While encouraged by the adoption of a uniform minimum sound alert standard, the WBU continues to believe that: 1) the proposed minimum sound standard is too low for safety; 2) the AVAS should remain on while the QRTV is active but stationary; and 3) the regulation should prohibit manufacturers from providing a means of pausing the alert sound.

33. The representative of WBU welcomed the preparation of the draft QRTV Regulation (agenda item 4.13.1) and the adjustment of the Terms of Reference of the IWG of the QRTV Regulation to tackle the concerns of WBU (WP.29-168-13). He also thanked the expert from Japan for his proposal to prohibit the AVAS pause switch that had been made at the sixty-third session of GRB. In this context, the representative of Japan expressed his support to the adoption of the draft QRTV Regulation upon understanding that, in the future, it could be amended prohibiting the pause switch. He invited experts from other countries to cooperate on this issue. The representative of the United States of America informed the World Forum that the national Rule on AVAS would be published in his country in the coming months and that the Rule would provide for AVAS sound at idle and would ban the pause switch. The representative of EU pointed out that the EU Member States would be ready to vote for the draft QRTV Regulation and thanked Japan for their proposal to address the pause switch issue at a later stage.

World Blind Union comments opposing the current provisions of the draft UN Regulation on quiet vehicle minimum sound levels, especially with regard to the effectiveness of the AVAS parameters, inclusion of “pause button”, and absence of stationary (“idling”) vehicle sound requirement.

100. The representative of the World Blind Union introduced WP.29-167-23 and WP.29-167-28 presenting the concerns of his organization on the recent proposal for a new Regulation on QRTV adopted by GRB in September 2015. He kindly requested further consideration related to the provisions on Audible Vehicle Alerting System (AVAS) sound pressure levels, optional installation of AVAS pause switches and sound emissions when stationary.

Presentation of research conducted by the World Blind Union and National Federation of the Blind in the United States to validate the effectiveness of the proposed minimum sound levels for quiet vehicles at 10 and 20 km/h. The researchers concluded that the proposed sounds levels do not add significantly to the detectability of an approaching vehicle by a blind pedestrian and that internal combustion engine vehicles were detected substantially sooner than quiet vehicles equipped with the proposed acoustic vehicle alerting system (AVAS).

100. The representative of the World Blind Union introduced WP.29-167-23 and WP.29-167-28 presenting the concerns of his organization on the recent proposal for a new Regulation on QRTV adopted by GRB in September 2015. He kindly requested further consideration related to the provisions on Audible Vehicle Alerting System (AVAS) sound pressure levels, optional installation of AVAS pause switches and sound emissions when stationary.

WBU study shows that UN levels are too low with the biggest concern being the risk of masking. The background noise applied during testing is an important factor and it often differs from real traffic situations. OICA proposed to design an adequate background sound from real world recordings taken at different spots.

Presentation by Dr. Edward C. Bell, Professional Development and Research Institute on Blindness, Louisiana Tech University.

21. The expert from WBU called for shared responsibility of drivers and vulnerable road users for road safety and requested that the Audible Vehicle Alert System (AVAS) of QRTV be “ON” while the vehicle is stationary and that the driver should not be able to deactivate (or pause) AVAS (GRB-62-03). He also referred to a study (GRB-62-16) suggesting that the proposed AVAS level of sound did not seem to make QRTV with AVAS more detectable to the average blind person than was QRTV without AVAS. According to the study, more research would be needed to determine a minimal noise level that would satisfy the desire to reduce noise emissions while remaining safe for pedestrians.

WBU and European Blind Union statement critical of the current draft UN Regulation for failing to adequately address the needs of the visually impaired.

21. The expert from WBU called for shared responsibility of drivers and vulnerable road users for road safety and requested that the Audible Vehicle Alert System (AVAS) of QRTV be “ON” while the vehicle is stationary and that the driver should not be able to deactivate (or pause) AVAS (GRB-62-03). He also referred to a study (GRB-62-16) suggesting that the proposed AVAS level of sound did not seem to make QRTV with AVAS more detectable to the average blind person than was QRTV without AVAS. According to the study, more research would be needed to determine a minimal noise level that would satisfy the desire to reduce noise emissions while remaining safe for pedestrians.

Presentation of WBU testing of AVAS as proposed by the draft UN Regulation (i.e., 50/56 DBA). Based upon this research, the WBU states the the proposed AVAS requirement would have little impact on the sound-recognition of quiet vehicles.

23. The expert of WBU presented a position paper (GRB-61-15) with concerns about an Audible Vehicle Alert System (AVAS) of Quiet Road Transport Vehicles (QRTV). He stressed that AVAS must fulfil four criteria, namely presence, direction, location and operation of a hybrid electric or electric vehicle. He further explained that the AVAS sound must be detectable and locatable, AVAS must be on while the vehicle is stationary and that the driver should not be able to switch off (or pause) AVAS.

Comments on the proposals and guidelines developed for acoustic vehicle alerting systems for quiet road vehicles.

8. WBU: Review of WBU position from document REG58-QRTV-01-004 – WBU Comments on CLEPA-QRTV Report October 2014: WBU named the overall Sound pressure level as the most important item. Other very important factors of the Regulation to come are pitch shifting, the amount of broadband (enabling to recognize vehicle’s speed and its directivity), sound at stationary (50 dB(A) is not seen as an environmental concern) and the abstinence of a pause switch (does it make sense to turn a safety feature off?)

WBU referenced document REG58-QRTV-01-004 – WBU Comments on CLEPA-QRTV Report October 2014, that was already presented during the 1st meeting in Tokyo and pointed the importance to present the content to both GRB and WP29. WBU expressed the concerns that with the proposed waiving of a sound at stationary and the inclusion of a pause switch to be operated at the discretion of the driver, the pedestian’s safety would be in the hands of the driver rather than of the pedestrian. WBU underlined that a high SPL is one of the most important attributes of AVAS.

The Chair responded that most participants see the SPL as included in the proposed UN Regulation as sufficiently high to be well detectable. The level is derogated from scientific researches. WBU is invited to present further data that underlines the need for a higher SPL.