The Alliance had already presented in earlier meetings to see issues with the cost benefit assessment provided to the Informal Group. Mr. Bilkhu now specifically addressed the concerns of the US manufacturers with the two documents GTR9-5-14 and GTR9-5-19. These concerns were reported in a study of JP Research, a contractor of the Alliance (document GTR9-6-16). Mr. Bilkhu presented the summary (document GTR9-6-15r1) of JP Research’s findings. He concluded that the methods used by JASIC and BASt may potentially lead to unrealistic assessments of the benefit for the US. On request of Mr. Martin he confirmed that “unrealistic assessment” in this case means “overestimation”.

Mr. Martin wondered whether the Alliance can draw different conclusions from their project. After some discussion on this it was noted that further work on this may be needed at least for future US rulemaking as NHTSA does not fully agree with the all assumptions made by the Alliance.

Mr. Zander commented that estimation of a benefit is a common process and may not be correct in all cases. However, benefits can just be estimated and a certain approach has to be used for this. BASt made good experiences with shifting the injuries and this is a well-known process that is widely accepted. Also, Mr. Zander pointed out that the assessment of JP Research may not have used the right figures of the GIDAS database. He presented a short document on this (document GTR9-6-25). Mr. Bilkhu promised to double-check the information. Mr. Edwards wondered whether it is an appropriate approach to shift injuries by one AIS and Mr. Zander confirmed that this is based on estimations. However, it needs to be noted that only those injuries are shifted where an improvement can be expected by the new tool. This does not necessarily lead to a shifted MAIS. After some discussion it was finally agreed that the Alliance will double-check the comments of BASt and provide feedback before the next meeting; all other parties are invited to also do so (action item A-6-05).

Dr. Konosu added that the data summarized by JASIC are Japanese data and that they are seen to be acceptable for Japan. However, it is true that the US may have a different situation. Then, the US should assess their data but cannot simply compare Japanese data to the PCDS data. Mr. Bilkhu agreed that an analysis for the US is needed and explained that this is usually delivered by their authority. Mr. Edwards added that the intention of the Alliance is just to get a better understanding of the assumptions made by JASIC.

On request of the chair, Mr. Stammen explained that NHTSA for the time being has no further comments on the cost benefit analysis. He explained that the preamble can reflect the discussion above which would be sufficient for NHTSA. Mr. Martin added that all presentations made were very valuable for NHTSA and will be considered in their rulemaking process. It was therefore concluded that action item A-5-09 from the 5th meeting can be closed.

Mr. Bilkhu added that, however, the US may have certain specifics that anyway may lead to different assessments of the cost benefit issue. Specifically, the bumper requirements in part 581 are in contradiction to the pedestrian safety requirements and – responding to a question of Mr. Broertjes on this in between – at the moment no vehicle complies to both, part 581 and (European) pedestrian legform test requirements. Some discussion on this came up, also mentioning that similar issues could exist with future UNECE-R 94 (frontal impact) requirements that currently are in discussion in Geneva. It was finally concluded that rulemaking processes in the US need to consider all these details in their future activities.

To finalize the discussion on this subject for the time being, Dr. Konosu presented a summary of his comments (document GTR9-6-27). He stated that the intention of Japan was to prepare information for their country and that other attendees of this meeting are very welcome to do the same for their countries.