Working draft of the proposed regulation on "Uniform Provisions Concerning the Approval of I. Emergency Call Devices (AECD); II. Vehicles with regard to the Installation of an AECD of an Approved Type; III. Vehicles with regard to their AECS.
4.1 Updated document ECE/TRANS/WP.29/2013/67/Rev.1
Document AECS-01-03 was presented by RUS.
OICA pointed out that the comments from Renault integrated in document AECS-01-03 should be disregarded, because they would be integrated in a further OICA document.
OICA was keen that RUS provides the justifications for the structure of their proposal.
RUS explained the 2-part structure as the devices and the installation of the devices. The annexes were too big to be included directly in the 1st draft.
OICA presented document AECS-01-04 focusing on the main points:
RUS agreed with the 3-part draft text.
OICA committed to prepare a revised text for the next meeting with the support from RUS.
Conclusion:
The European Commission questioned the change of name of the E-Call: the expert found it simple to use terms already present in existing standards.
Secretary explained that the proposed name was derived from the Russian proposal WP29/2013/67, and had the advantage of making an easy difference between the device as a separate component and the fully integrated system.
Russia said that the group should avoid using terms associated to existing specific systems. As an example GPS should be called GNSS. Russia supported the acronyms AECS and AECD.
Russia pointed out the loss of not referring to 2 GNSSs in the definition and argued that there is a need for e.g. compatibility to two mobile phone networks. OICA challenged the obligation of compliance with 2 GNSSs because connecting to two different GNSSs is not necessary everywhere.
It was recommended not addressing the definitions now, and rather focusing on requirements, and seeing the definitions when looking or after having looked at the requirements.
Conclusion: recommendation adopted, informal group to start the revision of the requirements.
Russia questioned the necessity of the Part III because the requirements there would probably be the same as those of Part I.
The UK questioned whether the vehicles not included in the scope would have to be approved to Part II of the regulation.
Russia was concerned that in case of Part III approval all components would have to be approved in addition to the vehicle approval. The expert from Russia found the situation of AECS similar to that of UN R116, which has 2 parts. Russia favoured that the Part III provides for a kind of exceptional approval way with limited additional provisions.
A debate took place about the way to understand and treat Part III.
It was recognized that the problem of separate component certification (e.g. use of communication device with prohibited frequency), could not be solved under the frame of the 1958 Agreement. The informal group acknowledged that the manufacturers have anyway to cope with this problem separately.
Japan informed that the HELPNET system includes mobile phone networks: Japan was keen to get a clear view as to whether AECS with separate mobile phone would be included or not in the provisions of the future regulation, for making an official position on this.
The European Commission was keen that AECS can function throughout the full life of the vehicle and throughout Europe. The European Commission had doubts that separate cell-phone system does permit this. Russia supported the European Commission that there seems to be currently no place in the regulation for this possibility of separate cell phone AECS.
OICA stressed the difference of lifecycles between vehicles and cell phone networks: 10 years vs. 3-5 years (same for the development times: 5-7 years for a passenger car vs. 2 years for a cell phone). The expert added that there is no obligation for the network providers to sustain their network during a determined time and that there is currently no answer to the problem of life cycle differences. It was suggested that this is a matter of good cooperation between the 3 actors; i.e. auto industry, PSAP, and network providers.
Russia took the example of other components in the car that could fail or be subject to wear. Unless there is an obligation for the car owner to replace or repair the component, nothing can ensure the good functioning, at least at the time of Type Approval. Russia suggested sticking to the AECS with embedded network access device.
The Secretary compared the AECS network situation to the case of LDWS when a Contracting Party changes its road marking: the embedded system would then have to comply with a situation not covered by the approval. OICA hence feared problems of responsibility and user claims, should the AECS be unable to function because of network breakdown.
Conclusion:
Paragraph 6.1. (EMC), Paragraph 6.2. (climate resistance) and 6.3. (mechanical resistance)
OICA informed that the 05 series of Regulation No. 10 will be ready very soon, and found that requirements for EMC are not necessary as it is common to the vehicle.
Russia found necessary to keep a reference to UN R10.
Conclusion: need for provisions that the AECD is not affected by electromagnetic field with reference to ISO-7637. Item to be confirmed at next meeting, together with replacement of paragraphs 6.1.1. and 6.1.2. and 6.1.3 with relevant references.
OICA questioned the presence of requirements on climate and mechanical resistance because other systems in vehicles do not have such requirements. This does not exist for e.g. lighting devices.
Russia agreed to replace Annexes 6 and 7 by relevant references and stressed that UN R116 for example does include climate resistance provisions.
Secretary proposal: copy/paste of paragraph 6.4. of UN R116
Russia stated that these requirements are in fact in the current Annex 6 of the Russian proposal.
Conclusion for EMC, climate resistance and mechanical resistance: all experts to verify for next meeting how best replace relevant annexes by references.
Paragraph 6.4. (Post-crash resistance)
Conclusion:
Paragraph 6.5. (reception of GNSS)
Russia found the OICA proposal not complete, and was keen that the reception of 2 GNSSs should be added at this place if deleted from the definition section.
The European Commission committed to confirm compliance of future Galileo with draft Annex 9. OICA wondered whether those detailed specifications of Annex 9 are appropriate for Type Approval process. The expert noticed that in addition, they are GLONASS related rather than GNSS-free.
The expert from Russia pointed out that the proposed annex 9 cannot be replaced with CEP95 test because the latter addresses only stationary test scenario and does not cover a number of essential parameters. Russia was of the opinion that GLONASS and GPS are cited, because they are the only existing GNSSs, and encouraged EU to provide the relevant data for their system. Russia supported the technology-neutral approach in the requirements; however, test methods have to be technology-dependant as they test operation with selected specific GNSSs.
OICA suggested that this item be reviewed at the next meeting, and in the meantime reviewed by a small task force where at least one expert is from CLEPA. OICA was of the opinion that GNSS is not technology neutral (e.g. EGNOS – European terrestrial positioning system could fulfil the AECS requirements). Yet EGNOS could be a corrective system complementing a GNSS which is probably the best available technology to date. The group convened that there are other technologies that can provide positioning and beneficially complement GNSS. The group agreed not to consider other possible augmentation systems and/or alternative positioning technologies and concentrate on the GNSS systems.
Conclusion:
Paragraph 6.6. (communication with mobile phone network)
Russia acknowledged the different mobile networks in different Contracting Parties, and the fact that Japan is not using GSM. Russia agreed with the possibility to display the relevant networks in an annex. Russia added that based on known frequency utilization policies, in Russian the regulation would continue to include both GSM and UMTS requirements.
Japan supported the OICA proposal of adding an annex. Japan committed to check the networks relevant for Japan for the next meeting.
OICA pointed out that the system cannot work with all networks worldwide and proposed to review the functioning of such annex. The expert from OICA proposed to refer to GSM as a minimum requirement and add other networks for markets where the system is intended to be marketed. He recalled that the network providers are the only party having no obligation and may change their network.
The European Commission committed to provide for next meeting a position with regard to acceptability of GSM as a minimum requirement. Japan confirmed to the group that GSM (2G) networks do not exist in Japan at all.
The UK suggested inspiring from regulations where the system must comply with “the country where the system is intended to be marketed”.
The Secretary proposed to eradicate the detailed requirements for particular mobile phone networks, and to make it regulated nationally.
The group faced 2 possibilities:
Conclusion:
Proposed wording as follows for addressing the 2nd alternative mentioned above:
Proposed wording to be reviewed at next meeting. Informal group may need the help of GSMA and other competent expert.
Paragraph 6.6.1. (SIM card)
Japan and OICA requested clarity about the capacity of updating information.
Russia clarified that this was intended for provisioning purposes should a network provider have this need for embedded SIM-card, as well as for the systems that are used as AECS as well as for other purposes, i.e. additional services. Russia however favoured the route of letting this regulated nationally.
OICA pointed out that this item was already discussed at EU level with the decision that separate approach (AECS vs. additional services) should be favoured.
Russia informed that SIM-IC (Subscriber Identity Module – Integrated Circuit) is mandatory in Russia.
The European Commission found it design restrictive to mandate SIM-IC in this regulation and was keen that privacy be respected and “personal SIM” could not be supported.
Russia explained that the term “personal” resulted from double translation of the term “Subscriber Identity Module” and agreed to delete the word “personal” from the regulation.
Japan requested clarification about which information is necessary to be updated. Russia informed having added the capacity of updating the SIM card profile because, in the Russian proposal, the SIM card is not removable. OICA clarified having put the word “upload” as a misunderstanding of the word “update”. Russia agreed to delete the provision of SIM card information updating capabilities if the group decides to follow the route of mobile communication network national regulation.
Conclusion:
The group agreed that all could be regulated and harmonized except what concerns the communication. Yet the concern of OICA was that the regulation only covers half a system in the end of the day. Russia questioned whether this remark indicate support of the approach to list requirements per territory in the Annex to the regulation as opposed to relaying entirely to the national regulation.
Informal group to make a decision about the way to address areas that are different in nature in the different Contracting Parties. This leads to the following alternative: