b. Terms of reference
Japan presented the document LKAS-01-02 as a proposal from J for an activity plan of the LKAS ad-hoc group.
OICA found it premature to discuss another meeting date (ref Table 1 of the document). The expert from OICA explained that there is currently no vision on the future and the strategy of the ad hoc group. He suggested to discuss this item when clarification about the issues and their possible solutions will be available, at the end of the meeting.
Conclusion: item to be discussed again at the end of the meeting (see item XXX).
At the end of the meeting, the Secretary recalled that GRRF did not provide any mandate to the group, rather suggested Japan to discuss with the interested parties on this issue. Hence a simple report to GRRF would be sufficient. Japan said that the meeting permitted to make clear what kind of items must be clarified.
Japan explained the Japanese idea of the work per document LKAS-01-03:
OICA understood the document as a summary of the objectives for the future rule or guidelines, but was keen 1st that all parties have a common understanding of the objectives of the meeting. The delegate suggested to 1st define the status of LKAS.
Japan claimed having already shown justifications for the work, with relevant safety benefits.
Germany questioned whether systems showing the problems shown in slide 1 of the document 01-03 still exist.
OICA acknowledged the above, but recalled that Japan is not signatory to UN R79, while other parts of the world are. He added that the current text of UN R79 could prevent poor systems from the market and that no data today show that LKAS has caused any accidents.
Japan informed [of its intention] to sign UN R79 in the near future, hence reviewed its text in depth, and found that the regulation does not well protect from the confusions and issues tabled in document LKAS-01-03. The expert from Japan stressed that this is why Japan proposes guidelines.
CLEPA pointed out the CEL annex of UN R79, which provides all the necessary requirements that the safety of the system must fulfil to get an approval.
The group had a debate on the way to proceed, and agreed that some further discussions and clarifications are still needed, such that the group decided to get back to this item later.
Sweden was keen to introduce their vision. The Chair, as representative of Sweden, introduced LKAS-01-09, made by the
OICA found a conflict with the LDWS EU commitment. The delegate from S clarified that the document was tabled to explain the commitment of Sweden in the ad hoc group. The delegate stress that the authorities usually rely very much on the good functionning of fthe driver assistance systems, which explains the need for a certain level of performance.
The expert from OICA pointed out that passenger cars are not driven by trained professionals, rather by usual customers (e.g. rental cars). The experts were informed that in addition, Sweden believes the LKAS to be a corner stone toward autonomous driving (in Sweden, by 2016).
OICA stressed that current LKAS are used only above a certain speed, in straight roads, etc. the experts questionned whether S has the objective of making the system work in all conditions. It was stressed by OICA that there are two kinds of systems currently on the market, comfort systems and safety systems. The expert wondered whether excluding low cost vehicles because the system may be too expensive for them. J was ready to discuss this item, relating to the content of the requirements.
OICA presented document LKAS-01-08. The expert explained that CLEPA/OICA there is currently no sufficient evidence nor urgency on the need to regulate LKAS and recommended that further investigation be conducted for assessing the best way forward.
The European Commission questioned how UN R79 can guarantee that LKAS can be overridden, and how technical services can test that. TRW clarified that the threshold is usually < 3 Nm on the steering wheel. European Commission suggested that threshold values are not limiting the designers, but that some self declaration is requested such that there is some
The European Commission saw some conflict between the requirement of tendency for self center, and the autonomous steering, where the radius decreases and LKAS follows the lane.
OICA clarified that the manufacturers are sensitive to their liability, and that, should a system work in a curve, then the manufacturer would have to demonstrate the safety of the system in all modes and situation, via the CEL annex.
The Chair questioned the threshold as from which a system should be regulated.
OICA answered that only continuous systems would be in stake, and that autonomous driving is currently of concern from the Contracting Parties rather than the manufacturers, as the technology is not mature for the market.
The Chair questioned the process of Type Approval if the manufacturer only discusses with the technical service. It was clarified that the Technical Services do tell the manufacturer what they have to do, rather than the inverse. The Netherlands clarified that the
A tour de table was organized for getting an overview of the Contracting Parties’ opinions about the question of regulating LKAS:
Germany found it premature to regulate LKAS due to lack of experience. The expert requested more justification for what makes confusion to the driver e.g. in the existing systems.
The Netherlands found it strange to create guidelines on LKAS, because documents LKAS-01-04 and LKAS-01-05 address corrective or automatically commanded steering, and it is too early to regulate autonomous steering. The delegate from
The Republic of Korea found that basic features like warning types (acoustic, optical and haptic), threshold for system performances and suppression conditions should be added to UN R79.
The European Commission found these upcoming systems beneficial, and found it a waste to prevent from introduction of the technology, but on the other hand feared the introduction of dangerous systems. The European Commission would oppose minimum performance requirements, but would agree with basic rules (qualitative text). Yet some non negotiable parameters should be defined (e.g. maximum steering wheel torque that needs to be overcome to regain control). The delegate from the European Commission was of the opinion that systems permitting e.g. to read the newspaper while driving should be forbidden (autonomous steering system). He was keen that a text exist for discriminating the autonomous systems from the others.
Spain had no official position.
J recalled their intention: minimum requirements for maitaining safety.
Japan introduced document LKAS-01-05 as a skeleton paper providing the basic requirements and their justifications for a legal document concerning LKAS.
After revision of document LKAS-01-05 by the group, the Chair clarified that his intention was to consider the option of no regulation, and taking account of the LKAS, perhaps per adaptation of UN R79. The Chair stated that the exercise of assessing document LKAS-01-05 with regard to R79 coverage would permit the group to have a view on whether the discussions should take the direction of guidelines, new regulation, amendments to R79 or other. Should the group
The Netherlands found guidelines inappropriate because ISO standards can already be considered as guidelines. The delegate from the Netherlands added that guidelines would not bring safety benefits, and UNECE would not be the good platform for this type of document. He said that should Contracting Parties want to mandate a system which brings safety improvement, then a regulation would be the right choice. But as long as LKAS is considered a comfort system, then UN R79 adaptation would solve all the issues. The European Commission fully supported the Netherlands.
The Republic of Korea also found that UN R79, perhaps adapted with a new annex dedicated to LKAS, could provide an appropriate basis for addressing LKAS, in particular Annex 6 which provides a concept wide enough for integrating the safety
Japan found that amendments to UN R79 would be better than guidelines.
Germany mostly agreed with the Netherlands that a new regulation is not a good solution for the
Sweden found amendments to UN R79 as the best way forward.
OICA found necessary that some further investigation is conducted on this. Regarding amending UN R79, it could depend on the added requirements. OICA committed to review all this at the forthcoming GERF meeting.
The Chair concluded that it is too early to consider performance limits. With regard to comfort vs safety, the Chair found that LKAS could be regarded as both, depending on the situation.
The Chair questioned how the manufacturers could do today between ITS, LDWS, ISO, Vienna Convention, product liability, UN R79, for approving a vehicle.
Japan presented the document LKAS-01-04. The expert from Japan informed the group that this document was an attempt to cover Industry’s concerns with regard to LKAS.
OICA found that a column showing the items covered by UN R79 was missing (warning, failure modes, whether in the core of the text or in the CEL annex).
The expert from OICA pointed out that each item was covered in some way or another by UN R79, ISO or the current Japanese guidelines. The delegate was seeking clarification about the “purpose” column in the document LKAS-01-04, e.g. the purpose of provisions for operating speed. Japan found this similar to the provisions in the introduction of AEBS regulation. Japan was keen that some fruitful discussions take place on these items.
Japan presented document LKAS-01-05. The expert from J clarified that in general, the option numbering is from the most severe (1) to the most relax (4).
The Chair found it necessary to study in depth the documents because it shows that, even if the LKAS is covered by different texts, their interpretation is such that the level of performance can differ very much (even be opposite).
Japan was also keen to discuss the document in depth, then decide the way to proceed.
It was suggested to add a column in document LKAS-01-05 showing how UN R79 addresses each item. Conclusion: the group agreed to add a column, for assessing whether the items are covered by R79. The aim was that, at the end of the exercise, the group should decide the way to proceed, i.e. amending UN R79, elaborate new guidelines, or any other option. The Secretariat then created the document LKAS-01-05-Rev.1