EC comments on the draft VGL informal group terms of reference
Document VGL-01-02/1
24 September 2015
Submitted by EC
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Previous Documents, Discussions, and Outcomes
4. | Terms of Reference
3.5.1. | Working Party on Lighting and Light-Signalling (GRE) (Seventy-third session, 14-17 April 2015)
4.2.3. | Design restrictive requirement in Regulation No. 48

50. The representative of France proposed to delete a design restrictive requirement in Regulation No. 48 for auto-levelling of headlamps equipped with any Light Emitting Diodes (LED) light sources (ECE/TRANS/WP.29/GRE/2015/21, ECE/TRANS/WP.29/GRE/73 and WP.29-166-23). The representative explained that, if LED were treated the same way as other lights sources, more LED headlamps would be fitted on new vehicles, and thus improving road safety and reducing CO2 emissions. WP.29 noted that recent studies indicate that the type of light source does not seem to be a major factor of headlamp glare, and that GRE had established an IWG to review all levelling requirements in Regulation No. 48 (para. 25 above). The EU representative stressed that also for this subject OLA should be involved to provide their analysis and preferred option.

51. WP.29 stressed that, in line with the text and spirit of the 1958 Agreement, Regulations should be technologically neutral and performance based. Therefore, WP.29 advocated the French proposal and invited GRE to adopt it and to submit it to WP.29 for consideration. WP.29 also pointed out the importance of the newly established IWG for finding a general solution for glare and visibility issues. WP.29 also instructed IWG and GRE to verify, as a matter of priority, that LED headlamps do not produce more glare compared to other light sources, to review all levelling requirements and to report back to WP.29.

6. (b) | Other proposals for amendments to Regulation No. 48

17. The experts from OICA and GTB proposed to introduce new criteria on the automatic levelling of headlamps based on the outcome of the GTB glare and visibility studies (ECE/TRANS/WP.29/GRE/2015/5). The expert from Poland suggested further modifications to this proposal (GRE-73-28). The experts from Germany and Japan proposed to impose automatic levelling in all cases, in order to reduce glare problems for drivers (GRE-73-18). Following an in-depth exchange of views on these three documents, GRE realized that no consensus could be found as long as there was no single proposal.

18. To make progress on this issue and prepare a comprising proposal, GRE decided to establish an Informal Working Group with a draft title “on Visibility, Glare and Levelling” (IWG VGL), for which the experts from Germany and Poland agreed to act as Chair and Secretary, respectively. GRE requested IWG VGL to submit its terms of reference for consideration at the next session of GRE and mandated the Chair to obtain, in June 2015, the consent of WP.29 for the establishment of this IWG.

20. The expert from France proposed to delete a design restrictive requirement in Regulation No. 48 for an auto-levelling device for low beam produced by any LED light sources, while for other light sources this requirement exists only if their reference luminous flux exceeds 2,000 Lm (ECE/TRANS/WP.29/GRE/2015/21 and GRE-73-25). According to the expert, should LED be treated in the same way as other lights sources, this would lead to more LED headlamps fitted on new vehicles, thus improving road safety and reducing CO2 emissions. The experts from Belgium, Germany, Japan and UK were of the view that this issue should be first referred to IWG VGL and be considered in one package with other proposals regarding levelling (see paras. 17 and 18 above), upon the understanding that a final solution developed by IWG VGL should be technology neutral. The experts from Italy, Spain, EC, CLEPA and OICA not only supported the French proposal as removing discrimination between various technologies of light sources, but also called for its adoption without delay, irrespective of the IWG activities. GRE agreed that the Chair would submit this issue to the June 2015 session of WP.29 for guidance and to report back to GRE at its next session.

8. (c) | Development of an International Whole Vehicle Type Approval (IWVTA)
9. | New business and late submissions
4. (b) | Regulation No. 48 (Installation of lighting and light-signalling devices)
4. (b (i)) | Proposal for amendments to the 04, 05 and 06 series of amendments

9. Taking into account the recent GTB study (GRE-71-32), the expert from France proposed to delete a design restrictive requirement for an automatic levelling device for all headlamps with LED light sources, irrespective of their luminous flux (ECE/TRANS/WP.29/GRE/2014/34). GRE agreed that this proposal should be tackled at the next session, in conjunction with the GTB proposals on visibility and glare issues (see para. 14 below).

4. (b (ii)) | Proposal for amendments to the 06 series of amendments

14. The expert from GTB recalled the outcome of the GTB study on visibility and glare (GRE-71-32) and presented a first draft of amendments to Regulation No. 48 addressing the visibility distance and glare issues (GRE-72-07). This proposal received comments by the expert from Poland (GRE-72-23-Rev.1). Various experts generally agreed that the current requirement for automatic levelling in Regulation No. 48 (2,000 lm luminous flux of the light source) should be replaced by other deciding factors for headlamp glare, such as the vehicle pitch angle, loading conditions and initial headlamp aiming. However, no consensus was reached on exact replacement criteria. The expert from UK suggested that an informal group be established to speed up the finalization of the amendment proposal. The experts from France, Germany, Italy and the Netherlands were of the view that GTB should be tasked to submit a concrete proposal to the next session of GRE. GRE invited GTB, OICA and interested Contracting Parties to organize a meeting with the aim to elaborate a revised proposal. The experts from France, Germany, Italy, Netherlands, Poland and UK expressed their interest in participating in this meeting.

4. (b) | Proposal for amendments to the 06 series of amendments

11. The expert from GTB introduced the results of their studies on visibility and glare (GRE-71-15 and GRE-71-32). The study concentrated on levelling in relation to load and its major objectives were to improve the understanding of different factors that influence visibility and glare and to identify results of the study that might reveal alternatives for automatic static levelling. The expert from OICA recalled their presentations on loading definitions and achievable aiming tolerances (see also GRE-67-27 and GRE-68-20).

12. The expert from Poland introduced a revised proposal ECE/TRANS/WP.29/GRE/2014/11 on initial aiming of dipped-beam headlamps and considering the original 75 +/-25 m visibility distance requirement.

13. GRE was of the view that the study had pointed out that the type of light source and its luminous flux are not the deciding factors in headlamp glare. Instead, the most important factors seem to be the vehicle pitch angle, loading conditions and initial headlamp aim. Therefore, the light source choice (LED) and the light source 2,000 lm criteria in UN Regulation No. 48 were found unnecessarily restrictive and creating barriers to new technologies. Different views were expressed whether automatic levelling should become a requirement for all categories of vehicles and light sources. Operating voltage was also mentioned as an additional factor of glare.

14. GRE invited the experts from Poland, GTB and OICA to submit one coherent proposal for amendments to UN Regulation No. 48 addressing the visibility distance and glare issuto the next GRE session.

4.6. | Consideration of draft amendments to existing Regulations submitted by GRE

55. Under agenda item 4.6.5 (UN Regulation No. 48), the World Forum agreed to defer consideration of document ECE/TRANS/WP.29/2011/99 and Corr.1 to its June 2012 session, subject to a final review by GRE at its March 2012 session.

Related and Previous Documents
GRE/2011/27
GRE-65-03
GRE-65-17
GRE-65-16
WP.29/2011/99
WP.29/2011/99/Corr.1
WP.29/2011/99/Corr.2
GRE-71-32
GRE-72-07
GRE/2015/5
GRE-73-28
GRE-73-18
GRE/2015/21
WP.29-166-23
Relates to UN R48 |