That is not what the proposed UNECE DCAS regulations stipulate.
In general, this is how the system should perform actions (that are not just lane keeping):
A manoeuvre shall only be initiated if the driver is not detected to be disengaged, and
(a) has commanded the system to perform the manoeuvre for a driverinitiated manoeuvre; or
(b) has acknowledged the system’s intention as needed for a driverconfirmed manoeuvre; or
(c) is given sufficient notice to react for a system-initiated manoeuvre.
See article 5.3.7.2.1.1. of the
proposed regulations (interesting read!).
Given that the article states "or", either one of the options a, b or c is fine. FSDbeta v12 is in compliance I believe, as long as it (1) does not detect a disengaged driver and (2) gives sufficient notice to the driver to react before performing a system-initiated manoeuvre.
Notice the term "sufficient" notice, not measured in an absolute value. This gives some leeway to the manufacturers to defend their systems.
The notice FSD v12 provides is in the visualization.
The type of language used applies to most aspects of autonomous driving. The regulations often state that the autonomous system should be "designed to" or "aim to" do this or that (eg. smooth turns in one continuous motion), but rarely are there hard cut-offs.
They explain this in the introduction (page 3-4 of the linked document):
7. This impact of system boundaries on the system’s ability to fulfil certain requirements,and the nature of how requirements can be assessed, is reflected by the language used in thisUN Regulation.
(a) Some requirements are expected to be always met, including in all relevant tests. Theseprovisions are phrased as “the system shall…”;
(b) Some requirements are such that whilst the system is generally expected to fulfil them,this might not always be appropriate or achievable under the specific circumstances, or external disturbances may still lead to a varying output. These provisions are phrasedas “the system shall be aim to…”; and
(c) Some requirements are difficult to verify by assessing system performance directly andare more readily verified by assessing the design of the system, for example byanalysing its control strategies. These provisions are phrased as “the system shall bedesigned to…”.
Most of the regulations seem achievable with v12.
Some I cannot assess not being an engineer, such as a maximum allowed lateral acceleration when turning/following a lane (so in all conditions)
which shall not exceed3 m/s² for M1 and N1 category vehicles and 2.5 m/s² for M2, M3, N2 and N3category vehicles. (article 5.3.7.1.2.)
When this is exceeded, the system has to nag the driver or hand control to him, but it has to keep assisting in steering:
5.3.7.1.4. When the system reaches its boundary conditions set out in paragraph 9.1.3.,and both in the absence of any driver input to the steering control and whenany the front tyre of the vehicle starts to unintentionally cross a lane marking,the system shall avoid sudden loss of steering support by providing continuedassistance to the extent possible as outlined in the safety concept of the vehiclemanufacturer. The system shall clearly inform the driver about this systemstatus by means of an optical warning signal and additionally by an acoustic orhaptic warning signal.
For vehicles of categories M2 M3 N2 and N3, the warning requirement aboveis deemed to be fulfilled if the vehicle is equipped with a Lane DepartureWarning System (LDWS) fulfilling the technical requirements of UNRegulation No. 130.
I imagine the lateral acceleration limits in the above articles provides some margin and Tesla FSD v12 falls within these boundaries.
If not, it'll be hard to rewrite the software to take into account these new constraints.
That is my main concern with these regulations. But again, I imagine these restraints provide leeway.
Even most articles that state the system SHALL do so and so, provide an exemption in certain situations, for example when safety requires it (for example stopping abruptly for a spotted pedestrian). I guess Tesla will have to cooperate with the local governments to show their software is in line with the regulations.
(UNECE regulations are adopted at a European level and the European member states then have to convert this into national laws, if I understand correctly. This will add to the timeline. So if in March the current regulations are accepted and they are valid starting September 1st 2024, the national laws still have to implement these regulations).
If we see FSD in Europe in 2025 I'll be happy. Before that I'm not expecting it. 2026 or later is very possible if Tesla cannot prove to regulators its software ticks all the UNECE DCAS boxes.
