ABS a requirement for ICVs in NSW

[Gaz64]

Originally Posted by Zedn

Bosch themselves told me it can't be done. When the people that design and make ABS say it can't be done safely.. it can't be done.

Yes, it can't be done because all other vehicles are programmed for their own weight, weight balance for and aft, tyre rolling diameters, wheel base, front and rear track, driveline package, etc.

Gary

[Treeve]

Ok so I had an email from someone at TfNSW who advise the RMS. They are of the understanding that the ABS requirement will be removed from the Brake Assesment Manual (they even said it was due in part to my lobbying, which is nice).

I’ve therefore asked that consideration be given now to ADRs 88 and 89 which come out in July next year for mandatory ESC and BAS (brake assistance) for category MA passenger vehicles. Hopefully we can catch this one before it becomes legislation on future.

Treeve

[Gaz64]

Originally Posted by Treeve

Ok so I had an email from someone at TfNSW who advise the RMS. They are of the understanding that the ABS requirement will be removed from the Brake Assesment Manual (they even said it was due in part to my lobbying, which is nice).

I’ve therefore asked that consideration be given now to ADRs 88 and 89 which come out in July next year for mandatory ESC and BAS (brake assistance) for category MA passenger vehicles. Hopefully we can catch this one before it becomes legislation on future.

Treeve

If they are waiving the ABS requirement, then it should be obvious to any Transport engineer that ESC, BAS, and any other EBCM controlled feature cannot be added to an ICV either.

Gary

[Rob. Smith]

Originally Posted by Treeve

Ok so I had an email from someone at TfNSW who advise the RMS. They are of the understanding that the ABS requirement will be removed from the Brake Assesment Manual (they even said it was due in part to my lobbying, which is nice).

I’ve therefore asked that consideration be given now to ADRs 88 and 89 which come out in July next year for mandatory ESC and BAS (brake assistance) for category MA passenger vehicles. Hopefully we can catch this one before it becomes legislation on future.

Treeve

Thank you for your efforts...this is a good move .

[Treeve]

Originally Posted by Gaz64

If they are waiving the ABS requirement, then it should be obvious to any Transport engineer that ESC, BAS, and any other EBCM controlled feature cannot be added to an ICV either.

Gary

This again misses the point about how legislation is written. We can all be smart and say “well it’s obvious that x, y and z can’t apply”, but what actually happens is that we have to comply with what the registration legislation says. And from next year there are new, separate ADRs for ESC and BAS. So these would again need specific exemptions and we’d go through all of this again. Now is the time to make sure that these are captured and not leave it to chance - because what will happen is you won’t be able to prove compliance with these ADRs, you won’t have an exemption and so you won’t be able to register your car.

Also, there are many ways to make these things work without ABS. So, just because cost prohibits it, doesn’t mean it can’t be done.

So we have to sort out an exemption now.

Treeve

[Gaz64]

Originally Posted by Treeve

This again misses the point about how legislation is written. We can all be smart and say “well it’s obvious that x, y and z can’t apply”, but what actually happens is that we have to comply with what the registration legislation says. And from next year there are new, separate ADRs for ESC and BAS. So these would again need specific exemptions and we’d go through all of this again. Now is the time to make sure that these are captured and not leave it to chance - because what will happen is you won’t be able to prove compliance with these ADRs, you won’t have an exemption and so you won’t be able to register your car.

Also, there are many ways to make these things work without ABS. So, just because cost prohibits it, doesn’t mean it can’t be done.

So we have to sort out an exemption now.

Treeve

Sorry Treeve, I'll disagree on one point.

To have any features of current ABS, an EBCM or ABS module has to fitted, period.

So if they waive ABS, but make ESC compulsory, then an ABS or EBCM has to be fitted.

The DMV people need to realise this before they start rewriting the rule book.

Gary

[Treeve]

No it doesn’t.
I’ve worked in motorsport where ABS is banned and we’ve not been allowed to measure wheel speeds but we’ve managed to create things that will do the job.
Just because you’ve only seen it done that way, doesn’t mean it’s the only way to do it.
Treeve

[Gaz64]

I don't think you will replicate the equivalent of Electronic Stability Control, (ESC) without measuring ALL wheel speeds.

Using Driveshaft rpm, or Crankshaft rpm as a single channel input is as about as good as Bosch 3 channel ABS with 1 channel looking at the rear axle.

How are you going to control a road car that is going out of control, sliding in wet conditions with an slightly inexperienced driver?

Until you have a system that can apply braking pressure to individual wheels, from a module that senses G force in 4 directions, (multi axis sensor), then you won't have what the DMV wants.

I've driven on skid pans with ESC turned on and off.
For the majority out there, thank goodness the default is ON in most cars these days.

Just for the record, I gave to your fund to fight these guys.

Gary

[Zedn]

I think the point Treeve is making is that we can’t assume an exemption for x is an exemption for y even if x is equal to y.

They already did this. ESC was exempt about 4 years ago but that didn’t stop abs being adopted.

Each adr is a piece of legislation, each requires exemption to be granted by authority under the act.

[Gaz64]

Originally Posted by Zedn

I think the point Treeve is making is that we can’t assume an exemption for x is an exemption for y even if x is equal to y.

They already did this. ESC was exempt about 4 years ago but that didn’t stop abs being adopted.

Each adr is a piece of legislation, each requires exemption to be granted by authority under the act.

Yes, that's correct.

You can have ABS without ESC.

You cannot have ESC (or BAS, EBD) without ABS.

And that's what the DMV needs to understand.
Their legislation is stupid, because it is written by a penpusher.

[Zedn]

Haha, yes it is stupid but it is what it is. It’s not about what the content is. An ADR comes in and is automatically applied to all vehicles in that category, we (well people like Treeve) then need to convince the right people that they should allow ICVs to be exempt. They then look at the requirements and make the decision. Problem is, in that time 12 months goes by and no one gets rego. Hence Treeve wanting to get in at the start to save us (people like me) an extended wait on a VIN.

[Treeve]

BAS without ABS: easy. No need to measure wheel speed except to apply brakes when the forward looking sensor says something is too close.
How do you make a wheel not lock up without measuring wheel speed? Well the difference is between friction of a rolling tyre and that of a sliding tyre. (We use the word stiction in this case - look it up, it’s real). So what happens when one tyre starts to have less friction? Well the forces through the suspension change very rapidly. The disc and wheel are locked into the hub and hence forces are transferred in a different way. Measure these - you’ve measured a locked up wheel (or one that has decelerated more than the others).
ESC comes down to yaw rates, roll rates, suspension positions and movements, engine speed vs ‘dead reckoned’ speed from acceleration sensors, steering input and a fair few algorithms. Can be used to cut spark to an individual cylinder, or change diff lockup settings (which we would also measure and record to have a fair estimate of wheel speeds).
No wheel speed measurement required, not breaking any rules, and you can implement ESC and BAS is without using a wheel speed measure or ABS controller which uses the brakes.
It’s been done this way by more than one team, and probably with more elegance than what I’ve just posted.
Just because you haven’t seen it done doesn’t mean it can’t be done.
Treeve

[Dimis]

Originally Posted by Treeve

Just because you haven’t seen it done doesn’t mean it can’t be done.
Treeve

And this is what they do to you... preoccupy you with semantic discussion that distract from the point. The point being it shouldn’t exist at all.

These are the same clowns who give themselves 1/4 million dollar annual pension, while swiping more money off regular pensioners, all while claiming its for the benefit of the country. Puhlease!

[Treeve]

Hang in a minute - I’m not distracted by this... let’s keep an eye on what has been achieved so far. The RMS came up with some rubbish which we’ve managed to get rid of. I’ve now taken another proactive step to work towards removing future requirements which are already legislated for July next year.
You have to argue the semantics because that is what the whole show is about. Otherwise we would have vaguely worded stuff which is open to interpretation - and then they have more power as they are the ones doing the interpretation.
I stand by my point - just because you haven’t seen it done doesn’t mean it can’t be done.
Treeve

[Gaz64]

Nobody is arguing here.

Only stating fact for road cars.

BAS is Brake Assist System, To ASSIST the driver in applying the brake pedal in case of emergency situations.

For when a driver doesn't apply enough PEDAL force.

If the RMS or DMV will somehow require BAS or ESC/ESP on an ICV but waive ABS installation, I'd like to see how that will be done to meet the ADR criteria without an EBCM fitted.

Gary

[Treeve]

So I’ve had a MAJOR win in the past week. NSW RMS VSCCS Notice 11 (regarding issuing VINs for ICVs) has been updated in line with the legislation. This now means the RMS can be challenged in local courts over their interpretations.
Funnily enough it was followed up in short order with a letter stating that ABS exemptions will continue without an end date for each ICV application.

[Auswallaby]

WOOOO HOOOO. Where can we get a copy of said letter????

[Gaz64]

Originally Posted by Treeve

So I’ve had a MAJOR win in the past week. NSW RMS VSCCS Notice 11 (regarding issuing VINs for ICVs) has been updated in line with the legislation. This now means the RMS can be challenged in local courts over their interpretations.
Funnily enough it was followed up in short order with a letter stating that ABS exemptions will continue without an end date for each ICV application.

The RMS has probably been reading this thread, hence why they have backed off.

To have other ABS functions without fitting ABS, .

Gary

[Treeve]

If you want a copy of said letter, find me in VSCCS Bulletin 1 (list of NSW certifiers - I’m called Treeve funnily enough...) and email me. I’ll reply with it attached.

The RMS may read this thread but it has more to do with the 18+ months I’ve been working with the Ombudsman, my local member, my solicitor and his QC associate and the $20k I’ve sunk into legal advice.

[Gaz64]

Originally Posted by Treeve

If you want a copy of said letter, find me in VSCCS Bulletin 1 (list of NSW certifiers - I’m called Treeve funnily enough...) and email me. I’ll reply with it attached.

The RMS may read this thread but it has more to do with the 18+ months I’ve been working with the Ombudsman, my local member, my solicitor and his QC associate and the $20k I’ve sunk into legal advice.

Yes, I understand the effort you have gone to get this far Treeve.

I don't think anybody else would have achieved this.

Gary