The Type Approval of the electronic braking systems - analysis of the causes of different interpretation of UNECE Regulation No.

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1 DUBOWSKI Adam P. 1 ZEMBROWSKI Krzysztof 1,2 PAWŁOWSKI Tadeusz 1 The Type Approval of the electronic braking systems - analysis of the causes of different interpretation of UNECE Regulation No. 13 in Europe INTRODUCTION PIMR the Industrial Institute of Agricultural Engineering is working on improving agricultural (rural) transportation, and as the first European research institute it pointed out that truck and gooseneck trailer technology is one of the best transportation options for the agricultural sector [1-10]. The implementation of new road units in agricultural and forestry transportation can immediately have an impact on improving road safety, especially on the international road transit network in Poland, on improving traffic flow and on better protection of the environment. In 1998 a research gooseneck trailer was designed and built. Over the next 15 years research trailers were tested with several trucks (Polonez-Truck, Lublin, Land Rover Defender 110, Mitsubishi L200). In 1998 the gooseneck trailer was equipped with electric brakes (Dexter Axle, USA) and a coupling device with a hitch ball 2-5/16 inches in diameter. Between 2004 and 2008 the electric brakes were replaced by several models of the Sens-a-Brake (SAB) system (manufactured by Edge International, New Zealand). In 2009, AL-KO International, Australia purchased SENSABRAKE from Edge International and firm is promoting this braking system under new name Electronic Air/Hydraulic (Brake Actuation) System, EAS for short, as the best braking system on the market, and delivered features that the large and heavy trailer owner would require [11]. For over 10 years of R&D work one of the main issues was how to modify the Dexter Axle electric brakes as well as the SAB system, so that they would conform with UNECE Regulation No. 13 requirements (R13) [12]. PIMR s main problem was that according Polish experts expertise such electronic brakes were not described in the main chapters of the R13 and their use on the market is not allowed yet. PIMR carried out R&D project N R /2008 a transport system based on the use of a new coupling and innovative control system for steering hydraulic brakes mounted in towed vehicles. The project was finished in 2010 and several research gooseneck trailers (category O2 and O3) were built and tested. Gooseneck trailer PIMR-N1 and classical trailer PIMR P1 were coupled with a research truck Mitsubishi L200 (ML200), unit is presented on figure 1. Fig. 1. M L200 truck with gooseneck trailer transports from the forestry nursery trees in the light containers. Vehicles are equipped with electronic Brake-By-Wire System ( PIMR-EBS [6,9] ) (archive PIMR-BE) 1 Przemysłowy Instytut Maszyn Rolniczych, Starołęcka 31, Poznań 2 kierownik Zespołu ds. Energetyki i Dynamiki Maszyn Rolniczych, zembrowski@pimr.poznan.pl,

2 1 R&D PROJECT, PATENT DISCLOSURES AND PIMR-EBS BRAKING SYSTEM HOMOLOGATION TESTS The achievements of this project were: several patent disclosures, a new electric-pneumatichydraulic brake system (PIMR-EBS [9,10]) and two Type Approvals for the PIMR-EBS electric brake system mounted in the trailer (GVW 3400 kg), approval no. E9-13R , and in the gooseneck trailer (GVW 4300 kg), approval no. E9-13R The tests were carried out by IDIADA Poland [13] and accepted by Spanish experts. Since 2010 the research road units were used in general transportation, mainly to transport agricultural machines and the PIMR s Hovercraft Tools Carrier. New research unit is based on Iveco Daily D35 4x4 truck and gooseneck trailer (NGS-10, [8] ) and it is equipped with PIMR-EBS [9,10]. NGS-10 trailer is designed to transport agricultural tractors and machines, especially new tracked vehicles with tools (figure 2, 3) which are used for removing greenery in protected aerials of national parks. Fig. 2. Research unit: Iveco Daily D35 4x4 truck and NGS-10 gooseneck trailer with agricultural Kubota tracked tractor and mower. Research unit is equipped with electronic braking system (PIMR-EBS, [9, 10] ) (archive PIMR-BE) Fig. 3. Research unit: Iveco Daily D35 4x4 truck and gooseneck trailer with PIMR s amphibian tracked tractor. Research unit is equipped with electronic braking system (PIMR-EBS, [10] ) (archive PIMR-BE) In the middle of 2012 PIMR sent a request to IDIADA Poland to run Type Approval update tests of the new version of PIMR-EBS. Surprisingly, our request was rejected by IDIADA Spain, although two Type Approval Certificates that had already been issued were counted as fully valid. At the beginning of 2013 the IDIADA changed its previous decision and sent us a new offer for testing the upgraded version of the PIMR-EBS in trailer and gooseneck trailer category O2 which would allow us to obtain an extension of each approval [14]. Unfortunately, we do not know why IDIADA Poland/Spain rejected our request to conduct new approval tests on trailers category O

3 2 UNECE TRANSPORT DIVISION The main reason for such a situation could be the: a) conservative nature of the majority of experts working at UNECE s World Forum in Harmonization of Vehicle Regulations Working Party 29 (WP.29) and their belief in traditional only solutions such as pneumatic or hydraulic brakes, or even dangerous inertia brakes, b) lack of cooperation between other Working Parties (e.g. WP.1 ), c) lack of an Official Authority of the UNECE Transport Division [15] that could present official worldwide interpretation of paragraphs in the chapters and annexes of the R13. The UNECE Transport Division (TD) that has been providing secretariat services to the World Forum for Harmonization of Vehicle Regulations (WP.29) for more than 50 years is not authorized to give an advice or to present proper interpretations of Regulation 13 s content. According Transport Division worker: Only Type Approval Authorities can carry out such an interpretation. Yet in the case of problems where is the inventor and/or manufacturer to ask for help? The most astonishing piece of information placed on the UNECE web page is that: The World Forum has incorporated into its regulatory framework the technological innovations of vehicles to make them safer and more environmentally sound and that the UNECE Transport Division acting as secretariat to the World Forum, the Vehicle Regulations and Transport Innovations section serves as the secretariat of the Administrative Committee for the coordination of work, and of the Administrative/Executives Committees of the three Agreements on vehicles administered by the World Forum. The term coordination work should mean that TD should have the validity to serve as an Official Appealing Office for inventors/manufacturers who do not agree with the interpretation of R13 requirements delivered by the National Type Approval Authorities (NTAA). The UNECE Transport Division should be able to issue an official position on the questionable interpretation, and UNECE s WP.29 experts and NTAA should not have such power and privileges. Instead of making a vehicle safer and more environmentally friendly, in ECE-R13 and its Chapter 5 we can find information stating that in compressed-air braking systems the only accepted connections between power-driven vehicles and trailers can be made by technically outdated pneumatic connections (paragraphs: , ). A slightly more modern solution ( ) is for years excluded from road units thanks to the work done by WP.29 experts, since in , footnote 4 we can read: that until uniform technical standards have been agreed which ensure compatibility and safety, such connection shall not be permitted. Open question to the UNECE WP.29 experts is: How many more years do you need to prepare and agree on proper uniform standards? How many more decades will it take you to confirm that electric systems are reliable, often safer and better than conventional pneumatic, hydraulic (not to mention the inertia-type) braking systems? 3 UNCLEAR STRUCTURE ECE-R13 IS THE CAUSE OF DIFFERENT INTERPRETATIONS OF ITS CONTENT In Chapter 5 the WP.29 experts did not include any definitions of the elements of advanced electric braking systems mounted in power-driven vehicles as well as in heavier trailers. This looks like an example of a conspiracy agreement that is being backed up by the lobbying of the main manufacturer players with the goal to discreetly and effectively protect pneumatic, hydraulic braking systems as well as inertia-type brakes, and to prevent any possibility of implementing modern and innovative braking systems steered only by wires. Perhaps this impression looks too offensive to UNECE s WP.29 experts. From the point of view of the inventors of such an advanced electronic braking system this is a very polite version of their opinion. 3278

4 PIMR received government funding to support R&D project (ca. EUR 300,000) and that amount is nothing compared to projects such as SPARC-EU [16] and HAVEit [17], which are being carried out in Europe. Thanks to our new transportation system we want to improve safety and efficiency in agricultural and forestry transportation we want to replace farm tractor transportation with modern truck-gooseneck trailer units (cat. O2/O3). and furthermore to save energy sources (every year up to 75 thousand tons of oil are used up in Poland). The NTAA experts wrongly interpretations of ECE-R13 are blocking market implementation of advanced electric braking systems and new road units. This is happening despite enormous European funds going into innovative systems. 4 EXAMPLES AND PROBLEMS DUE TO THE UNCLEAR STRUCTURE OF R13 Project SPARC-EU ( ) was supported by Framework 7 (Project Cost: Mio Project Funding: 6.50 Mio ) or its next-stage continuation as Project HAVEit ( ) in total investments of EUR 28 million were made in HAVEit, of which EUR 17 million were EU grants and EUR 11 million were contributed by 17 partners, of which EUR 7 million were invested by the automobile industry. The results of both SPARC-EU and HAVEit have been the development of a very advanced electro-mechanical braking system that can be used in a wide range of power-driven vehicles, personal cars as well as trailers which is much better, safer, and environmentally friendlier than conventional pneumatic, hydraulic, not to mention junk-type and life threatening inertia-type brakes. What is the problem with content of the UNECE Regulation No. 13? The problem is that since 2002 the experts of WP.29 did not react and did not forecast the needs for implementing new requirements for modern, innovative steered-by-wire braking systems. WP.29 experts during this period implemented annex 14 and described the European requirements for electric brakes in such a way that it became a caricature of the original system adopted from the U.S.A. Compared to the original idea of that system, in the European-accepted version the main safety feature a safety button or potentiometer for steering only the trailer s brakes was removed, as was the ability to adjust the reaction of the brakes on different road surfaces and during different weather conditions. Two new requirements were implemented into European market: a) to mount an inertia control device on trailers, and b) to reduce the level of amperes (up to 15A) going from truck/car to trailer. Thanks the UNECE WP.29 experts work - manufacturers can implement electric brakes in Europe, but the cost of an inertia controller placed on a trailer is 5x higher than the prices for typical, e.g. Tekonsha [18] or Dexter Axle [19], controllers. In the U.S.A you can use up to 4 axles with electric brakes, whereas in Europe only two such axles can be used. Why in Europe we need to reduce the electric power to 15A when there are the technical options of mounting additional electric generators? This European version of electric brakes is only slightly better than that of inertia-type brakes. Thus we believe that European and worldwide manufacturers of inertia-type brakes are surely pleased that the electric brake competitor is not a real threat. The customers are happy they can buy a simple and inexpensive braking system but...it looks as if at UNECE WP.29 nobody cares that inertia brakes are very dangerous for safety transportation and environmental protection. For a decade (until May of 2007), such inertia/surge brakes were excluded from private and commercial use in many states of the U.S.A., and surely UNECE WP.29 experts were aware of this. The American Rental Association formed a Surge brakes Coalition [20]. After more than 10 years of struggle, rental businesses finally declared victory on surge brakes in The U.S. Department of Transportation s Federal Motor Carrier Safety Administration (FMCSA) in Washington, D.C. published final regulations that allowed surge brakes on all small and medium-sized trailers, even those used in 3279

5 interstate commerce. The new rules went into effect April 5, In PIMR s opinion this is not a victory but an approval of populist demand and an example when the FMCAS the official governmental department failed in the area of improving road safety in U.S.A. national transportation. Since 1998 year, the content of R13 annex 18 was expanded, but this happened in such a way that the reader is sure that the complex electric system can be granted the Type Approval, yet experts from the Type Approval Authorities have quite an opposite understanding of annex 18 s content. For a better understanding of such interpretational discrepancies we can look at the results of the HAVEit Project. During the HAVEit final keynote event Haldex presented the following conclusions [21]. One of them was that HAVEit s EBM system was in many respects able to comply with R13, and a specific focus on annex 18 of R13 was made during the review. Despite that effort, according to the TUV Institute for Vehicle Technology and Mobility in Essen, the German report assesses the Haldex EBM system for trucks as: new EBM technology is not fully covered by the technical requirements of UNECE Regulation No. 13, and this is due to the fact that the EBM system produces actuation forces using electric energy instead of hydraulic or pneumatic energy in the case of the conventional braking system. Therefore, due to the nature of the electro-mechanical braking system, the Haldex EBM system cannot literally meet all of the technical requirements of UNECE Regulation No. 13 [22]. The next important piece of information on that page of the report is that for requirements which cannot be met, proposals are made to update R13. The TUV report was issued in May 2011 two years have passed and again the same question remains: How has the content of ECE-R13 changed to open up equal market chances for manufacturers of advanced electric brakes that are mounted in trucks and trailers category O2-O4? 5 R13 - A DIFFERENT UNDERSTANDING OF CHAPTER AND ANNEX CONTENT BY THE INVENTORS/MANUFACTURERS AND THE EXPERTS OF NATIONAL TYPE APPROVAL AUTHORITIES. PIMR s diagnosis is that the content of R13 gives rights to obtain the Type Approvals for any advanced electronic braking system. We need to underline that, according to our knowledge, only the experts at IDIADA Poland/Spain were able to run a proper methodology for testing our electric-pneumatic-hydraulic PIMR-EBS braking system. In 2010 year, thanks to an IDIADA Poland expert s effort and intellectual ability to combine the requirements of several chapters and annexes of ECE-R13, our PIMR-P1 trailer (Gross Vehicle Weight 3400 kg) and PIMR-N1 gooseneck trailer (GVW 4300 kg) obtained Type Approvals. The above-mentioned approval process was not easy due to the pioneering nature of the new methodology of testing such an innovative electronic braking system, which is steered only by wires. The new testing procedure was mainly developed by IDIADA Poland in close cooperation with PIMR s inventors/research team. So, such double success of obtaining the Type Approvals for a gooseneck trailer and trailer, both category O2, shows that good will, understanding the importance of innovative braking technology and common sense are enough to overcome problems. The problems connected with PIMR s request to run tests for an extension of already issued Type Approvals by IDIADA Poland/Spain show inner, backstage discussions with other experts, which probably took place during meetings of UNECE WP.29 or during discussions with experts of the Type Approval Authorities from EC. In PIMR s opinion the content of R13 s chapters and annexes should be treated equally, but different opinions are presented by several of the Type Approval Authorities experts in the same way as TUV NORD in Essen [22]. 3280

6 PIMR is sure that such different opinions are based on improper citation of R13 paragraphs and the traditional conservative interpretation that looks at the main chapters as if at some sacred, authoritative text, and that experts treat the content of the annexes as unimportant requirements in the Type Approval procedure. For such experts innovative, safety and environmental issues do not count at all. PIMR is of the firm opinion that such an approach is not covered by the general goals of the UNECE Transportation Division. In Chapter 2 of R13 we can read a general definition of transmission. The paragraph has a very important part which is shown as bolded text. In the paragraph there is also a somehow misleading sentence shown as underlined text: 2.5. Transmission means the combination of components comprised between the control and the brake and linking them functionally. The transmission may be mechanical, hydraulic, pneumatic, electric or mixed. Where the braking power is derived from or assisted by a source of energy independent of the driver, the reserve of energy in the system is likewise part of the transmission. The transmission is divided into two independent functions: the control transmission and the energy transmission. Whenever the term transmission is used alone in this Regulation, it means both the control transmission and the energy transmission. The control and supply lines between towing vehicles and trailers shall not be considered as parts of the transmission. It has to be underlined that in the above-mentioned chapter there is no footnote with a restriction concerning the use of an electric transmission to steer, control and power (Brake-By-Wire) electric braking systems as was observed in paragraph and its footnote 4. In our understanding this paragraph allows for not only mechanical, pneumatic and hydraulic transmission, but also for electric transmission. Again, the question is: on what basis are Type Approval Authorities stating that only pneumatic or hydraulic transmission is approved by UNECE Regulation No. 13? Several negative results of the UNECE WP.29 experts work have been pointed, so probably accidently the experts approved the content of annex 18, and in its paragraphs (1 & 2.2) we can clearly read: 1. General This annex defines the special requirements for documentation, fault strategy and verification with respect to the safety aspects of complex electronic vehicle control systems (paragraph 2.3. below) as far as this Regulation is concerned. This annex may also be called, by special paragraphs in this Regulation, for safety related functions which are controlled by electronic system(s). This annex does not specify the performance criteria for the system but covers the methodology applied to the design process and the information which shall be disclosed to the Technical Service, for type approval purposes. This information shall show that The system respects, under normal and fault conditions, all the appropriate performance requirements specified elsewhere in this Regulation Electronic control system means a combination of units, designed to co-operate in the production of the stated vehicle control function by electronic data processing. Such systems, often controlled by software, are built from discrete functional components such as sensors, electronic control units and actuators and connected by transmission links. They may include mechanical, electro-pneumatic or electro-hydraulic elements. The system, referred to herein, is the one for which type approval is being sought. The first finding is that the reader of annex 18 is assured that a new modern electronic system can obtain Type Approval. The second finding is that there are no references to paragraph (compressed-air systems). The third finding is that in paragraph we have additional requirements that are specified only for electric brakes which are poorly adapted in Europe from the U.S.A.: 3281

7 In the case of a power-driven vehicle equipped to draw a trailer with an electrical braking system, according to paragraph 1.1. of Annex 14 to this Regulation, the following requirements shall be met:... The above-mentioned annex 14 describes only European specific requirements for lower quality electric brakes based on the inertia feature. The requirements can, but in our opinion do not need to, be expanded to advanced electric braking systems with electric transmission (with electric control and electric supply lines). A careful reading of the chapters and annexes shows that the content of ECE-R13 is not against new electric systems (brake-by-wire systems). It is true that the content of ECE-R13 is not clearly and logically presented. There are too many technical details that in fact work as barriers against development not as a lever for modern braking systems. The effect of such an approach is reminiscent of a situation when the Occupational Safety and Health Administration (U.S.A.) first to came into existence, inspectors and enforcers of the thousands of OSHA regulations gave business-owners fits. Tired of being hit on and nearly regulated out of business they fought back and managed to have some of the power stripped away from the federal agency. Some argued that if all the OSHA rules were follow to the letter, even cowboys would be regulated beyond recognition. To illustrate the point, this drawing (figure 4) was sent out and posted in work areas throughout the land. A copy of this drawing was made by A.P. Dubowski in Smithville, Texas, U.S.A. in Fig. 4. Results of the efficient work of O.S.H.A. experts (archive PIMR-BE) It is highly probable that if WP.29 experts could expand the requirements of R13, such a cowboy would not obtain vehicle -type approval because the driven road unit has no efficient braking system (the horse has only non-skid spark suppressors) and, in addition, because such a road unit has no pneumatic or hydraulic connections between the towing/powered vehicle and the towed vehicle with an E.P.A. emissions control system. Of course, the enclosed picture is directly connected with the work results of the experts at O.S.H.A., but it is also a very good example illustrating the effects of the WP.29 experts work. This is very likely to be true when one finds that Haldex is going into the restructuration process in an Internet message [23]. This happened thanks to the UNECE Transportation Division s improper coordination and supervision of WP.29 experts work. Without proper control of UNECE WP.29 experts, they have for years not been able to make a proper update of ECE-R13 requirements. It looks as if they did this to protect the market position and profits of an unnamed but well-known group of European manufacturers of conventional braking systems. 3282

8 In Memo/10/343 (issued in Brussels, July 20, 2010) Road Safety Programme it is stated that detailed measures have been presented and, among others, For electric vehicles, the Commission will bring forward a package of concrete measures setting technical standards for safety [24]. We should be glad that at least somebody at UNECE TD and in Europe is thinking about the importance of electric vehicles. The problem is that three years have passed and we are still waiting for new standards and the proper treatment of innovative electric brake innovators/manufacturers. CONCLUSIONS 1. The content of UNECE Regulation No. 13, its chapter 2, especially point 2.5 and annex 18 allows for the Type approval of the new advanced electric systems (brake-by-wire systems). There are no other legislative and technical restrictions, and there is no needs to have additional pneumatic, hydraulic connections between towing and towed vehicles. 2. UNECE Transportation Division should take the leader and supervisor role over the work of the WP.29 experts. 3. UNECE Transportation Division should be the main source of official worldwide interpretation of the Regulation No UNECE Regulation No. 13 requirements should be reshaped and simplified, all paragraphs should be treated equally in the chapters and annexes. 5. Inertia braking systems, as most dangerous, should immediately be forbidden for use in Europe. They should be replaced by modern electronic braking systems. Abstract The paper describes the issues that have arisen due to the unclear structure of UNECE Regulation 13 s (R13) chapters and annexes and its content which is protecting traditional, technically outdated pneumatic/hydraulic and inertia braking systems which constitute an archival-type and very dangerous braking system. The content of R13 is far behind the modern innovative braking systems that have been developed in European R&D Projects (e.g. SPARC-EU, HAVEit). These are much safer, efficient and more environmentally friendly as compared to the conventional pneumatic, hydraulic braking systems that are being protected/forced into use in Europe by UNECE WP.29 experts. ECE-R13 should be rewritten and the volume of unnecessary technical details should be removed in order to give an equal chance for other manufacturers who do not belong to the few worldwide players. The difficulty that arises in reading the content of R13 and the UNECE Transportation Department s - lack of the official interpretation of the requirements are the cause of the conservative interpretations that are presented by the majority of experts of Type Approval Authorities in Europe. An exceptional example is IDIADA Poland/Spain, with different attitude and different interpretation of R13 which was able to run a successful approval test on Mitsubishi L200 truck coupled with trailer (PIMR P1) and gooseneck trailer (PIMR-N1), both category O2 and all vehicles equipped with the electric-pneumatichydraulic PIMR-EBS braking system Homologacja elektronicznych układów hamulcowych - analiza przyczyn różnego interpretowania przepisów Regulaminu 13 EKG ONZ w Europie Streszczenie Artykuł opisuje problemy związane z niejasną strukturą Regulaminu nr 13 EKG ONZ (R13), którego rozdziały i zawarte w nich wymagania - praktycznie chronią technicznie przestarzałe: pneumatyczne/hydrauliczne oraz niebezpieczne bezwładnościowe układy hamulcowe. Zawartość R13 pozostaje w tyle za nowoczesnymi innowacyjnymi układami hamulcowymi, które zostały opracowane w ramach Europejskich Projektów Badawczych (np. SPARC-UE, HAVEit). Elektroniczne układy hamulcowe są bardziej bezpieczne, bardziej wydajne i bardziej przyjazne dla środowiska w porównaniu z konwencjonalnymi pneumatycznymi, hydraulicznymi układami hamulcowymi, których stosowanie w Europie jest nieformalnie wymuszane przez ekspertów WP.29 EKG ONZ. Regulamin nr 13 powinien być ponownie zredagowany w formie zwartego dokumentu, bez zbędnych, zbyt szczegółowych opisów technicznych. Proponowane zmiany powinny zapewnić równych szanse dla producentów, którzy nie należą do nielicznej grupy monopolistycznych firm działających w świecie. Brak jasnych przepisów Regulaminu 13 oraz uchylanie się Departamentu 3283

9 Transportu EKG-ONZ od prezentowania oficjalnej interpretacji przepisów jest przyczyną konserwatywnych interpretacji większości ekspertów instytucji homologacyjnych w Europie. Wyjątkowym przykładem jest IDIADA Polska / Hiszpania, która shomologowała układ hamulcowy PIMR-EBS w zestawach: samochód Mitsubishi L200 z przyczepą (PIMR P1) oraz z naczepą typu gęsia szyja (PIMR N1) obie kategorii O2. BIBLIOGRAPHY 1. Dubowski A.P.: Reinventing Light Truck s semitrailers and Electric brakes System for quality and safety Transport improvement in Europe, Traffic without borders - traffic without limits, Mobile Conference in Duisburg-Zons-Köln, 2-4 June Dubowski A.P., Pawłowski T.: Medium size road units - an innovative approach for improving efficiency and safety of agricultural transportation in Poland and Europe as well. XXXI CIOSTA- CIGR V Congress Proceedings: Increasing work efficiency in agriculture, Horticulture and forestry. Hohenheim, Germany Sept , 2005, pp , ISBN Dubowski A. P., Pawłowski T., Weymann S.: Land Rover fire truck modernization for improving transportation needs of the forestry farms and tree nurseries. International Conference - Innovation Technology to Empower Safety, Health and Welfare in Agriculture and Agro-food Systems. Ragusa, Italy / 09/ Dubowski A. P., Grzelak J., Pawłowski T., Karbowski R., Rakowicz A., Weymann S., Zembrowsk K.: R&D works progress on agricultural and forestry transportation units equipped with modern electronic brake system gooseneck trailers that could be coupled with light trucks or farm tractors. International Conference on Agricultural Engineering AgEng 2010 Towards environmental Technologies Clermont-Ferrand, France, 6 8/09/2010, ISBN 13: Exhaust Emissions from agricultural vehicles used in transport. Jerzy Merkisz, Piotr Lijewski, Dubowski A. P., Weymann S., Grzegorz Skorny. Konferencja: IV Międzynarodowy Kongres Silników Spalinowych June 2011, Radom. 6. Dubowski A.P.; Rakowicz A.; Weymann S.; Zembrowski K.; Pawłowski T.; Karbowski R.: PIMR-EBS braking system in automotive road units. The Archives of Automotive Engineering, Scientific Publishing House PIMOT No. 3/2011 (53), str Dubowski A.P., Zembrowski K., Pawłowski T.: Nowy system transportowy PIMR - postęp prac wdrożeniowych a trudności natury legislacyjnej. Wyd. Instytut Naukowo-Wydawniczy SPATIUM, Autobusy-Technika, Eksploatacja, Systemy Transportowe; Nr 3, Dubowski A. P., Zembrowski K., Pawłowski T., Vicente N., Rakowicz A., Wojnilowicz Ł., Weymann S., Karbowski R.: Naczepa NGS-10 do transportu zestawów pojazdów gąsienicowych. TRANSCOMP 2013, ISSN , TTS nr 10/2013, pp ; 9. Patent Nr pt.: Układ elektryczno-pneumatyczny do sterowania pneumatycznohydraulicznym zespołem wykonawczym i pracą hydraulicznych hamulców, zwłaszcza lekkich i średnich naczep i przyczep samochodowych. 10. PL/ /PLA TRACTOR-TRAILER BRAKING SYSTEM - international patent no. PCT/PL2011/ The system for controlling of the executive assembly of the hydraulic brakes, especially of the automotive of light and medium size of gooseneck trailers and trailers). 11. AL-KO International Pty Ltd - ( ). 12. UNECE Regulation No IDIADA Poland - ( ). 14. Dubowski A.P., Zembrowski K., Pawlowski T.: New PIMR s transportation system - legislative obstacles affecting the implementation works progress. Autobusy (ISSN ) nr 3/2013, pp UNECE Transport Division Transport Research and Innovation Portal: SPARC-EU - ( ). 3284

10 17. HAVEit ( Highly Automated Vehicles for Intelligent Transport ) - ( ). 18. Tekonsha - ( ) 19. Dexter Axle - ( ) 20. American Rental Association Surge brakes coalition - ( ) 21. HAVEit final Event Keynote 22 SUP Haldex, Fedric Seglo: Brake-by-wire on heavy truck 22. TÜV NORD Mobillat GmbH&Co. KG Institute for Vehicle Technology and Mobility, Technical Service for braking Systems, in Essen - excerption of page of Report of the order No.: , issued Haldex restructuring ( ). 24. MEMO/10/343 Road Safety Programme : detailed measure

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