Mercedes-Benz India Comments on published standard IS Turning Circle & Manueverability Requirements

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1 Mercedes-Benz India Comments on published standard IS Turning Circle & Manueverability Requirements Sr. No. Clause No. Current Proposed Justification 1. Clause 5.0 Maneuverability Requirements 5.1 The vehicle shall be able to maneuver on either lock inside a circle of 12.5 m radius without any of its outermost points projecting outside the circumference of the circle. 5.2 When the outermost points of the vehicle are moving on either lock on a circle of 12.5 m radius the vehicle shall be able to move within the limits of a circular track 7.2 m wide as shown in Fig.1 or Fig 2 as applicable Any vehicle must be able to maneuver on either side for a complete circular trajectory of 360 inside an area defined by two concentric circles, the outer circle having a radius of 15 m and the inner circle having a radius of 5.30 m, without any of the vehicle s outermost points (with the exception of the protruding parts excluded from the measurement of the vehicle width) projecting outside the circumferences of the circles. For vehicles with axle-lift devices, this requirement also applies with the retractable axle's) in the lifted position or loadable axle's) in the unladen condition The requirements of paragraph 5.1. shall be verified with the outermost front point of the vehicle guided along the contour of the outer circle (see figure A). The requirement of 12.5m is revised to 15 m with respect to the following considerations. The 3-axle buses currently type approved are of 14 m length and are not capable of meeting the requirements due the length and completely different chassis design with respect to Europe. The current 3-axle buses meet the TCD requirements of 24m and the overhang requirements as per the CMVR rule 93. However, enough length is required for the front and rear overhangs of the buses. An effort to meet the 12.5m

2 5.3 With the vehicle stationary, a vertical plane tangential to the side of the vehicle and facing outwards from the circle shall be established by marking a line on the ground. In the case of an articulated vehicle the two rigid portions shall be aligned with the plane. When the vehicle moves from a straight line approach into the circular area described in paragraphs 5.1 and 5.2 above, no part of it shall move outside of this vertical plane by more than dimension U in the case of a rigid vehicle and in Fig. 2 in the case of an articulated vehicle. 5.2 With the vehicle stationary, a vertical plane tangential to the side of the vehicle and facing outwards from the circle shall be established by marking a line on the ground. In the case of an articulated vehicle the two rigid portions shall be aligned with the plane. When the vehicle moves from a straight line approach into the circular area described in paragraphs 5.1 and 5.2 above, no part of it shall move outside of this vertical plane by more than dimension U given in Fig.A in the case of a rigid vehicle and in Fig. B in the case of an articulated vehicle. requirement of TCCD and maneuverability requires major design changes in the complete bus relating to the overall length reduction by means of reduction of wheel base and overhangs. This could subsequently affect the seating configurations etc. For a 15m length buses which is permitted as per CMVR, with the given axle weight combination, wheelbase, overhangs, it can be maneuvered in a circle of 30m. Hence, we opine that considering the maximum length with the given wheel base and overhang combinations; we propose to increase the maneuverability requirement from 12.5 to 15m. Also the current ECE R107 specifies a maneuverability procedure without locking the wheels while maneuvering and clearly excludes the protruding items like rear view mirrors etc.

3 In the case of vehicles covered in 1.2, the turning clearance circle radius as defined in 3.2 shall not exceed dimensions R given in fig.1 & fig.2 as applicable. Delete the clause ECE regulation does not specify any TCCD requirements. The ECE only specifies the Maneuverability requirements. Insert the following figure Fig A Editorial correction with respect to change in clause 5.0

4 Fig 1 FIG B Editorial correction with respect to change in clause 5.0

5 ` FIG C Editorial correction with respect to change in clause 5.0

6 For, Mercedes-Benz India Pvt. Ltd Sanjeev Mandpe Nikhil Desai General Manager Manager Product Homologation Product Homologation

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