CEMA position on draft braking regulation, 4 June 2008 ENTR/F1/ /rev16

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1 CEMA PT16 N05Rev CEMA position on draft braking regulation, 4 June 2008 ENTR/F1/ /rev16 CEMA is the European association representing the agricultural machinery industry. It represents the industry of 11 European countries with a turnover of 21 billion Euro and 4,500 production sites in Europe. This position is expressing the latest CEMA s essential concerns on the draft regulation on braking for tractors proposed by the European Commission. They should be duly noted in order to pursue a fruitful dialog. CEMA has gained the impression from the course of discussion at the 82nd meeting of the WGAT on October 3rd, 2007 and also from further talks with the EU Commission that its position would be aligned with the TRL study conclusions and the proposed draft regulation. Such a misunderstanding should be dissipated by the below remarks. CEMA is prepared to draft the amendments to the draft regulation in accordance to his remarks. 1. TRL study The work performed by TRL triggered many criticisms from industry and other experts. Technical and editorial errors were found in the text such as the construction and fitting requirements for vehicles of category R1, R2 and S1 for instance. They must be corrected. Furthermore requirements for category C were not considered. Other mistakes are to be identified regarding the protocols and the tractor features used for testing. For instance: - Engaging of the front axle during braking has not been considered, while it has a high impact on the stability of the tractor while braking. - Tractor alone and some typical combinations of tractors and loaded-unloaded trailers have not been tested. - TRL have not included requirements for Advanced Braking Technologies (ABT, see 3) on towed vehicles. CEMA considers that implementing ABT or ABS on a tractor does not make sense when it is not required on the towed vehicle As a matter of principle the industry could only accept regulatory proposals based on rigorous scientific approach. CEMA is therefore asking that TRL propositions shall not be automatically adopted. 2. Legal certainty and technical review During the course of discussion, it was proposed that all identified technical problems and mistakes would be tackled by a Technical review after the adoption of the regulation and before it s entering into force. After taking legal advice, CEMA now estimates that this solution couldn t be retained any more. A technical review wouldn t give the industry the legal certainty it needs for planning and designing the envisaged technical changes. Furthermore all identified problems arising from technical mistakes or wrong testing approaches should be corrected before the adoption of the regulation and not after. 1

2 3. Clear distinction between braking requirements for tractors above and below 60 km/h The requirement that tractors with a maximum speed of more than 40 km/h shall be equipped with antilock braking systems (ABS) is not acceptable for CEMA CEMA believes that the provisions of Annex XIV for ABS should only be applied on vehicles with a maximum speed exceeding 60 km/h. Tractors below that speed should not be bound to use this specific technology. In case ABS or other advance braking system ABT would be mandatory at speeds of more than 60 km/h, it would need to be ensured that the ABS could be switched off, as this is also necessary and usual for other off-road vehicles. Similar provisions to UNECE Regulation 13, Annex 13, paragraph 4.5 should be included to ensure that the ABS is reconnected once the start device has been set to the run position. Today there are no ABS systems on the market available for traditional tractors which are usable in the field. Truck ABS can not be fitted without modifications to tractors or other vehicles intended for application in the field. With the automatic engagement of the front axle during braking the stability of the tractor while braking has been improved. But this technology will not work in combination with ABS. Tractors below 60 km/h are mainly used in combination with towed agricultural implements but the majority of them cannot be equipped with ABS. ABS only makes sense if tractor and towed vehicle are equipped with and not only the tractor. All mandatory requirements for ABS or ABT should coincide with the implementation dates of Stage IV of the engine emission directive according to the power bands. These new requirements on braking systems will have a major impact on the tractor design; therefore this redesign should be aligned with the introduction of future emission Stages in order to reduce manufacturer s efforts for design and construction of tractors. Today manufacturers usually combine major redesign with the implementation of new engines and after treatment technologies. As a matter of legal principle, CEMA cannot accept that the industry should be forced to use any specific technology and wouldn t have the free choice to define its own technical solutions for reaching a requested level of performances (solutions we cover under ABT designation). 4. Split brake pedals (appendix I, ) It is not accepted that on split brake pedals (so-called "steering brake") an automatic speed limitation at 30 km/h be required when the pedals are not coupled. Section of appendix I, should therefore state the following: "The service brake of the tractor may comprise right and left hand devices. It must be possible to connect them up so that they can be actuated in a single operation, and possible to disconnect them again. The driver must be able to verify easily from his driving place whether the devices are connected or not. Each device, right or left hand, must have a system of adjustment, which may be either manual or automatic, enabling the balance of the brakes to be easily restored. The trailer s service brake must be activated when a single (right or left hand) brake pedal on the tractor is actuated." (Functional/safety problem in field) The requirement for automatic/controlled coupling of the left and right side brakes above a given threshold speed shall coincide with any eventual mandatory requirement for ABT. 2

3 The manual coupling of the split brake pedals has been already accepted by WGAT before (rev13). Automatic coupling of the split brake pedal is technically not achievable on simple tractors without high sophisticated electronics and sensors. The coupling of the brake pedals should be under the responsibility of the driver same as coupling of the towing device, coupling of the pneumatic/hydraulic connectors of the trailer brakes or the adjustment of the rear view mirrors. Note: Automatic coupling of the split brake pedal inclusive electronics and sensors would become object to the type approval of brakes (electronic safety assessment). 5. Compatibility between tractors and towed vehicles (appendix II, diagrams) The corridors of appendix II should by modified as follows: Diagram 2 from appendix 10 of the ECE regulation 13 should be applied for tractors and trailed vehicles designed and intended to be used at speeds exceeding 30 km/h. Whereby laden tractors must not exceed the upper border line but may fall below the lower border line of the laden corridor. There should be special provisions vehicles which are designed and intended to be used at speeds not higher than 30 km/h. There are technical and economical reasons to justify this that were previously developed. This would mean a reduced service braking performance level and an exemption for compliance with the compatibility corridors of appendix II. General This means that passenger cars, trucks and their trailers have to meet European compatibility requirements only if their maximum design speed exceeds 25 km/h. Tractors need these special provisions because traditional tractors are not technically able to meet the compatibility curves for trucks. The wide range between unladen mass and maximum permissible mass of the tractor would require automatic adjustment of the braking performance between the front and rear axle adjusted by load sensing devices to be able to meet the compatibility requirements of ECE R13. Those automatic load sensing controls need an input of parameter, either the pressure of a pneumatic suspension or the spring deflection to receive information about the actual load. For this reason tractors must be equipped with suspension in general. Such systems are not practical for field applications (position control of the rear three point linkage is not compatible to full suspension) or economically not feasible for all kind of tractors from the today s point of view. Therefore tractors should meet the corridor for unladen conditions of diagram 2 from appendix 10 of the ECE regulation 13. But laden tractors must not exceed the upper border line but may fall below the lower border line of the laden corridor. Those requirements could be achieved with the general basic adjustment of the braking system. With such requirements the critical effects during braking of a combination of tractor and trailed vehicle ( Jack knife effect ) can already be reduced or eliminated, because in a vehicle combination the trailed vehicle will be braked with a higher deceleration than the tractor. (diagrams will be added) see annex Trailed vehicles should meet the compatibility diagrams of ECE R13 to achieve the free exchangeability of trailed vehicles. To meet the compatibility requirements trailers and trailed implement have to be fitted with a load sensing system, automatic or manual from the today s point of view. 3

4 6. Braking values for towing vehicles with a maximum speed not exceeding 30 km/h (Annex II, ) For towing vehicles with a maximum speed not exceeding 30 km/h the following formula should be applied to calculate the maximum braking distance: smax 0.15 v + v²/92; the respective value for d M is 3.5 m/s². General justification Alignment between braking requirements for agricultural and commercial vehicles This means that passenger cars, trucks and their trailers have to meet European braking requirements only if their maximum design speed exceeds 25 km/h. Today general requirements concerning braking performance, such as stopping distance or mean fully developed deceleration are prescribed in national road safety legislation for all vehicles intended for road use not covered by EC directives. German StVZO 41 requires a mean fully developed deceleration of 3,5 m/s 2 for all vehicles not exceeding 25 km/h. (Other national requirements of other member states have to be checked). The maximum speed is the only criteria for requirements on braking performance. It is not necessary to create special exemptions for various tractor types. Technical justification There are a lot of 2-wheel driven ag tractors on the European market, which are braked on the rear axle only. These kinds of tractors are not able to meet a mean fully developed deceleration of 5.0 m/s 2. Mean fully developed deceleration of 5.0 m/s 2 might cause unstable driving conditions for some T4.1 (high clearance) tractors because of the high centre of gravity. If tractors are not able to achieve a mean fully developed deceleration of 5.0 m/s 2 the maximum design speed of tractors should be the possibility to be limited to 30 km/h. 7. Braking values for towed vehicles (Annex II, and ) CEMA disagrees that the same braking values independent of their permitted maximum speed should be valid for all towed vehicles. A differentiated review is rather required also for towed vehicles: "The sum of the forces exerted at the periphery of the braked wheels shall be at least X % of the maximum stationary wheel load, X having the following values: Maximum design speed v max (in km/h) X (in %) v max < v max 50 General justification Alignment between braking requirements for agricultural and commercial vehicles This means that passenger cars, trucks and their trailers have to meet European braking requirements only if their maximum design speed exceeds 25 km/h. 4

5 Today general requirements concerning braking performance, such as stopping distance or mean fully developed deceleration are prescribed in national road safety legislation for all vehicles intended for road use not covered by EC directives. German StVZO 41 requires a mean fully developed deceleration of 3,5 m/s 2 for all vehicles not exceeding 25 km/h. (Other national requirements of other member states have to be checked:. 2,5 mean deceleration in France (about equivalent to 3.5 mean fully deceleration ), 2.5 mean fully deceleration in the UK. The maximum speed is the only criteria for requirements on braking performance. It is not necessary to create special exemptions for various types of towed vehicles. Technical justification There are a lot of towed implements on the European market, which are braked on one axle or one wheel only. These kind of towed vehicles are not able to meet a mean fully developed deceleration of 5.0 m/s 2. Usually those implements cannot be technically modified in order to improve the braking performance, because the structure and the mass distribution are optimised according to their application and the limited free space for installation of braking systems. Also implements and trailers with tyre diameter exceeding 1.5m cannot find appropriate brake drums/axles on the market (trailed sprayers, manure or slurry spreaders ) Mean fully developed deceleration of 5.0 m/s 2 might cause unstable driving conditions for special trailers or towed implements with limited mass on the braked wheels or the high centre of gravity of the towed vehicle itself. If it is technically not possible to achieve a mean fully developed deceleration of 5.0 m/s 2 with towed vehicles it should be possible to limit the maximum permitted speed of those vehicles to 30 km/h. 8. Category C At this moment it is unsure whether vehicles of Category C can meet the Regulation. For this reason, it s necessary to assess whether there is a need for adaptation of the Regulation in order to make it appropriate for category C vehicles taking also in consideration that rubber and steel tracks have different characteristics. 9. Hydrostatic drive The special provisions for vehicles with hydrostatic drive shall be re-inserted as written in the previous document version. There was agreement on this in a previous WGAT meeting. (Instability when braking at high rate) 10. Other specific and general items There should be a special provision for trailed appliance conveyors specially designed for carrying harvesting cutter bars. An inertia service brake should be allowed up the 6 tons (sum of axle loads). Again, there was agreement on this in a previous WGAT meeting. All implementation dates should be synchronized where possible with some of the key dates of the time table of the engine emission Directive for tractors (2000/25/EC as last amended by 2005/13/EC). Other separate Directives under 2003/37/EC may need a revision in order to fulfil the requirements of this Regulation. Speed marking decals (30, 40, 60 km/h) may be needed and the vehicles itself may need markings for clear identification. Industry shall make proposals for new work items for standardization in the field of connectors to the relevant ISO Sub Committees. 5

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