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Document Title Amendment to the draft regulation (AEBS/LDWS-15-01) concerning pneumatic rear suspensions
Reference Number AEBS/LDWS-15-04
Date
29 Jun 2011
Source(s) Germany
Rulemaking Area(s) UN R131 Advanced Emergency Braking
Meeting(s)
Downloads
UNECE server .pdf format
Excerpts from session reports related to this document
AEBS/LDWS | Session 15 | 26-27 May 2011

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).

The expert from D informed that the proposal AEBS/LDWS-15-04 towards amendments to paragraph 6.4.5. originates the fact that it is not always possible in practice to reach the 4 m/s².

J could not support this proposal because systems complying with this new provision would still need to be developed.

CLEPA pointed out that the text does not contain any definition of “deceleration phase”.

UK supported J and CLEPA.

F continued with the general reservation.

The informal group held a debate about the performance requirements of the emergency braking phase.

The Chair suggested that D comes up with a proposal for GRRF-71 of September 2011, as the informal group did not receive mandate to deal with this item, and as the D proposal did not receive support from the Contracting Parties present at the 15th meeting of the informal group.

- OICA to present a consistent proposal for non-pneumatic suspension vehicles
- No progress achieved by AEBS/LDWS-15 towards vehicles of categories M2, N2 < 8 tons
- D to decide whether presenting a proposal along the lines of document AEBS/LDWS-15-04 (“deceleration phase”)
- J to decide whether presenting a proposal along the lines of document AEBS/LDWS-15-07