Proposal to clarify section 6.1.2.1 regarding crash causation. During approval process, when collisions involve the ADS during the manufacturer’s real-world or confirmatory testing, a root cause analysis is required and an explanation provided. Where the ADS is determined to have played a role in causation, the manufacturer will provide evidence of how related causal factors have been addressed in the final ADS prior to approval. Post-deployment collisions are covered by the ISMR process taking into account the applicable law of the country in which the collision occurred.

Proposal to revise the explanation for para. 8.3.3.1 to clarify the relationship between assessment of the manufacturer’s testing under 8.3.2 and confirmatory testing. The revision adds language specifying that during assessment, the assessor can determine the need for additional scenarios or variations and shall convey this information to the manufacturer requesting additional test evidence under agreed upon protocols. The revision changes “trustworthy” to “accurate” and specifies that confirmatory testing verifies the accuracy of the manufacturer’s testing, with the exception of real-world testing that cannot be precisely replicated.

Proposal to revise explanation of Annex 3 in the draft guidance document. The change proposes language clarifying that performance issues constitute an unreasonable risk to safety only when deviations, degradations, or limitations in ADS capabilities, based on analysis of their frequency and severity, present an unreasonable risk within the declared ODD. The revision specifies that listed factors are examples for consideration in determining whether an unreasonable risk exists but do not necessarily constitute such a risk themselves.

Proposal to delete from the interpretation of failures to meet ADS requirements under para. 6 in Annex 3 the items “Collisions” and “Deviation from Remote Interaction/Intervention as described in the Safety case,” as these are not ADS requirements under para. 6, and collisions are otherwise reportable under the critical occurrences criterion.

Proposal to insert provisions clarifying that when assessing manufacturer’s testing activities under paras. 8.3.2.1.1, 8.3.2.1.2, 8.3.2.2.2, and 8.3.2.2.3, the approval authority or designated technical service may identify situations or scenarios not included in manufacturer’s test evidence, convey that information to the manufacturer, and request additional test evidence covering those situations or scenarios under agreed upon protocols, with the assessor able to determine the need for variations to tested scenarios or conditions to verify that the manufacturer’s evidence is representative and able to support the safety case, where variations may include adjustments to initial conditions, parameter ranges, or environmental assumptions within the bounds or at the boundaries of the declared ODD but may also consider behaviour at ODD exit or outside the ODD, with such variations expected to be reasonable and compatible with the limitations and abilities of the toolchains and allow comparison with initial results provided by the manufacturer or be assessable against the expected behaviour of the system.

Proposal to clarify MRC for ADSF-2 in para. 6.1.5.4.1. The revised text corrects the assertion that ADSF-2 features can meet a lower standard for MRC because of fallback user presence in ADSF-1. It clarifies that ADSF-2 features do not include an ADS fallback response requiring a fallback user, though such features may be present in vehicles with human users. Both ADSF-1 and ADSF-2 features must aim to bring the ADS vehicle to a stop in a safe location complying with traffic rules following ODD exit.

Proposal to revise Annex 3, item 2 regarding “ADS failure to achieve a mitigated risk condition when necessary.” The revised text maintains the four bullet points describing when such occurrence is expected to be reported when an MRC is required. The rationale states the regulatory text does not require reporting when an MRC is achieved but in an unsafe stop location, which is not defined in the regulation, nor when an MRC is achieved but conflicts occur during the MRC.

These provisions require manufacturers to contact authorities in territories where features of the ADS can be active in advance of formally applying for approval. The intention is to make receiving authorities aware that an automated vehicle is destined for their territory. An ADS or feature whose ODD includes a geo-fence limiting operation to specific territories is clearly destined for just those territories. A manufacturer is not required to notify authorities in countries where the manufacturer does not intend to sell or operate the ADS or vehicles equipped with the ADS.

Proposal to add a bullet citing Automated Vehicle Safety Consortium (AVSC) Best Practice for ADS Remote Assistance Use Case (Nov. 27, 2023), available at https://avsc.sae-itc.com/publication/avsc-04-2023, which provides detailed explanation of different discrete functions underneath the broader remote operations heading, divided into interactions with vehicles or a fleet of vehicles and interactions with humans, with each then divided into more specific types of functions.

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

SAE J3134 is copyright protected – Please read the disclaimer on first page.

In 2011 a particle number (PN) limit was introduced in the European Union’s vehicle exhaust legislation for diesel passenger cars. The PN method requires measurement of solid particles (i.e. those that do not evaporate at 350 °C) with diameters above 23 nm. In 2013 the same approach was introduced for heavy duty engines and in 2014 for gasoline direct injection vehicles. This decision was based on a long evaluation that concluded that there is no significant sub-23 nm fraction for these technologies. This SAE paper (2015-24-2512) examines the suitability of this PN method for L-category vehicles (two- or three-wheel vehicles and quadri-cycles).

Barouch Giechaskiel, Alessandro Zardini, and Giorgio Martini (EC Joint Research Centre) SAE paper examining the suitability of current EU particle number methods for application to motorcycle-type vehicles.

SAE comments on the working document for ADS safety requirements.

Proposal to clarify that some ADS configurations would not expect any occupant role in driving the vehicle during a trip.

Proposal to clarify statement concerning driving automation systems below the level of an ADS.

Proposal to differentiate ADS capabilities to perform the DDT from other ADS functional aspects.

Proposal to clarify the introductory explanation concerning DDT performance across scenario conditions and use of representative tests.

Proposal to clarify introductory text concerning attention to ADS capabilities outside the scope of DDT performance.

SAE comments on the Chinese proposal to update the ‘resistence to atmospheric agents’ test by applying the spectral energy distribution of sunlight as defined in CIE Publication No. 85:1989, Table 4.

In document GRE/2011/35, China proposed to update the ‘resistance to atmospheric agents’ test under UN R112 by applying the spectral energy distribution of sunlight as defined in CIE Publication No. 85:1989, Table 4. Following up on its initial response (document GRE-68-41), SAE explains its opposition to the proposal.

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.

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