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UN R51: Proposal for corrections to the 03 series of amendments
Document GRBP/2024/22
2 July 2024
Submitted by OICA
Status: Formal GR review
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Previous Documents, Discussions, and Outcomes
3. | UN Regulation No. 51 (Noise of M and N Categories of Vehicles)

10. The expert of OICA proposed a regulatory package for the sound emission limits of electric vehicles (EVs) equipped with Exterior Sound Enhancement Systems (ESES) (ECE/TRANS/WP.29/GRBP/2024/22, GRBP-80-20-Rev.1 and GRBP-80-21-Rev.1). The expert of EC introduced a counter proposal (GRBP-80-12 and GRBP-80-23), including an alternative definition of Exterior Sound Producing and Amplifying System (ESPAS) in lieu of ESES. According to her, for EVs the emission of additional exterior sound is only acceptable as long as it addresses safety concerns and should be strictly prohibited whenever safety is not at stake, as in the case of ESPAS or ESES. In addition, she proposed to include EVs in the scope of ASEP, in order to reap the full benefits of switching to EVs in terms of noise emission. In reply, the expert from OICA pointed out that in many situations AVAS was not sufficient for road safety (for example, in the vicinity of schools) and that ESES could play a role in those situations. He also mentioned that there seemed to be a market demand for ESES from some drivers who otherwise would not buy EVs.

11. The expert from Switzerland pointed out that there was no easy way to determine a worst-case situation with regard to ESES. For this reason, he supported the EC proposal rather than the OICA one, but acknowledged the fact that all parties in GRBP share the objective of addressing this issue.

12. The expert from the Netherlands expected a positive effect of the increasing number of EVs on noise reduction, particularly in cities at urban speeds, being the key consideration for the Netherlands. According to him, prohibiting ESES, as suggested by EC, seemed to be the most certain solution to secure the EV noise reduction benefits at this moment. He was also mindful of other influencing factors.

13. The expert from France stated that, to combat noise pollution for the well-being of the society, it would be impossible for the Government to justify adding unnecessary noise to EVs. The expert from the United Kingdom stated that he would need more time to study the proposals in combination with draft amendments to UN Regulation No. 138 (see paras. 18-21 below). The experts from Germany and Japan pointed out that any prohibition of ESPAS (ESES) should be done with caution and suggested that this topic be discussed further in a new subgroup (group of interest) and then by IWG RD-ASEP.

14. The expert from OICA volunteered to act as Secretary, should a new subgroup be established. The experts from Switzerland and EC indicated their interest in co-chairing the new subgroup, subject to approval of their management. GRBP welcomed these statements and noted that the new subgroup could kick off in conjunction with the meetings of IWG RD-ASEP and GRBP Task Forces (TF) in October 2024 (see para. 45 below). In the interim, GRBP invited all experts to send their comments to the experts from EC and OICA without delay, with a view to preparing a working document for the next session.

5. | UN Regulation No. 138 (Quiet Road Transport Vehicles)

20. The expert of OICA introduced draft amendments to the 02 series of amendments to UN Regulation No. 138 (GRBP-80-28), which took into account a new definition of “Exterior Sound Enhancement System” (ESES) proposed for UN Regulation No. 51 in ECE/TRANS/WP.29/GRBP/2024/22 submitted by OICA. According to OICA, UN Regulation No. 138 should remain a safety UN Regulation while the environmental concerns should be addressed by UN Regulation No. 51. GRBP noted that the two Regulations provide parallel specifications for an overlapping speed range (20 – 50 km/h).

21. Given the complexity of the problem and lack of time, GRBP was not in a position to take a decision on the proposals by the experts of EC and OICA. To make progress, the Chair suggested that the proposals be first considered within a new group of interest before GRBP would revert to them at the next session. GRBP agreed that discussions could first start in October 2024 in the framework of the new subgroup on UN Regulation No. 51 (see para. 14 above) with a later establishment of a separate subgroup on UN Regulation No. 138, if necessary.

Relates to UN R51 |