AEBS/LDWS-14-09
Proposed amendments to Annex 3 of document GRRF/2011/24 (AEBS – collision mitigation regulation)
Source(s)
Date
5 May 2011
Status
Subject
Meeting(s)
UNECE server
Excerpts from session reports
AEBS/LDWS | Session 15 | 26-27 May 2011

The Chair recalled the interpretation of the UNECE Secretariat that should the cells of Row 3 be blank, the vehicles in stake would be excluded from the performance requirements of the regulation.

OICA informed that some Technical Services interpretation was that in the case of blank cells, the vehicle presented for Type Approval would have to comply with the general performance requirements of paragraph 5. The Chair concluded that in view of this different opinion that there was currently no clear interpretation of the situation.

The informal group started the revision of the document AEBS/LDWS-15-01 (00 series of amendments).

OICA presented the document AEBS/LDWS-15-05 proposing to simply delete the row 3 due to the fact that a Collision Warning System (CWS) cannot be considered by the vehicle manufacturers as an AEBS corresponding to the definition currently existing in the text of the draft regulation. The expert from
OICA recalled that the vehicle manufacturers have today no experience nor knowledge about the
behaviour and consequences of the fitment of such system in wide scale on the vehicles. OICA stated
that the vehicle manufacturers are ready to start the analysis of such technology in the context of a
rulemaking in the frame of UNECE, if the Contracting Parties would wish to do so. Concerning AEBS
itself, the vehicle manufacturers could only provide technical expertise for existing technology or
technology currently under development, but would not be ready to provide advice to non-existing
technology as this would not be credible. The logical consequence of such situation would then be to simply delete the proposed row 3 of the table of documents AEBS/LDWS-15-01 & 02 for the time the technology is being developed. In this context, the scope of the regulation should be limited to the proposal as in document AEBS/LDWS-15-05.

CLEPA recalled that the best they could offer was the proposed performance requirements tabled in document AEBS/LDWS-14-09, but stated that CLEPA could support the “no requirement” approach proposed by OICA OR some clear requirements. UK had concerns about the “no requirement” route, because it would be contradictory to harmonization.

The expert from the UK informed about their proposal (applying to Step 1 only):
- M2 toward stationary target (cells B3, B4, B5): blank cells
- N2<8t toward stationary target (cell B5): no requirement
- M2 toward moving target (cells E3, E4, E5): flexible willing
- N2<8t toward moving target (cell E5): to be discussed.

Japan recalled that the GSR demands requirements for the vehicles of category M2 and N2, also for those with GVW below 8 tons. J was keen that the requirements of all categories be discussed at UNECE rather than EU level, hence requested that technical requirements be discussed for all categories M2/N2/M3/N3 in the context of UNECE and that the mandatory fitment be discussed at the level of each Contracting Party. The expert from J informed about their sympathy for the UK approach. F informed being present mainly for listening the technical arguments of the different parties, hence could not provide any position nor take any decision.

The Chair recalled that the informal group in this context (five Contracting Parties present, of which two could not provide positions) could anyway not make any decision, but was requested by GRRF-70 to explore and propose possible solutions for the outstanding issues.

CLEPA could accept the deletion of their proposal for stationary target test (see document AEBS/LDWS-14-10). The expert from CLEPA however was of the opinion that these cells should not be blank as this would open the requirements to anything wished by any Contracting Party, preventing the manufacturers from a clear vision of the requirements worldwide.

The Chair requested clarification about the OICA proposal of document AEBS/LDWS-15-05:

1) OICA proposal seems to go out of the mandate of the informal group as it does not propose pass/fail criteria, rather except some vehicles from the scope of the regulation.

OICA clarified that the vehicle manufacturers currently have some clue of the technical feasibility for heavy vehicles, and as a consequence could accept requirements applying to these vehicles. For the vehicles where there is no development today, the expert made clear that OICA cannot describe in detail the requirements for a further step. OICA informed to be ready to develop some systems, but could not define them in advance. For CWS indeed, OICA insisted on the need to collect some experience.

2) What would OICA recommend as performance requirements if the regulation does only reproduce the state of the art?

OICA informed that for the vehicles in Row 3 (N2≦8 t and M2), the development would still to be started. OICA would favour to bring some vehicles on the market first, but could not commit on some figures or technical requirements for the time being.

The Chair then questioned how the informal group could meet the terms of reference and how to explain this situation to GRRF. OICA pointed out the difference between the legal system at UNECE level, demanding requirement description, which is not possible for future technology, and the legal system at EU level, not demanding requirement description.

The Chair, as representative of the European Commission, informed that the EC cannot accept a scope not including all vehicles covered by the General Safety Regulation. In this case, the European Commission could not propose the Member States to sign up such Regulation, and as a consequence would not be bound by the UNECE AEBS Regulation. This IG meeting is the last possibility for the Commission services to show flexibility, as there is not yet a draft implementing measure on AEBS under the GSR tabled. He added that the European Commission would have some sympathy for the UK proposal.

OICA clarified that, with regard to the UK proposal, they could not accept a CWS. In the case of an emergency braking system proper, the AEBS for vehicles with hydraulic braking system is not currently under development.

D recalled that the UNECE context provides possibility to promote optional requirements for vehicles where the technology is being developed.

The Chair concluded that there appeared to be no room for progress unless parties would be ready to show some willingness to change their position.

The group then started the revision of document AEBS/LDWS-15-02 (01 series of amendments)

OICA presented the document AEBS/LDWS-15-05: OICA informed having currently no knowledge for those vehicles in row 3 (N2≦8 t and M2), suggested to keep them out of the scope of the regulation during the time of their development, but was ready to change the regulation in the future for introducing some additional categories into the regulation.

D reminded that knowledge about those vehicles is lacking and suggested optional requirements.

CLEPA stated that, if there are long term phases between the two series of amendments, there is no reason for avoiding accurate requirements. The expert informed that CLEPA would accept no requirement at all for these vehicles in the early stage, but would not support undetermined requirements in the 2nd stage. If there is short term between the stages, CLEPA would support the OICA position.

Japan requested clarification about a possible conflict about the deletion of row 3 between 2013 and 2016 with the European GSR, and hence confirmed their position as in step 1.

D was keen that all vehicles be included in the scope of the regulation, and solving the non-existing technology by the way of footnotes committing to further development. The expert in consequence promoted a blank row 3.

The European Commission clarified their position that if there would be no significant difference in stringency of the requirements between the 2 series of amendments, then there would be no need for a 01 series.

Conclusion:
- New 3rd option from OICA, for the 1st step, per document AEBS/LDWS-15-05,
- No clear support from the other parties for this 3rd option.
- No progress made by the informal group towards reaching consensus on this item