Welcome to the latest installment of “International Update” – a monthly feature of the Washington Insider from John Creamer, MEMA’s advisor on international regulatory affairs. This month's installment reviews the outcomes of the recent session of the UN World Forum for the Harmonization of Vehicle Regulations (WP.29) held in Geneva, June 24-28. During the session, WP.29 adopted a new regulation for the approval of light vehicle automatic emergency braking systems (AEBS), approved a “framework” for pursuing automated driving regulations, and showed interest in applying technology to shift from periodic vehicle inspections to “continuous” “whole-life” “in-service compliance”. The update also provides a list of regulatory changes of possible interest to MEMA members.
If there are topics you would like to see addressed in future “International Update” columns or if you have questions about this installment, please contact Leigh Merino with MEMA. Please click through to read the whole column.
New Automatic Emergency Braking Regulation
During its June session, WP.29 adopted a new regulation for the type approval of AEBS on passenger cars and light trucks (category M1 and N1). The new regulation (UN R152) provides the technical specifications for mandatory AEBS installation in Japan starting next year and across the European Union starting in 2022.
The AEBS regulation addresses urban-use scenarios, including vehicle-to-vehicle and vehicle-to-pedestrian collisions. The test procedures include:
- Warning and activation test with a stationary vehicle target
- Warning and activation test with a moving vehicle target
- Warning and activation test with a moving pedestrian target
- False positive test passing between stationary vehicles
- False positive test passing a stationary pedestrian
- Deactivation test (automatic reactivation after manual deactivation)
Broadly, the regulation sets a 40-42 km/h relative speed threshold for car-to-car collision avoidance for passenger cars and a 38-42 km/h threshold for light trucks and vans. At or above the thresholds, the regulation sets maximum relative impact speed limits in km/h. For the pedestrian test, the no-contact thresholds broadly start from 35 km/h with exceptions for “full cab” trucks. By 2024, regulators expect the full-cab distinction to disappear while the no-collision speed thresholds rise (under the draft 01 series of amendments).
The new standard does not include tests with a cyclist target. However, these scenarios are under consideration for a future update (beyond the 01 series) in line with EU intentions.
Automated Vehicle Framework
The United States, European Union, and Japan jointly submitted a “framework” for global cooperation to ensure the safe deployment of automated driving systems (ADS). This framework document on automated/autonomous vehicles (SAE Level three and higher) sets out a basic vision, broadly defined key issues, and a table of priorities with timeframes. Under the framework plan, WP.29 will deliver a new regulation for the type approval of low-speed (≤60 km/h) on-highway SAE Level 3/4 automated lane-keeping systems by next March. The current draft text is under development within a dedicated group on Automatically Commanded Steering Functions (ACSF).
At the same time, additional expert groups will focus on defining functional requirements and new validation methods for the assessment of high-level ADS. Concurrently, groups on cybersecurity, software updates and “data storage systems for automated driving” (DSSAD) – an advanced form of event data recorder for automated vehicles – will produce further technical specifications and type approval procedures.
Next month’s International Update will provide a fuller update on these various activities.
Continuous Vehicle Inspections
In line with the proceedings of the International Motor Vehicle Inspection Committee (CITA), which is the global organization for vehicle inspection agencies, WP.29 showed interest in shifting from “periodical technical inspections” to “whole-life vehicle compliance.” WP.29 administers an international agreement for the acceptance of technical inspections (especially for heavy-duty transport) known as the 1997 Agreement. An expert group working on the further development of this agreement noted their interest in applying new technologies – especially related to the capabilities of automated driving for continuous system monitoring and data collection – to ensure “continuous roadworthiness”.
In addition to concepts coming out of deliberations on automation, the UN Working Party on Pollution and Energy (GRPE) has also expressed interest in continuous monitoring, especially given keen political interests in “real driving emissions” (RDE) testing and concerns over long-term emissions performance (including tampering issues).
Although “in-use compliance” remains an ambiguous term (in the absence of specifications to comply with), it appears there is a rising interest in applying vehicle connectivity and other advanced technologies to continuously monitoring vehicle safety and environmental performance.
Child Safety in Buses and Coaches
WP.29 approved a request from the UN Working Party on General Safety (GRSG) to form a new expert group focused on children and buses. The new group, Safer Transport for Children in Buses and Coaches, expects to formally submit one or more new approval regulations for child restraint systems and possibly other measures to improve child occupant safety before the end of 2022.
Regulatory Changes Adopted During the June WP.29 Session
The following is a listing of regulatory proposals adopted during the June session:
- UN R17 (Seat strength): Supplement 1 to the 09 series of amendments – Clarifies the conditions under which side-facing seats may be installed in buses of category M2 and M3, classes A and I.
- UN R24 (Diesel pollutants): Supplement 5 to the 03 series of amendments – Aligns UN R24 with UN R85 (measurement of net power) with regard to correction factors.
- UN R44 (Child restraint systems): Supplement 16 to the 04 series of amendments – Ends the possibility for new CRS approvals under UN R44 from 1 September 2020 (after which all new child restraint system approvals would be under UN R129 (the “enhanced” CRS regulation).
UN R79 (Steering equipment): Supplement 1 to the 03 series of amendments – Clarifies requirements for the optical signal during a Corrective Steering Function intervention:
- ensure sufficient flashing tell-tale visibility for the driver;
- specify the duration of such signals;
- ensure a safe hierarchy of signals (e.g., primacy of emergency steering over corrective steering);
- clarify that deactivation when departing an Operational Design Domain means the “off mode”; and,
- add a cross-reference to paragraphs that define cases of manual and automatic deactivation.
- UN R83 (Motor-vehicle emissions): Supplement 13 to the 06 series of amendments and Supplement 9 to the 07 series of amendments—Clarifies the relationship among approval levels, reference fuels and particulate number limits for positive-ignition vehicles and modifies the calculation formulae for determination of evaporative emissions (in accordance with UN GTR No. 19). Also, resolves a contradiction in requirements concerning the provision of SCR reagent consumption data via the serial port of the standard diagnostic connector.
- UN R85 (Net power measurement): Supplement 9—Reduces testing burdens by introducing an alternative test method to “decrease the charge air cooler outlet temperature by the same amount that the ambient conditions for the vehicle test varied from the standard temperature.” This aligns with SAE J1349, “9.3 Application of Vehicle Transient Data to Net Power Test.”
- UN R90 (Replacement brake components): Supplement 5 to the 02 series of amendments – Aligns text in Annex 7 with motorcycle braking provisions of UN R78 and adds references to conventional and electric quadricycles (L6 and L7 vehicles up to 550 kg) to enable type approval for replacement brake linings.
- UN R115 (LPG/CNG retrofit systems): Supplement 8 – Aligns UN R115 with the GTR 15 WLTC harmonized emissions test cycle.
- UN R138 (Quiet road transport vehicles): Supplement 1 to the 01 series of amendments – Exempts hybrid vehicles where the internal combustion engine is active under the UN R138 test conditions, clarifies permissible operating conditions (such as in the U.S. where the speed range extends to 30 km/h) for the audible vehicle alerting system (AVAS), differentiates requirements for indoor and outdoor test facilities, and aligns maximum sound threshold with UN R51 on vehicle noise.
- UN R139 (Brake assist systems): Supplement 2 – Clarifies that UN R139 does not mandate the installation of brake assist systems (BAS) on vehicles but rather specifies requirements for the approval of vehicles should they be equipped with a BAS system.
- UN R140 (Electronic stability control systems): Supplement 3 – Clarifies that UN R140 does not mandate the installation of electronic stability control systems (ESC) on vehicles but rather specifies requirements for the approval of vehicles should they be equipped with an ESC system.
- UN GTR 15 (Worldwide Harmonized Light Vehicle Emissions Test Procedure or “WLTP”): Amendment 5 – A comprehensive facelift to the regulation to improve clarity. The accompanying technical report provides detailed explanations of the changes. NOTE: The U.S. and Canada abstained during the adoption vote since neither country applies GTR 15.
- UN GTR 19 (WLTP Evaporation Emissions Test Procedures) : Amendment 2 – Improves and amends the evaporative emission family definitions and the Type 4 test procedures with regard to test equipment requirements and calibrations, evaporative emission measurement enclosures, and use of variable volume SHED facilities. The accompanying technical report provides detailed explanations of the changes. NOTE: The U.S. and Canada also abstained during the adoption vote since neither country applies GTR 19.