Knorr-Bremse comments on the OICA comments to document GRRF/2012/2 (Proposal for Supplement 10 to the 11 series of amendments to Regulation No. 13).

Using AMEVSC-08-05e as a basis and taking into account the comments in AMEVSC-08-10e, the proposal tabled at the 72nd GRRF (GRRF/2012/2 (AMEVSC-07-10e)) was review paragraph-by-paragraph and point-by-point.

The results of this review are given in document AMEVSC-08-11e with the major amendments being:

► Appendix 1 paragraph 1.3.

• o Clarified that the simulation tool can only be used in a braking system type-approval when the vehicle parameters of the vehicle to be type-approved are included in the simulation tool and when the value of each parameter is within the validated range of the simulation tool.
• o Clarified that a vehicle manufacturer using an externally sourced simulation tool must carry-out at least one confirmation test and that any subsequent confirmation tests resulting from a simulation tool modification are subject to a discussion between the vehicle manufacturer, the Technical Service and the Type-approval Authority.

► Appendix 2 paragraph 1.1. – all listed parameters divided into 2 types and placed in 2 new sub-paragraphs 1.1.1. and 1.1.2.

• o Parameters that do not have a numerical value within the simulation model, but are important in understanding the capability of the simulation tool in paragraph 1.1.1.
• o Parameters that do have a numerical value within the simulation model in paragraph 1.1.2.
• o Footnote clarifies that the simulation tool must not include all the parameters listed in paragraphs 1.1.1. and 1.1.2., but any parameter that is not specifically accounted for shall be a limitation on the use of the tool.
• o Changes within the parameter:
  • ► Gearbox
    • ► In addition to moving gearbox type with examples to paragraph 1.1.1., gearbox characteristics are added to paragraph 1.1.2.. This allows both the suitability of the tool to be established with regard to the different gearbox types, and the way in which they are taken into account within the tool to be identified.
  • ► Brake
    • ► In addition to moving brake type with examples to paragraph 1.1.1., brake characteristics are added to paragraph 1.1.2.. This allows both the suitability of the tool to be established with regard to the different brake types, and the way in which they are taken into account within the tool to be identified.
  • ► Additional steering axles
    • ► The word “additional” and the examples deleted. This removes the any confusion with regard to the word “additional” as the item now clearly applies to all steered axles. The wording “working principle” in brackets indicates that the influence of the steering axle(s) on the vehicle stability function has to be considered in the simulation tool.
  • ► Drive train option
    • ► Additional examples added for clarification

• o Additional parameters
  • ► While the listing of parameters in paragraphs 1.1.1. and 1.1.2. are considered to represent a minimum check list, it was recognised that a simulation tool manufacturer might wish to included additional parameters, e.g. tyre characteristic value, suspension characteristic value. Therefore, the introducing sentence to paragraph 1.1.2. includes the wording “at least” to clarify (ensure) that additional parameters – as considered desirable by the simulation tool manufacturer – can be added to the simulation tool.

► Appendix 2 paragraph 1.4.2.

• o Paragraph structure revised to clarify that the requirement is a minimum specification for the simulation tool.

► Appendix 3

• o Appendix 3 brought inline with the amendments made to Appendix 2.

The proposed new paragraph 2.5.1. to Appendix 2 – document AMEVSC-08-09e – was discussed, with the result being shown in document AMEVSC-08-12e and the clean text taken into AMEVSC-08-11e.

► Similar idea to Annex 11 Appendix 2 paragraph 1.2.1.
► Part of the appendix and not a transitional provision with specific dates, as it will be a supplement

• o The change does not justify a series of amendments status
  • ► It was considered that very few simulation tools have been validated.
  • ► Any modification to the simulation tool that affects its scope of application will necessitate a re-validation of the tool.

Proposal for additional wording to paragraph 3.3 in order to clarify the use of test reports and ensure that the vehicle manufacturer is fully aware that responsibility is not given away when using a test report in accordance with Annexes 11, 12 or 19.

There was insufficient time to discuss the various documents and, as a result, come to a conclusion. However, it was clear that there are still widely differing views on the responsibilities and implications in the use of test reports within a type-approval.

While it was agreed that only the vehicle manufacturer can obtain a braking system type-approval and in the case of a problem related to the type-approval it is the vehicle manufacturer who is responsible for the consequences, there was disagreement as to whether this was clearly the case in the actual use of a test report.

• ► Paragraph 3.3. specifies that “a vehicle, representative of the vehicle type to be approved, shall be submitted to the Technical Service conducting the approval tests.”
  • o Does this mean, for example, that:
    • a) the vehicle referred to in paragraph 3.3. and a vehicle in the test report shall be the same with regard to type, i.e. the same type from the same manufacturer, or
    • b) the vehicle referred to in paragraph 3.3. shall contain the same item that is the subject of the test report and the “approval tests” referred to in paragraph 3.3. are the tests to be carried-out at the time of type-approval for which there are no test reports.
• ► Regarding paragraph 3.4. is the need for the vehicle manufacturer to show conformity of production sufficient for the vehicle manufacturer to be aware of their responsibilities when using test reports.

As a means to resolve the issues surrounding the use of test reports, OICA suggested the replacement of the test report with a component or system type-approval and indicated that this was under investigation by a Germany Industry (VDA) special working group.

After a long discussion there remained widely differing views, with the consensus being that none of the proposals being considered provided a clear way forward in resolving these differences.

Therefore, it was agreed that no specific amendment proposal would be made to GRRF and the chairman would report on the various points that had been discussed with a view to GRRF deciding:

• - Is there a problem that requires resolution?
  • o Annex 21 specific, ECE R13 specific or ’58 Agreement specific?

In the event of a yes decision, the recommendation would be the establishment of a new informal working group.

• - Before the introduction of test reports within the type-approval process it was appropriate that the Technical Service conducting the type approval was provided with a vehicle on which to conduct the tests as required by the regulation, hence paragraph 3.3. – “a vehicle, representative of the vehicle type to be approved, shall be submitted to the Technical Service conducting the approval tests.” With the addition of test reports within the type-approval process, and no change to paragraph 3.3. does this mean, for example, that:
  • a) the vehicle referred to in paragraph 3.3. and a vehicle in the test report shall be the same with regard to type, i.e. the same type from the same manufacturer, or
  • b) the vehicle referred to in paragraph 3.3. shall contain the same item that is the subject of the test report and the “approval tests” referred to in paragraph 3.3. are the tests to be carried-out at the time of type-approval for which there are no test reports.

• - Should an Approval Authority only grant an approval when all the Technical Services providing test reports used in a braking system type-approval are designated by them for that specific work? Is there a difference in the case of a system type-approval and in the case of a vehicle type-approval?

Discussion points:

• - Is there a difference in responsibility when a Technical Service sub-contracts type-approval test work (with or without an Approval Authority approved test report) or when they receive an Approval Authority approved test report from another Technical Service that they then use in a type-approval? Is there a difference between a system type-approval and a vehicle type-approval?

• - Although it is only the vehicle manufacturer who can obtain a braking system type-approval and, as a result, it is the vehicle manufacturer who is responsible in the first instance for any resulting consequences, is it clear that this responsibility goes not go away when a provided test report is used in the type approval?

• - Is the need for the vehicle manufacturer to show satisfactory arrangements at the time of type-approval with regard to conformity of production, as required by paragraph 3.4., sufficient for the vehicle manufacturers to be aware of their responsibilities when using test reports?

The various working documents submitted for this meeting were discussed in detail. For the outcome of the discussions, please see document ACV-06-10.

Provisions for mismatching between 12/24 volt
The group went through the 12/24v document from Jost. In Australia most trailers are 12v. The group concluded that this working group does not need to make mention of this at all as the situation is not critical.

Measuring response time
Jost made some measurements. Response time of an ACV is lower than with a helix cable. When we are measuring with a simulator, we have to measure the supply system. We need a set of rules for the conventional system (annex 6) and a set of rules for the automated system.

If volume L in annex 6 is left then we have a problem. A valve adds 0.06s. We need to change the volume in annex 6 for the automated system.

If the connection line between truck and trailer is different then this must be taken into account. We actually need a longer length.

The group agreed that the method as outlined still applies but there are open issues:
- Is there room for a different value of L? If the volume L is changed then it must be changed in the calibration also.
- Timing is a secondary issue. We know the measurement is good but we don’t know how it should be changed.

Solid connection of hoses
This item was not discussed.

A point for the next meeting : think about a manual button that would make the driver leave his cab.

A representative from Schrader presented a draft for a cost/benefit-analysis of TPMS. The draft was supported by further companies (Conti VDO, Knorr-Bremse, Beru, Entire Solutions LLC) but it is not a CLEPA or an ETRTO paper. The calculations in the draft which are based on a direct system show a very positive benefit/cost-relation even if the lower end of the range is taken for comparison. Besides fuel/CO2 saving and accident avoidance the TPMS can contribute a lot to tyre cost reduction because tyre wear increases considerably on under-inflated tyres.

There was agreement that the draft could be refined by taking into account further aspects like changing from summer to winter tyres or replacement/disposal of sensors and sealings.

However, it is obvious that the EU commission wants to use the potential for CO2-reduction which is given by TPMS and therefore further refinement of the cost/benefit calculation does not seem to be necessary.