Poland comments on the draft VGL informal group terms of reference
Document VGL-01-02/2
24 September 2015
Submitted by Poland
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Previous Documents, Discussions, and Outcomes
4. | Terms of Reference
6. (a) | Proposals for amendments to the 05 and 06 series of amendments
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.

8. (c) | Development of an International Whole Vehicle Type Approval (IWVTA)
4. (b) | Proposal for amendments to the 06 series of amendments

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. | Regulation No. 48 (Installation of lighting and light-signalling devices)
4. (a) | Proposal for amendments to the 04, 05 and 06 series of amendments
4. (b) | Proposal for amendments to the 06 series of amendments

12. The expert from Poland presented GRE-70-41, introducing ECE/TRANS/WP.29/GRE/2013/57 and proposing performance based requirements on initial aiming of dipped-beam headlamps as an alternative to the existing requirements. The proposal received some comments (GRE-70-42). The expert from France requested adding proper tolerances from the Conformity of Production provisions. GRE agreed to revisit this subject (on initial aiming and considering the original 50 m visibility distance requirement) at its next session on the basis of a revised document, which the expert from Poland volunteered to prepare.

4. (c) | Other amendments to Regulation No. 48
5. (d) | Regulations Nos. 48 and 112
5. (f) | Regulations Nos. 6 and 48
4. (a) | Proposal for amendments to the 04, 05 and 06 series of amendments
4. (b) | Proposal for amendments to the 06 series of amendments

12. The expert from Poland introduced ECE/TRANS/WP.29/GRE/2013/15 proposing an alternative to the existing initial aiming provisions. The experts from France and the United Kingdom requested the author to clarify the aspect linked to the measurements and to specify the measurement method as well as the tools to be used. The expert from the Netherlands supported, in general, the proposal but questioned waiving automatic levelling as an incentive to use this alternative method. GRE agreed to resume consideration on this matter at its October 2013 session on the basis of an updated proposal prepared by the expert from Poland in collaboration with experts from France, the Netherlands and the United Kingdom.

4. (c) | Other amendments to Regulation No. 48
5. (e) | Regulations Nos. 19, 48 and 98
5. (j) | Regulations Nos. 6, 7 and 48
Related and Previous Documents
GRE-65-30
GRE-73-18
GRE-73-17
GRE/2011/32
GRE-66-17
GRE/2012/21
GRE-67-33
GRE-67-37
GRE/2012/27
GRE-68-31
GRE-68-32
GRE-68-34
GRE/2013/15
GRE-70-41/Rev.1
GRE/2013/57
GRE/2014/11
Relates to UN R48 |