Detailed analysis on the compatibility or incompatibility of the scopes and technical provisions for trolleybuses of UN Regulations Nos. 100 and 107
Document GRSG-111-21
11 October 2016

The proposal by Belgium GRSG/2016/05 aimed at removing the amended additional safety prescriptions for trolleybuses from annex 12 of UN Regulation No. 107 for the Construction of M2 and M3 vehicles (R107), and inserting them into UN Regulation No. 100 on Electric Powertrain Vehicles (R100), see proposal GRSP/2016/07. This document explains how the scope and technical provisions for trolleybuses of R100 and R107 are complementary, but not yet fully compatible.

Submitted by Belgium
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Previous Documents, Discussions, and Outcomes
2. | Regulation No. 107 (M2 and M3 vehicles)

5. The expert from Belgium recalled the discussion at the previous GRSG session on ECE/TRANS/WP.29/GRSG/2016/5 and presented a detailed analysis on the compatibility or incompatibility of the scopes and technical provisions for trolleybuses of UN Regulations Nos. 100 and 107 (GRSG-111-21). As an outcome of this analysis, she recommended to fully align the provisions of the UN Regulations concerned. She added that the removal of the safety prescriptions for trolleybuses from UN Regulation No. 107 and their presence in UN Regulation No. 100 on electric power trained vehicles would avoid a double type approval process. She announced her intention to also submit the outcome of the analysis to the experts of the Working Party on Passive Safety (GRSP). GRSG welcomed the important work done by the Belgium delegation.

6. The expert from France preferred to keep the provisions for trolleybuses in UN Regulation No. 107. He added that a double type approval was only necessary for hybrid vehicles and that the provisions for trolleybuses in UN Regulation No. 107 were still necessary for trolleybuses with conventional propulsion systems. The expert from Switzerland endorsed that position. The expert from the Russian Federation raised a study reservation. The expert from OICA underlined the need to align the provisions for trolleybuses in UN Regulations (e.g. ‘isolation’ to be replaced by ‘insulation’).

7. Referring to the discussion of WP.29 at its June 2016 session (report ECE/TRANS/WP.29/1123, para. 30), GRSG agreed to also involve the experts from the Working Party on Lighting and Light-Signalling (GRE) and GRSP at their forthcoming sessions. GRSG agreed to take a final decision on this subject at its next session in April 2017 awaiting the outcome of the discussion in GRE and GRSP. For that purpose, the secretariat was invited to keep GRSG-111-21 on the agenda as a reference document.

17. | Regulation No. 100 (Electric power trained vehicles)

39. The expert from Belgium introduced ECE/TRANS/WP.29/GRSP/2016/7 to transfer additional safety provisions for electrical safety of trolleybuses from UN Regulation No. 107 (M2 and M3 vehicles) to UN Regulation No. 100 (Electric Power Trained Vehicles). She clarified that the proposal aimed at informing GRSP about the issue of interpretation of the scope of the two Regulations to cover electrical safety of trolleybuses. The expert from EC suggested an in-depth analyse to verify if the proposal would be correctly allocated as an amendment to UN Regulation No. 100. On this issue, the expert from OICA argued for more clarity. He added that for the time being he was not in the position to provide an answer. He suggested that closer coordination on this subject with other Working Parties, such as the Working Party on General Safety and the Working Party on Light and Lighting-Signalling, should be encouraged. He finally suggested asking guidance from WP.29 at its June 2016 session on the way forward. GRSP also noted that electrical safety of trolley buses had many implications on different UN Regulations such as UN Regulations Nos. 10 (Electromagnetic Compatibility) and 107 (Approval of category M2 or M3 vehicles with regard to their general construction). GRSP noted that GRSG at its April 2016 session had preferred to maintain the provisions on trolley buses into UN Regulation No. 107. GRSP agreed to resume discussion on this subject at its December 2016 session. In the meantime, the expert from Belgium volunteered to conduct a detailed analysis and to introduce a proposal on all related issues to GRSG and GRE and to submit an informal document to the June 2016 session of WP.29 to explain the issue and in the view of receiving guidance.

2. (a) | Proposals for further amendments

6. The expert from Belgium presented ECE/TRANS/WP.29/GRSG/2016/5 proposing to remove the new safety prescriptions for trolleybuses from UN Regulation No. 107 and insert them into UN Regulation No. 100 on electric power trained vehicles. The expert from UK raised concerns about the differences in the scopes of both Regulations and their application to trolleybuses. GRSG noted the comments by the Working Party on Lighting and Light-Signalling (GRE) about possible alignments of UN Regulations Nos. 107 and 116 with UN Regulation No. 10 on electromagnetic-compatibility (GRSG-110-04). The expert from OICA introduced GRSG-110-08-Rev.1 on the applicability of UN Regulation No. 100 versus Annex 12 of UN Regulation No. 107 with respect to electrical safety provisions. The expert from France explained that the origin of the current problem of trolleybuses was linked to the application of the European Union (EU) legislation on whole vehicle type approval. The expert from Japan informed GRSG about the intention of the Chair of GRE to seek the advice of WP.29 on this subject at the forthcoming session in June 2016. The GRSG Chair questioned the need to also involve the experts of the Working Party on Passive Safety (GRSP) in charge of UN Regulation No. 100. A number of experts expressed their preference to keep the electric safety provisions within UN Regulation No. 107. Thus, GRSG agreed that the experts of the Working Parties concerned should work on a simple solution avoiding further burden for public transport operators. The expert from Belgium volunteered to conduct a more detailed analysis on the compatibility or incompatibility of the scopes and technical provisions for trolleybuses of UN Regulations Nos. 10, 100 and 107.

7. GRSG agreed to resume consideration of this subject at its next session in October 2016 awaiting the outcome of the analysis by Belgium. GRSG requested the secretariat to keep ECE/TRANS/WP.29/GRSG/2016/5 on the agenda as a reference document.

Related and Previous Documents
GRSG/2016/5
GRSP/2016/7
Relates to UN R100 | UN R107 |