NOTES FROM TAAM SUB-GROUP MEETING TO DISCUSS QUADRICYCLES

Transcription

1 NOTES FROM TAAM SUB-GROUP MEETING TO DISCUSS QUADRICYCLES Held on 6 April 2006 in Dublin after the main TAAM Attendees: Belgium European Commission Finland France Germany Hungary Ireland Latvia Luxembourg Netherlands Norway Poland Spain Sweden United Kingdom A meeting was held after the main TAAM in Dublin on 6 April 2006 in order to develop some proposals for consideration by the Motor Cycle Working Group with a view to improving the safety of quadricycles approved for road use. The scope of the meeting was also extended to cover three-wheel vehicles and pocket bikes. BACKGROUND The TAAM has previously discussed questions about quadricycles covered by the motorcycle framework directive. On each occasion the meeting has expressed concern about the safety of some of these vehicles on public roads in particular quad bikes and go-karts. Whilst, it has been noted that individual Member States might be able to apply 2002/24/EC Article 4 section 6 (see also 70/156/EEC Article 4 Section 2) to prevent registration on a national basis, it is also generally accepted that if the quadricycles meet all the relevant legislative requirements it is difficult to refuse them an approval. There has therefore been a consensus opinion at previous meetings that the legislation should be changed to restrict these types of vehicles. The Commission is currently discussing the legislation covering quadricycles and has invited the TAAM to submit some proposals to support the discussion (see the minutes of the March 2005 TAAM held in Spain) The TAAM sub-group acknowledged that its roll was not to propose actual legislation but simply to make some practical proposals/suggestions for motorcycle design criteria that could be used to support ongoing discussions in the Motor Cycle Working Group.

2 LEGISLATION 2002/24/EC CHAPTER I - Scope and definitions Article 1 1.This Directive applies to all two or three-wheel motor vehicles, whether twin wheeled or otherwise, intended to travel on the road, and to the components or separate technical units of such vehicles. This Directive does not apply to the following vehicles: (a) vehicles with a maximum design speed not exceeding 6 km/h; (b) vehicles intended for pedestrian control; (c) vehicles intended for use by the physically handicapped; (d) vehicles intended for use in competition, on roads or in off-road conditions; (e) vehicles already in use before the application date of Directive 92/61/EEC; (f) tractors and machines, used for agricultural or similar purposes; (g) vehicles designed primarily for off-road leisure use having wheels arranged symmetrically with one wheel at the front of the vehicle and two at the rear; (h) cycles with pedal assistance which are equipped with an auxiliary electric motor having a maximum continuous rated power of 0,25 kw, of which the output is progressively reduced and finally cut off as the vehicle reaches a speed of 25 km/h, or sooner, if the cyclist stops pedalling, nor to the components or technical units thereof unless they are intended to be fitted to vehicles covered by this Directive. It does not apply to the approval of single vehicles except that Member States granting such approvals shall accept any type-approval of components and separate technical units granted under this Directive instead of under the relevant national requirements. 2. The vehicles referred to in paragraph 1 shall be subdivided into: (a) mopeds, i.e. two-wheel vehicles (category L1e) or three-wheel vehicles (category L2e) with a maximum design speed of not more than 45 km/h and characterised by: (i) in the case of the two-wheel type, an engine whose: cylinder capacity does not exceed 50 cm 3 in the case of the internal combustion type, or maximum continuous rated power is no more than 4 kw in the case of an electric motor; (ii) in the case of the three-wheel type, an engine whose: cylinder capacity does not exceed 50 cm 3 if of the spark (positive) ignition type, or maximum net power output does not exceed 4 kw in the case of other internal combustion engines, or maximum continuous rated power does not exceed 4 kw in the case of an electric motor; (b) motorcycles, i.e. two-wheel vehicles without a sidecar (category L3e) or with a sidecar (category L4e), fitted with an engine having a cylinder capacity of more than 50 cm 3 if of the internal combustion type and/or having a maximum design speed of more than 45 km/h, (c) motor tricycles, i.e. vehicles with three symmetrically arranged wheels (category L5e) fitted with an engine having a cylinder capacity of more than 50 cm 3 if of the internal combustion type and/or a maximum design speed of more than 45 km/h. 3. This Directive shall also apply to quadricycles, i.e. motor vehicles with four wheels having the following characteristics: (a) light quadricycles whose unladen mass is not more than 350 kg (category L6e), not including the mass of the batteries in case of electric vehicles, whose maximum design speed is not more than 45 km/h, and (i) whose engine cylinder capacity does not exceed 50 cm 3 for spark (positive) ignition engines, or (ii) whose maximum net power output does not exceed 4 kw in the case of other internal combustion engines, or (iii) whose maximum continuous rated power does not exceed 4 kw in the case of an electric motor. These vehicles shall fulfil the technical requirements applicable to three-wheel mopeds of category L2e unless specified differently in any of the separate directives;

3 (b) quadricycles, other than those referred to in (a), whose unladen mass is not more than 400 kg (category L7e) (550 kg for vehicles intended for carrying goods), not including the mass of batteries in the case of electric vehicles, and whose maximum net engine power does not exceed 15 kw. These vehicles shall be considered to be motor tricycles and shall fulfil the technical requirements applicable to motor tricycles of category L5e unless specified differently in any of the separate Directives. PROPOSALS FROM MEETING TAAM Sub-Group Proposals regarding Quadricycles Tricycles and Pocket Bikes PART I: 4 AND 3 WHEEL VEHICLES The view of the meeting was that Quadricycles and Tricycles should be considered in two distinct categories, namely: - Those with saddles - Those with seats A: Vehicles with Saddles Quadbikes Design proposals to improve safety of vehicles to be approved for road use: - Minimum track width [suggestion: 1000mm] - Minimum Track/Wheelbase ratio [suggestion: wheelbase to be at least 1.2 times the track of the front and rear axles] - Differential on all driving axles - Only one seat (i.e. driver only passengers not allowed) - Must meet Anti-tampering requirements (to maintain restrictions on engine power/road-speed) - Must be fitted with e marked (or E marked) tyres suitable for the vehicle use on public roads - Must meet high speed stability test (e.g. Elk test) - Must meet wheel-guard requirements

4 Trikes (3 wheel bikes) The meeting proposed that the following requirements should also be applied to motor tricycles (and three-wheel mopeds) with saddles: - Minimum track width for two-wheel axle [suggestion: 1000mm] - Minimum Track/Wheelbase ratio [suggestion: wheelbase to be at least 1.2 times the track of the two wheel axles] - Differential on driving axles (if 2 wheels used for drive) - Must meet Anti-tampering requirements (to maintain restrictions on engine power/road-speed) - Must be fitted with e marked (or E marked) tyres suitable for the vehicle use on public roads - Must meet high speed stability test (e.g. Elk test) - Must meet wheel-guard requirements

5 B: Vehicles with Seats Design proposals to improve safety of vehicles to be approved for road use: 4 Wheel Microcars - Minimum R point height for all seating positions [suggestion: 450mm] - Passenger compartment to be fully enclosed with fully closed bodywork (with or without doors) up to a minimum height above R point [suggestion: 200mm above R point] - Must meet seat belt and seat belt anchorage requirements - Must be fitted with windscreen (with specific dimension requirements) - Must meet wheel-guard requirements - Must meet requirements for protection of fuel tank 3 Wheel cars The meeting proposed that the following requirements should also be applied to 3 wheel cars (motor tricycles) with seats: - Minimum R point height for all seating positions [suggestion: 450mm] - Passenger compartment to be fully enclosed with fully closed bodywork up to a minimum height above R point [suggestion: 200mm above R point] - Must meet seat belt and seat belt anchorage requirements - Must be fitted with windscreen (with specific dimension requirements) - Must meet wheel-guard requirements - Must meet requirements for protection of fuel tank

6 PART II: POCKET BIKES Pocket Bikes fall under the provisions for two wheel bikes. Design proposals to improve safety of 2 wheel vehicles to be approved for road use: - Must have saddle - Minimum Wheelbase [suggestion: 1000mm] - Minimum Saddle height [suggestion: 550mm] - Minimum Handlebar height [suggestion: 550mm] - Minimum Handlebar width [suggestion: mm] - Minimum dimension between centre of saddle and pivot point of handlebar [suggestion: mm] - Minimum Road Wheel diameter [suggestion: 10 inches] TAAM Quadricycle Sub-Group 6 April 2006

7 ATTACHMENT 1 TAAM PAPER - QUADRICYCLES

8 UK1: QUESTION FOR TAAM IRELAND APRIL /24/EC MOTORCYCLE FRAMEWORK DIRECTIVE QUADRICYCLES BACKGROUND The TAAM has previously discussed questions about quadricycles covered by the motorcycle framework directive. On each occasion the meeting has expressed concern about the safety of some of these vehicles on public roads. Whilst, it has been noted that individual Member States might be able to apply 2002/24/EC Article 4 section 6 (see also 70/156/EEC Article 4 Section 2) to prevent registration on a national basis, it is also generally accepted that if the quadricycles meet all the relevant legislative requirements it is difficult to refuse them an approval. There has therefore been a consensus opinion at previous meetings that the legislation should be changed to restrict these types of vehicles. The Commission is currently discussing the legislation covering quadricycles and has invited the TAAM to submit some proposals to support the discussion. In line with the minutes of the March 2005 TAAM held in Spain, it is now proposed to form a TAAM task force to develop some proposals for submission to the Commission. The purpose of this paper is therefore to remind TAAM members of the previous discussions and to seek participants for the task force. TASK FORCE TIMING It is intended that the task force will meet in the afternoon of Thursday 6 April at the end of the main TAAM. Those interested in participating are requested to arrange their travel plans according

9 LEGISLATION 2002/24/EC Article 4 section 6 However, if a Member State finds that a vehicle, system, component or separate technical unit which complies with the provisions of paragraph 1 is nevertheless, a serious risk to road safety, it may refuse to grant the type-approval. It shall forthwith inform the other Member States and the Commission thereof, stating the reasons on which its decision is based. 2002/24/EC CHAPTER I - Scope and definitions Article 1 3. This Directive shall also apply to quadricycles, i.e. motor vehicles with four wheels having the following characteristics: (a) light quadricycles whose unladen mass is not more than 350 kg (category L6e), not including the mass of the batteries in case of electric vehicles, whose maximum design speed is not more than 45 km/h, and (i) whose engine cylinder capacity does not exceed 50 cm 3 for spark (positive) ignition engines, or (ii) whose maximum net power output does not exceed 4 kw in the case of other internal combustion engines, or (iii) whose maximum continuous rated power does not exceed 4 kw in the case of an electric motor. These vehicles shall fulfil the technical requirements applicable to three-wheel mopeds of category L2e unless specified differently in any of the separate directives; (b) quadricycles, other than those referred to in (a), whose unladen mass is not more than 400 kg (category L7e) (550 kg for vehicles intended for carrying goods), not including the mass of batteries in the case of electric vehicles, and whose maximum net engine power does not exceed 15 kw. These vehicles shall be considered to be motor tricycles and shall fulfil the technical requirements applicable to motor tricycles of category L5e unless specified differently in any of the separate Directives.] DISCUSSION There are currently three main types of quadricycle: 1. Quad Bikes: There is concern about the general safety of quad bikes when used on public roads particularly when passengers are carried 2. Microcar:

10 Due to the mass restrictions for quadricycles, there is concern about the crash performance of microcars. 3. Road Going Kart: There is concern about the lack of driver protection and visibility of these karts from other vehicles. Some additional thoughts to prompt further discussion: - Specify a minimum R point height for the driver and passenger: This would be intended to eliminate road going Karts - Specify a minimum amount and type of bodywork: This might be used to effectively remove the sales appeal of quad-bikes and Karts - Remove quadricycles from the motorcycle framework and re-classify them as M and N catory vehicles under framework directive 70/156/EEC, as amended.

11 EXAMPLES OF PREVIOUS TAAM PAPERS ABOUT QUADRICYCLES TAAM SPAIN MARCH Vehicle suitable for use on roads? - Sweden 3, Netherlands 6 and Commission 2 TAAM QUESTION 3, from Sweden for TAAM SUBJECT: Vehicle suitable for use on roads? DIRECTIVE: 2002/24/EC RELEVANT SECTION: 2002/24/EC, Chapter I, Article 1, item 1. Scope and definitions 1. This Directive applies to all two or three-wheel motor vehicles, whether twin-wheeled or otherwise, intended to travel on the road (the Swedish version of 2002/24/EC states intended for road traffic ), and to the components or separate technical units of such vehicles.... DISCUSSION Are these types of vehicles intended for road traffic?

12 Questions by the TAAM delegation of The Netherlands 6. No Directive: 2002/24/EC Subject: Type-approval of two or three-wheel motor vehicles Text: Recently, this vehicle (see enclosed pictures) came to the RDW for a registration certificate. We were surprised to find out that it was type-approved and thus came with a CVO (L7e). Because the maximum speed is 100 km/h, it may be possible to encounter this vehicle on the motorway. More likely is that we encounter it, but we don t see it because of its height. We feel that it is a hazard to allow such a vehicle on the motorway. DIRECTIVE 2002/24/EC Article 4 subsection 6: However, if a Member State finds that a vehicle, system, separate technical unit or component which complies with the provisions of paragraph 1 is nevertheless a serious risk to road safety, it may refuse to grant the type-approval. It shall forthwith inform the other Member States and the Commission thereof, stating the reasons on which its decision is based. Question : 1. Is it possible to refuse this kind of vehicles pursuant to article 4 (2002/24/EC)? 2. Are there Member States who have laid down a criterion for this article 4 section 6? 3. Do other member states register this kind of vehicle? If yes, do you impose any restrictions? If no, on what grounds do you refuse the registration? 4. Do we really want this kind of vehicles on our European roads?

13 European Commission 2 : Question For TAAM Madrid March 2005 Type-approval of quadricycles according to Directive 2002/24/EC According to our information the motor vehicle below has been type-approved as a quadricycle according to Directive 2002/24/EC The Commission services would like to get the views of the TAAM members if this vehicle fulfils all requirements in order to be used on public roads. TAAM MINUTES: General feeling that these vehicles are unsafe and must not circulate on public roads but the problem is that there are some Member States that find difficulties in forbidding the registration of a vehicle with a WVTA. It was decided to create a working group which will collect all possible ideas and deal with this question (even considering how to change the framework directive).

14 TAAM FRANCE SEPTEMBER Quadricycles with more than 15 kw - Slovenia 1 and Procedures and requirements for granting type CE approvals Estonia 1 Directive 92/61/EEC and 2002/24/EEC Slovenia 1 Question In our country we have a problem how to treat vehicles Quadricycles L7e with more than 15 kw? Formally these vehicles can be classified neither in category L nor in M1. Directive 92/61/EEC and 2002/24/EEC Estonia 1 Question Procedures and requirements the Type Approval Authority must fulfill for granting the EU Type Approval in relation to vehicle types L7e? TAAM MINUTES: These vehicles are not within the scope of Framework Directive 2002/24/EC. There is uncertainty between Member States, which legislation is applicable. Depending on the country these vehicles are approved according to the requirements applicable for M1 vehicles, agricultural vehicles, 2-3 wheels vehicle or according to national legislation. Some participants were of the opinion that these vehicles should be included in the Framework Directive 2002/24/EC and specific requirements should be developed. Additional Notes: This item concerned the classification of quadricycles principally designed for off-road use by farmers. They are particularly popular in the USA and sales in some European markets are increasing. This topic was previously discussed at the June 2001 TAAM in Norway.

15 A quadricycle with engine power of not more than 15kW and with an unladen mass of not more than 400kg (or 550 kg for vehicles designed to carry goods) can be approved under the provisions of 2002/24/EEC as an L7e category vehicle. The questions from Slovenia and Estonia concern the classification of quadricycles with more than 15kW. The meeting acknowledged that there is a problem with the classification of higher power quadricycles and the Commission delegate explained that the motorcycle legislation did not really take account of this type of vehicle. The meeting agreed that there are two main options: - They would have to be classified as M1 category vehicles or - Their engine power should be limited to 15 kw or less However, the meeting also accepted that, on one hand, these vehicles would not meet the requirements for M1 vehicles whilst, on the other hand, the manufacturers would not wish to limit the engine power to 15kW. It was noted that in some countries, UK included, these vehicles are typically classified as agricultural vehicles and hence, in these cases, the M1/L7e classification is not an issue. There was a consensus view that, in practice, the vehicles should be limited to off-road (i.e. non-public road) use only and several delegates expressed the view that these vehicles are not safe for use on public roads (particularly if they don t have a rear axle differential). It was also pointed out that the definition of public road can vary from country to country. The meeting was in favour of more stringent legislation to specifically forbid the use of high power quadricycles on public roads although no action plan was agreed.

16 TAAM NORWAY JUNE Definision of ATV s. (Norway) TYPE-APPROVAL OF ALL TERRAIN VEHICLES (ATV) QUADRICYCLES ACCORDING TO ECWVTA AND NATIONAL REGULATIONS Questions raised by Norway Part I Norway has received the WVTA no E4*92/61*0087*00, valid for a light quadricycle. This vehicle has no bodywork and in our opinion - is primarily designed for off-road leisure use (ref. enclosed picture). In the Scope and definitions of Directive 92/61/EC, chapter I, is it written in article 1, no 1: This Directive does not apply to the following vehicles: vehicles designed primarily for off-road leisure use having wheels arranged symmetrically with one wheel at the front of the vehicle and two at the rear,. In no 3 of the same chapter and article is it written: (a) light quadricycles whose unladen weight is less than 350 kg, ; these shall be considered to be mopeds; In no 2 of the same chapter and article is it written: The vehicles referred to in paragraph 1 shall be divided into: - moped, i.e. two or three wheeled vehicles fitted with an engine. We would like to raise the question to the TAAM if the vehicle mentioned above should be defined into the group vehicles designed primarily for off-road leisure use having wheels arranged symmetrically with one wheel at the front of the vehicle and two at the rear. Such vehicles are not covered by Dir. 92/61/EC. Part II On the Norwegian market there are several kinds of all terrain vehicles of similar type to the one mentioned above. However, these are of a heavier type, with engine-power exceeding 15 kw (15 kw is power-limit for quadricycles in Dir. 92/61/EC, actual vehicles are covered by Dir. 70/156/EC). These vehicles are manufactured in USA and Japan, and are common on the USmarket. In our national regulations we do not have any vehicle category for these vehicles (except for passenger car), as they appear from the manufacturer. However, being equipped with a three-point linkage at the rear, they are classified and approved in the category tractor (national category, which differs a little from the EC agricultural and forestry tractor). Typically for all these vehicles, are that the manufacturers declaration saying that these vehicles are only designed for off-road use - use on roads are unsafe. We have not succeeded in getting further information concerning this from the manufacturers. Of this reason, such vehicles in Norway are only permitted for use outside public roads. We would appreciate getting some information about how these vehicles are dealt with in the other EEA-countries.

17 TAAM MINUTES: It s clear that four-wheeled ATV s are covered by the scope of the directive. It s only the three wheelers for off-road use that are out of the scope because of their dangerous construction. It s up to the member-state to make eventual restrictions for use. This kind of vehicles is also defined as tractors, machines or cars in some countries, with speed restrictions and in some countries also only for off-road use.

18 ATTACHMENT 2 TAAM PAPER POCKET BIKES

19 KBA Paper Germany 4 Directive 2002/24/EC Pocket bikes Issue There are a lot of new types of vehicles, so called pocket bikes, entering the EU-market. On several exhibitions these vehicles are presented for sale. Some of them do have a WVTA (medium size) some don t (smaller size). The vehicles which have a valid WVTA do fulfil the requirements of all separate directives mentioned in the framework directive 2002/24/EC. Although this is the case, we think that those bikes are not safe on the roads and should not have the right to be driven on public roads. In Germany the WVTA for such a medium range pocket bike is of the category L1e and has got a vmax of 45km/h. So for Germany it is not possible to reject these bikes from being registered, because of the only obligation for those mopeds to have a valid insurance (small insurance number plate). The KBA would like to add this issue to the discussion about changing the directive 2002/24/EC in its scope. To get an impression please have a look at the pictures: