Russia questioned the necessity of the Part III because the requirements there would probably be the same as those of Part I.
The UK questioned whether the vehicles not included in the scope would have to be approved to Part II of the regulation.
Russia was concerned that in case of Part III approval all components would have to be approved in addition to the vehicle approval. The expert from Russia found the situation of AECS similar to that of UN R116, which has 2 parts. Russia favoured that the Part III provides for a kind of exceptional approval way with limited additional provisions.
A debate took place about the way to understand and treat Part III.
It was recognized that the problem of separate component certification (e.g. use of communication device with prohibited frequency), could not be solved under the frame of the 1958 Agreement. The informal group acknowledged that the manufacturers have anyway to cope with this problem separately.
Japan informed that the HELPNET system includes mobile phone networks: Japan was keen to get a clear view as to whether AECS with separate mobile phone would be included or not in the provisions of the future regulation, for making an official position on this.
The European Commission was keen that AECS can function throughout the full life of the vehicle and throughout Europe. The European Commission had doubts that separate cell-phone system does permit this. Russia supported the European Commission that there seems to be currently no place in the regulation for this possibility of separate cell phone AECS.
OICA stressed the difference of lifecycles between vehicles and cell phone networks: 10 years vs. 3-5 years (same for the development times: 5-7 years for a passenger car vs. 2 years for a cell phone). The expert added that there is no obligation for the network providers to sustain their network during a determined time and that there is currently no answer to the problem of life cycle differences. It was suggested that this is a matter of good cooperation between the 3 actors; i.e. auto industry, PSAP, and network providers.
Russia took the example of other components in the car that could fail or be subject to wear. Unless there is an obligation for the car owner to replace or repair the component, nothing can ensure the good functioning, at least at the time of Type Approval. Russia suggested sticking to the AECS with embedded network access device.
The Secretary compared the AECS network situation to the case of LDWS when a Contracting Party changes its road marking: the embedded system would then have to comply with a situation not covered by the approval. OICA hence feared problems of responsibility and user claims, should the AECS be unable to function because of network breakdown.
Conclusion: