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. 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'
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.
