India supports the purpose of the amendments to GTR No. 3 (GRRF/2014/4) and UN R78 (GRRF/2014/5) to provide same safety in the case of a failure in CBS as that of the conventional system of the two independent brakes for two wheelers. However, India believes the application of the amendments to three-wheelers requires additional consideration. Therefore, in order to proceed with amendments concerning CBS for two-wheelers, India proposes changes to the proposed text in order to allow further consideration of three-wheelers.

Proposal to clarify the intent of the selected paragraphs to ensure that systems with with one service brake meet braking performance requirements using only that brake system (i.e, without any assistance from the secondary brake system). There had been an interpretation that for systems with two service brakes each brake had to meet the requirements which would result in higher stringency levels than intended by the requirement for single brake systems.

The proposal also clarifies the parts of the braking system that should be considered with respect to hydraulic brake and mechanical transmissions and further clarifies that the test procedures are designed to simulate a brake failure rather than produce one.

Proposal to clarify provisions concerning the use of Combined Braking Systems (CBS) and for a series of amendments to clarify a variety of requirements, notably concerning test surface requirements, ABS cycling, and peak braking coefficient measurements. The proposal clarifies the terms “inoperative” and “disconnected”, introduces the “K-method”.