Follow-up on the Implementation of UNECE R51( Noise Emission) in Southeast Asian Countries

Background

Volume 35 of News from JAMA reported JAMA's Recommendations on the Implementation of UNECE R51 (vehicle noise emission regulation). This is in response to ASEAN Member States' plans to harmonize their national regulations on noise emission with R51. To follow-up on the progress of implementation, JAMA Noise Committee experts conducted a courtesy call in January to the concerned regulators and industry representatives of three major vehicle producing countries in Southeast Asia that have planned to implement or promulgate R51 in 2011: Indonesia, Malaysia, and Thailand. The following paragraphs reveal the background and main outcomes and of this mission in further detail.
 
 
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Indonesia

The first stop of JAMA's mission was Indonesia. The Indonesian Ministry of Environment (MOE) had promulgated a decree on the type-approval for vehicle noise emission in 2009. For the implementation of this decree, a Technical Guidance that specified the technical requirements in detail had to be drafted. Currently, the Technical Guidance is still being drafted by the Directorate General of Land and Transportation (DGLT). It is targeted to be completed by 6 April 2011. Hence, implementation of this regulation will commence after 6 April this year.
To ensure smooth implementation, it is important that the testing methods specified in the Technical Guidance are in-line with those specified in the UNECE R51.

This is to avoid the regulation from becoming a unique national regulation, which defeats the purpose of using UNECE regulations to harmonize technical vehicle regulations more commonly used among international communities. With regards to this concern, JAMA noise experts held a meeting with the automotive industry representatives from Gabungan Industri Kendaraan Bermotor Indonesia (GAIKINDO) or the Association of Indonesian Automotive Industries, during their visit in January. GAIKINDO took JAMA's advice on technical harmonization and worked with the concerned regulators on this matter.

Aside from the regulation on type-approval for vehicle noise emission, which is only applicable to new vehicles, MOE is also looking at regulating noise emission from in-use vehicles as well. In-use vehicles have to be regulated through a stationary noise test in regular inspection. JAMA vehicle noise experts have always been advocating the use of ECE Regulation Resolution Number 3 (R.E.3) with a referential noise limit value rather than an absolute noise limit. This is to avoid the possibility of conflicting test results with those of the new type of vehicles regulated under R51 (for details of potential conflict when using an absolute limit value in stationary noise test for in-use vehicles, and R51's new type-approval for new vehicles at the same time, please refer to NFJ Volume 35 at http://www.jama-english.jp/asia/news/2009/vol_35.pdf).

However, JAMA understood from an MOE officer in 2009 that they will still be employing an absolute noise limit value for the first phase in regulating in-use vehicles, and will only gradually shift to referential noise limit value from the second phase onwards around 2013. The reason for using an absolute noise limit value in the first phase is because there will still be a significant amount of existing old vehicles not type-approved under R51. These vehicles are unable to be regulated by referential noise limit in the beginning stage, and it is not possible to ignore these vehicles should they wish to abate noise pollution. According to the same officer, old vehicles contribute to a major source of noise pollution.

To resolve this inevitable need to regulate old vehicles not type-approved under R51 and to avoid potential conflict of stationary noise limit value with R51 as far as possible, JAMA experts have agreed to collaborate with GAIKINDO to conduct research and data collection in order to derive an appropriate stationary noise limit value. An appropriate limit value refers to an absolute limit value for a stationary noise test that is sufficient to control noise issues of old vehicles, yet will not fail vehicles that have been type-approved under R51 and does not employ an absolute stationary noise limit value. MOE welcomes the joint proposal from the industry and agrees to consider the research outcome. The outcome of GAIKINDO and JAMA's joint research is expected to be submitted to MOE in 2011.


Malaysia

Malaysia is already a signatory of the United Nations WP29's (World Forum for Harmonization of Vehicle Regulations) 1958 Agreement and has adopted the UNECE Regulations, which include R51. The only thing left is to incorporate it into their mandatory national regulation on vehicle noise. To do that, SIRIM, a standard institute owned by the government of Malaysia, will have to withdraw the current MS1915, which is not based on R51.
The MS1915 is a general Malaysian Standard (voluntary standard) on vehicle noise emission. As part of the procedures to implement any mandatory regulation under the WTO, all WTO signatories, including Malaysia, will need to promulgate a general standard and spell out its technical specification prior to the implementation of mandatory regulation.

MS1915 has already been agreed to be withdrawn during a SIRIM meeting in late January this year. The revision of this MS to incorporate R51's requirements has also commenced.

Similar to the advice JAMA offered to Indonesia, JAMA experts informed Malaysia that the testing methods specified in the general standards and technical requirements at the national level should be in-line with those specified in the R51. SIRIM is already considering ISO362-1, a measurement method on noise emission still under discussion by the United Nations WP29 to be incorporated into the future R51's updated version. By including ISO362-1 in their new MS draft, JAMA cautioned that the over-progressiveness may backfire.

As ISO362-1 is still under discussion, and up till now, there is not a single country that has adopted this standard into practice; the adoption of such a standard ahead of the rest of the world would result in a technical barrier.

As a regular participant in ISO conferences and the WP29's Rapport du Groupe de travail du bruit (GRB) or the Working Party on Noise, a JAMA noise expert informed SIRIM that there are still some problems with the test methods under ISO362-1. The amendment will be discussed in GRB.

It is expected that the above issues will be discussed again in a Consultative Committee on vehicle noise regulation, which includes the Malaysia Automotive Association (MAA), to be formed under the auspices of the Department of Environment in near future. It is, however, uncertain that R51 can be promulgated in Malaysia in 2011.


Thailand

Like Malaysia, Thailand is also a signatory to the 1958 Agreement, but the country has yet to sign up with any of the UNECE regulations annexed to the Agreement. According to the Thai Automotive Industry Association (TAIA), the Department of Land Transport (DLT) of Thailand has plans to promulgate R51 in 2011, and enforce it on new model vehicles from 1 January 2014 and existing model vehicles from 1 January 2016. However, during JAMA's visit early this year to DLT, the delegates were informed that the plans may be postponed due to the delay foreseen in the completion of the test course. For the time being, maker test reports, third party's test reports, and witness tests at the maker's factory by DLT are still acceptable procedures to gain type-approval certificates.

However, when the inland test course is completed, all new vehicles, including those imported from overseas and those produced locally, might have to be tested in this DLT facility only.

For stationary noise test requirement on in-use vehicles, it is understood that the Pollution Control Unit (PCU) of Thailand is still undergoing the collection of data to finalize an appropriate noise limit value. To the least, this test requirement on in-use vehicles will not be carried out this year.

Conclusion

Except for Singapore, which has already tightened its noise limits on all new vehicle noise emission since 2010, and will be tightening its noise limits on in-use vehicles from April 2011, the implementation date of vehicle noise regulations for the rest of the Southeast Asian countries are less clear at the moment. Other than those car-manufacturing-countries in this region mentioned above that have plans in implementing or promulgating R51, Vietnam and Philippines have also expressed plans to support the standard harmonization scheme under the ASEAN Consultative Committee for Standards and Quality-Automotive Product Working Group (ACCSQ-APWG). Nonetheless, there is still no clear time-schedule that has been announced by the authorities of these two countries. One has to take note, however, that the regional plan to harmonize R51 into national regulation in 2015 is under the ACCSQ-APWG Roadmap. The capacity to implement it by 2015 is totally another issue to be taken up though.
 

 
    
 


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