CLEPA supports the general approach in the current draft UN R for children left in vehicles regulation. Systems shall detect presence of children through a technology neutral approach based on performance requirements. Door-logic based systems have known weaknesses and are insufficient as standalone solutions. Systems shall appropriately address situations where children are unknowingly or knowingly left in vehicles, with suitable test cases covering real-life relevant situations and child restraint system installations. CLEPA proposes replacing references to in-direct plus or direct sensing systems with sensing system throughout the regulation.
Proposal to insert a new introduction section defining application to vehicles of categories X and Y equipped with an Automated Driving System, to amend para. 6.1.5. to replace “driver assist systems” with “driver assistance systems”, to remove the non-exhaustive list “cameras, radar devices, etc.”, to replace “disoriented” with “misaligned”, and to add provisions clarifying that the exemption for sensor damage does not apply to automated driving systems unless the Automated Driving System performance of the Designed Driving Task is not affected.
Proposal to:
This Regulation establishes uniform provisions for crashworthiness approval of N1Y vehicles regarding fuel system integrity, electrical shock protection, and crash compatibility during frontal, rear, and lateral collisions. The provisions for frontal impact are based on UN R94 or UN R137 per manufacturer choice with Technical Service agreement; lateral impact provisions are based on UN R95; rear impact provisions are based on UN R153. Vehicles with maximum design speeds not exceeding applicable impact speeds shall be tested at their maximum design speed and comply with post-impact requirements. Crash Compatibility Criterion shall not exceed 40–45 g and Crash Compatibility Value shall not exceed 100–120 g×tonne. For vehicles derived from types already approved under UN R94, UN R137, UN R95, or UN R153, previous test results may be used if mass increases do not exceed 8 per cent.
Proposal, updated with in session comments, to amend Footnote 1 to reference document ECE/TRANS/WP.29/78/Rev.8, amend para. 6.1.5. to clarify that the exemption for sensors being part of driver assistance systems does not apply to automated driving systems, remove non-exhaustive examples of sensors, replace “disoriented” with “misaligned”, and align terminology to “driver assistance systems”. The exemption for driver assistance systems is retained because their failure does not prevent manual vehicle operation, whereas automated driving systems’ perception equipment forms part of the driving function, and damage to sensing devices may prevent vehicle operation contrary to Regulation No. 42’s objective.
Updated document with in-session comments.
Draft text for a new UN Regulation on crashworthiness of vehicles of category N1Y, including comments from France: