Industry backs standard ESC
BY MARTON PETTENDY | 24th Mar 2009
The nation’s top representative group for the automotive industry yesterday released its response to the draft Regulatory Impact Statement (RIS) for the Control of Vehicle Stability released on July 22 by the federal minister for infrastructure, transport, regional development and local government, Anthony Albanese.
The proposed ESC mandate, to be implemented via new Australian Design Rule (ADR) legislation that would bring Australia into line with a new global technical regulation (GTR8), attracted industry-wide support when it was announced last year.
However, many car-makers expressed alarm at the government’s intention to put the new ADR in place by late last year, which could have made ESC compulsory in Australia as early as this year.
As reported by GoAuto last year, many car-makers said some new models could become unavailable in Australia due to the logistical problems involved with complying with the ESC ADR if it was instituted too soon. Some said the cost of vehicles would rise as a result of the new ESC mandate.
Two days after the government’s ESC RIS was released in July, the Federal Chamber of Automotive Industries (FCAI) issued a press release highlighting the fact that more than half of all new vehicles sold in Australia in the preceding 12 months were already fitted with the potentially-life-saving safety technology.
At the time, the FCAI said the industry needed to consider if an ESC ADR was necessary, while Mr Albanese said: “The RIS will look at a range of issues including whether the goal of safer vehicles can be achieved via non-regulatory means.” Victoria has already mandated ESC in all new cars from 2011, the same year it will be required on all new passenger vehicles sold in the US.
Research done for the British government found vehicles equipped with ESC are 25 per cent less likely to be involved in a fatal accident than those without it.
In yesterday’s response to the government RIS, the FCAI has now officially supported the introduction of an ESC ADR that is: harmonised with the GTR applicable to the ADR vehicle categories MA (passenger cars), MB (passenger vans) and MC (off-road vehicles) and effective no earlier than October 29, 2012 for new models and October 29, 2014 for all (existing) new vehicles.
The FCAI says this timing would be in line with the expected ESC mandates in Europe and Japan, but industry insiders believe the Rudd government would be keen to institute the new ESC ADR before the next federal election, which will be held before then.
Industry observers say the government would be more likely to accept the FCAI’s recommendation that ESC should not be mandated for NA vehicles (light goods vehicles), and MD1 and MD2 vehicles (light buses up to 3.5-tonne GVM) in the proposed timeframe.
Nor does the FCAI support the recommendation in the RIS to require all vehicles up to 4.5 tonnes GVM to have ESC meeting the technical requirements of GTR8 because: in Europe the requirement is applicable only to vehicles up to 3.5 tonnes Japan is only considering mandatory ESC for vehicles up to 3.5 tonnes the fitting of ESC to vehicles over 3.5 tonnes in Europe is covered by UN ECE Regulation 13.11 and a timeframe for considering the adoption of UN ECE R13.11 is already in for vehicles over 3.5 tonnes.
As part of its case to delay the introduction of an ESC-mandating ADR for new passenger vehicles beyond October 2012, the FCAI said it recognised the importance of ESC but highlighted the need for regulations relating to Australia’s relatively small new vehicle market to be in line with global vehicle standards.
“In December 2008 more than 60 per cent of new passenger vehicles, and more than 80 per cent of SUVs, were fitted with ESC,” said the FCAI.
“Current plans indicate that this increase in fitting of ESC to new MA, MB and MC category vehicles will continue. FCAI members expect to have ESC available (standard fit or as an option) on more than 95 per cent of new MA, MB and MC category vehicles by 2012.
“As the market and industry are clearly responding to fitting ESC the FCAI questions whether an ADR for fitting ESC to MA, MB and MC category vehicles is justified.
“Due to the global nature of the vehicle industry and Australia’s small share of the world market the introduction of ESC into an ADR must recognise the scheduled introduction timing of overseas markets. Australia’s introduction of mandatory ESC cannot be in advance of the introduction of similar regulation in major overseas markets.
“It is our understanding that mandatory ESC on M1 category vehicles will be introduced in the EU, as part of a General Safety Regulation from 29/10/2012 for new models and 29/10/2014 for all new vehicles.
“Advice from the Japan Automotive Manufacturers Association (JAMA) is that Japan has introduced ECE R13H and is also considering introducing mandatory ESC for M1 category vehicles (except micro-mini) in the same timeframe as the EU as the introduction expected in the EU General Safety Regulation.
“It is necessary to ensure the availability of components for vehicles to be sold in Australia. As the major automotive markets of Europe, the US and Japan will also be increasing the fitting of ESC to vehicles as their own regulations are implemented, the component suppliers will also need to tool up and increase production of the ESC components.” The FCAI said that the one million-plus new vehicles sold in Australia in 2008 represented less than 1.5 per cent of the global market. The FCAI said that proportion would shrink further as emerging economic markets like Brazil, Russia, India and China (BRIC) grew and new vehicles sales declined in Australia by 12 per cent in 2009.
“Australia is one of the most open and competitive automotive markets in the world with more than 50 brands, 350 models and 20 source countries,” said the FCAI. “Less than 17 per cent of new passenger vehicles sold in 2008 were manufactured locally with the remaining 83 per cent of new vehicles imported from various countries and regions of the world including Asia, Europe and Africa.
“The motor vehicle is increasingly a global product and one of the most comprehensively regulated products. In considering regulations, the government’s role is to balance social and economic benefits with safety and environmental performance.
“The FCAI considers that government should base regulations on sound science and economics and that regulation is justified only when there is demonstrated need for government intervention because the market or vehicle manufacturers are not responding to a demonstrated need or new technology.
“Additionally, vehicle regulations in Australia should be both nationally consistent and harmonised with international regulatory standards. As economies of scale are critical in the automotive industry, all manufacturers have tended to limit the number of locations any one model is produced and that model is then cross-shipped to markets where there is demand.
“This approach benefits initially the manufacturer through reducing costs and ultimately the consumer by improving affordability and increasing product choice.
“The introduction of individual or unique national standards and regulatory requirements can seriously affect this approach through increasing production cost, which must be passed along to the consumer, without necessarily improving safety or environmental performance.” The FCAI said it did not support the fitment of ESC on light commercial vehicles (LCV) in the timeframe proposed by the draft RIS because the technology was unavailable on most such vehicles, whose model cycles were significantly longer than passenger cars. The FCAI also points out that complex LCV model ranges made the cost of ESC fitment prohibitive, while their extensive range of load-carrying configurations made ESC calibration difficult.
“While many of the light goods vehicles on the market in Australia already have ESC fitted, there are significant numbers of light goods vehicles (both light trucks and vans) that do not currently have ESC and there are no current plans to undertake the development work for fitting ESC to many of these models,” said the FCAI.
“It needs to be recognised that goods vehicles have a longer product cycle (ie: time between new models) and subsequent technical development cycle than passenger vehicles. For example, the product cycle for a light commercial vehicle could typically be up to 10 years in Australia while passenger cars will have a much shorter product cycle of four to five years.
“Lower annual sales volumes and a higher number of variants for light commercial vehicles require longer product cycles to provide the necessary return on investment on the initial investment in the product development.
“NA category vehicles that have not been designed for ESC cannot be easily adapted due to the vehicles design characteristics. Many NA category vehicles are available with a range of gross vehicle mass (GVM) that may be available with relatively minor specification levels, eg: essentially the same vehicle body/chassis with wheel/tyre combination and/or suspension and/or engine/transmission option. Each combination would need ESC calibration resulting in high development costs.
“A significant issue with developing ESC for NA category vehicles is that the vehicle's final configuration (and consequently the centre of mass or centre of gravity) is not predictable by the OEM.
“For example, how does the OEM calibrate the ESC for a cab-chassis vehicle? The OEM specifies GVM, but not where the final customer's configuration places its centre of mass or COG with implications for how the ESC control algorithm deals with the yaw that it measures and/or infers.” As part of its response to the RIS, the FCAI gave the government a confidential list of models that could be withdrawn from Australia if ESC is mandated for LCVs as well as passenger cars.
“Many NA category vehicles sold into Australia are cab-chassis work vehicles and are principally designed for the Asian market rather than the EU or US. Advice from JAMA is that the Japanese government has not yet decided to mandate fitting ESC to N1 category vehicles.
“The Australian market is too small in terms of total sales to justify ESC development on Australian specification models resulting in these models being withdrawn from the Australian market.
“Models that are not also sold into Europe or the US would not have ESC development already conducted or in any forward model development plan.
“As information on vehicles that may be withdrawn from the Australian market is confidential, as is all information on forward model plans, the data will not be provided in the body of this submission and will be provided separately to the department.
“This will allow the FCAI submission to be made public without commercially sensitive information.
“If the outcome of the RIS is still to include NA category vehicles in the new ADR the industry would ask for additional introduction timing beyond what would be expected for MA, MB and MC category vehicles.
“The introduction timing for NA vehicles, if they are to be included in the scope of any ADR requiring mandatory fitting of ESC, should be aligned with the expected timing for fitting ESC to vehicles over 3.5 tonnes GVM as already identified in the NTC Heavy Vehicle Braking Strategy.”
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