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英国论文（paper）-关于行人保护的咨询文件-Pedestrian protection - consultation paper Contents The Consultation Criteria .............................................................................................4 Introduction....................................................................................................................4 Background.....................................................................................................................4 Framework ...............................................................................................................................4 Technical content .....................................................................................................................5 The Commission's Proposal ..........................................................................................5 Monitoring ......................................................................................................................6 Costs & Benefits .............................................................................................................6 Issues to be addressed ....................................................................................................6 Framework ...............................................................................................................................6 Technical content of first phase ...............................................................................................7 Monitoring................................................................................................................................7 Phase two .................................................................................................................................7 Finally..............................................................................................................................8 Dear Sir or Madam I am writing to invite your comments on a number of issues arising from the European Commission's proposal to enter into a negotiated agreement on pedestrian protection with car manufacturers. This would require new cars to be designed so as to reduce the severity of injuries suffered by pedestrians in accidents. The attached paper sets out the background, explains the Commission's proposal, looks at costs and benefits (although we are still working to clarify these) and identifies issues where we would welcome your views. The consultation is in accordance with the Cabinet Office Code of Practice on Written Consultation. However, as the Commission's timetable is tight the consultation period will be six weeks, rather than the usual twelve. Ministers have cleared this. Please send any comments you wish to make, in writing, to Ms B Natarajan at the above address (by Friday 12 October 2001. Please note that we may be asked to make public the contents of the replies that we receive. When you send in your reply could you therefore please say if you do not want us to make a copy of it available if we are requested to do so. If you have any complaints or comments about the consultation process, please contact the DTLR consultation co-ordinator: Martin Leppert, 1/H9, Eland House, Bressenden Place, London SW1E Yours faithfully PETER O'REILLY Association of Chief Police Officers Association of Chief Police Officers (Scotland) Aston Martin Lagonda Ltd Automobile Association Bentley Motors Ltd BMW (GB) Ltd BRAKE Bristol Cars Ltd British Medical Association British Motorcyclists Federation Caterham Cars Ltd Child Accident Protection Trust Chrysler Jeep Chrysler Jeep Imports UK Citroen UK Ltd Colt Car Company Ltd Consumer Association Convention of Scottish Local Authorities County Surveyors' Society Cyclists' Touring Club Daewoo Cars Ltd Daihatsu UK Ltd Department for Education and Skills Department of Health Department of Trade & Industry Disabled Persons Transport Advisory Committee DoE Northern Ireland Driving Standards Agency Fiat Auto UK Ltd Ford Motor Co Ltd Freight Transport Association General Motors Hawk Cars Health & Safety Executive Highways Agency Home Office Honda UK Hyundai Car UK Ltd Isle of Man Jaguar Cars Ltd KIA Cars (UK) Ltd Lada Cars Lamborghini Cars Land Rover Local Authority Road Safety Officers Association Local Government Association Lotus Cars Ltd Mazda Cars (UK) Ltd McLaren Cars Ltd Mercedes Benz Ltd MG Rover Morgan Motor Co Ltd Motor Industry Research Association Motor Schools Association Motorcycle Action Group Motorcycle Advisory Group Motorcycle Industry Association National Assembly for Wales NG Cars Ltd Nissan Motor GB Ltd Parliamentary Council for Transport Safety Pedestrian Association Perodua Peugeot Motor Company Ltd Porsche Cars (GB) Ltd Professor Richard Allsop, University College London RAC Foundation of Motoring Reliant Motors Ltd Renault UK Ltd Rolls-Royce Motor Cars Ltd Royal Society for the Prevention of Accidents SAAB (GB) Ltd Scottish Executive Society of Motor Manufacturers & Traders States of Jersey Suzuki GB Plc Toyota GB Ltd Trades Union Congress TRL Ltd TVR Engineering Ltd Ultima Sports Cars Ltd Vauxhall Motors Ltd Vehicle Certification Agency Vehicle Inspectorate Volkswagen Group UK Ltd Volvo Cars UK Ltd Welsh Local Government Association The Consultation Criteria 1. Timing of consultation should be built into the planning process for a policy (including legislation) or service from the start, so that it has the best prospect of improving the proposals concerned, and so that sufficient time is left for it at each stage. 2. It should be clear who is being consulted, about what questions, in what timescale and for what purpose. 3. A consultation document should be as simple and concise as possible. It should include a summary, in two pages at most, of the main questions it seeks views on. It should make it as easy as possible for readers to respond, make contact or complain. 4 Documents should be made widely available, with the fullest use of electronic means (though not to the exclusion of others), and effectively drawn to the attention of all interested groups and individuals. 5. 指导英国论文Sufficient time should be allowed for considered responses from all groups with an interest. Twelve weeks should be the standard minimum period for a consultation. 6. Responses should be carefully and open-mindedly analysed, and the results made widely available, with an account of the views expressed, and reasons for decisions finally taken. 7. Departments should monitor and evaluate consultations, designating a consultation coordinator who will ensure the lessons are disseminated. Introduction 1. This consultation paper invites comments on a number of issues arising from the negotiated agreement on pedestrian protection which the European Commission has decided in principle to make with car manufacturers. All comments received will help to establish the UK's negotiating position in European discussions. Background 2. The European Commission has for some time been expected to make a proposal to require new cars to be designed so as to reduce the severity of injuries suffered by pedestrians in accidents. Over the years the UK has done much work to advance this issue. The basic principle is that new car models should be required to pass a series of technical tests (involving instrumented headforms and legforms) which would indicate how they would interact with a pedestrian. Framework 3. It had long been assumed that pedestrian protection requirements would be introduced in a Directive. However, last year the car manufacturers, through their representative bodies, lobbied for a negotiated approach, such as was taken on CO2 emissions. After prolonged discussion with the motor industry, the Commission has decided in principle to proceed on the basis of a negotiated agreement and has produced a proposal for an agreement. This was announced on 11 July. The Commission has indicated that it will consult Member States and the European Parliament. It is not yet clear exactly how this will be handled as the Commission has no specific machinery to cope with agreements of this nature. Technical content 4. The European scientific committee (EEVC-WG17), through which many European member states collaborate on research, presented a report to the Commission in 1999 containing a proposal for a pedestrian protection Directive. Following the approach from manufacturers, the Commission asked its Joint Research Centre (JRC) - a scientific group not previously involved in pedestrian protection - to look at the issues. The JRC favoured a less onerous test procedure (close to that initially proposed by the manufacturers), which the Commission are now proposing as the first phase of the negotiated agreement. The Commission's Proposal 5. The Commission has issued a draft communication setting out its intention to make an agreement on pedestrian protection with the motor industry (discussions with the European manufacturers'#p#分页标题#e# association (ACEA) have been concluded, discussions with the Japanese and Korean associations (JAMA and KAMA) are still in progress, but agreement seems likely). The Communication can be 6. Under the terms of the agreement, the key commitments from industry are to: i. ensure that the parts of new cars forward of the windscreen meet the technical test requirements recommended by the JRC (to apply to new models from 1 July 2005; 80% of all new registrations from 1 July 2010, 90% in 2011 and all new registrations by 2012); ii. introduce anti-lock braking systems (ABS) in 2003 and daytime running lamps in 2002 on all new vehicles; iii. not fit rigid bull bars on new vehicles from 2002; and iv. comply with the EEVC-WG17 targets for pedestrian safety (to apply to new models in 2010; and all new registrations progressively from 2012, but not later than the end of 2014) through application of the EEVC-WG17 technical requirements or other measures which provide equal protective effect. The Annex sets out the technical test requirements referred to in i. and iv. above. 7. The agreement would apply to all M1 vehicles (i.e. passenger vehicles with nine or fewer seats) which weigh 2.5 tonnes or less. It would also apply to N1 vehicles (i.e. goods or dual purpose vehicles) which are derived from M1 vehicles and which weigh 2.5 tonnes or less. 8. The terms of the agreements would be binding on all ACEA, JAMA and KAMA members. This would include large manufacturers and their smaller subsidiaries. Independent companies would not be included, in the same way that passive safety requirements in Directives usually exclude vehicle producers with small outputs. Monitoring 9. The agreement proposes that compliance will be overseen by a Monitoring Committee to be set up by the Commission. Tests would be carried out by independent technical services for the vehicle manufacturers. From the implementation dates, manufacturers would supply the Monitoring Committee with copies of certified test reports. Costs & Benefits 10. The issue of costs and benefits is a complex one and we are still in the process of establishing these for the negotiated agreement proposed by the Commission. This will inevitably take time. 11. Historically, there have been major differences of opinion over the likely cost of implementing the full EEVC-WG17 requirements; the vehicle manufacturers, in particular, believed that the manufacturing costs would be very high. In 1997, an independent study by MIRA for the Commission estimated an additional cost per vehicle of around £160 to £280. However, by last year, views on likely costs of some design changes had become closer and, following our discussions with industry, we estimated that a figure of around £30 per car was the likely cost of a possible intermediate measure. Today this figure could well be lower for some car models. At least one now in production may already be approaching, and in some aspects exceeding, the proposed phase one requirements at, we estimate, an additional manufacturing, design and development cost of around £15. A further cost element is the degree to which pedestrian friendly car fronts would be more susceptible to minor damage - this is very difficult to estimate. There will also be environmental costs associated with any weight increase. 12. The estimates of benefits vary widely. The above MIRA study estimated a range for the EEVC proposals of between £40 and £325 per car over its life, depending on assumptions. Although not linked to any particular study, the vehicle manufacturers believe that the first phase would deliver 80% of the benefits expected from the full EEVC-WG17 requirements, in terms of deaths and serious injuries avoided. Using similar approximations we believe that this over-estimates the benefits by 20% for deaths and 10% for serious injuries. Our review will look closely and afresh at the benefits achievable. 13. Industry's commitment would result in ABS being a universal fit on all motor vehicles, except motorcycles, with the resulting benefits expected of such universality. It could be expected that should the fitting of ABS become standard the cost would fall to £60. 14. Daytime Running Lamps (DRL) are forward facing lamps used to make a vehicle more visible when used during the daytime. There is no standard for DRLs so it is unclear what manufacturers would fit or adapt. Benefits and costs could therefore vary considerably. Some options could result in increased maintenance requirements resulting from reduced life of current production bulbs, all will result in an increase in fuel consumption. Initial estimates of the total life cost are of the order of £100-200 per vehicle. Issues to be addressed Framework 15. In our judgement, the technical requirements are broadly similar to what we might have expected to have been agreed for the first phase of a Directive. Although, the technical requirements for the first phase are less onerous than the full requirements proposed by EEVCWG17. The difference is that while the first phase of the Commission's proposal is expected to start taking effect in 2005, the first phase of a Directive would be unlikely to bite until 2007 at the earliest. 16. We are considering the concept of a negotiated approach, giving earlier first phase benefits. Your views on this are invited. Technical content of first phase 17. Although we expect the first phase to be less onerous than the full EEVC-WG17 requirements, there is an element of the technical proposal which gives us particular concern. When testing the effect of the bumper area on the pedestrian leg, a limit is set on the amount by which the knee is permitted to bend laterally. Under the Commission's proposal, this is set at a maximum of 210. In our view, this level of lateral bending will mean a very high likelihood of disabling ligament damage at the specified 40 km/h impact. Here the JRC focussed on the manufacturing feasibility rather than the biomechanical aspects. 18. We believe the Commission should be invited to review this area with manufacturers. Your opinion on this is invited - particularly the extent to which it would be right to put the whole agreement at risk to press this point. 19. ABS is fully defined, so there is no need to discuss the detail of the technicalities. DRL is not defined, so it is important to understand what is being offered. 20. We believe that Member States should be involved in any decisions on how to implement DRL. Monitoring 21. Although the agreement includes a proposal for monitoring, we believe there should be more detail on procedures for checking, auditing and policing the agreement and dealing with transgressions. 22. We believe the Commission should be invited to review the monitoring arrangements with a view to agreeing a more robust procedure with manufacturers. Your views on this are sought. Phase two 23. The second phase of the agreement commits manufacturers to achieving the full EEVC-WG17 technical requirements, or introducing other measures which have equivalent effect. This gives rise to the complex question of how other measures will be assessed as being equivalent. 24. We believe the Commission should consider establishing an expert technical forum, involving Member States, to establish a mechanism and resources for continued development of all car pedestrian protection measures. Your thoughts on this are invited. Finally 25. The paragraphs above highlight specific issues which we have identified. We would also be grateful to have comments on any other issues, figures or business impact to help us produce a Regulatory Impact Assessment. 26. Comments should be sent, in writing, to Ms B Natarajan, Zone 2/04, Great Minster House, 76 Marsham Street, LONDON SW1P 4DRby Friday 12 October 2001. PROPOSED FOR PHASE ONE PROPOSED BY EEVC - WG17 Child head Mass 3.5 kg 2.5kg Impact speed 35km/h 40 km/h Wrap around distance[1] 1.0m - bonnet rear reference 1.0m - 1.5m Max HIC[2] 2/3 bonnet area with HIC <1000 1/3 bonnet area with HIC < 2000 1000 Adult head Mass 4.8kg 4.8kg Impact speed 35km/h 40 km/h Wrap around distance[1] Covers windscreen for reference only. 1.5m - 2.1m (not beyond bottom of windscreen frame) Leg to bumper Area Full bumper Full bumper Impact speed 40 km/h 40 km/h Max tibia acceleration 200g 150g Max knee bend angle 21° 15° Max knee shear 6mm 6mm UPPER LEG TO BONNET LEADING EDGE Energy cap[3] 700J - but for reference only 700J Femur load limit 5kN - but for reference only 5kN Max bending moment 300Nm- but for reference 300Nm only Upper leg to bumper Femur load limit 7.5kN 5kN Max bending moment 510Nm 300Nm 1. The wrap around distance is the testable area of the car front, based on the region most likely to be struck by the head of an adult or child in a frontal collision. 2. HIC = Head Injury Criteria. This is the value normally used in accident research to assess the liklehood of serious head injury. 3. Energy cap is the maximum energy to be applied by the upper leg to the bonnet leading edge. The actual energy will depend on the shape of the car. |
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