J presented document LKAS-02-02 as the results of the discussions that took place at GRRF-78, where the Chair requested wording improvements, and the status of the system as “ready to intervene”.
NL questioned the case when the system is intervening then the markings disappear, hence the LKAS turns to switched-off status. NL was of the opinion that, in that case, the LKAS should continue warning after it is turned into switched-off status.
CLEPA recalled that the group agreed that the driver is assumed to be monitoring the driving tasks.
OICA presented the OICA input amending GRRF-78-11. This document was amended by the group as follows (changes can be found in document LKAS-02-04):
- The European Commission challenged a reference to paragraph 5.1.1., as unnecessary as paragraph 5.1.1. should anyway be fulfilled. The expert nevertheless found the original text clearer than the OICA proposal.
- A debate took place on the wording “fade out in a progressive manner”:
- Redundant hence confusing statement (repetition of paragraph 5.1.1.)
- No time or moment figure available from Industry
- As the technology is still rather immature for being regulated, J found that general requirements should be preferred to precise figures
- Yet the OICA proposal refers to figures currently existing in UN R79
- The system is not designed to work in tight curves, rather in “highway conditions”.
- J could support the proposal from OICA; yet the expert wanted to ensure whether the Technical Services could assess the system under such wording.
Conclusion paragraph 126.96.36.199.: the group agreed on a final wording (see LKAS-02-04 sent to the group as ECE-TRANS-WP29-GRRF-2015-XXe (LKAS adhoc group) R79 draft LKAS V1).
J presented the document LKAS-02-05, proposing amendments to GRRF-78-14 for introduction of ACSF provsions into UN R79.
The European Commission welcomed LKAS-02-05 as automatic driving is a subject that is currently discussed at EU level, yet found that the subject goes a bit beyond the usual Type Approval regulations.
CLEPA also welcomed the document
OICA presented a short PPT presentation on lane changing maneuvre on highways. The driver must voluntarily activate the system.
OICA supported CLEPA, and supported opening UN R79 to this technology.
NL found the document a good starting point but found necessary to get more precise requirements.
J pointed out that the requirements can be different according to the systems. The expert recalled that the aim is to maintain road safety via an “if fitted” regulation. He acknowledged that this proposal mainly provides design requirements.
The Chair, as S representative, found it a good start: lane keeping and lane changing system.
J found lane changing assist a very important system and was keen to put the necessary resources to provide the relevant requirements, primarily focusing on highway situation. The expert wondered whether such system, in particular for emergency lane change, are covered by the Vienna Convention.
OICA made the comparison with ESP, where the driver must provide an input, but the system intervenes only when the driver cannot anymore master the situation. Concerning the text, OICA found the structure improved compared to the document presented at GRRF-78, e.g. regarding the modified definition of Automatically Commanded Steering Function
The secretary pointed out that there is a need to open the regulation for permitting the Industry to start designing the technology.
CLEPA found the proposal wise as restricted to certain use cases, and the expert was of the opinion that the regulation could evolve in the future with the evolution of the technology.
OICA informed that regins do not have the limitation of 10km/h and that there is a need that the UN region can take profit of the new technologies. The expert voiced that UNECE should not be left behind, but should rather open up to such new technologies, with appropriate requirements to ensure safety.
The group went through LKAS-02-03 document.
Paragraph 188.8.131.52.4. (b):
- The group convened that the transient from auto mode to manual mode is a key to the system safety. As there is a need for a certain time, J found the 2 seconds a minimum. There is a need also to find a consensus wording avoiding different interpretations. Yet the different situations should be taken into account, and there is no guarantee that the system can predict the future such in advance.
- There was a debate about the origin of the 2-second value, in comparison of the limits adopted at AEBS. Some experts indeed feared that the 2-seconds requirement is too demanding.
- Other case: degraded mode
- Sub-paragraph (b) in J approach was clarified: it addresses both fault and non-fault conditions; while (b) in CLEPA approach only addresses non-fault conditions (fault conditions are addressed in sub-paragraph (c) ).
Paragraph 184.108.40.206.4. (c):
- Agreed that the CLEPA proposal addresses the fault conditions
- OICA informed having very much challenges with regard to PTI and OBD, and suggested that this PTI item is extracted from AEBS up-to-date regulation.
- J was keen to explain a proposal for OBD.
- NL supported a text aligned on that of AEBS, having no connector, rather a simple warning lamp. The delegate insisted that PTI should remain a quick and simple check.
- CLEPA challenged as well the Japanese approach: no standardized connector, data, protocols, etc.
- The European Commission informed about high probability that the EU requires an OBD-X (safety related OBD)
J presented LKAS-02-07 on OBD:
- The delegate from J informed that the document is a pilot project for assessing the possibility of OBD for safety systems.
- OICA had the following comments:
- Misunderstanding in what is OBD: OBD is not necessarily an electronic interface readable by a scan-tool. This is the technical solution chosen for emission systems, where the history and background is different from safety systems. OBD is primarily a system which has the capability of detecting malfunctions and to communicate them off-board. The definition in OBD GTR clarifies what is OBD.
- The safety systems currently in the vehicles do fulfil most of the OBD requirements (e.g. the system has the capability of detecting malfunctions and indicating their occurrence by means of an alert system…). Safety regulations have followed a different route compared to emission system regulations (e.g. fault detection and warning to driver is required “since forever” for safety systems. This approach is consolidated by the CEL Annex, which does not exists for emissions).
- OBD is a subject wider than LKAS/ACSF, hence should be discussed at another level.
- Do not confuse roadworthiness (safety at PTI) vs. repair and maintenance at service station.
- e.g. the EBS contains 1100 failure codes
- Only the effect of the faiures on the performance of the system is important for safety, not the root cause of the failure.
- The root cause of the failure is important only to repair the vehicle.
- OBD provisions cannot be copy/pasted from emissions as emissions are one system while safety systems are maybe 15 or 20 systems or functions, with different variants for every manufacturers… Thus the emission approcah is not relevant for safety systems. It would generate huge costs for industry, without clear benefits.
- Data are protected by private life data protection as they own to the vehicle driver.
- The expert warned about the danger of actuating the equipment for the sake of PTI as this can damage some safety devices.
- Anti-tampering: when all codes and protocols are freely available, then hackers have easier access to the manufacturers internal safety systems. From this standpoint, current UNECE requirements are securing the confidentiality of vehicle manufacturers measures to protect against simple unauthorized modification (e.g. 220.127.116.11 in UN R79).
- The Chair recalled about the never ending discussions being held with OBD for emissions.
- The European Commission
- informed that they are looking to the possibility to mandate OBDX for safety systems, in the frame of roadworthiness. The expert from the European Commission was of the opinion that there is no need to check at PTI that the vehicle systems which are optional have to correctly function (example of the wiper).
- Was keen that OBD be discussed in depth within this informal group.
- J was keen that the driver can maintain the vehicle/system by himself, hence the need to make the data and protocols available. He found unfair that the dealer has access to the data, and not the owner. Yet the owner can buy the necessary equipment.
- OICA reminded repair and maintenance is a topic which is separate and not linked to safety or roadworthiness of the vehicle.
- The Chair cited the recitals (17) of the EU directive 2014/45. (note: recitals in EU directives are not requirements).
- NL stated that OBD should not be used for checking safety system at PTI. The tell-tale should illuminate when there is a direct danger, no need for OBD in this perspective. PTI should remain a simple check.
- European Commission to provide input on this item for next meeting
- Item to remain in agenda.
- Strong reluctance from Industry.