Excellent discussion. I am very wary of frameworks though. Frameworks and guidance rarely lead to best practices. What they do is provide legal air cover for the lowest bars. What is needed here are detailed scenarios. Yes it’s a massive undertaking — better get started.
As for simulation as the primary test tool and validating the simulation I could not agree more. That needs to be qualified since most of the simulation products in this industry are inadequate and will provide massive false confidence. Simulation fidelity testing like the FAA runs in the US should be the guide. Key issues with most systems is they are not proper real-time, full motion simulators are not being used and vehicle, tire and road models are not precise enough especially in degraded conditions. If all of this is not done right and qualified to some level of sigma at a factor better than a human it will cause far more harm than good.