3. GRRF focused its work on the text in square brackets in ECE/TRANS/WP.29/2011/92 (Step 1- original version of the Regulation on Advanced Emergency Braking Systems) and ECE/TRANS/WP.29/2011/93 (Step 2-01 series of amendments to the Regulation), both on the agenda of the November 2011 session of WP.29: Requirements for vehicles not equipped with pneumatic rear-axle suspension, requirements for N2 and M2 vehicles, requirements for vehicles not equipped with pneumatic braking and transitional provisions between step 1 and step 2.

4. The Chair of the informal group on Automatic Emergency Braking and Lane Departure Warning Systems (AEBS/LDWS) reported on the progress made by the informal group from the last GRRF session to the meeting held on 12 September 2011 in conjunction with the proper session of GRRF. He introduced GRRF-71-25 as the outcome of the discussion of the informal group. In particular, it was proposed to tackle, in the preamble of the Regulation, vehicles not equipped with a pneumatic rear-axle suspension. The expert from OICA proposed in GRRF-71-24 to add in paragraph 5.1. the possibility for an “optional” type-approval for vehicles not equipped with a pneumatic rear-axle suspension. The expert from Germany supported this proposal. The secretariat and the expert from EC were of the opinion that these vehicles were already tackled in the preamble (see above) and that the wording for paragraph 5.1. was confusing because by definition a UNECE Regulation was optional. Furthermore, it was not clear for the secretariat which requirements would apply to these vehicles. GRRF could not reach a final decision on this OICA proposal and agreed to let the World Forum for Harmonization of Vehicle Regulations (WP.29) decide whether an “optional” type-approval in paragraph 5.1. was appropriate for vehicles not equipped with a pneumatic rear-axle suspension.

5. The expert from OICA proposed in GRRF-71-24 replacing ECE/TRANS/WP.29/GRRF/2011/39 to exclude from the scope of the original version of the AEBS Regulation: N2 vehicles below 8 tons, M2 vehicles and vehicles not equipped with pneumatic braking. After discussion GRRF supported this proposal.

6. For the 01 series, the expert from OICA proposed in GRRF-71-24 to include all N2 and M2 vehicles in the scope of the Regulation. However, for N2 vehicles below 8 tons and M2 vehicles, it was proposed to set the limit values in Annex 3 at a later stage (before 1 November 2016), in order to give more time to GRRF to develop special requirements for these vehicles. GRRF supported this proposal but with the alternative wording proposed by the expert from EC in GRRF-71-26. GRRF committed itself to develop these requirements in the proposed timeframe.

7. 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 recalled the preference by the expert from Germany, for 2 seconds specifically for legal reasons. However, since a majority of experts favoured 1.4 second, GRRF proposed to remove the square brackets from 1.4 seconds in the table in Annex 3 of ECE/TRANS/WP.29/2011/92 and ECE/TRANS/WP.29/2011/93. Since the requirements of rows 1 and 2 of ECE/TRANS/ WP.29/2011/92 and ECE/TRANS/WP.29/2011/93 became identical, GRRF agreed to merge the two rows of the table.

8. GRRF considered GRRF-71-16 (OICA) and GRRF-71-23 (EC) amending the transitional provisions of the 01 series of amendments. Since GRRF could not reach a final decision, GRRF requested the secretariat to draft the transitional provisions according to the objectives fixed in GRRF-71-30. After discussion, GRRF adopted GRRF-71-30-Rev.2 as reproduced in Annex II. One paragraph reproducing the text of the 1958 Agreement was left in square brackets for final decision by WP.29 at its November 2011 session.

9. In concluding the discussion, GRRF adopted GRRF-71-27-Rev.1 as reproduced in Annex II and requested the secretariat to submit it to WP.29 and the administrative Committee of the 1958 Agreement (AC.1) as amendments to ECE/TRANS/WP.29/2011/92 and ECE/TRANS/WP.29/2011/93, for consideration at their November 2011 sessions.

UK presented the document AEBS/LDWS-16-02 and OICA presented the document GRRF/2011/39.

The Chair expressed concern that the OICA proposal could be understood as a means to exclude some vehicles from the scope. However OICA clarified that these vehicles with nonpneumatic rear axle suspension may be approved.

CLEPA questioned which authority could verify the meaning of the “available on the market” and “validated”. OICA clarified that this was precisely the reason why such wording had been elaborated.

J was keen to have a visibility of the future.

S supported the OICA position on this topic.

The Chair, as representative of the European Commission, considered this OICA document as being proposals for amendments to the working document GRRF submitted to WP.29. The European Commission considered that the Preamble should be just a guidance and should therefore not entail any restriction of the freedom for the Contracting Parties to mandate AEBS, and therefore should not be introducing a legal uncertainty. UK suggested replacing the proposed date by the 01 Series of amendments. Japan was keen that a Contracting Party can mandate the AEBS on these vehicles BEFORE the date of the 01 Series of amendments.

D found such additional paragraph in the preamble as proposed by OICA not necessary.

NL acknowledged the problems with the rigid suspension, and could support the UK proposal as more flexible.

F supported the addition of a new paragraph, but requested to add the reason why such further development is needed.

RUS proposed to meet the request from J with the addition of a sentence addressing the parameters that should be taken into account when approving these vehicles.

S clarified that the text in the Introduction is not such important, rather the text in paragraph 5.

OICA provided further technical clarifications about the difficulty for the vehicles with rigid rear axle suspension to comply with the text requirements and be simultaneously robust and reliable.

The Chair pointed out that the UK proposal only addresses the Introduction, and pointed out that the OICA proposal for the Preamble is linked with the proposed changes to paragraph 5.1.1.

OICA clarified for the experts that J does not face such problem of pitch angle as the vehicles are not of the same types, and hence does not need particular technology for addressing the large pitch angle problem.

The new wording for the additional paragraph in the Introduction was then developed per document GRRF-71-27.

CLEPA, UK, RUS and D could accept the proposal for compromise of the new text.

J had still concerns and had a reservation toward the new proposal. In addition they were keen to come back to this item after consideration of paragraph. 5.1.1.

S proposed to replace the wording “sensor technology” by “system”. This provoked a further debate which again improved the wording.

NL and F could support the new wording as well.

OICA also could support the compromise.

Conclusion: additional paragraph adopted in the Introduction to be proposed per document GRRF-71-27.

The group firstly discussed the Footnote 1 and its reference in row 1:

• RUS proposed to delete the reference to footnote N°1
• J suggested to delete row 2 and introduce the reference to N2>8t into cell A1.
• NL supported to delete footnote 1
  OICA, UK accepted this.

OICA presented (document GRRF/2011/39) and the reason why deleting row 3, as it is a base for discussing scope, row 3 and footnote 2: AEBS is a system braking the vehicle. However, leaving the row blank would be misleading as the AEBS would not brake. The Technical Services would not know what to do as there would be no performance requirement. The expert from OICA stressed that it would be cleaner and clearer to have a regulation with a defined scope and clear performance requirements for these vehicles within the scope. He hence considered better to delete the row than keeping it blank.

• D suggested to keep the row 3, blank, and to fill it in when technology will be available.
• NL found the OICA proposal the most “straightforward” as it is impossible to have in the scope vehicles with no requirement, at least for the 00 Series of amendments. Some requirement could be added for the 01 series.
• UK supported NL.
• F supported OICA, i.e. deleting the row 3 for the 00 and 01 Series of amendments.
• J stated that the 1st priority is the heavier vehicles. But the technical requirements for lighter vehicles would be accepted by J. J however was keen to follow the majority.
• RUS was ready to support OICA from a logical standpoint for the 00 Series. But the expert was of the opinion that for the 01 series of amendments all vehicles should be included.

The Chair then asked OICA whether their proposal would indeed imply no harmonization. OICA clarified that the regulatory process in Geneva is such that harmonization exists.

The Chair then concluded that, according to the OICA proposal, Contracting Parties are not bound by the AEBS Regulation for the vehicles outside the scope of the Regulation and could therefore impose the requirements they would consider appropriate. Hence the European Commission would not have to take into account the discussions held at the UNECE platform about these excluded vehicles for mandating AEBS in the context of the GSR.

OICA clarified that as from the time there is no existing vehicle of these categories with AEBS, it would be premature to discuss precise requirements for the 01 series. The expert added that, of course, a regulation is always open to any amendment.

The Chair suggested then introducing the current 00 series requirements in the 01 series of amendments, assuming that AEBS technology for these vehicles would exist at the time of the application date for 01 series of amendments.

• NL supported this compromise.
• RUS suggested to delay the adoption of the 01 series of amendments as the situation for the 01 series is unclear (e.g. up to March 2012 WP29 session). The Chair however considered this an entirely new approach because all the proceedings so far have been based on the adoption of 00 + 01 series of amendments as a package. The Chair however committed to present this new idea to GRRF-71 as an additional option.
• UK had a reservation about the proposal of having blank row 3 in the 01 series.
• The European Commission recalled their position was clearly based on the objective that both 00 and 01 series should have all vehicles covered. But the European Commission could accept such compromise for the sake of safeguardingharmonisation. Simply excluding these vehicles from the scope of the 00 and 01 Series would delete any incentive to see AEBS introduced in the market for those vehicles.
• OICA concern about RUS to discuss 01 later: need for Industry to keep the current visibility for the vehicles already agreed. As Dr. Zastrow, the OICA spokesman found the Chair’s proposal interesting, and needed internal inquiry with OICA members about it.
• CLEPA clarified that the row 3 should be deleted or filled in with the wording currently proposed (and coming from CLEPA). CLEPA also could accept e.g. blank cells with a reference to a footnote stating that relevant requirements must still be developed. The fear was that a Contracting Party decides to mandate requirements which cannot be economically viable.

The Chair tried to summarize the options on the table as follows:

1. Keeping row 3 (D) and full scope + footnote about further development for 01 Series.
2. Excluding these vehicles by deleting row 3 (original OICA proposal)
3. Exclusion for the 00 Series but inclusion in the 01 series.(UK + EC)
4. Delaying adoption of 01 series to the time when some satisfying performance requirements will be ready (RUS).
5. Keeping row 3 blank, with some commitment that GRRF would come to definition of requirements before application of 01 Series of amendments (Chair’s compromise)

The Chair suggested to simply reporting back to GRRF the 5 options, assuming some clear input from OICA at GRRF-71. The group then decided to provide time to members for internal discussions.

OICA then agreed to follow the proposal from the Chair where, in the 01 series, a note would explain some commitment that performance requirements will have to be developed.

UK could not support the RUS proposal delaying adoption of 01 series to the time when some satisfying performance requirements will be ready. UK could support deletion of row 3 from 00 series, with some requirements in row 3 at the 01 series. These requirements would be the result of some discussion with Industry.

• NL, F, RUS, CLEPA and S could support this approach.
• F had no strong opinion about the requirements in the 01 series for these vehicles.
• D could support the approach, subject to further consideration.
• J wanted further consideration.
• OICA then committed to develop relevant text for row 3 in the 01 series of amendments for further consideration and discussion at the 71st session of GRRF.

Conclusion: compromise approach agreed, subject to further advice from the UNECE Secretariat and discussion in GRRF71.

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.