3. The Chair of the informal group on Advanced Emergency Braking and Lane Departure Warning Systems (AEBS/LDWS) reported on the progress made by the informal group from the last GRRF session up to the meeting held from 9 to 11 May 2011 in conjunction with the proper session of GRRF.
4. He explained that guidance given by GRRF at its February 2010 session had been endorsed by the informal group: optional interrupting of the warning phase, the alleyway test for false reaction test, M1 saloon cars or soft targets for test targets and radar frequency spectrum allocation not covered by the Regulation.
5. He added that a number of issues had not been solved by the informal group and still needed guidance from GRRF: The scope of the Regulation(s), vehicles that should be exempted from AEBS requirements, the criteria that shall be used for the warning/activation test and the regulatory approach.
6. Regarding the possible exemption of certain vehicles from AEBS requirements, the secretariat reminded GRRF that, for the sake of clarity and transparency, it was preferable for vehicles not covered by the Regulation, to be clearly listed in the scope part of the Regulation and not in a footnote in an Annex to the Regulation. The expert from EC supported this view in GRRF-70-01 and considered that exemptions to some specific vehicles should remain in the hands of Contracting Parties and should therefore not be considered at UNECE level.
7. GRRF agreed that the only prerequisite for the fitting of AEBS was antilock braking systems (ABS) and that vehicles exempted from Electronic Stability Control (EVSC) should not directly be exempted from AEBS requirements. The expert from Italy initially raised a reservation but was prepared to accept the majority position on this particular point. GRRF noted the opposition by the expert from Germany over this decision
8. GRRF considered ECE/TRANS/WP.29/GRRF/2011/27 from CLEPA and OICA exempting buses of Class I, II and A from AEBS requirements, as well as special purpose vehicles and off-road vehicles because of possible incompatibility of AEBS with the design of these vehicles (AEBS dangerous for standing passengers, no space to fit AEBS radars, etc.). A number of experts were of the opinion that since some of these vehicles may be used on highways, it should be possible in principle to type approve them with AEBS and that exemptions for particular cases should be left to the Contracting Parties. In conclusion, GRRF agreed to provide guidance to the Contracting Parties on such vehicles in a specific paragraph of the preamble of the Regulation. GRRF agreed to have a final review of the wording of this paragraph, reproduced in Annex II, at its September 2011 session.
9. GRRF also discussed the issue as to whether the draft Regulation should include requirements for vehicles not equipped with pneumatic rear axle suspension (i.e. vehicles with rigid rear axle suspension). The expert from CLEPA presented GRRF-70-08 showing the vertical angle capability of AEBS sensors and that, for these vehicles, sensor system development was required. A number of experts were of the opinion that such vehicles should not be subject to the pass/fail values proposed in Annex 3 of the draft Regulation because the present AEBS were not able to cope with the variation of the pitch angle of these vehicles. Other experts were in favour of including such vehicles in Annex 3 of the draft Regulation to support the development of specific sensor systems for these vehicles. Other options considered by GRRF were to cover such vehicles in a further step of the Regulation or only require warning systems with no action on the brakes for these vehicles in a first step. GRRF could not reach a final decision and agreed to let WP.29 decide on this issue. GRRF requested the AEBS/LDWS informal group to study the possible options mentioned above, as well as the alternative proposal (GRRF-70-02-Rev.1) proposed by Germany. The AEBS/LDWS Chair agreed to hold a meeting of the informal group before the summer break (26-27 May 2011) on this topic.
10. GRRF discussed the pass/fail values proposed by the informal group for the warning and activation test in Annex 3 of the draft Regulation, in particular in GRRF-70-03, GRRF-70-04, GRRF-70-05 and GRRF-70-06. GRRF agreed in principle to have requirements for N2 vehicles above 8 tonnes equipped with mitigation systems (row 2 of the table in GRRF-70-05) and deleted the “blank row” option for this group of vehicles.
11. With regard to the timing of the first warning mode for a moving target for collision avoidance requirements (i.e. cells E1 and E2 of the table in GRRF-70-06), GRRF noted the preference by the expert from Germany, for 2 seconds in particular for legal reasons. However, a majority of experts favoured 1.4 second. Therefore, GRRF agreed to delete the 2 second option and to keep the value of 1.4 second in square brackets in cells E1 and E2 of the table in GRRF-70-06 (avoidance systems) as well as in cell E1 of the table in GRRF-70-05 (mitigation systems).
12. GRRF could not agree on the other text in square brackets in the table (footnotes, row 3) (see also para. 9). For N2 vehicles below 8 tonnes and M2 vehicles (row 3), GRRF requested the AEBS/LDWS informal group to further discuss the possibility of further developing the specific requirements for these vehicles, including requiring warning systems only or covering such vehicles in a further step.
13. On the regulatory approach, the AEBS/LDWS Chair recalled that, following the guidance given by GRRF at its September 2010 session, two separate draft Regulations were on the GRRF agenda: ECE/TRANS/WP.29/GRRF/2011/23 on collision avoidance emergency braking systems and ECE/TRANS/WP.29/GRRF/2011/24 on collision mitigation emergency braking systems. The AEBS/LDWS Chair added that, at the request of OICA, the informal group had reconsidered the possibility to combine the two sets of requirements into one single Regulation, taking the form of a base Regulation (Step 1- 00 series of amendments) (ECE/TRANS/WP.29/GRRF/2011/25), supplemented by an a 01 series of amendments (Step 2) (ECE/TRANS/WP.29/GRRF/2011/26). GRRF could accept in principle the latter approach provided adequate transitional provisions could be found between the two implementation steps.
14. The AEBS/LDWS Chair presented the draft transitional provisions between step 1 and step 2 of the draft Regulation prepared by the informal group in GRRF-70-06 superseding ECE/TRANS/WP.29/GRRF/2011/26, indicating that for none of these provisions consensus had been reached.. A number of experts were in favour of further simplifying these transitional provisions. However, GRRF could not reach a final decision and agreed to send the draft transitional provisions contained in GRRF-70-06, as reproduced in Annex II, for final decision by WP.29 at its November 2011 session.
15. Given the urgency of this draft Regulation for some Contracting Parties and considering that further progress might be difficult at GRRF level, GRRF agreed to send ECE/TRANS/WP.29/GRRF/2011/25 and ECE/TRANS/WP.29/GRRF/2011/26, amended by GRRF-70-04 and GRRF-70-05 as reproduced in Annex II to this report, for consideration by WP.29 and the Administrative Committee of the 1958 Agreement on Vehicle construction (AC.1), for consideration at their November 2011 session, as draft new Regulation on AEBS and draft 01 series of amendments to the new Regulation. It was noted that WP.29 would have to discuss, at its November 2011 session, the unresolved issues in square brackets in the draft text, in particular, which vehicles should be excluded from AEBS requirements and the appropriate transitional provisions that should apply between the above mentioned step 1 and 2. GRRF agreed to review these proposals at its September 2011 session.
The Chair introduced document AEBS/LDWS-15-03 proposing that, in the 1st implementation step (00 series of amendments) vehicles of category M3, N3, and N2 > 8 tons, which are not equipped with pneumatic rear axle suspension, comply with the collision detection and warning requirements (CWS), but not with the emergency braking requirement.
D introduced document AEBS/LDWS-15-04 and pointed out that the proposal would make footnotes of the table superfluous.
OICA introduced document AEBS/LDWS-15-05 concerning paragraph 5.1.1. on rear axle suspension.
OICA clarified that some development time is necessary for the vehicles equipped with non-pneumatic rear axle suspension.
The Chair introduced the document AEBS/LDWS-15-06 (DK position that vehicles without air suspension should not be excluded from the demand for AEBS).
The expert from CLEPA clarified that the warning is the critical part of the system: the driver is a better sensor than the radar, and he could be irritated by false alarms, then switch the system off. Low cost CWS would provide no safety benefits but high cost CWS would be too expensive. The expert hence found no benefits in CWS.
J was of the opinion that AEBS sensor technology can apply to all kind of suspension; hence J was keen to have the same requirements for vehicles with any type of suspension. However J was agreeing to exclude the steel suspension vehicles from the scope for the EU countries. As a consequence, J preferred the OICA proposal to the D proposal, and let the decision of including the relevant types of vehicle up to the convenience of the Contracting Parties. But the expert from J insisted that nevertheless the possibility of approving these vehicles should remain in the regulation. As a conclusion, J favoured to keep some flexibility at the UNECE platform. The expert informed that the experience of the Japanese market with vehicles of category 3 is such that there is no need for any restriction on the pitch angle, but acknowledged that however current experience in Japan is limited to rigid trucks. The expert from J concluded that to his opinion the best solution would be regulating at UNECE, but if this is impossible then J would be flexible on the presence of these vehicles in the regulation.
OICA recalled the difference between the Japanese and the European rigid suspension vehicles:
Japanese N3 vehicles have long wheel base and low pitch angle. CLEPA did not share this OICA vision, but considered that J vehicles have a longer rear overhang, making the situation worse in Japan.
OICA clarified that in J the vehicles equipped with AEBS and rigid rear axle suspension have long wheelbases.
Concerning the technology, CLEPA recalled the document presented at the 70th GRRF providing clarification of the sensor availability (document GRRF-70-XXX). The expert was of the opinion that the technology would not be implemented without making it mandatory.
OICA clarified that when the pitch angle is small enough then OICA is ready to implement the technology.
UK found reasonable that these vehicles be included in the UNECE regulation, but did not yet consider a “may” as proposed by OICA and D. UK then had a reservation in order to study this new possibility.
The Chair found no reason to make such distinction, clarified that the document AEBS/LDWS-15-03 is a proposal from Chair of the informal group as an attempt to find an acceptable compromise on the rear axle suspension issue. In view of the lack of support, the Chair withdrew his proposal AEBS/LDWS-15- 03. The European Commission believed that the wording proposed by OICA in the 2nd paragraph of 5.1.1. is contradictory to the objective of international harmonization and is not in line with the guidelines from the UNECE secretariat on how the scope of application for a UNECE Regulation should be specified .
The Chair summarised the discussions by concluding that he would report to GRRF-71 that the informal group could not meet the mandate given by GRRF to find a solution to the outstanding rear axle suspension issue.
OICA announced later during the meeting that OICA was ready to reach some performance requirements for rigid suspension vehicles by 2016 under certain conditions: if proper systems are available in 2013 then OICA can commit to AEBS performance requirements for rigid suspension vehicles starting 2016 (New Types). This of course would depend on the good cooperation with the AEBS suppliers. The target for performance requirements would be the same as for the pneumatic suspension. The expert informed that the vehicle manufacturers need two years for validating the systems provided by the suppliers and fitted on the vehicles.
CLEPA recalled that the proper sensors (fitted with integrated levelling system) are currently available, but that these need the logic signal input to control the internal levelling system, and that this input must be provided by the vehicle itself. CLEPA could not start development for such systems for one manufacturer only, but would start development programs if there is wide order from the 7 main vehicle manufacturers.
D recalled that all safety systems to date were firstly introduced by the market, and then made mandatory. The delegate however declared that the process with AEBS seems to be the inverse: firstly mandating, and then defining the system. In conclusion, D could not support the OICA proposal.
The Chair recalled the famous song of Bob Dylan: “Times They Are A-changing”.
OICA suggested to add the OICA commitment into the Preamble.
UK had a reservation.
F also had reservation.
J could support the OICA proposal but could also follow the majority.
The Chair requested OICA to put their proposal on paper well in advance before the September GRRF to permit consideration by a maximum of Contracting Parties.
Conclusion:
- OICA to provide official input, as committed, for GRRF-71
- Input consisting of
o paragraph 5.1.1. as proposed in document AEBS/LDWS-15-05;
o relevant wording for footnote 3 to document AEBS/LDWS-15-02 (“applicable only to vehicles with pneumatic rear axle suspension”);
o proper performance requirements and application dates for the vehicles equipped with rigid rear axle suspension.
- Complete document to be prepared and tabled by OICA for GRRF-71 (September 2011).
Concerning the Footnote 4, OICA proposed to delete it according to their proposal (GRRF/2011/39).
J pointed out that some Contracting Parties want to mandate AEBS on non-pneumatic rear suspension vehicles, Hence J could accept the proposal from OICA (GRRF/2011/39 in paragraph 5.1.1.) as it provides this flexibility.
OICA confirmed the interpretation of the document GRRF/2011/39 that a Contracting Party wishing to do so can mandate AEBS on rigid suspension vehicles.
The Chair however recalled document WP29/2011/48 stating that the wording proposed by OICA can provoke legal uncertainty. In this view, the European Commission was hesitant in supporting the proposed text in 1.§ 5.1.1 .
The Chair proposed to seek advice from the UNECE Secretariat about this item at GRRF-71.
- J supported this proposal.
- D found the OICA proposal quite clear and could support it.
- NL was of the opinion that the guidance provided in the Introduction would be sufficient. In this view, the proposal from OICA to mention rear-axle suspension vehicles could be deleted as well.
- UK had a reservation about whether the mention in the Introduction would be sufficient guidance to the Contracting Parties.
Conclusion: the informal group agreed to request guidance to UNECE Secretariat. At GRRF-71.