Why we are campaigning
The growing number of electric vehicle (EV) and electric-hybrid vehicles (EHV) is a fundamental concern to blind and partially sighted people. As much as we appreciate the environmental benefits and the noise reduction of our daily road traffic, the introduction of these vehicles has created potential life and independence threatening hazards for blind, partially sighted and other vulnerable pedestrians.
Coping with orientation and moving around independently can be quite a challenge for blind and partially sighted persons. The public environment offers a range of possibilities, but also presents a lot of obstacles for us, which occur very often somewhat unexpectedly and may prevent us handling regular and new routes and directions in a safe and comfortable manner. A tremendous source of information which facilitates the orientation of blind and low vision persons is the sound generated by road traffic. We heavily rely on this source to make safe crossing decisions, to assess and interpret traffic situations, to perform an accurate body alignment whilst crossing the road, in short to audibly picture our daily environment and act accordingly.
The introduction of electric and electric hybrid vehicles is a great threat to the independence and safety of blind and partially sighted persons and minimizes the chances of using road traffic as a reliable and safe audible source. Due to an almost silent operation it is virtually impossible for blind road users to detect an electric or hybrid vehicle, assess its distance and direction correctly and early enough to avoid being hit. Collisions between pedestrians and EVs and EHVs are more likely and may lead to harmful injuries or at worst even kill pedestrians.
Over recent years research has been carried out attempting to analyze reliable accident data in order to assess the hazard potential posed by quiet vehicles.
In the UK, Morgan et al. in their comparative analysis come to the conclusion that proportionally more electric and hybrid vehicles hit a pedestrian than ICE (Internal Combustion Engine) cars.
The University of Dresden has looked into the perception and evaluation of vehicle exterior noise of EHVs and EVs and has found that “(…) additional sound is needed for detection of pre coming /approaching EVs/EHVs.”
Finally, in a recent study, the UK based TAS has examined accident data and EVs/EHVs and has found that these vehicles “(…) are likely to be involved in accidents where pedestrians are injured.” The number of accidents where pedestrians are injured by EVs/EHVs has increased, from 98 in 2012 to 151 in 2013, an increase of 54%. Whereas 2013 represented a record low for such accidents involving internal combustion vehicles, it was a new high for electric/hybrid-electric vehicles, with the percentage increase in accidents far outstripping the increase in vehicle numbers.
As explained earlier, quiet vehicles present a higher level of risk to pedestrians than conventional vehicles when travelling at a speed of 0 km/h to 20 km/h in the currently prevailing mixed road traffic situation. When travelling at higher speeds, the noise generated by the tires in combination with the road becomes the dominant noise source and exceeds the vehicle noise. For this reason it is necessary to establish a ceiling of 20 km/h for an additional sound to ensure that the vehicle is audible even in low-traffic areas. The following traffic scenarios create a particularly great safety risk for blind and partially sighted people if there is no additional sound for EVs and EHVs.
Unsafe street crossings without zebra crossings or traffic lights: While crossing these intersections, blind and partially sighted persons rely heavily on their hearing and use the noise of the oncoming traffic as an auditory cue to make safe crossing decisions. However, quiet vehicles are impossible to detect audibly and thus create a high level of accident risk.
Traffic-signalled intersections with audible and/or tactile signals: Particularly in urban areas, many intersections are controlled by traffic lights equipped with audio or tactile equipment to assist blind and partially sighted people to cross the road safely. Right-turning traffic moving into the crossing lane open to the blind pedestrian involves a high risk of collision. Even if pedestrians have the right of way they cannot be sure vehicles will yield to them.
Minor roads, vehicles coming from driveways, gateways, parking lots: In these environments, blind pedestrians are unable to perceive a quiet vehicle approaching or backing out on the road. Also, an inaudible vehicle approaching suddenly may frighten the pedestrian.
Crossing at small and large roundabouts: Roundabouts are increasingly replacing traditional intersections in many parts of Europe. This trend creates great concerns about the accessibility of these free-flowing intersections to blind and partially sighted pedestrians. Blind pedestrians move orthogonally (left-right-up-down). This is why they generally find orientation at roundabouts difficult. While the noise produced by conventional internal combustion engines may in some cases provide sufficient orientation clues to blind pedestrians, the absence of any noise considerably increases the risk of collision with an electric vehicle.
Due to the strong intervention of the European Blind Union, the European Union and the UNECE (United Nations economic Commission for Europe) have addressed the necessity for additional artificial sound generation for electric and electric hybrid vehicles. The EU “Regulation on the Sound Level of Motor Vehicle” (EU 540 / 2014) legally prescribes the mandatory installation of an AVAS (Acoustic Vehicle Alerting System) into electric- and hybrid-electric vehicles. Car manufacturers must equip new types of their electric cars with an AVAS system by 1 July 2019. In addition, all new electric and hybrid vehicles must have an AVAS by 1 July 2021. This is clearly the biggest success of our campaign. On a less positive note, EBU is disappointed to see that the pause switch has become mandatory as well. Under the new regulation, the AVAS will have to default to the switched-on position whenever the car is restarted. Restarting means that the engine needs to be turned off completely and does not apply to start-stop technology. All related AVAS specifications and requirements are regulated in Annex 8 of the EU 540 regulation.
EBU was also concerned to find that the transitional periods, i.e. the timeframe within which the regulation must be fully transposed are far too extended. Unfortunately the regulation does not contain an obligation for car manufacturers of retrofitting vehicles which are already in use. Thousands and thousands of quiet vehicles without AVAS will be out on the roads until 2019 and leave pedestrians with low vision unprotected – a really frightening prospect.
Under Regulation EU 540/2014 the European Commission is empowered to adopt delegated acts “to review Annex VIII and to include more detailed requirements on the performance of AVAS or of active safety systems taking into account the UNECE work on that issue, by 1 July 2017.” This is an important aspect as any progress which might be secured on the UNECE work will improve the forthcoming EU regulation No 540 / 2014 as the text of latter needs to be harmonized with the UN regulatory work.
A task force consisting of experts from standardization bodies, vehicle manufacturers, sound generation and production and representatives from national governmental transport ministries, has devised an UNECE regulation which outlines technical requirements for the operation and testing of AVAS systems, which will be installed in electric and electric hybrid passenger cars and buses.
Experts from the European Blind Union and World Blind Union, representing the world's blind and partially sighted population, attended most of the working group meetings. Though we were not entitled to formally vote for the inclusion or refusal of proposal elements, we strongly raised concerns of any provisions which might be adverse to the aim of AVAS as a safety feature. Due to our extensive commitment and perseverance the following key elements of the regulation could be established.
The installation of a pause switch will be prohibited and is no longer a permissible option for car manufacturers and car drivers. This new and very positive requirement was introduced in the current GRB noise party meeting, held in September 2016 and was unanimously adopted by all working group members. In order to be incorporated into the UNECE regulation this new requirement needs to be adopted by WP.29 in March 2017. Since all experts from the noise party are backing up this essential safety requirement it is likely that WP.29 will give its consent to this new stipulation.
A sound at stationary which indicates the presence of a standing silent vehicle is a voluntary option for car manufacturers.
The current situation
Since the EU regulation does not permit the omission of a pause switch and the voluntary introduction of a stationary sound if desired, this new regulation is already a success, but far from being sufficient to ensure safety for vulnerable road users. EBU and WBU have jointly lobbied for stronger requirements like the compulsory introduction of a stationary sound and the increase of the minimum sound level. The UNECE regulation was adopted in March 2016 by WP.29 the World Party on Vehicle Regulations, which is the supreme body, entitled to adopt all UNECE vehicle related legislations. To reflect the concerns and objections of EBU and WBU to the current text WP.29 has prolonged the working mandate of the quiet road transport vehicle task force. Any new findings can still be incorporated as amendments to the adopted UNECE regulation.
Future prospects seem to look more rewarding for the world's blind road users, since a shift of mindset within national transport delegations is taking place. More real life studies and demonstrations of an AVAS system are in the design process and will be carried out in the very near future. Still it is our commitment and our moral obligation to raise awareness for the need of an AVAS as a constantly operating safety system, which enables any pedestrian with or without sight to detect a silent vehicle at any time and under any conditions, to take safe and well-informed crossing decisions. Furthermore, EBU as the representative body of over thirty million blind and partially sighted persons needs to try and ensure that the UNECE regulation requirements will also find be included in the EU540/2014 regulation, to ensure the worldwide ban of a pause switch for AVAS systems and a consistent and harmonized safety regulative frame all over the world for EVs and EHVs. We also have to look carefully and meticulously at new technical developments concerning self-automated driving vehicles to ensure that these vehicles are taking our safety requirements into account and do not create a future source of insecurity and danger to our community.