Informal Group on Accident Emergency Call Systems | Session 2 | 5-6 Dec 2013
Paris
Agenda Item 8.3.
Requirements

Paragraph 6.1. (EMC), Paragraph 6.2. (climate resistance) and 6.3. (mechanical resistance)

OICA informed that the 05 series of Regulation No. 10 will be ready very soon, and found that requirements for EMC are not necessary as it is common to the vehicle.

Russia found necessary to keep a reference to UN R10.

Conclusion: need for provisions that the AECD is not affected by electromagnetic field with reference to ISO-7637. Item to be confirmed at next meeting, together with replacement of paragraphs 6.1.1. and 6.1.2. and 6.1.3 with relevant references.

OICA questioned the presence of requirements on climate and mechanical resistance because other systems in vehicles do not have such requirements. This does not exist for e.g. lighting devices.

Russia agreed to replace Annexes 6 and 7 by relevant references and stressed that UN R116 for example does include climate resistance provisions.

Secretary proposal: copy/paste of paragraph 6.4. of UN R116

Russia stated that these requirements are in fact in the current Annex 6 of the Russian proposal.

Conclusion for EMC, climate resistance and mechanical resistance: all experts to verify for next meeting how best replace relevant annexes by references.

Paragraph 6.4. (Post-crash resistance)

Conclusion:

  • Agreement that post-crash resistance is addressed in the regulation.
  • All experts to review this internally for next meeting.

Paragraph 6.5. (reception of GNSS)

Russia found the OICA proposal not complete, and was keen that the reception of 2 GNSSs should be added at this place if deleted from the definition section.

The European Commission committed to confirm compliance of future Galileo with draft Annex 9. OICA wondered whether those detailed specifications of Annex 9 are appropriate for Type Approval process. The expert noticed that in addition, they are GLONASS related rather than GNSS-free.

The expert from Russia pointed out that the proposed annex 9 cannot be replaced with CEP95 test because the latter addresses only stationary test scenario and does not cover a number of essential parameters. Russia was of the opinion that GLONASS and GPS are cited, because they are the only existing GNSSs, and encouraged EU to provide the relevant data for their system. Russia supported the technology-neutral approach in the requirements; however, test methods have to be technology-dependant as they test operation with selected specific GNSSs.

OICA suggested that this item be reviewed at the next meeting, and in the meantime reviewed by a small task force where at least one expert is from CLEPA. OICA was of the opinion that GNSS is not technology neutral (e.g. EGNOS – European terrestrial positioning system could fulfil the AECS requirements). Yet EGNOS could be a corrective system complementing a GNSS which is probably the best available technology to date. The group convened that there are other technologies that can provide positioning and beneficially complement GNSS. The group agreed not to consider other possible augmentation systems and/or alternative positioning technologies and concentrate on the GNSS systems.

Conclusion:

  • Agreement to focus on GNSS technology
  • Interested experts will organize a re-check of the Annex 9, with the participation of the experts from the supplier industry.
  • Deadline: 3rd meeting of the informal group.
  • Interested experts to contact Secretary for coordinating the work (probably via webex meetings)

Paragraph 6.6. (communication with mobile phone network)

Russia acknowledged the different mobile networks in different Contracting Parties, and the fact that Japan is not using GSM. Russia agreed with the possibility to display the relevant networks in an annex. Russia added that based on known frequency utilization policies, in Russian the regulation would continue to include both GSM and UMTS requirements.

Japan supported the OICA proposal of adding an annex. Japan committed to check the networks relevant for Japan for the next meeting.

OICA pointed out that the system cannot work with all networks worldwide and proposed to review the functioning of such annex. The expert from OICA proposed to refer to GSM as a minimum requirement and add other networks for markets where the system is intended to be marketed. He recalled that the network providers are the only party having no obligation and may change their network.

The European Commission committed to provide for next meeting a position with regard to acceptability of GSM as a minimum requirement. Japan confirmed to the group that GSM (2G) networks do not exist in Japan at all.

The UK suggested inspiring from regulations where the system must comply with “the country where the system is intended to be marketed”.

The Secretary proposed to eradicate the detailed requirements for particular mobile phone networks, and to make it regulated nationally.

The group faced 2 possibilities:

  1. Initial proposal with detailed requirements in annex with list of existing networks, or
  2. Let it regulated nationally.

Conclusion:
Proposed wording as follows for addressing the 2nd alternative mentioned above:

  1. [The AECD shall be capable of communication on mobile telephone communication network(s) of the market where the AECD is intended to be put on the market.]
  2. [The AECD shall comply with at least the mobile telephone communication network(s) indicated in the national regulation of the Contracting Party where the AECD is submitted for approval]
  3. [The Applicant shall provide evidence of compliance of capacity of communication on
    mobile telephone communication network(s) of the markets where the AECD is intended to be marketed, by documentation.

Proposed wording to be reviewed at next meeting. Informal group may need the help of GSMA and other competent expert.

Paragraph 6.6.1. (SIM card)

Japan and OICA requested clarity about the capacity of updating information.

Russia clarified that this was intended for provisioning purposes should a network provider have this need for embedded SIM-card, as well as for the systems that are used as AECS as well as for other purposes, i.e. additional services. Russia however favoured the route of letting this regulated nationally.

OICA pointed out that this item was already discussed at EU level with the decision that separate approach (AECS vs. additional services) should be favoured.

Russia informed that SIM-IC (Subscriber Identity Module – Integrated Circuit) is mandatory in Russia.

The European Commission found it design restrictive to mandate SIM-IC in this regulation and was keen that privacy be respected and “personal SIM” could not be supported.

Russia explained that the term “personal” resulted from double translation of the term “Subscriber Identity Module” and agreed to delete the word “personal” from the regulation.

Japan requested clarification about which information is necessary to be updated. Russia informed having added the capacity of updating the SIM card profile because, in the Russian proposal, the SIM card is not removable. OICA clarified having put the word “upload” as a misunderstanding of the word “update”. Russia agreed to delete the provision of SIM card information updating capabilities if the group decides to follow the route of mobile communication network national regulation.

Conclusion:

  • Whatever the decision for paragraph 6.6., the SIM card shall be mandatory and shall be non-removable by the user.
  • SIM-IC accepted as well as SIM card depending on national regulation
  • Other requirements to be regulated nationally.

The group agreed that all could be regulated and harmonized except what concerns the communication. Yet the concern of OICA was that the regulation only covers half a system in the end of the day. Russia questioned whether this remark indicate support of the approach to list requirements per territory in the Annex to the regulation as opposed to relaying entirely to the national regulation.

Documentation
AECS-02-02 Working draft of the UN Regulation on emergency call devices