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Stakeholder consultation on a preliminary draft proposal for a regulation on pedestrian protection - summary of contributions

Stakeholder consultation on a preliminary draft proposal for a regulation on pedestrian protection - summary of the results

Introduction

The Commission has formulated a draft proposal for a Regulation which would replace the existing Directive on Pedestrian Protection and, at the same time, amend the requirements of Phase II following the required feasibility study. In line with this proposal an internet consultation process was carried out in order to allow for comment to be made by all interested parties.

Replies

A total of seventeen replies were received to the request for comment. Of these the breakdown of source is:

  • Government 2
  • Industry 7
  • NGO 5
  • Other 3

Issues Identified

The following provides a summary of the main issues which were raised by the correspondents:

1. Adult/Child headform test relaxation zones (7 replies - 2 Gov, 5 Ind.)

Comment:
The draft proposes that the relaxation zones to be allowed for both child and adult headforms would be one third of the individual designated test areas.

Replies from industry request that the one third of the area should be based on the combined test areas. Two replies added the consideration that the child headform area should have a maximum of one third as relaxation zone.

2. Concern with application date for BAS (7 replies - 1 Gov, 6 Ind.)

Comment:
The point is made that to require all vehicles to be fitted with brake assist in 2008 would be too demanding and may even require the withdrawal of some models from the market. The majority of comments considered that 2010 would be achievable for all vehicles with one comment suggesting 2008 for new types. It was also noted that there was some inconsistency in the intended application dates in the proposal.

3. Provide requirement for future amendments (5 replies - 1 Gov, 4 NGO)

Comment:
The main concern is that where certain issues are monitored within the proposal there should be a stated requirement to review and update the requirements accordingly.

4. Reliability issue for BAS (5 replies - 1 Gov, 4 Ind.)

Comment:
The question was raised of how issues of the reliability of brake assist should be dealt with.

5. Allowance for transition between phase I and phase II (4 replies - 1 Gov, 3 Ind.)

Comment:
The request in each case is to ensure that there may be no retroactive application of the requirements.

6. Headform test Speeds (4 replies - 4 NGO)

Comment:
All replies on this subject contained the stated preference for a retention of the 40km/h test speed for the head impact tests.

7. Clarification required on use of Collision Avoidance (4 replies - 2 Gov, 1 NGO, 1 Ind.)

Comment:
Replies question the potential use of such a technology as an alternative to passive measures and stresses the need for full validation before acceptance for use.

8. Provide test specification for Brake Assist (3 replies - 1 Gov, 1 Ind., 1 NGO)

Comment:
The provision of requirements for testing and verification of brake assist systems was requested.

9. General application dates (2 replies - 2 NGO)

Comment:
Requests to bring the application dates of all requirements forward of those dates in the existing Directive.

10. Requirement for high bumper test (2 replies - 2 Ind.)

Comment:
Replies request that the definition for a high bumper vehicle, and subsequent requirement for the legform test, should be changed.

11. Correspondence with global technical regulation (gtr). (2 replies - 1 Gov, 1 Ind.)

Comment:
Requests are made to ensure correspondence with the work on-going to develop a global technical regulation under the UN/ECE in Geneva.

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