He has, the Knack..
Join Date: Jun 2006
Location: Sydney
Posts: 1,042
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Quote:
Notes from Meeting Thursday 23 July, 2009 regarding Suspension Modifications in NSW
Meeting held at the Offices of RTA Safer Vehicles Branch, North Sydney
In attendance:
From the RTA NSW Centre for Road Safety:
Keith Simmons General Manager, Safer Vehicles
Dan Leavy, Principal Policy Manager, Light Vehicles, Safer Vehicles Branch
Gabriel Denoury, Project Engineer, Safer Vehicles Branch
From the Australian National Four Wheel Drive Council:
Rob Kelly, President (Also Committee Member of 4WD Industry Council)
From NSW-ACT Four Wheel Drive Council:
Greg Russell, President
Roger Sheath, Vice President
From AAAA:
Grahame McCraw, Convenor for the Australian 4WD Industry Council
The meeting was called some weeks ago by Rob Kelly to introduce the ANFWDC and NSW-ACT Officials, toward opening dialogue on 4WD vehicle compliance issues and related matters. As the Co-ordinator of the 4WD Vehicle Lift Project, I was invited to attend to contribute from the Interim Test Report. The matter of VSI 50 and the NSW Minister for Roads Press Release (Lowering and Raising vehicles) quickly became the main topic of discussion. The meeting covered the following points:
1. RTA advised that the primary purpose of the VSI 50 was to improve safety for road users, specifically the severity of impact on other vehicles and passengers in vehicle to vehicle collisions. The incompatibility of vehicle heights was a concern to the NSW Government (NSW Govt.) and even a small reduction in the likelihood of injury was a worthwhile step. RTA was moving in incremental steps to improve safety.
2. RTA advised that the National Code of Practice (VSB14) is aimed at being a national minimum level of uniformity in vehicle modifications, and allows within its scope that individual states have the power to vary vehicle compliance requirements according to local conditions. Whilst supporting the concept of uniformity, it was clearly affirmed that where NSW local conditions require, they will override the VSB14. NSW believes that restricting the variation of vehicle heights from the manufacturer’s trim height is in the interests of improving road safety. RTA is has of advice from Vehicle Manufacturers that variations in the height of vehicles over 50mm will adversely affect their safety.
3. In answer to the question of what research has brought the RTA to this position (VSI 50) response was given that studies done by ANCAP on Used vehicles etc; Monash University on Pedestrian Safety and Accident Statistics in Australia and New Zealand, show that variations in vehicle height create incompatibility, significant to the safety for vehicle, occupants and other road users. Occupant Safety and ‘aggressivity’ of vehicles are of significant concern to the RTA and studies on pedestrian safety have shown 4WD vehicles are likely to have a greater impact on pedestrians than PMV.
4. Keith Simmons commented that in his experience with Army, NP&WS, Police fleet vehicles, those vehicles did not require lifting to perform their duties. 4WD NSW responded that modified vehicles from 4WD Clubs are sometimes called on by NP&WS to traverse tracks for which they believe their Fleet vehicles are unsuitable.
5. In response to questions about “Conditional Registration”, we were advised that would be, such as: permission to transit a modified (50mm<150mm vehicle lift) 4WD vehicle to a competitive event by the shortest route, for the purpose of competing. It would not allow the use of such vehicles as a ‘daily driver’.
6. It was clearly emphasised that VSI 50 will become requirement for modified vehicles in NSW.
7. RTA did concede that the release and implementation date of the VSI 50 was rushed, having been with the Minister’s Office for a period of review which left limited time before the nominated date of implementation. Also that consultation was limited.
8. RTA acknowledged that Police had the ‘call’ to target vehicles with greatest variation from the Manufacturer’s height, allowing lesser variations to continue unapproached. It was anticipated that this could be a way in which the VSI was policed in the field.
9. RTA advised that there had been incoming calls of support for VSI 50, including 3 from Suppliers of Aftermarket suspension products.
10. RTA noted that in a meeting with AAAA in October 2008, it was mentioned that RTA was addressing the matter of Suspension modifications. AAAA pointed out that consultation involves release of draft documents for consideration (before enactment) and opportunity for discussion with interested stakeholders, rather than simply mentioning a topic among a raft of matters covered in broad ranging meeting.
11. 4WD Representatives acknowledged that raising the vehicle does affect the stability, however minor lifts (to 75mm) can and do improve stability. This has been demonstrated in the Vehicle Lift Project Testing undertaken by the AAAA/4WDIC.
12. RTA advised that their aim was to set requirements so that vehicles could be driven by anyone in safety. AAAA responded that testing done thus far was with every-day modified vehicles accessorised as is typical of the general public’s vehicles. Modified vehicles outperformed standard trim height vehicles in the stability testing under ISO3888.
13. In answer to the question “Where does VSI 50 leave the Vehicle Lift Project Test Report, advice was that VSI 50 is a live document and RTA will look at proposals for variations, without assurance of adopting any proposal.
14. RTA suggested that a ‘type approval’ or ‘design approval’ could be a way in which suppliers of aftermarket vehicle lift products could ease the compliance process for vehicle owners. This would be vehicle specific although what spread of vehicle platforms could be covered by a single approval would need further discussion. Blanket approval from limited testing would not be acceptable to RTA. With regard to P5 of VSI 50 “Other Changes”:
For a vehicle that has been raised up to 50 mm in accordance with its manufacturer’s specifications and using parts supplied by the manufacturer or equivalent parts, the certificate must be provided by the manufacturer or a manufacturer’s authorised dealer, a person competent in such modifications or an engineering signatory. For all other raised vehicles and all lowered vehicles the certificate must be provided by an engineering signatory.
It was advised that the reference to ‘manufacturer’ was to the Vehicle Manufacturer. However later it was advised that under VSI 50 the manufacturer of the vehicle modification product could provide a certificate that the modification when fitted in accordance with the fitting instructions provided (including a disclaimer), to the appropriate vehicle; would be acceptable for aftermarket products.
15. Vehicles with variable suspension OE were acceptable as compliant with all current ADRS at the time of their release.
16. It was noted that vehicles modified under VSI 50 would be required to maintain their compliance with applicable ADRs.
17. The details of rules concerning Conditional Registration were still being ‘worked out’, however to assist the public interest a FAQ section would shortly be placed on the RTA web site regarding the VSI 50.
18. It was stated that the imperative was to target the ‘taller’ modified 4WD vehicles on the roads.
19. RTA advised that the Minister would likely consider exemptions for some 4WD vehicles, however they would not be widespread and owners would need to demonstrate their need for such an exemption. Possibly where 4WDers (Club members) might obtain statement from local Police that their modified vehicles were required and acceptable in local conditions and circumstances, and owners could seek exemption on that basis. The RTA also mentioned a few times that certain organisations may be given exemption, possibly on a restricted or conditional basis, and subject to support. The 4WD Assoc advised they would pursue this with the RTA.
20. RTA emphasised a number of times through the meeting that this was not designed to ban vehicle lifts … lifts to 50mm could be certified and greater lifts were possible, subject to conditional registration where need could be established … however the intention was to reduce the number of dangerous vehicles on NSW Roads.
21. In response to further questions, advice was given that if a vehicle lifted<50mm was presented for registration with the following:
a. Certificate from aftermarket manufacturer stating that the product when fitted according to their fitting instructions and to the appropriate vehicle was safe, (including a disclaimer)
and
b. A certificate from the owner or fitter that it had been fitted in accord with the manufacturer’s instructions
It would be considered for and likely, granted registration.
22. It was stated a number of times that VSI 50 was not retrospective. However, where a vehicle was subject to further modifications the certifying engineer would assess the vehicle for overall safety and compliance and consider any changes in vehicle height which would bring it under VSI 50.
23. 4WD and AAAA noted that this VSI 50 would influence consumer’s vehicle choice; affect employment among manufacturers, distributors and fitters of aftermarket products and the effect would even be felt in tourism related businesses.
24. On related matters, RTA advised:
a. Major changes to the Authorised signatory scheme for vehicle certification were under development and would likely roll out on 2010. This would include fully electronic accessibility of vehicle modification records.
b. Bullbars regulations were under scrutiny from a road users safety point of view and could possibly change.
25. In response to comment, RTA advised that the 50mm limit was not an arbitrary figure, but arrived at after consideration of available research. The proposal by the AAAA/4WDIC to the AMVCB Working Party for a 75mm combined lift in suspension and tyres, had not progressed to RTA knowledge. AAAA immediately provided the full interim Test Report and Video to RTA representatives at the meeting. RTA responded by acknowledging that they would consider any factual testing but would give no guarantee of accepting any proposal.
26. AAAA acknowledged that while 4WD was the primary discussion area of this meeting, the lowering of vehicles was as contentious (or more) a matter among users and Industry and the AAAA would have further input on that.
27. Meeting concluded with the following request by 4WD and AAAA:
a. That the Minister delays the implementation of VSI 50 from August 1.
b. That the period of delay allows wide consultation with User’s groups and Industry.
c. That VSI 50 be significantly modified from its present form.
d. That advice to and consultation with, both groups on this and any other relevant matters be ongoing, as both groups have valuable input and experience to offer.
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Appears that there is still a long, long way to go to convince the RTA to change their minds. Even more concerning for car enthusiasts is the lack of representation aside from the AAAA, who represent both 4WD and car enthusiasts.
Is there any car enthusiasts body, like the Australian National Four Wheel Drive Council or the NSW-ACT Four Wheel Drive Council?
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