolidated proposal for consideration at the next session.