Proposal of a research project to assist the ACSF informal group in the development of provisions for the approval of lane-keeping and lane-change assistance and other ACSF systems.

This is a copy of the document prepared during the third LKAS ad hoc group session (document LKAS-03-09) proposing refinements to the draft amendment to UN R79 that would enable the type approval of lane-keeping systems that incorporate automatic steering functions operating above 10 km/h (document GRRF-78-14).

41. The expert from Sweden introduced ECE/TRANS/WP.29/GRRF/2015/2 as amended by GRRF-79-04, submitted by the LKAS small drafting group and introducing definitions and related LKAS requirements in to Regulation No. 79. The proposal received some comments. The expert from Japan introduced GRRF-79-29 in conjunction with item 12(b) below. GRRF agreed to resume discussion at its September 2015 session based on revised proposals.

50. The expert from Japan introduced GRRF-79-29, presenting the proposals on LKAS discussed under item 9(b) as well as GRRF-79-15 tabled by the expert from Japan and Germany, superseding ECE/TRANS/WP.29/GRRF/2015/4 and proposing amendments to Annex 5 to the Consolidated Resolution on the Construction of Vehicles (R.E.3) inserting provisions for Remote Controlled Parking (RCP) systems. Noting that traffic rules in some countries would require the driver being seated in the car during its motion, and also noting the preference of GRRF to not amend R.E.3 for this purpose, GRRF advised the authors of the proposal to consider a new Regulation for RCP. GRRF agreed to resume consideration on this item at its September 2015 session.

The LKAS group proposes several options for the transitional period for consideration and eventual decision by the GRRF. Industry proposes a three-year period before entry into effect while some government representatives propose immediate entry into effect for new type approvals since they believe current LKAS systems already meet the requirements.

This proposal adds text adopted during the December 2014 LKAS group session that will need to be incorporated, likely through an informal document, to the formal text submitted to the GRRF (document GRRF/2015/2).

Refinements to the text as developed during the 3rd LKAS ad hoc expert group session.

“If fitted” clause for application to the LKAS requirements proposed for introduction into UN R79.

Text prepared by the experts from the LKAS small drafting group to introduce new definitions and the related LKAS requirements in to the text of UN Regulation No. 79.

55. The Chair of GRRF recalled the activities done by the IWG on ACSF and proposed to postpone the discussion on LKAS (ECE/TRANS/WP.29/GRRF/2015/2 and GRRF-79-04) to make sure that the findings of the informal group could be reflected when working the technical provisions for LKAS. The expert from France agreed to present GRRF-80-08 at the February 2016 session of GRRF. GRRF agreed to resume consideration of this item at its nest session.

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):

Paragraph 5.1.6.2.:

• 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.

49. The Chair of GRRF recalled the activities done by the IWG on ACSF and proposed to postpone the discussion on LKAS (ECE/TRANS/WP.29/GRRF/2015/2 and GRRF-79-04) to make sure that the findings of the informal group could be reflected when working the technical provisions for LKAS. The expert from France recalled that the work on LKAS had a high priority and invited GRRF to reflect on whether a discussion on the submitted documentation should take place at this session. The experts from Germany and OICA agreed that the proposal produced by the SIG on LKAS was of a high quality but noted that some definitions should be aligned with those of ACSF. Therefore, GRRF agreed to defer the discussion to the September 2016 session. GRRF noted that LKAS were considered as discontinuous corrective steering, while ACSF would cover systems similar to LKAS but performing continuously. GRRF agreed that the boundaries of these systems needed clarification. GRRF requested the IWG on ACSF to work on the boundary definitions. GRRF agreed to resume consideration of this item at its nest session.

52. This agenda item was discussed together with the following agenda item. The secretariat noted the decision of their authors and GRRF to remove ECE/TRANS/WP.29/GRRF/2015/2, GRRF-79-04, GRRF-80-08 and GRRF-81-14 from the agenda, as the progress done under the following agenda item would cover the subjects covered by those documents.

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. 5.5.2.1 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.

Conclusion:
- European Commission to provide input on this item for next meeting
- Item to remain in agenda.
- Strong reluctance from Industry.