India’s Comments on documents GRRF/2014/4 and /5
Document GRRF-76-32
13 February 2014

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.

Submitted by India
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Previous Documents, Discussions, and Outcomes
5. (a) | Regulation No. 78

20. The expert from IMMA introduced ECE/TRANS/WP.29/GRRF/2014/5 and ECE/TRANS/WP.29/GRRF/2014/6 as amended by GRRF-76-19 and GRRF-76-36-Rev.1 proposing general clarifications to UN Regulation No. 78 and specific clarifications for the use of Combined Braking Systems (CBS). The proposals received some comments and the expert from IMMA consolidated these requested changes into a revised proposal (GRRF-76-45). The expert from India introduced GRRF-76-32 on three wheelers, which GRRF agreed to revisit on the basis of a revised proposal at its September 2014 session. GRRF requested the secretariat to distribute GRRF-76-45 with an official symbol at the September 2014 session.

5. (b) | Global Technical Regulation No. 3

21. The expert from IMMA introduced on behalf of the sponsor, Italy, ECE/TRANS/WP.29/GRRF/2014/3 and ECE/TRANS/WP.29/GRRF/2014/4 as amended by GRRF-76-35-Rev.1, proposing similar amendments to those proposed for Regulation No. 78 (see para. 20, agenda item 5a). These proposals received comments and the expert from IMMA consolidated these requested changes into a revised proposal (GRRF-76-44). GRRF requested the secretariat to distribute GRRF-76-44 with an official symbol at its September 2014 session.

12. (b) | Revision and extension of approvals
Related and Previous Documents
GRRF/2014/4
GRRF/2014/5
Relates to GTR No. 3 | UN R78 |