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 update previews the upcoming session of the UN Working Party on Passive Safety (GRSP), including proposed updates to electric vehicle safety and rear impact requirements, as well as an overview of expected regulatory changes in 2020. For context, the GRSP gathers technical experts from the world’s vehicle regulatory agencies to decide on and recommend proposals for common crash-testing and passive-safety requirements. If approved by GRSP, the proposals would go to the World Forum for the Harmonization of Vehicle Regulations (WP.29) for formal adoption by the middle of next year.
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WP.29 November Session
As expected, the World Forum adopted the slate of proposals for amendments to current UN type-approval regulations previewed in November’s International Update with one exception. The European Commission asked for a delay in considering the proposal to introduce provisions for the approval of Remote-Controlled Maneuvering (RCM) systems under UN Regulation 79 (R79).
GRSP December session
The GRSP will meet next week in Geneva during 10-13 December 2019. The session will consider a major amendment to Global Technical Regulation No. 7 on head restraints. This amendment would specify a head restraint height between 720 mm and 830 mm including a new method for measuring the effective height of head restraints and formalize the use of the Biofidelic Rear Impact Device (BioRID II) test dummy. This proposal also eliminates the backset measurement test procedure using the HRMD method as an acceptable test method. These changes would also impact type approvals under UN R17 given that UN Regulations are required to align with Global Technical Regulations. A proposal to align UN R17 with GTR No. 7 is also on the GRSP December agenda.
Several proposals will also deal with the advent of the new “General Safety Regulation” (GSR) of the European Union (see the March 2019 Insider for more details). In particular, the frontal and side impact crash regulations (UN R94 and UN R95) will be updated to remove limits on their application to light passenger cars (M1) and light trucks (N1). Another significant change is a proposal for new type-approval requirements for rear impact tests and electric vehicle safety. This new regulation on the safety of high voltage systems and fuel system integrity in a rear-end collision would update certain requirements currently in UN R34 on rear-end crash testing and UN R100 on battery electric vehicles. The high-voltage provisions transpose requirements adopted under GTR 20 on electric vehicle safety last year.
Expectations for 2020
Since this International Update is the last one for 2019, it seems appropriate to take a quick look at regulatory activities likely to generate new requirements next year. Without further ado, the following list covers the pipeline of principal WP.29 initiatives for changes to international requirements:
- Increased allowance for unsuccessful Advanced Emergency Braking Systems (AEBS) test runs
- Increased limits for car-to-pedestrian AEBS performance
- Low-speed, on-highway automated lane-keeping system (ALKS) approval requirements
- Progress on car-to-bicycle AEBS requirements
- Requirements for automated lane-keeping data recording and storage
- Global event data recorder (EDR) specifications
- Allow for temporary modification of rearview mirror fields-of-view (e.g., overlays)
- Reversing field-of-view and object detection requirements
- Exempt obscuration area from sunroof test zones to allow for installation of equipment (e.g., rain sensors, inside mirror, ADS sensors)
- Recommendations on widths for sunroof ceramic printed areas
- Allow for more flexibility in instrument panel telltale colors
- Electric vehicle battery durability requirements
- Formalization of BioRID II rear impact dummy drawings, specifications, and manuals
- Uniform specifications for 3D H-Point Machine
- Global Real Driving Emissions (RDE) regulation
In addition, work will advance on major new requirements for heavy vehicle field-of-vision requirements. These requirements (also included in the EU GSR program) would require substantial redesigns of urban delivery trucks to provide drivers with clearer frontal and lateral views of pedestrians and cyclists. In principle, meeting these requirements (based upon the direct vision standards pioneered by the City of London) would involve lowering the truck chassis and driver compartments while expanding the windshield area. The current plans target early 2021 for formal delivery of the proposed requirements for consideration within WP.29.
Upcoming WP.29-related Meetings
The UN Working Party on Pollution and Energy (GRPE) will meet in Geneva during 14-17 January 2020. The main item on the agenda will be a proposal to transpose the Worldwide Harmonized Light Vehicle Emissions Test Procedure (WLTP) established by GTR No. 15 into the international type approval system (i.e., under UN Regulations, including updates to existing emissions regulations and a new regulation on WLTP). The WLTP introduction will proceed in two phases with a proposal for second-phase requirements also on the GRPE agenda. Another significant measure would update OBD requirements pursuant to the new WLTP requirements and methods.
The UN Working Party on Automated/Autonomous and Connected Vehicles (a.k.a. GRVA) will meet during 10-14 February in Geneva. The group has a heavy agenda in February, especially given the deadlines for delivering proposals to the March 2020 session of the WP.29. As a result, other meetings will be held in January by various expert groups on automated vehicle functional requirements, validation methods for automated driving system assessment, and on EDRs and automated driving system data storage. Furthermore, a technical group on “automatically commanded steering functions” will also seek to finalize approval requirements for on-highway automated lane-keeping systems (ALKS) for use at speeds up to 60 km/h. Another expert group focused on regulating cybersecurity and software updates will meet in Washington, DC during 21-23 January 2020. This group is expected to finalize its proposal for certifying management processes to ensure cybersecurity and software safety as a prerequisite to obtaining type approvals for advanced vehicles.