  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.
