ATA Provides Feedback on NHVR Performance Based Standards Updates
The Australian Trucking Association (ATA) has submitted its feedback on the National Heavy Vehicle Regulator's (NHVR) proposed updates to Performance Based Standards (PBS). These critical updates focus on Static Rollover Threshold (SRT), Rearward Amplification (RA), and High Speed Transient Offtracking (HSTO).
Key Points of Support
The ATA's submission generally endorses the overall direction of the reform, recognizing its potential to enhance road safety and operational efficiency. Specifically, the ATA supports the improved incorporation of modern stability control technology into the standards. Furthermore, the clarification of SRT requirements for vehicles transporting dangerous goods has been welcomed.
The ATA's submission generally supports the reform direction, endorsing the improved incorporation of modern stability control technology and the clarification of SRT requirements for vehicles transporting dangerous goods.
Areas Requiring Further Development
While supportive of the reform's intent, the ATA's submission highlights several critical aspects that require additional refinement. This is crucial to ensure the revised standards are practical, nationally consistent, and ultimately effective in their application.
Modelling and Testing Concerns
A primary concern revolves around the proposed modelling approach for Electronic Stability Control (ESC) and Roll Stability Control (RSC). The ATA views this approach as incomplete, noting that critical behaviors are not yet adequately represented. This poses a significant risk of inconsistent and unreliable assessments once the standards are implemented.
Furthermore, new dynamic test manoeuvres, such as the roundabout profile and the J entry to transient curve, are currently in a proof-of-concept stage. Essential details, including entry speeds, tolerances, severity definitions, and definitive pass/fail criteria, are yet to be firmly established. Without these specifics, the tests cannot serve as reliable equivalence checks against the foundational 0.35g SRT baseline.
National Consistency and Compliance
The ATA's submission strongly emphasizes the urgent need for nationally consistent guidance on pathways for Rearward Amplification (RA) and High Speed Transient Offtracking (HSTO). Broader clarification regarding the appropriate use of Lateral Transfer Ratio is also essential to ensure uniformity across the industry.
To safeguard the integrity of the updated standards, robust protocols for reduced speed testing must be developed. Additionally, the ATA calls for complementary compliance measures to ensure the effective in-service performance of stability systems.
The ATA acknowledges that permitting stability control systems to activate during RA and HSTO testing is appropriate. However, they note that replacing the traditional constant speed requirement with an entry speed allowance significantly affects test comparability across different scenarios. To maintain crucial national consistency and comparability, precise guidance on acceptable speed decay, steering path tolerances, and dynamic thresholds will be absolutely necessary.