Analysis of draft EU ADS Performance Requirements

Recently, the European Commission published draft regulation for uniform procedures and technical specification for the type-approval of motor vehicles with an automated driving system (ADS). While the draft regulation is welcome progress for an industry ready to deploy life saving automated vehicle technology, we believe that the requirements can be further improved to enhance the safety and societal acceptance of automated vehicles (AVs). In this paper, we evaluate the draft regulation's performance requirements that would impact the Dynamic Driving Task (DDT). We highlight potential problems that can arise from the current proposed requirements and propose practical recommendations to improve the regulation.