Comments concerning:

• AVAS Pause Switch
• AVAS Sound Pressure Levels
• Maximum AVAS Sound Pressure Level
• AVAS Sound when vehicle stationary

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.

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.

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).

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

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

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.

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