WBU and European Blind Union statement critical of the current draft UN Regulation for failing to adequately address the needs of the visually impaired.
21. The expert from WBU called for shared responsibility of drivers and vulnerable road users for road safety and requested that the Audible Vehicle Alert System (AVAS) of QRTV be “ON” while the vehicle is stationary and that the driver should not be able to deactivate (or pause) AVAS (GRB-62-03). He also referred to a study (GRB-62-16) suggesting that the proposed AVAS level of sound did not seem to make QRTV with AVAS more detectable to the average blind person than was QRTV without AVAS. According to the study, more research would be needed to determine a minimal noise level that would satisfy the desire to reduce noise emissions while remaining safe for pedestrians.